QAPP 4.0_signed.pdf

South Carolina DHEC Title: UST Management Division QAPP Underground Storage Tank Management Division Revision Number: 4.0 Revision Date: July 2020 Page: 1 of 231

QUALITY ASSURANCE PROGRAM PLAN

FOR THE UNDERGROUND STORAGE TANK MANAGEMENT DIVISION

Bureau of Land and Waste Management

South Carolina Department of Health and Environmental Control Columbia, South Carolina

July 2020

Revision Date: July 2020 Page: 3 of 231

A2 TABLE OF CONTENTS

SECTION A – PROJECT MANAGEMENT

A1 TITLE AND APPROVALS

A2 TABLE OF CONTENTS

LIST OF ACRONYMS

A3 DISTRIBUTION LIST

A4 ORGANIZATION

A5 PROBLEM DEFINITION/BACKGROUND

I. Introduction II. Quality Assurance Policy III. Authority

A6 PROGRAM DESCRIPTION

I. THE RISK-BASED CORRECTIVE ACTION (RBCA) PROCESS

II. SITE ASSESSMENT

III. SITE IDENTIFICATION AND PRIORITY CLASSIFICATION

IV. INITIAL GROUNDWATER ASSESSMENT (IGWA) WORK SCOPE

V. TIER I ASSESSMENT WORK SCOPE

VI. TIER 1 EVALUATION

VII. TIER 1 EVALUATION OUTCOMES

VIII. TIER II ASSESSMENT

IX. TIER 2 EVALUATION

X. TIER 2 EVALUATION OUTCOMES

XI. TIER III ASSESSMENT

XII. TIER 3 EVALUATION

XIII. TIER 3 EVALUATION OUTCOMES

XIV. SITE REHABILITATION (ACTIVE OR MNA)

XV. VERIFICATION MONITORING FOR MONITORED NATURAL ATTENUATION

XVI. NO FURTHER ACTION DECISIONS

XVII. OTHER UST WORK TO BE IMPLEMENTED

A7 DATA QUALITY OBJECTIVES AND DATA QUALITY INDICATORS

A8 TRAINING AND CERTIFICATION

I. DHEC Requirements:

II. Contractor Requirements

A9 DOCUMENTS AND RECORDS

I. Introduction II. Receptor Survey & Site Data III. Monitoring Well Information IV. Groundwater and Surface Water Data V. AFVR Information VI. Granulated Activated Carbon Installation VII. Corrective Action Activity Summary VIII. Results & Discussion IX. Tables X. Figures XI. Appendices

Revision Date: July 2020 Page: 4 of 231

SECTION B – DATA GENERATION AND ACQUISITION

B1 SAMPLING PROCESS DESIGN/EXPERIMENTAL DESIGN

I. IGWA SAMPLING PROCESS DESIGN

II. TIER I ASSESSMENT SAMPLING PROCESS DESIGN

III. TIER II ASSESSMENT SAMPLING PROCESS DESIGN

IV. SITE REHABILITATION

V. BORING, FIELD SCREENING, AND WELL INSTALLATIONS

B2 SAMPLING METHODS

I. SOIL SAMPLING

II. GROUNDWATER LEVEL MEASUREMENT AND SAMPLING

III. SURFACE WATER SAMPLING

B3 SAMPLE HANDLING & CUSTODY

I. Chain of Custody Form Requirements II. Sample Collection Preservation

B4 ANALYTICAL METHODS

B5 QUALITY CONTROL REQUIREMENTS

I. Laboratory QA/QC

B6 INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE

B7 INSTRUMENT/EQUIPMENT CALIBRATION AND FREQUENCY

B8 INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES

B9 NON-DIRECT MEASUREMENTS

B10 DATA MANAGEMENT

I. Field Data II. Laboratory Data

SECTION C – ASSESSMENT AND OVERSIGHT

C1 ASSESSMENT AND RESPONSE ACTIONS

C2 REPORTS TO MANAGEMENT

SECTION D – DATA VALIDATION AND USABILITY

D1 DATA REVIEW, VERIFICATION AND VALIDATION

D2 DATA VALIDATION AND VERIFICATION METHODS

D3 RECONCILIATION WITH USER REQUIREMENTS

Tables

TABLE 1. DISTRIBUTION LIST

TABLE 2. POTENTIAL INITIAL RESPONSE ACTIONS AT TYPICAL RELEASE SITES

TABLE 3. POTENTIAL EXPOSURE PATHWAYS

TABLE 4. CHOICE OF COMPLIANCE POINTS

TABLE 5. ASSESSMENT TIER COMPARISON

TABLE 6. COC MASS REDUCTION CALCULATION EXAMPLE

TABLE 7. WELL CASING DIAMETER VS. WELL VOLUME

TABLE 8. FIELD PARAMETER ACCEPTANCE CRITERIA

TABLE 9. LIST OF CONSUMABLES AND ACCEPTANCE CRITERIA

TABLE 10. ASSESSMENT AND RESPONSE ACTIONS

TABLE 11. VALIDATION ACTIVITIES

TABLE 12. CONSIDERATIONS FOR USABILITY ASSESSMENT

Page: 5 of 231

Figures

FIGURE 1. ORGANIZATIONAL CHART

FIGURE 2. FIGURES OF COMPLIANCE POINTS…………………………………………………………………………………

Appendices

APPENDIX A: UST MANAGEMENT DIVISION RBCA DECISION MAKING FLOW CHART

APPENDIX B: CONTRACTOR ADDENDUM

APPENDIX C: SITE-SPECIFIC WORK PLAN

APPENDIX D: RBSL LOOK-UP TABLES

APPENDIX E: SITE CONCEPTUAL MODELS

APPENDIX F: ANALYTICAL PARAMETERS AND METHODS

APPENDIX G: PRESERVATION AND HOLDING TIMES

APPENDIX H: LEACHABILITY MODEL AND DOMENICO MODEL

APPENDIX I: STANDARD FIELD CLEANING PROCEDURES

APPENDIX J: UST MANAGEMENT DIVISION RETENTION SCHEDULE

APPENDIX K: CONTRACTOR VERIFICATION CHECKLIST

APPENDIX L: SCDHEC EQC AND OCRM QUALITY MANAGEMENT PLAN

APPENDIX M: PROJECT STATUS UPDATE FORM

APPENDIX N: GLOSSARY OF TERMS

APPENDIX O: DOCUMENT REVIEW AND REVISION RECORD

Revision Date: July 2020 Page: 6 of 231

LIST OF ACRONYMS

ACQAP Annual Contractor Quality Assurance Plan AFVR Aggressive Fluid and Vapor Recovery AST Aboveground Storage Tank BFD Blind Field Duplicate bgs Below Ground Surface BLWM Bureau of Land and Waste Management BTEX Benzene, Toluene, Ethylbenzene, and Xylenes CAP Corrective Action Plan CASE Corrective Action System Evaluation CIO Chief Information Officer CFM Cubic Feet per Minute CNFA Conditional No Further Action CoC Chemical of Concern CPC Compliance Point Concentration CWA Clean Water Act DHEC Department of Health and Environmental Control DIPE Di-Isopropyl Ether DL Detection Limit DQI Data Quality Indicator DQO Data Quality Objective DRO Diesel Range Organics EDB Ethylene Dibromide or 1,2 Dibromoethane EFIS Environmental Facility Information System EtBE Ethyl tert-Butyl Ether EA Environmental Affairs FPP Free Phase Product FST Field Screening Technique GAC Granular Activated Carbon GRO Gasoline Range Organics HPT Hydraulic Pressure Test ICAR Interim Corrective Action Report IGWA Initial Groundwater Assessment LIF Laser Induced Fluorescence LNAPL Light Non-Aqueous Phase Liquid LOD Limit of Detection mg/kg milligrams per kilogram MIP Membrane Interface Probe MDL Method Detection Limit MNA Monitored Natural Attenuation MTBE Methyl tert-butyl Ether NFA No Further Action OFA Onsite Field Audit OIP Optical Image Profiler ORP Oxidation Reduction Potential PAH Polynuclear Aromatic Hydrocarbons PE Professional Engineer

Revision Date: July 2020 Page: 7 of 231

PG Professional Geologist PQL Practical Quantification Limit QA/QC Quality Assurance / Quality Control QAP Quality Assurance Plan QAPP Quality Assurance Program Plan QAM Quality Assurance Manager QL Quantification Limit QMP Quality Management Plan RL Reporting Limit RBCA Risk Based Corrective Action RBSL Risk Based Screening Level RPD Relative Percent Difference SC DHEC South Carolina Department of Health and Environmental Control SOP Standard Operating Procedure SSWP Site Specific Work Plan SSTL Site Specific Target Level SUPERB State Underground Petroleum Environmental Response Bank TAA Tert-Amyl Alcohol TBA Tert-Butyl Alcohol TBF Tert-Butyl Formate TOC Total Organic Carbon µg/L micrograms per liter UST Underground Storage Tank VOC Volatile Organic Compound

Revision Date: July 2020 Page: 8 of 231

A3 Distribution List

The SCDHEC Underground Storage Tank Management Division Quality Assurance Program Plan, and subsequent revisions thereof, will be distributed to the following:

Name Title Organization/Address Telephone Number

Fax Number Email Address

Ben Singh Project Officer UST Section, USEPA Region 4, 61 Forsyth St., SW, Mail Code 9T25, Atlanta, GA, 30303

404-562-8922 **** Singh.Ben@epa.gov

Channing Bennett

Environmental Scientist

UST Section, USEPA- Region 4, 61 Forsyth St., SW, Mail Code 9T25, Atlanta, GA, 30303-8960

404-562-8276 **** Bennett.Channing@epa.gov

Liza I. Montalvo Quality Assurance Manager

USEPA - Region 4

980 College Station Road

Athens, GA 30605

706-355-8708

**** Montalvo.Liza@epa.gov

Bill Truman Regional Program Manager

UST Section, USEPA- Region 4, 61 Forsyth St., SW, Mail Code 9T25, Atlanta, GA, 30303-8960

404-562-9457 **** Truman.Bill@epa.gov

David Graves Quality Assurance Manager

SCDHEC, Environmental Affairs

2600 Bull St., Columbia, SC, 29201

803-898-4272 gravesda@dhec.sc.gov

Henry Porter Bureau Chief SCDHEC, Bureau of Land and Waste Management, 2600 Bull St., Columbia, SC, 29201

803-898-1411 803-898-0673 porterhj@dhec.sc.gov

Don Siron, PG Assistant Bureau Chief

SCDHEC, Bureau of Land and Waste Management, 2600 Bull St., Columbia, SC, 29201

803-898-1376 803-898-0673 sirondl@dhec.sc.gov

Mihir Mehta, PE

Director SCDHEC, UST Management Division, 2600 Bull St., Columbia, SC, 29201

803-898-0623 803-898-0673 mehtam@dhec.sc.gov

Eric Cathcart Manager SCHDEC, UST Management Division, Regulatory Compliance Section, 2600 Bull St., Columbia, SC, 29201

803-898-0633 803-898-0673 cathcaef@dhec.sc.gov

Ashleigh Thrash, PG

Manager SCDHEC, UST Management Division, Assessment & Non- Permitted Petroleum Section, 2600 Bull St., Columbia, SC, 29201

803-898-0607 803-898-0673 thrasham@dhec.sc.gov

Debra Thoma Manager SCDHEC, UST Management Division, Corrective Action & Quality Assurance Section, 2600 Bull St., Columbia, SC, 29201

803-898-0643 803-898-0673 thomadl@dhec.sc.gov mailto:Bennett.Channing@epa.gov mailto:cathcaef@dhec.sc.gov mailto:thrasham@dhec.sc.gov mailto:montsla@dhec.sc.gov

Revision Date: July 2020 Page: 9 of 231

Name Title Organization/Address Telephone Number

Fax Number Email Address

Stephanie Briney

Manager SCDHEC, UST Management Division, Corrective Action & Field Support Section, 2600 Bull St., Columbia, SC, 29201

803-898-0595 803-898-0673 brineysm@dhec.sc.gov

Christopher Doll, PG

Manager SCDHEC, UST Management Division, 2600 Bull St., Columbia, SC, 29201

803-898-0649 803-898-0673 dollcs@dhec.sc.gov

Robert Hodges, PG

Manager SCDHEC, Site Assessment, Remediation & Revitalization Division, Brownfields Section, Columbia, SC 29201

803-898-0919 hodgesrf@dhec.sc.gov

TBD –listed in the Addenda

Project Managers

SCDHEC, UST Management Division, 2600 Bull St., Columbia, SC, 29201

803-898-2544 803-898-0673 -----

SC Certified UST Site Rehabilitation Contractors*

This will be covered in the contractor’s ACQAP or addendum to this Programmatic QAPP.

Table 1. Distribution List

* Copies of the UST QAPP will be provided to all SCDHEC Certified UST Site Rehabilitation Contractors. It will be the responsibility of those contractors to provide the UST QAPP to any analytical laboratories or other subcontractors that they utilize.

The Annual Contractors Quality Assurance Plan (ACQAP) or site-specific QAPP Addendums also include distribution lists of those personnel specific to the project(s) that will be receiving a copy of the UST Programmatic QAPP and the ACQAP or site-specific QAPP Contractor Addendums. Personnel will be required to sign that they have received a copy of the most recent UST Programmatic QAPP and the site-specific QAPP Contractor Addendums or ACQAP.

A4 Organization

To implement this Quality Assurance Program Plan (QAPP), the UST Management Division has established a suitable management structure. Personnel from the Underground Storage Tank (UST) Management Division and Bureau of Land and Waste Management of South Carolina Department of Health and Environmental Control (SCDHEC) will provide technical management and oversight of the Site Rehabilitation work to be performed. The successful implementation of the QAPP involves a large educational component.

Management and support personnel involved should be qualified, by training and/or expertise, to assume the necessary responsibilities.

The responsibilities for key positions within the SCDHEC UST Management Division are listed and an Organizational Chart is presented as Figure 1 below:

Quality Assurance Manager - The Quality Assurance Manager (QAM) is responsible for the oversight of all quality assurance activities associated with SCDHEC sampling and analysis standard operating procedures (SOPs). The QAM reports directly to upper management. The QAM will resolve any issues when corrective actions are needed to address data quality issues involving SCDHEC staff and SOPs. The QAM will approve the SCDHEC UST Programmatic QAPP.

mailto:dollcs@dhec.sc.gov

Revision Date: July 2020 Page: 10 of 231

UST Management Division QAPP Coordinator - The UST Management Division QAPP Coordinator is responsible for revisions to the UST Programmatic QAPP as necessary. The UST QAPP Coordinator will ensure that copies of the QAPP and all revisions are distributed to all parties listed in the Distribution List.

The UST QAPP Coordinator will approve the SCDHEC UST Programmatic QAPP and will provide UST Project Managers with guidance to ensure the content of the site-specific QAPP Contractor Addendums or Site-Specific Work Plans (SSWP) is correct and complete. The UST QAPP Coordinator also reviews and approves contractors ACQAP submittals.

Division Directors - The Division Directors will provide necessary liaison with the QAM and the Regional Office to help ensure that UST QA Program requirements are consistently met within the state.

Section Managers - Section Managers are responsible for oversight of the UST Project Managers. The Section Managers provide input to site-specific decisions in addition to ensuring consistency with policies and procedures of the UST Management Division. Section Managers will address QA matters with the UST Project Managers and the contractors at the site level and will approve site-specific QAPPs.

UST Project Managers - UST Project Managers are responsible for direct oversight of contractors conducting assessment and Site Rehabilitation of releases at UST sites. Project Managers perform day-to-day review of plans and reports related to Site Rehabilitation activities on their assigned sites. These reviews include verification and analysis of data submitted to the UST Management Division by Site Rehabilitation Contractors and analytical laboratories and recommendations for future work. Project Managers are responsible for the review of and approval of site-specific QAPP Contractor Addendums or SSWPs to ensure compliance with the UST Programmatic QAPP. The UST Project Managers are also responsible for validating the Project Data.

Site Rehabilitation Contractor - The Site Rehabilitation Contractor is an independent contractor responsible for managing and coordinating field and office activities needed for assessments or cleanup. Site Rehabilitation Contractors that perform activities involving data analysis and interpretation must be registered with SCDHEC as a Class I Site Rehabilitation Contractor. Site Rehabilitation Contractors that perform activities involving only data collection (e.g., drilling, sampling) must be registered with SCDHEC as a Class II Site Rehabilitation Contractor. All Site Rehabilitation Contractors are responsible for submitting QAPP Addenda with each Site Specific Work Plan (SSWP) or Annual Contractor Quality Assurance Project Plan (ACQAP) that describes all South Carolina UST site work conducted by the contractor, as detailed below in Section A5. The Site Rehabilitation Contractor is also responsible for validating and verifying the Project Data. UST Division Project Managers must be notified of UST site work in South Carolina at least 4 days prior to the initiation of field activities.

Analytical Laboratory - The Analytical Laboratory receives the soil and water samples, performs the requested analyses, and provides analytical reports. Analytical laboratories must be certified by the SCDHEC Office of Environmental Laboratory Certification in accordance with Regulation R.61-81 for the analytical methods performed.

Soil Boring and Monitoring Well Driller - The Driller installs soil borings and monitoring wells. All soil borings and monitoring wells must be installed by a certified South Carolina (SC) well driller in accordance with South Carolina Well Standards and Regulations, R.61-71.

https://scdhec.gov/sites/default/files/media/document/R.61-81.pdf https://www.scdhec.gov/sites/default/files/media/document/R.61-71.pdf

Underground Storage Tank Management Division Revision Number: 4.0

Revision Date: July 2020 Page: 11 of 231

Organizational Chart for SCDHEC UST

Figure 1. Organizational Chart

Page: 12 of 231

A5 Problem Definition/Background

I. Introduction

Over 11,000 releases have been reported from regulated underground storage tanks (USTs) in South Carolina. The SCDHEC UST Management Division addresses the chemicals released from leaking USTs.

UST releases are present in virtually every type of South Carolina community, ranging from rural to metropolitan. The petroleum chemicals of concern (CoC) present in the soil and groundwater constitute potential risks to human health and the environment and require investigation so that decisions can be made regarding appropriate site rehabilitation actions or possible closure. Environmental data are critical to decision-making concerning the protection of the public and the environment from the adverse effects of pollutants from leaking underground storage tanks.

II. Quality Assurance Policy

The UST Management Division of the SCDHEC Bureau of Land and Waste Management (BLWM) adopts by reference the following Quality Assurance Practice statement as documented in the Environmental Affairs Quality Management Plan (QMP):

Environmental data are critical to decision making. Making the correct decision based on the data is important in the protection of the public and the environment. The Department’s quality assurance practice is that there be sufficient QA activities conducted to demonstrate that all environmental data generated, processed, or used will be scientifically valid, legally defensible, and of known and acceptable precision and accuracy. Data shall be complete, representative, and comparable. The quality of all data generated by and for DHEC shall meet or exceed all Department and EPA requirements. Data of the appropriate type and quality shall be used by the Department in all of its environmental programs and decision-making processes. In addition, all employees are responsible for adhering to this practice and other policies, procedures and guidance of the quality system.

Quality assurance (the documentation of quality control) and quality control practices are needed to ensure that data involving all environmental efforts – e.g., pollution abatement, cleanup, public health protection, and environmental technology - successfully perform their intended role.

All such decisions must be technically defensible and must be protective of human health and the environment. It is the policy of the UST Management Division to investigate all leaking UST sites in a consistent fashion and to ensure that responsible parties act in an expeditious manner to perform the appropriate Site Assessments and, when circumstances dictate, implement an adequate remedial plan.

The UST Management Division determines which actions are required at a release site based on the decision-making process outlined in the flow chart in Appendix A.

The policy of the UST Management Division is and will be to collect water and soil quality data that are scientifically valid, defensible, and of known accuracy. The UST Management Division presently uses existing guidance and the procedures outlined in this plan to ensure that investigations are accurately conducted and defensible in an administrative proceeding. Contractors certified by the UST Management Division to perform UST release investigations are required to submit a QA/QC plan with a site-specific QAPP Addendum or an Annual Contractor Quality Assurance Plan (ACQAP) with SSWPs based on USEPA QA/R-4 and this document, the UST Programmatic QAPP, prior to engaging in site activities.

Page: 13 of 231

III. Authority

The SCDHEC Underground Storage Tank Management Division Quality Assurance Program Plan is established under authority provided in Section II.A.1 of the South Carolina SUPERB Site Rehabilitation and Fund Access Regulations, R.61-98.

A6 Program Description

The SCDHEC UST Management Division treats each leaking UST site on a case-by-case basis. The UST Project Manager assigned to each site ensures progress on legal and routine actions and decides on the degree of remediation required based on several factors. The primary factor to be considered is whether a direct threat to human health or the environment currently exists. Such cases are prioritized, and direct action is taken to protect the public and environmental receptors. At a minimum, free phase product removal is required, to the extent practicable, wherever it is encountered. It is the goal of the UST Management Division to clean the groundwater to site-specific target levels (SSTLs) based on all current and potential receptors as measured by the sampling of monitoring wells throughout the CoC plume.

Because every site will be treated on a case-by-case basis, the UST QAPP is designed to be appended with specific site information for each release. These appendices are developed by Contractors and reviewed and approved by DHEC UST Project Managers. The UST Project Manager will ensure that all required information from a site is presented in a Site-Specific Work Plan (SSWP) or site-specific QAPP Contractor Addendum. The information will include, at minimum, a site map with the sampling sites indicated, the history of the site, the number of samples to be collected, when the sampling will take place, the Laboratory that will be used along with their DHEC Laboratory Certification Number, and who will collect the samples. The site-specific QAPP Contractor Addendum or SSWP will be submitted to the UST Project Manager for approval at least 15 business days before sampling is to commence. The site-specific QAPP Contractor Addendum (Appendix B) or SSWP (Appendix C) must be approved before site work begins.

The UST Management Division has developed a format for these addenda.

For sites where repetitive data-producing activities such as quarterly monitoring are being conducted under an approved Corrective Action Plan (CAP), the Contractor will prepare the site-specific QAPP Contractor Addendum or SSWP one time at the initiation of CAP implementation and will be reviewed annually at a minimum and revised as changes warrant for the duration of activity under the CAP.

The QAPP for the UST Management Division detailed in this document describes the course of action for South Carolina leaking UST site activities. Site activities which generate environmental data include soil and water sample collection and analysis; soil boring and monitoring well installation; decontamination procedures; groundwater, geophysical, and other survey measurements; and data reduction and analyses.

Site-specific QAPP Contractor Addenda or SSWPs present information specific to the site including location, topography, work schedules including the start and completion dates, and resource constraints.

All releases are prioritized in accordance with the ranking system outlined in Site Priority Classification detailed in this section. Releases qualified for funding from the SUPERB Account are funded in order of relative risk based upon availability of funds in the SUPERB Account. All other releases are investigated as rapidly as possible, depending upon the tank owner's ability to conduct necessary Site Rehabilitation activities. Each of the releases is unique depending on its components, the type of product stored, the local hydrogeologic conditions and the history of the release.

https://www.scdhec.gov/sites/default/files/docs/Agency/docs/lwm-regs/R61-98.pdf https://www.scdhec.gov/sites/default/files/docs/Agency/docs/lwm-regs/R61-98.pdf

Page: 14 of 231

Initial investigations are conducted using standardized scopes of work (i.e., Initial Groundwater Assessment (IGWA), Tier I Assessment) that provide sufficient data on the extent and severity of contamination and the location of proximate potential receptors to allow preliminary ranking of the risk presented by a release and determination of subsequent scopes of work. Comprehensive investigations of releases that will require Site Rehabilitation are conducted in accordance with the Tier II Assessment work scope. The Tier II work scope provides a systematic approach to obtaining all of the data necessary to fully characterize the extent and severity of a release and determine its potential risk to human health and the environment. The Site Rehabilitation process outlines the data gathering necessary to document the progress and completion of site rehabilitation for petroleum releases. The UST Management Division will utilize a decision-making flow chart (Appendix A) to determine what scope of work is to be conducted at a site. UST Contractors are required to submit an addendum to this QAPP (see Appendix B) or if working under an approved ACQAP, an SSWP (see Appendix C) containing site information. This information includes site selection, work schedules, geographical locations, and time or resource constraints since this information is specific for each UST release project/site.

These and all other pertinent site activities that will generate environmental data will be subject to UST Programmatic QAPP requirements. Potential uses for collected environmental data include but are not limited to the estimation of the magnitude and extent of contamination, characterization of site conditions for development of remedial action procedures, and documentation of effectiveness of remediation.

The primary goal of the quality assurance program outlined in this document is to ensure that all data generated by or for the SCDHEC UST Management Division which relates to UST site activities will be scientifically valid, legally defensible, and of known and acceptable precision and accuracy. Specific objectives of the quality assurance procedures include the following:

All data generated for or by the UST Management Division will be of sufficient or greater quality to withstand scientific and legal challenge;

The intended use of all data and any limitations on that use will be determined and clearly defined before data collection efforts begin to ensure that the necessary levels of data quality are attainable;

All sample collections and analysis are project specific and will be defined in investigation work plan;

All data produced for or by the UST Management Division will be of known and acceptable precision, accuracy, representativeness, completeness, and comparability. Data not within specified quality parameters will not be accepted and the sample shall either be re-analyzed, re-extracted or re-digested, or if necessary, the sample re-collected; and

All projects will receive adequate supervision by the UST Management Division staff to ensure quality data is collected.

The structure of the Assessment and Corrective action process for identified USTs releases is described below.

I. THE RISK-BASED CORRECTIVE ACTION (RBCA) PROCESS

The Risk-Based Corrective Action (RBCA) process is a stepwise, tiered approach for the assessment and cleanup of UST releases. The steps of the RBCA Process are outlined below with a discussion of the site-

Page: 15 of 231 specific factors that determine the actions required for a given release. The RBCA process is also illustrated as a flow chart in Appendix A.

a. RBCA Procedures

When a petroleum release from a UST facility is identified, owners/operators of facilities must ensure that initial abatement measures are taken to prevent further releases, control fire and explosion hazards, and remove accessible free phase petroleum product pursuant to SC UST Control Regulations, R.61-92.

Investigation plans, RBCA evaluation reports, Site Rehabilitation Plans, and Engineering Reports must be approved by the UST Management Division, as necessary, and in accordance with applicable guidance and regulations. All Site Rehabilitation activities related to UST releases must be performed by a SCDHEC certified Site Rehabilitation Contractor as required by the SUPERB Fund Access and Site Rehabilitation Regulations, R.61-98.

b. Risk Based Screening Levels

The RBCA process utilizes Risk Based Screening Levels (RBSLs) established to protect human health and the environment from exposures to specific contaminants in environmental media. RBSLs have been derived for the substances associated with petroleum most likely to be encountered in environmental media at a release site and to potentially cause adverse effects to human health and the environment.

The following substances are considered potential CoCs at all UST sites, and RBSLs have been derived to regulate their concentrations in water and soil: Benzene, Toluene, Ethylbenzene, and Xylenes, collectively referred to as (BTEX), Methyl tert-butyl Ether (MTBE), Naphthalene, 1,2-dichloro-ethane (DCA), Ethylene Dibromide or 1,2-dibromoethane (EDB), and lead. Polynuclear Aromatic Hydrocarbons (PAHs) heavier than naphthalene are considered to be potential CoCs at UST sites where kerosene and diesel fuel has been released. Metals, including arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver are treated as potential CoCs when waste oil is suspected to have been released at a UST site.

Action levels have been developed for several additional oxygenates, which have been added to petroleum, including: Ethyl tert-butyl ether (ETBE), 3,3-dimethyl-1-butanol, tertiary-amyl methyl ether (TAME), diisopropyl ether (DIPE), tert-butyl formate (TBF), tert-butyl alcohol (TBA), tert-amyl alcohol (TAA), and ethanol.

Analytical parameters for ranges of petroleum constituents, such as Gasoline and Diesel Range Organics (GRO and DRO), and Total Petroleum Hydrocarbons (TPH) analysis may be requested by UST project managers to determine the potential sources of petroleum contamination at a release site. Screening levels are not used for comparison to aggregate petroleum parameters because the toxicity of ranges of different compounds cannot be described accurately. The UST division does not employ a “surrogate” approach to the evaluation of toxicity of petroleum ranges, instead, the individual components of petroleum for which toxicity has been demonstrated are selected as individual CoCs.

II. SITE ASSESSMENT

Once a UST release has been identified, the information necessary to determine if emergency action is appropriate and to compare contaminant concentrations to RBSLs must be obtained. Initial Groundwater Assessment (IGWA) and Tier I Assessment activities are carried out to obtain the information necessary for completion of preliminary soil and groundwater quality evaluation and the completion of a Tier 1 Risk https://scdhec.gov/sites/default/files/media/document/R.61-92_0.pdf https://scdhec.gov/sites/default/files/media/document/R.61-98.pdf

Page: 16 of 231

Evaluation. Tier II Assessments are carried out if CoC concentrations in impacted environmental media require additional delineation.

III. SITE IDENTIFICATION AND PRIORITY CLASSIFICATION

An evaluation of potential immediate exposures to danger and environmental hazards is conducted upon the identification of a release. Emergency Action to eliminate immediate exposure is required as soon as such exposures are identified. The UST Management Division should be notified at (803) 898-2544 or, when necessary, an emergency can be reported directly to the Emergency Response Program at 1-888- 481-0125 or (803) 253-6488. Appropriate actions must be implemented as soon as possible to eliminate an immediate threat. Typical release scenarios and response actions to eliminate immediate threats are provided in Table 2.

Scenario Potential Initial Response

Explosive levels or concentrations of vapor are present in a residence or other building

Evacuate occupants; begin abatement measures such as ventilation.

Explosive levels are present in the subsurface utility system

Evacuate immediate vicinity; begin abatement measures such as ventilation.

Free-phase product is present in significant quantities at ground surface, on surface water bodies, or in utilities.

Prevent further free-phase product migration, institute recovery, monitor vapor concentrations.

An active water supply well, water supply line, or public water is impacted or immediately threatened.

Notify users, provide alternate water supply, and treat water point of use.

A sensitive habitat or sensitive resources are impacted. Minimize extent of impact by containment measures and implement habitat management to minimize exposure.

Table 2. Potential Initial Response Actions to Eliminate Immediate Threats at Typical Release Sites

Releases are classified by SCDHEC into categories based on the current and projected degree of risk to human health and the environment identified during initial release investigation and subsequently upon completion of each tier evaluation. Site classification is an on-going process based on available information.

Releases may be reclassified following abatement, further assessment information, and remedial actions.

Release sites are classified according to the following criteria:

Classification 1 - The highest priority classification is for those releases that pose an immediate threat to human health and the environment. Sites are placed in Classification 1 if:

a) An emergency situation exists;

b) A fire or explosion hazard exists;

c) Vapors or free product exists in a structure or utility;

d) Concentrations of CoC have been detected in a potable water supply or surface water supply intake;

e) Free product exists on surface water;

f) CoC exists in surface water.

Classification 2 - The second priority classification is for releases that pose a significant near term (0 to 1 year) threat. This Classification is subdivided into 2a and 2b. Sites are placed in Classification 2 if:

Classification 2a:

Page: 17 of 231

A significant near term (0 to 1 year) threat to human health, safety, or sensitive environmental receptors exists; or

Potable supply wells or surface water supply intakes are located < 1-year ground water travel distance down gradient of the source area.

Classification 2b:

Free product exists in a monitoring well at a measured thickness > 1 foot; or Potable supply wells or surface water supply intakes are located < 1,000-feet down gradient of the source area (where ground-water velocity data is not available).

Classification 3 - The third priority classification is for those releases where there is a short-term (1 to 2 years) threat. This Classification is subdivided in to 3a and 3b. Sites are placed in Classification 3 if:

Classification 3a:

A short-term (1 to 2 years) threat to human health, safety, or sensitive environmental receptors exists;

Potable supply wells or surface water supply intakes are located > 1-year and < 2-years groundwater travel distance down gradient of the source area; or

Sensitive habitats or surface water exist < 1-year ground-water travel distance down gradient of the source area and the groundwater discharges to the sensitive habitat or surface water.

Classification 3b:

Free product exists in a monitoring well at a measured thickness > 0.01 feet;

Concentrations of CoC above the RBSL have been detected in a non-potable water supply well;

Hydrocarbon-containing surface soil (< 3-feet below grade) exists in areas that are not paved;

Sensitive habitats or surface water used for contact recreation exist < 500-feet down gradient of the source area (where ground-water velocity and discharge location data are not available);

The site is located in a sensitive hydrogeologic setting, determined based on the presence of fractured or carbonate bedrock hydraulically connected to the impacted aquifer; or Ground water is encountered <15-feet below grade and the site geology is predominantly sand or gravel.

Classification 4 - The fourth priority classification is for releases where there is a long-term (> 2 years) threat to human health or the environment. This Classification is subdivided into 4a and 4b. Sites are placed in Classification 4 if:

Classification 4a:

A long-term (>2 years) threat to human health, safety, or sensitive environmental receptors exists;

Potable supply wells or surface water supply intakes are located > 2-years and < 5-years groundwater travel distance down gradient of the source area; or

Non-potable supply wells are located < 1-year groundwater travel distance down gradient of the source area.

Classification 4b:

Free product exists as sheen in any monitoring wells;

Page: 18 of 231

Non-potable supply wells are located < 1,000-feet down gradient of the source area (where groundwater velocity data is not available); or

The groundwater is encountered < 15 feet and the site geology is predominantly silt or clay.

Classification 5 - The fifth priority classification is for releases where there is no current demonstrable threat to human health or the environment but where data indicate COC concentrations are above the RBSLs and further assessment is needed. Groundwater travel times are calculated from the monitoring well closest to the exposure point that contains concentration of COCs above the RBSLs. Sites are placed in Classification 5 if:

There is no demonstrable threat, but additional data are needed to show that there are no unacceptable risks posed by the site;

assessment data for the site indicate concentrations of chemicals of concern are above the risk-based screening levels or site-specific target levels, as appropriate, and further assessment is needed; or

Assessment data for the site indicate concentrations in sample are below the RBSL or SSTL, as appropriate, but the samples are determined not to be representative, therefore, further assessment is needed.

IV. INITIAL GROUNDWATER ASSESSMENT (IGWA) WORK SCOPE

An IGWA is conducted at sites where a release of petroleum from a regulated underground storage tank (UST) has been confirmed and preliminary information is necessary to categorize the release. The objective of this scope of work is to determine the initial risk classification of the confirmed release by conducting a receptor survey, installing one groundwater monitoring well, and collecting and analyzing one soil and one groundwater sample for petroleum chemicals of concern. The general elements of an IGWA are outlined in the section below. Report requirements are detailed in Section A9, and field investigation requirements in Section B. The following primary components of the IGWA are intended to determine whether a reported release requires additional investigation:

A receptor survey including the location of all private and public water supply wells (drinking and non-drinking) and other potential receptors as defined in the Risk Based Corrective Action (RBCA) Process (i.e., utilities, surface waters, wetlands, basements) within a 1,000-foot radius of the site;

Documentation of land use at the site and adjacent land as residential, commercial, agricultural, industrial, etc. Any UST site(s) within a 500-foot radius of the subject site and their UST permit number(s) should be documented in the Report of Findings;

Monitoring Well or Boring Installation documentation (Section B1);

A description of Soil and Groundwater Sampling and Analyses and a presentation of results in comparison to RBSLs. (Section B2 ); and Presentation of all results in a Report of Findings Submitted to the owner/operator and UST

Management Division.

V. TIER I ASSESSMENT WORK SCOPE

A Tier I Assessment is conducted at sites where a release of petroleum from a regulated UST has been confirmed and additional information is necessary to classify the release in the RBCA process (See

Page: 19 of 231

Appendix A for flow chart). The sampling and data collection requirements for a Tier I assessment are presented in Section B. The work scope requirements for Tier I Assessments include:

A review of historical records of site activities and past releases;

Quantification of the CoCs and biological indicator parameters in soil and groundwater as specified by the UST Project Manager;

Location of primary source(s) of CoCs: - USTs, product lines, dispensers, service bays, etc.;

Location of secondary source(s) of CoCs: - free-product, soil with concentrations above RBSLs, etc.;

Determination of regional or site-specific hydrogeologic conditions (e.g., depth to ground water, flow direction, gradient, ambient groundwater quality, groundwater flow velocity);

Location of current and reasonable future potential receptors within 1,000 feet of the site Identification of potential significant transport and exposure pathways. A complete exposure pathway includes:

A source and mechanism for CoC release into the environment;

A transport medium (e.g., air, soil, groundwater, vapor migration through soil and utilities) for the CoC to move from the source to a receptor;

A point of potential contact of the receptor with the medium (points of exposure such as drinking water wells, surface water bodies); and An exposure route or for the CoC to affect a potential receptor (e.g., ingestion, inhalation, dermal contact).

9) Determination of current and reasonably anticipated future uses of the property, groundwater, surface water, and sensitive habitats for the site and adjacent properties. Use of property shall be determined based on factors such as: zoning laws; comprehensive infrastructure such as transportation and public utilities; existing institutional controls, such as deed restrictions; site location in relation to urban, residential, commercial, industrial, agricultural, and recreational areas; Federal/State land use designation; historical or recent development patterns; and location of wellhead protection areas;

10) Documentation, if available, of changes in CoC concentrations over time (i.e., stable, increasing, decreasing);

11) Documentation, if appropriate, of CoC concentrations measured at point(s) of exposure (e.g., in nearby drinking water wells, CoC vapor concentrations identified in nearby utilities); and

12) Collection of water and/or air samples, as appropriate, from any existing exposure point (well, underground structure, water body) that has a potential of being impacted by virtue of its proximity to the source.

Page: 20 of 231

VI. TIER 1 EVALUATION

Data obtained from an IGWA allows comparison of CoC concentrations to the soil and groundwater RBSLs to determine if additional Tier I or Tier II Assessment is required.

Data obtained from a Tier I Assessment are used in three steps to complete the Tier 1 Evaluation:

c. Comparison with RBSLs

For a Tier 1 Risk Evaluation, it is assumed that all exposure points are located in or near the source area.

CoC concentrations should be compared with the values provided in the RBSL Tables in Appendix D for the groundwater ingestion, soil leaching to groundwater, vapor inhalation, and soil ingestion pathways. For other chemicals of concern not included in Appendix D, the RBSLs may be calculated based on an estimated increased lifetime cancer risk limit of 10-6 and a hazard index of 1. As the toxicity of TPH concentrations is not accurately quantifiable, it is not used in the risk decision-making process. Each CoC is evaluated separately for each exposure route, as SC RBCA does not consider the additive effect of risk from different CoCs and different routes of exposure.

Exposure point concentrations of CoCs in impacted media are determined by the following during Tier I evaluations:

Groundwater - The maximum CoC concentration obtained during the most recent sampling event should be used. Historical sampling events can be used to establish trends.

Soil - The maximum CoC concentration obtained during the last sampling event should be used for the ingestion and dermal contact pathways. For the soil leaching to groundwater pathway, the average of two soil sample results or highest single sample with the highest non-zero concentrations from each source will be compared with RBSLs.

Air - The maximum CoC vapor concentration obtained during the most recent sampling event should be used. Historical sampling events can be used to establish trends.

d. Site Conceptual Exposure Model

A site conceptual exposure model uses information about the following to identify all complete and potential exposure pathways:

Release information

Pertinent release information includes but is not limited to: the historical use of the property where the release occurred, the approximate age of the release, and the properties of the CoC (e.g., solubility, volatility) that were released.

Site Characteristics

Pertinent site characteristics include, but are not limited to: geology, soil type, depth to bedrock, depth to groundwater, bulk density, porosity, water content, hydraulic gradient, ground-water flow direction, seepage velocity, fractional organic carbon and the physical distribution of each CoC around the source.

Proximity of existing potential receptors and their characteristics:

Page: 21 of 231

The construction specifications (e.g., depth, diameter, and material of construction of a private well or storm sewer) of all existing potential exposure points should be identified;

Location of all aquatic receiving environments (e.g., rivers, lakes, marshes, etc.) within 1,000 feet; and

The current land use should be identified for each property that is impacted, may potentially become impacted, or is adjacent to a potentially impacted property, (e.g., vacant lot, restaurant, school, residence, factory).

Applicable zoning or land use ordinances

The local city or county administrative authorities should be contacted for information pertaining to any restrictive zoning and land use ordinances. Zoning ordinances set broad-scale restrictions on property development such as residential, commercial, or industrial. Land use ordinances may establish smaller scale restrictions such as disallowing the installation of drinking water or irrigation wells. A photocopy of the applicable sections of the ordinances should be provided. If a copy cannot be obtained, the ordinance number and the name, phone number, and business address of the appropriate city or county authorities should be provided with the relevant information.

Potential Exposure Pathways

Based on the estimated age of the release, known distribution of the CoCs, and the potential for migration, all complete and potential exposure pathways should be identified and summarized for land use (current and future conditions). For example, drinking water wells may not currently exist but ground water may reasonably become a source of irrigation or drinking water. The following potential exposure pathways should be considered for evaluation:

Environmental Medium Potential Exposure Pathways

1. Air - Vapor Inhalation

- Explosive hazard

2. Surface Water - Ingestion

- Dermal contact

- Inhalation of Volatiles (enclosed space and outdoor)

3. Groundwater - Ingestion

- Dermal contact

- Inhalation of Volatiles (enclosed space and outdoor)

4. Surficial Soil - Ingestion

- Dermal contact

- Inhalation of Particulates

5. Subsurface Soil - Ingestion (during excavation)

- Dermal contact (during excavation)

- Inhalation of Particulates

- Leaching to groundwater

Table 3. Potential Exposure Pathways

Exposure routes and pathway summarization for the site conceptual model are shown in Appendix E.

Page: 22 of 231

e. Identify Additional Data Requirements

For each complete or potential exposure pathway identified in the site conceptual model, identify the data necessary to evaluate potential risk associated the pathway and to quantify the potential impact. For example, if the accumulation of vapor phase contaminants in a utility is a concern, additional data may be necessary to characterize the transport of the CoC from the source to the utilities via ground water, the extent of volatilization from the ground water, the transport of vapors from the ground water to the utility, and the construction specifications (material of construction and types of seals) of the utility. These data requirements would then become an integral part of a Tier II assessment. The site conceptual model format for various media of exposure should be summarized in the tables given in Appendix E and included in the final report as required in Section A9 of this document.

VII. TIER 1 EVALUATION OUTCOMES

Once the Tier 1 Evaluation is completed, three decision options are available for consideration based on CoC concentrations and site characteristics:

a. No Further Action

If the exposure point concentrations (see Tier 1 Evaluation for an explanation of the representative concentrations) of the CoCs are below the RBSLs, further assessment and/or cleanup is not necessary (see No Further Action Decisions).

b. Emergency Action

Typical release scenarios and response actions to eliminate any immediate threat are provided in Table 2.

Emergency Action to eliminate immediate exposure is required. The Underground Storage Tank Management Division should be notified at (803) 898-2544, or when necessary, an emergency can be reported directly to the Emergency Response Program at 1-888-481-0125 or (803) 253-6488. Appropriate actions must be implemented as soon as possible to eliminate an immediate threat.

c. Concentration above RBSLs

If the concentrations of the CoCs are above the RBSLs, a Tier II Assessment is warranted under the following conditions:

If CoC concentrations exceeds the RBSL but it is predicted that the use of site-specific data will allow substantially different Site-Specific Target Levels (SSTLs) to be determined;

If the cost of remedial action to reach RBSL will likely be greater than Tier II Evaluation (data collection, analysis, review, etc.) and subsequent remedial action;

Free phase product is present; or The approach or assumptions used to derive the Tier I goals are not appropriate for conditions at the site.

Page: 23 of 231

VIII. TIER II ASSESSMENT

Additional Site Assessment may be required to fully evaluate the current and future exposure pathways identified in the Tier 1 Evaluation. The Tier II Implementation section outlines a comprehensive Site Assessment approach for obtaining the additional information necessary for a Tier 2 Evaluation. The Tier II Assessment is used for sites with petroleum releases from regulated underground storage tanks (USTs) where additional investigation of site-specific conditions is warranted based on existing data from previous investigations. Tier II Assessment defines site geology and the extent of the contamination horizontally and vertically. The number and placement of wells and borings are not specified in this QAPP.

Tier II Assessments include:

Determination of geology;

Description of the site-specific hydrologic conditions;

Delineation of the extent of free-phase product;

Determination of horizontal and vertical extent of each CoC above its RBSL, as appropriate;

Determination of changes in concentrations of each CoC over time (i.e., increasing, stable, or…