Final Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP) U.S. Army SSC.pdf

DRAFT FINAL

Uniform Federal Policy – Quality Assurance Project Plan For

Environmental Remediation Services U.S. Army Soldier Systems Center

Natick, Massachusetts

Prepared for

United States Army Environmental Command

Northeast Environmental Services and Support Division

2450 Connell Road, Bldg. 2264

JBSA Ft Sam Houston, TX 78234-7664

Prepared by:

Plexus Scientific Corporation

5510 Cherokee Avenue, Suite 350

Alexandria, VA 22312

Contract W91ZLK-13-D-0010

Delivery Order 0004

March 2016

Draft Final UFP-QAPP U.S Army Soldier Systems Center

Natick, Massachusetts Revision Number: 02 Revision Date: 3.7.16 i

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 PROJECT MANAGEMENT AND OBJECTIVE ELEMENTS

2.1 TITLE AND APPROVAL PAGE

2.2 DOCUMENT FORMAT AND TABLE OF CONTENTS

2.2.1 Document Control Format

2.2.2 Document Control Numbering System

2.2.3 Table of Contents

2.2.4 QAPP Identifying Information

2.3 DISTRIBUTION LIST AND PROJECT PERSONNEL SIGN-OFF SHEET

2.3.1 Distribution List

2.3.2 Project Personnel Sign-Off Sheet

2.4 PROJECT ORGANIZATION

2.4.1 Project Organization Chart

2.4.2 Communication Pathways

2.4.3 Personnel Responsibilities and Qualifications

2.4.4 Special Training Requirements and Certification

2.5 PROJECT PLANNING/PROBLEM DEFINITION

2.5.1 Project Planning

2.5.2 Problem Summary, Site Description and Background, and Project Description

2.6 PROJECT QUALITY OBJECTIVES AND MEASUREMENT PERFORMANCE CRITERIA

2.6.1 Development of Project Quality Objectives Using the Systematic Planning Process

2.6.2 Measurement Performance Criteria

2.6.2.1 Precision

2.6.2.2 Accuracy/Bias

2.6.2.3 Sensitivity and Quantitation Limits

2.6.2.4 Representativeness

2.6.2.5 Comparability

2.6.2.6 Completeness

2.7 SECONDARY DATA EVALUATION

2.8 SUMMARY OF PROJECT TASKS

3.0 MEASUREMENT AND DATA ACQUISITION ELEMENTS

3.1 SAMPLING TASKS

3.1.1 Sampling Process Design and Rationale

3.1.2 Sampling Procedures and Requirements

3.1.2.1 Sample Collection Procedures

3.1.2.2 Sample Containers, Volume and Preservation

3.1.2.3 Equipment/Sample Containers Cleaning, Decontamination Procedures

3.1.2.4 Field Equipment Calibration, Maintenance, Testing and Inspection Procedures

3.1.2.5 Sampling Supply Inspection and Acceptance Procedures

3.1.2.6 Field Documentation Procedures

3.1.2.7 Sample Identification

3.1.2.8 Field Quality Control Requirements

3.1.3 Analytical SOPs

3.1.4 Analytical Instrument Calibration Procedures

3.1.5 Analytical Instrument and Equipment Maintenance, Testing and Inspection

3.2 SAMPLE COLLECTION DOCUMENTATION, HANDLING, TRACKING AND CUSTODY PROCEDURES

Natick, Massachusetts ii

3.2.1 Sample Collection Documentation

3.2.2 Sample Handling and Tracking System

3.2.3 Sample Custody

3.3 DATA MANAGEMENT TASKS

3.3.1 Project Documentation and Records

3.3.2 Data Package Deliverables

4.0 ASSESSMENT AND OVERSIGHT ELEMENTS

4.1 ASSESSMENTS AND RESPONSE ACTIONS

4.1.1 Planned Assessments

4.1.2 Assessment Findings and Corrective Action Responses

4.2 QA MANAGEMENT REPORT

4.3 FINAL REPORTS

5.0 DATA REVIEW ELEMENTS

5.1 OVERVIEW

5.2 DATA REVIEW

5.2.1 Data Verification

5.2.2 Data Validation

5.2.3 Usability Assessment

6.0 REFERENCES

Natick, Massachusetts iii

FIGURE

Figure 1-1: Site Location Map

APPENDICES

Appendix A: Worksheets

Appendix B: Plexus Standard Operating Procedures

Appendix C: ALS Environmental Sample Chain of Custody

Appendix D: ALS Environmental DoD ELAP Certificates

Appendix E: ALS Environmental Standard Operating Procedures

Natick, Massachusetts iv

LIST OF ACRONYMS

ADR Automatic Data Review

APP Accident Prevention Plan

COC Chain of Custody

COC Contaminant of Concern

DL Detection Limit

DoD Department of Defense

DOE Department of Energy

DQO Data Quality Objectives

ELAP Environmental Laboratory Accreditation Program

ESD Explanation of Significant Difference

HAZWOPER Hazardous Waste Operations and Emergency Response

ICAL Initial Calibration

IDQTF Intergovernmental Data Quality Task Force

LGAC Liquid-Phase Granular-Activated Carbon

LOD Limits of Detection

LOQ Limits of Quantitation

MS/MSD Matrix Spike/Matrix Spike Duplicate

NPL National Priority List

OSHA Occupational Safety and Health Administration

PCE Tetrachloroethene

PLC Programmable Logic Control

PQO Project Quality Objectives

QA Quality Assurance

QC Quality Control

QAPP Quality Assurance Project Plan

QSM Quality Systems Manual

R Percent Recovery

RA(O) Remedial Action Operation

ROD Record of Decision

RPD Relative Percent Difference

SOP Standard Operating Procedure

SSC Soldier Systems Center

SSHP Site Safety and Health Plan

TCE Trichloroethene

TSA Technical Systems Audit

UFP Uniform Federal Policy

USEPA Environmental Protection Agency

VGAC Vapor-Phase Granular-Activated Carbon

VOC Volatile Organic Compound

Natick, Massachusetts

1.0 INTRODUCTION

This Uniform Federal Policy (UFP) - Quality Assurance Project Plan (QAPP) has been prepared by

Plexus Scientific Corporation (Plexus) under contract number W91ZLK-13-D-0010, Task Order

(TO) No. 0004, with the Department of the Army U.S. Army Mission and Installation Contracting

Command (MICC) to provide environmental remediation services for three sites (NRDEC-05, NRDEC-11, and NRDEC-16) at U.S. Army Soldier Systems Center (SSC), Natick, Massachusetts.

The Site Location Map is provided as Figure 1-1.

Figure 1-1. Site Location Map

Natick, Massachusetts

The primary purpose of the work herein is to provide an ongoing assessment of the effectiveness of the hydraulic containment of the groundwater plumes at the three areas, provide results of the evaluation of progress toward overall cleanup of the three groundwater plumes to the regulators and the public in a timely fashion, evaluate trends in contamination concentrations over time, collect hydrogeologic data to characterize local groundwater flow conditions, collect data for use in designing future remedial actions, and evaluate the natural attenuation processes at the facility.

This UFP-QAPP has been prepared following guidance from the UFP-QAPP Manual (IDQFT, 2005).

The UFP-QAPP Manual is a set of consensus documents prepared by the Intergovernmental Data

Quality Task Force (IDQTF) to provide instructions for preparing QAPPs for any environmental data collection operation. The UFP was developed as a joint initiative by the United States Environmental

Protection Agency (USEPA), the US Department of Defense (DoD), and the US Department of

Energy (DOE) to ensure that environmental data are of known and documented quality and suitable for their intended uses and environmental data collection and technology programs meet stated requirements.

Natick, Massachusetts

2.0 PROJECT MANAGEMENT AND OBJECTIVE ELEMENTS

The primary purpose of the work herein is to perform Remedial Action Operation (RA(O)) for the duration of the contract or until achievement of response complete, whichever is sooner, for NRDEC-

05, NRDEC-11, and NRDEC-16.

2.1 TITLE AND APPROVAL PAGE

The Title and Approval Page contains project information and required approval signatures from all parties involved with project implementation and oversight. The Title Approval Page is included as

Worksheet #2 (Appendix A).

2.2 DOCUMENT FORMAT AND TABLE OF CONTENTS

The following sections describe the document format and document control as required by the UFP-

QAPP Manual. In addition, these sections describe requirements regarding the Crosswalk to UFP-

QAPP worksheet and UFP-QAPP elements.

2.2.1 Document Control Format

The header of each page in this document provides the following information:

The title of the document.

The document status (i.e., internal draft, draft, final).

The date of the current revision.

2.2.2 Document Control Numbering System

Due to the limited size and scope of this project, a document control numbering system is not required.

2.2.3 Table of Contents

The organization of the QAPP is outlined in the Table of Contents.

2.2.4 QAPP Identifying Information

The identifying information for the QAPP is provided on Worksheet #1 (Appendix A).

2.3 DISTRIBUTION LIST AND PROJECT PERSONNEL SIGN-OFF SHEET

2.3.1 Distribution List

The distribution list documents entities and individuals to who copies of the approved QAPP and any revisions, amendments or addenda will be sent. The distribution list is located on Worksheet #3

(Appendix A).

2.3.2 Project Personnel Sign-Off Sheet

The Project Personnel Sign-Off Sheet documents that all project personnel performing the work have read the applicable sections of the QAPP and will perform the tasks as described. The Project

Personnel Sign-Off Sheet is located on Worksheet #4 (Appendix A).

Natick, Massachusetts

2.4 PROJECT ORGANIZATION

The following sections identify the organization setup, pathways to communication, personnel roles, qualifications and relevant training.

2.4.1 Project Organization Chart

The Project Organizational Chart included as Worksheet #5 (Appendix A) shows the reporting relationships between the Army, Plexus, and all subcontractors. The Plexus Team will conduct and oversee all field activities and also oversee all subcontractors.

2.4.2 Communication Pathways

Communication Pathways are outlined on Worksheet #6 (Appendix A). These pathways include the points of contact for resolving project related technical issues, sampling and analysis problems and for distributing preliminary, screening and definitive data to managers, users and the public.

2.4.3 Personnel Responsibilities and Qualifications

The roles, responsibilities and qualifications of project personnel are included in Worksheet #7

(Appendix A).

2.4.4 Special Training Requirements and Certification

Special training requirements are included in Worksheet #8 (Appendix A). Personnel handling potentially contaminated media will have received Occupational Safety and Health Administration

(OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) training. Refer to the Project Accident Prevention Plan / Site Safety & Health Plan (APP/SSHP) for additional information.

2.5 PROJECT PLANNING/PROBLEM DEFINITION

This section addresses project planning, existing environmental conditions and Site background.

2.5.1 Project Planning

Project planning was conducted during the Kick-Off Meeting. This session is documented in

Worksheet #9 (Appendix A).

2.5.2 Problem Summary, Site Description and Background, and Project

Description

The problem summary, site description and background, and project description information are detailed in Worksheet #10 (Appendix A).

Problem Summary

Plexus was selected to provide all the required supervision, labor, and materials to perform environmental remediation services for multiple sites at U.S. Army Soldier Systems Center (SSC), in Natick, Massachusetts.

Natick, Massachusetts

Site Description and Background

SSC (formerly Natick R, D, and E Center) was officially established in 1953 as the Quartermaster

Research and Development Center, a major U.S. Army laboratory whose primary mission was the research and development of food, clothing, and personal and organizational equipment vital to the support of the individual combat soldier. SSC is located approximately 17 miles west-southwest of Boston in Natick, Massachusetts. SSC occupies 78 acres on a small peninsula extending from the eastern shore of the South Pond of Lake Cochituate, Massachusetts. SSC was placed on the National Priorities List (NPL) on May 31, 1994, primarily due to detections of chlorinated solvents in groundwater. A pilot groundwater extraction and treatment system was started in 1998. The Army and the USEPA signed a Record of Decision (ROD) for groundwater at site NRDEC-05 in September 2001. Subsequently, sites NRDEC-11 and NRDEC-16 were added to the 2001 ROD through an Explanation of Significant Difference (ESD) signed on May

13, 2013. The three groundwater sites - NRDEC-05, NRDEC-11, and NRDEC-16 - are similar in that they all are located within the footprint of the 78-acre SSC installation, all involve groundwater contaminated with trichloroethylene (TCE), tetrachloroethylene (PCE), or a mixture of both contaminants, and all three sites are currently being treated using the same treatment technology at the same pump and treat facility under the same ROD. All three sites are in RA(O) status. All known areas of sediment and soil contamination at SSC have been cleaned up.

2.6 PROJECT QUALITY OBJECTIVES AND MEASUREMENT PERFORMANCE

CRITERIA

This section documents the environmental decisions that need to be made and the level of data quality needed to ensure that those decisions are based on sound scientific data.

2.6.1 Development of Project Quality Objectives Using the Systematic Planning

Process

Project quality objectives (PQOs) were determined during the planning process to determine the necessary level of data quality to be collected to answer specific environmental questions and ensure environmental decisions will be made based on sound scientific data (Worksheet #11; Appendix A).

2.6.2 Measurement Performance Criteria

Measurement performance criteria are discussed below and presented on Worksheet #12

(Appendix A).

2.6.2.1 Precision

Precision is the degree to which a set of observations or measurements of the same property, obtained under similar conditions, conform to themselves. Precision is usually expressed as standard deviation, variance, percent difference or range, in either absolute or relative terms. Precision data indicate how consistent and reproducible the field sampling or analytical procedures have been.

Precision of the field sampling process will be determined through evaluation of field duplicate samples. Field duplicate samples will be collected at a frequency of five percent of the number of

Natick, Massachusetts discrete samples. Additionally, the laboratory will perform analysis of matrix spike and matrix spike duplicates (MS/MSDs). MS/MSDs will be collected at a frequency of five percent of the number of discrete samples.

The laboratory objective is to equal the precision demonstrated for the applied analytical methods on similar samples. Precision measures the reproducibility of measurements under a given set of conditions. Specifically, it is a quantitative measure of the variability of a group of measurements compared to their average value.

Precision will be evaluated using field duplicates, laboratory duplicates and MS/MSDs, and it will be expressed as the relative percent difference (RPD). RPD will be calculated using the following equation:

2/)21(

RR

RR

RPD

where: R1 = Result 1

R2 = Result 2

Criteria for evaluation of laboratory replicates are specified in the applicable methods. The objective for field replicate precision is < 30% RPD for all matrices.

Worksheet #12 (Appendix A) provides the sampling and analytical measurement performance criteria for precision for each method and matrix to be sampled.

2.6.2.2 Accuracy/Bias

Accuracy is defined as the degree of agreement of a measurement or average of measurements with an accepted reference value; bias describes the systematic or persistent distortion associated with a measurement process. The terms accuracy and bias are used interchangeably in this document.

Accuracy will be evaluated by the use of calibration and calibration verification procedures, laboratory control samples, and surrogates at the frequencies specified in the analytical methods utilized. Accuracy will be calculated as percent recovery and will be evaluated by the acceptance criteria specified in the DoD Quality System Manual (QSM; DoD, 2013). The equation to determine percent recovery (R) is as follows:

𝑅 = 𝑎𝑛𝑎𝑙𝑦𝑡𝑖𝑐𝑎𝑙 𝑣𝑎𝑙𝑢𝑒 𝑜𝑓 𝑠𝑝𝑖𝑘𝑒𝑑 𝑠𝑎𝑚𝑝𝑙𝑒 𝑡ℎ𝑒𝑜𝑟𝑒𝑡𝑖𝑐𝑎𝑙 𝑣𝑎𝑙𝑢𝑒 𝑜𝑓 𝑠𝑝𝑖𝑘𝑒𝑑 𝑠𝑎𝑚𝑝𝑙𝑒 x 100

Worksheet #12 (Appendix A) provides the sampling and analytical measurement performance criteria for accuracy/bias for each method and matrix to be sampled.

2.6.2.3 Sensitivity and Quantitation Limits

The sensitivity of an analytical method/instrumentation is a measure of the ability of the test

Natick, Massachusetts method/instrumentation to meet prescribed minimum levels for reporting. Sensitivity is a significant consideration in the selection of an analytical method(s) that can achieve project-specific Data Quality

Objectives (DQOs). For this project, analytical requirements for sensitivities are represented by DoD

QSM defined limits of quantitation (LOQs), limits of detection (LODs) and detection limits (DLs).

The LOQ is the lowest concentration that produces a quantitative result within specified limits of precision and bias. For DoD projects, the LOQ shall be set at or above the concentration of the lowest initial calibration (ICAL) standard. The LOD is defined as the smallest amount or concentration of a substance that must be present in a sample in order to be detected at a high level of confidence (99 percent). At the LOD, the false negative rate is 1 percent. The DL is the smallest analyte concentration that can be demonstrated to be different from zero or a blank concentration at the 99 percent level of confidence. Below the DL, the false negative rate is 50 percent. Laboratory sensitivities and detection limits are provided on Worksheet #15 (Appendix A).

2.6.2.4 Representativeness

Representativeness is a qualitative term that describes the extent to which a sampling design adequately reflects the environmental conditions of a site. Sampling and handling procedures, as well as laboratory practices, are designed to provide a standard set of performance-driven criteria to provide data of the same quality as other analyses of similar matrices using the same methods under similar conditions. Representativeness will be determined by a comparison of the quality controls for these samples against data from similar samples analyzed at the same time.

2.6.2.5 Comparability

Comparability is the degree to which different methods or data agree or can be represented as similar.

This investigation will employ narrowly defined sampling methodologies, use of standard sampling procedures and equipment, uniform training, documentation of sampling, standard analytical protocols/procedures, quality control (QC) checks with standard control limits, and universally accepted data reporting units to ensure comparability to other data sets. Through proper implementation and documentation of these standard practices, the project will establish confidence that data will be comparable to other project and programmatic information by following all procedures in the QAPP throughout the entire project.

2.6.2.6 Completeness

Completeness is a measure of the amount of valid data collected using a measurement system. It is expressed as a percentage of the number of measurements that are specified in the QAPP. The goal of completeness is to generate the maximum amount of valid data. The highest degree of completeness would be to find all deliverables valid and acceptable. The lowest level of completeness is excessive failure to meet established acceptance criteria and consequent rejection of data. All samples collected in the field for analysis must be accounted for in the data packages, and the data should be 100% complete from a deliverable standpoint, as tracked through the chain-of-custody process. The impact of rejected or unusable data will be made on a case-by-case basis. Loss of critical data may require re-sampling or re-analysis.

Natick, Massachusetts

2.7 SECONDARY DATA EVALUATION

Prior investigations of NRDEC-05, NRDEC-11, and NRDEC-16 sites at U.S. Army SSC, Natick, Massachusetts, are summarized on Worksheet #13 (Appendix A).

2.8 SUMMARY OF PROJECT TASKS

The Worksheet #14 (Appendix A) provides a description of the field activities that will be performed.

Plexus field Standard Operating Procedures (SOPs) are listed on Worksheet #21 (Appendix A) and found in Appendix B.

Natick, Massachusetts

3.0 MEASUREMENT AND DATA ACQUISITION ELEMENTS

This section covers how project data will be collected, measured and documented. Proper implementation of these activities will help ensure that resulting data are scientifically sound, of known and documented quality and suitable for their intended use.

3.1 SAMPLING TASKS

The following sections include all components of the project-specific sampling system, including process design and rationale, procedures and requirements.

3.1.1 Sampling Process Design and Rationale

The general sampling process is discussed in this section, as well as in Worksheets #17 and #18

(Appendix A). More detail is provided in the LTMP, as last amended in February 2011 (ECC, 2011).

In accordance with the LTMP quarterly, semi-annual, and annual samples from 70 monitoring wells will be submitted for Volatile Organic Compounds (VOCs), 1,4-dioxane, metals, pesticides, and coliform analysis, or a subset thereof, while performing RA(O) at the three sites under this contract:

NRDEC-05, NRDEC-11, and NRDEC-16.

3.1.2 Sampling Procedures and Requirements

Sampling procedures that will be used are documented in the following sections.

3.1.2.1 Sample Collection Procedures

Groundwater samples are to be collected from extraction wells. Samples from the EWs will be collected through spigots located inside the treatment system building or at the individual wellhead.

Purging and sampling from monitoring wells is be conducted using low flow techniques using dedicated discharge tubing and bladder pumps. In wells where a dedicated pump was not installed, the groundwater samples will be collected using stainless steel non-dedicated bladder pumps. The wells identified with a small diameter, 0.86 inches, will be collected using alternative sampling methods, such as peristaltic or submersible pumps, which are capable of fitting into the smaller-diameter wells.

Following collection, samples will be placed in an ice chest and kept on ice to approximately 4 degrees

Celsius (°C). They will be transported under chain-of-custody procedures to an analytical laboratory.

3.1.2.2 Sample Containers, Volume and Preservation

Sample container, preservation and hold time requirements are detailed on Worksheet #19 (Appendix

A). Sample containers will be provided by the analytical laboratory. Sample bottle requirements, preservation and holding times are discussed further below.

Sample Containers

Sample bottles and equipment are to be managed so as to prevent cross contamination, or contamination from an outside source. Special attention shall be paid to activities that may lead to

Natick, Massachusetts inadvertent contamination of sample bottles and equipment. Disposable gloves are to be worn for handling all cores and samples and then properly disposed. Sample containers are purchased pre-cleaned and treated according to USEPA specifications for the methods. Sampling containers that are reused are decontaminated between uses by the USEPA-recommended procedures (i.e., USEPA

540/R-93/051).

Sample Preservation

Sample volumes, container types, and preservation requirements for the analytical methods performed on samples are listed on Worksheet #19 (Appendix A).

Holding Times

Sample holding time tracking begins with the collection of samples and continues until the analysis is complete. Holding times for methods that may be required for this work are specified on Worksheet

#19 (Appendix A).

3.1.2.3 Equipment/Sample Containers Cleaning, Decontamination Procedures

Equipment/Sample Container Cleaning

All equipment that may directly or indirectly contact samples will be decontaminated in a designated decontamination area. In addition, care will be taken to prevent the sample from coming into contact with potentially contaminating substances, such as tape, oil, engine exhaust, corroded surfaces, and dirt.

Decontamination Procedures

The procedures in the SOPs shall be used to decontaminate sampling devices. The following is a summary of those procedures. For sampling and smaller excavation devices, the equipment will be scrubbed with a solution of potable water and Liquinox, or equivalent mercury-free, laboratory-grade detergent. The equipment will be rinsed with copious quantities of potable water, and analyte-free water and air dried on a clean surface. If the sampling device shall not be used immediately after being decontaminated, it shall be wrapped in oil-free aluminum foil, placed in a closed stainless steel, glass, or Teflon container, or wrapped in plastic or placed in a zip-lock bag.

3.1.2.4 Field Equipment Calibration, Maintenance, Testing and Inspection

Procedures

Field equipment calibration, maintenance, testing and inspection information and requirements for all field equipment are detailed on Worksheet #22 (Appendix A). .

3.1.2.5 Sampling Supply Inspection and Acceptance Procedures

Sample containers will be provided by the analytical laboratory. Sample bottles will be prepared and packaged for shipment to minimize bottle breakage and maintain adequate sample temperature.

Samples will be packaged in rigid-plastic ice chests and either picked up by an overnight courier or by a representative of the laboratory. Arrangements will be made with the laboratory before sample shipment to ensure that a person will be available to receive and handle the samples. The samples will be characterized as environmental samples. The following are procedures for packaging and

Natick, Massachusetts shipping of environmental and hazardous waste samples.

It is anticipated that all samples collected will be considered environmental samples and will be handled as such. Environmental samples are defined as those samples collected from environmental matrices such as soil, groundwater, or sediments that are not considered high-hazard samples.

Environmental samples will be packaged for shipment as follows:

1. Sample containers will be checked to ensure that they are adequately identified with sample labels.

2. A rigid-plastic cooler (such as a Coleman® or other sturdy cooler) will be used as a shipping container. In preparation for shipping samples, the drain plug (if present) will be taped shut from the inside and outside.

3. The sample containers will be sealed in watertight bags (e.g. zip-loc bags).

4. The bottles will be placed upright in the lined cooler in such a way that they do not touch and will not touch during shipment. Molded plastic or sealed foam, bubble wrap, or other material will be placed between and around each container.

5. All samples will be shipped to the laboratory using ice and chilled to 4°C +/- 2°C.

6. The cooler will be filled with packing material.

7. The completed chain of custody (COC) record will be placed into a sealable plastic bag, sealed, and taped to the inside cover of the corresponding cooler.

8. The cooler lid will be secured by wrapping the cooler in two different locations with strapping tape or duct tape.

9. The completed air bill will be taped to the outside cover of the corresponding cooler.

10. “Fragile” labels will be placed on at least two sides and “This Side Up” labels on at least two sides of the cooler.

11. The signed custody seal will be affixed across the front and one side of each cooler/lid interface and covered with clear packing tape.

12. The laboratory will be notified if the sample is suspected to contain any substance that would require laboratory personnel to take additional safety precautions.

13. The shipper will be notified of the contents and packing material and the cooler will be delivered to the shipper’s custody.

3.1.2.6 Field Documentation Procedures

All field measurements and observations will be recorded in project field logbook. Field measurements include measurement of sampling depths and visual observations about the weather and sampling area. Field documents will be legible and written in ink and all entries signed and dated.

Corrections or revisions to sample documentation shall be made by drawing a line through the original entry and initialing and dating any changes.

Chain of Custody Record

Procedures to ensure the custody and integrity of the samples begin at the time of sampling and

Natick, Massachusetts continue through transport, sample receipt, preparation, analysis and storage, data generation and reporting, and sample disposal. Records concerning the custody and condition of the samples are maintained in field and laboratory records.

Plexus will maintain chain-of-custody records for all field and field QC samples. A sample is defined as being under a person's custody if any of the following conditions exist: (1) it is in their possession,

(2) it is in their view, after being in their possession, (3) it was in their possession and they locked it up or, (4) it is in a designated secure area.

All sample shipping containers shall be sealed in a manner that shall prevent or detect tampering if it occurs. In no case shall tape be used to seal individual sample containers (i.e. jars, bottles, etc.).

Samples shall not be packaged with activated carbon unless prior approval is obtained from Plexus.

The following minimum information concerning the sample shall be documented on the COC forms

(Appendix C):

Unique sample identification

Date and time of sample collection

Source of sample (including name, location, and sample type)

Designation of MS/MSD

Preservative used

Analyses required

Name or initials of collector(s)

Serial numbers of custody seals and transportation cases (if used)

Custody transfer signatures and dates and times of sample transfer from the field to transporters and to the laboratory or laboratories

Bill of lading or transporter tracking number (if applicable)

3.1.2.7 Sample Identification

The method of sample identification used depends on the type of sample collected. In-situ field samples are those collected for specific field analysis or measurement where the data are recorded directly in bound field logbooks, on well purge forms, or on sample data sheets, with identifying information, while in the custody of the sampling team. The documentation of field records is further discussed in Section 2.4. Examples of such in-situ field measurements and analyses include temperature, pH, conductivity, dissolved oxygen (DO), and oxygen reduction potential (ORP).

Samples other than those collected for in-situ analysis are identified by using a standard or label which is applied to the sample container. Sample labels should consist of a unique field identification number that distinguishes each sample from all others. The site-specific sample number will link the sample to the sample source or sampling point identification. The following information shall be included on the sample label using waterproof, non-erasable ink:

Natick, Massachusetts project number;

field identification or sample station number;

date and time of sample collection;

whether the sample is preserved or unpreserved;

type of preservative, if applicable;

the general types of analyses to be performed; and relevant comments (such as readily detectable or identifiable odor, color, or known toxic properties).

In order to ensure that each field sample number for every sample collected at SSC is unique, an

8 character sample identification system will be used. An example of a field sample number is as follows:

MX018B39

The following bullet items present information to be used when assigning sample identifications

(off-site analyses):

Digit 1 Indicates the type of sample has been collected (M = monitoring well, ground water)

Digit 2 Designates a sample as a field sample “X”, field duplicate sample “D”, matrix spike “M” or matrix spike duplicate “S”.

Digits 3, 4, 5 Indicates the well number using 0s as place holders for locations with less than three digits (MW-18B-2 digits would be “018”).

Digit 6 Indicates the well interval either “A”, “B”, or “C”.

Digits 7, 8 Indicates the sample event number.EE Sample Quality Assurance/ Quality Control

(QA/QC) Type Code, if applicable.

FD = field duplicate

TB = Trip blank

EB = Equipment blank

Matrix spike (MS)/matrix spike duplicate (MSD) volumes will use the same sample identification as the primary sample, but will indicate MS/MSD as necessary in the comments section on the chain of custody.

3.1.2.8 Field Quality Control Requirements

The field QC Summary for each Analyte/Analytical Group is detailed in Worksheet #20

(Appendix A).

The laboratory subcontractor for the analysis of the characterization samples is ALS

Environmental in both Rochester, New York, and Middletown, Pennsylvania. ALS Environmental

Natick, Massachusetts is DoD Environmental Laboratory Accreditation Program (ELAP) certified. Copies of the DoD

ELAP certificates are provided in Appendix D.

Field Duplicates

A field duplicate sample is a second sample collected at the same location as the original sample.

Duplicate samples will be collected simultaneously or in immediate succession, using identical recovery techniques, and treated in an identical manner during storage, transportation, and analysis. The sample containers will be assigned an identification number in the field so that the field duplicate sample cannot be identified (blind duplicate) as duplicate samples by laboratory personnel performing the analysis. Field duplicates will be collected at a frequency of 5% (one in

20) of the total number of samples collected.

MS/MSDs (Matrix Spike/Matrix Spike Duplicates)

The MS and MSD are aliquots of sample spiked with known concentrations of all target analytes. The spiking occurs prior to sample preparation and analysis. Each analyte in the MS and MSD will be spiked at a level less than or equal to the midpoint of the calibration curve for each analyte. The

MS/MSDs are used to document potential matrix effects associated with a site. The MS/MSD will be designated on the COC. The sample replicates will be generated in the field and will be used by the laboratory to prepare the appropriate MS/MSDs. A minimum of one MS and one MSD will be designated for every 20 samples.

Equipment Blanks

Equipment blanks will be prepared by pouring the laboratory provided de-ionized water over and through the non-dedicated sampling pump (before it is used) to determine if any contaminants are present on the non-dedicated pump that are not associated with the groundwater at the site.

Analysis of equipment blanks will be performed for VOCs. Equipment blanks will be prepared and collected at a frequency of one per sampling event.

Trip Blanks

Trip blanks consist of a VOC sample vial filled in the laboratory with ASTM Type II reagent grade or organic-free water, transported to the sampling site, handled like an environmental sample, and returned to the laboratory for analysis. Trip blanks are not opened in the field. Trip blanks are prepared only when VOC samples are collected and analyzed for VOC analytes.

Trip blanks are used to assess the potential introduction of contaminants from sample containers or during the transportation and storage procedures. Each cooler of samples sent to the laboratory for analysis of VOCs will contain one trip blank.

3.1.3 Analytical SOPs

Methods and analytical SOPs to be used for analysis are presented on Worksheet #23 (Appendix A).

The analytical method SOPs are presented in Appendix E and kept on file at ALS Environmental and Plexus.

Natick, Massachusetts

3.1.4 Analytical Instrument Calibration Procedures

For detailed analytical instrument calibration procedures refer to the analytical SOPs referenced in

Worksheet #24 (Appendix A) and included in Appendix E.

3.1.5 Analytical Instrument and Equipment Maintenance, Testing and Inspection

Analytical instrument and equipment maintenance, testing and inspection information is presented in

Worksheet #25 (Appendix A).

3.2 SAMPLE COLLECTION DOCUMENTATION, HANDLING, TRACKING AND

CUSTODY PROCEDURES

Sample collection documentation, handling, tracking and custody procedures used to ensure that sample integrity and custody are maintained are described in the following sections.

3.2.1 Sample Collection Documentation

Field sampling documentation will be included on the COC and in the field logbook. Waterproof sample labels will be filled in using indelible ink and sample identifications (ID’s) will be written in duplicate on each sample container’s lid using permanent marker.

3.2.2 Sample Handling and Tracking System

The sample packaging and shipment procedures summarized below will ensure that samples will arrive at the laboratory with the COC intact. The on-site senior scientist/engineer is responsible for the care and custody of the samples until they are transferred or properly dispatched. Sample labels are to be completed for each sample. The Plexus Project Manager, in conjunction with the COR, will review all field activities to determine whether proper custody procedure was maintained during the field work and to decide if additional samples are required. Sample handling is summarized on

Worksheet #26 (Appendix A).

3.2.3 Sample Custody

Samples will be accompanied by a properly completed and signed COC form. The sample ID code, sample time, sample date, matrix, preservation and number of containers will be listed on the COC form. When transferring the possession of samples, the individuals relinquishing and receiving will sign, date and note the time on the record. This record will document transfer of custody of samples from the sampler to another person, to the laboratory or to/from a secure storage area. Because field personnel will be having samples transported from the site to the laboratory via a courier service the appropriate tracking number will be documented in a signature blank (with type of service noted [e.g., Federal Express]) on all associated COC forms. All shipping documentation will be retained by the laboratory along with the original corresponding COC forms.

Natick, Massachusetts

All shipments will be accompanied by the COC record identifying the contents. The original record will accompany the shipment and copies will be retained by the sampler for return to project management and the project file. An example COC is included as Appendix C in lieu of Worksheet

#27.

3.3 DATA MANAGEMENT TASKS

All project data and information will be in a format that is usable by project personnel. The following sections describe how project data and information will be documented, tracked and managed. A summary of project documents is provided on Worksheet #29 (Appendix A).

3.3.1 Project Documentation and Records

Project documents and records that will be generated for every aspect of the project are listed on

Worksheet #29 (Appendix A).

3.3.2 Data Package Deliverables

Data packages will be provided in hard copy and electronic format. Worksheet #30 (Appendix A) provides information for the laboratory (ALS Environmental) performing the analysis for the study.

Natick, Massachusetts

4.0 ASSESSMENT AND OVERSIGHT ELEMENTS

This section ensures that planned project activities are implemented as described in this QAPP and that reports are provided to apprise management of the project status and any QA issues that arise during implementation. Assessment activities help to ensure that resultant data quality is adequate for its intended use, and that appropriate responses are in place to address nonconformance or deviations from this QAPP.

4.1 ASSESSMENTS AND RESPONSE ACTIONS

The following sections describe the planned assessments that will be conducted and the response actions that will be taken.

4.1.1 Planned Assessments

The following assessments may be used to evaluate the effectiveness of project activities:

Readiness Review – To be completed prior to initiating field work, readiness will be systematically reviewed and documented.

Field Safety Audit – To be completed during field activities. All aspects of field safety, paperwork procedures, personnel, training, equipment inspections, and activity hazard analysis’ procedures are examined for conformance with the APP.

Field QC Audit – To be completed during field activities. All aspects of field quality are examined for conformance with the QAPP.

Off-Site Laboratory Technical Systems Audit (TSA) – The laboratories are responsible for performing their own internal audits and for following calibration procedures with data review conducted at a frequency so that errors and problems are detected early, thus avoiding the prospect of redoing large segments of work.

Field Logbook Assessment – Field logbooks used in the field will be reviewed to ensure recorded field data conformance with the QAPP

4.1.2 Assessment Findings and Corrective Action Responses

Situations related to this project requiring corrective action will be documented and made part of the project file. For each measurement system identified that requires corrective action, the responsible individual for initiating the corrective action and also the individual responsible for approving the corrective action will be identified.

4.2 QA MANAGEMENT REPORT

Project status reports will be prepared and submitted to lead organization members on a monthly basis. The monthly status report will include project information; overall completion of each task, work planned for the following month and will list all work performed, deliverables submitted and nonconformance issues identified during the reporting period. Each monthly status report will be

Natick, Massachusetts submitted by the 10th day of the month following the reporting period. A QA management report table is included as Worksheet #31, 32 and 33 (Appendix A).

4.3 FINAL REPORTS

Draft reports will be prepared and submitted for each site following receipt of the validated data and will present the findings and conclusions. Figures, analytical result tables, photographs, laboratory reports, and other applicable documents will be included in reports as applicable.

Natick, Massachusetts

5.0 DATA REVIEW ELEMENTS

The following sections describe how the project data will be examined, evaluated, and used for decision-making. Following the identified processes will ensure data used for decision-making are valid and defensible and of appropriate quality to support the project data conclusions.

5.1 OVERVIEW

Three distinct evaluative steps will be used to ensure that project data quality needs are met. These data review steps are verification, validation and usability assessment and will be applied to all aspects of the study from which data is generated.

A peer review of deliverables will be performed. The Project Manager will have overall responsibility for the review process. To assure an adequate and independent review, the reviewer selected for the review must be technical specialist(s) for the function they are reviewing, and have not been involved in the study that is being reviewed. Based on the scope of work for this project, an external peer review is not warranted.

The peer reviewer will perform an independent review of the completed internal draft, draft and final reports before they are submitted. Review will include the report text, figures tables, laboratory report and other appendices. The review comments will be in writing, and will include comments and value added analysis on the possible significance of each comment.

Quality Control objectives include confirming that the report:

Meet customer requirements

Comply with applicable laws, regulations, policies and sound technical practices

Are of adequate scope and level of detail

Are consistent, logical, accurate and comprehensive

Are based on convincing and consistent assumptions

Adequately describe the problems and opportunities, planning objectives and constraints, existing conditions, future without-project conditions, and future with-project conditions to support recommendations

Address outstanding action items from milestone conferences, issue resolution conferences and other reviews.

The reviewer will present written comments to the Project Manager and the Project Manager will address the comments in the report deliverable. The comment period will begin after the project team completes the preliminary draft, draft and final reports. Comments must be provided to the Project

Manager at least one week before the scheduled delivery dates outlined in Worksheet #16 (the project schedule; Appendix A).

Natick, Massachusetts

5.2 DATA REVIEW

5.2.1 Data Verification

Data verification will be conducted on the confirmation sampling analytical data. Laboratory data will be 100% verified using Automatic Data Review (ADR) (Level III Data review). Findings will be issued in a Data Verification Report and presented as an appendix to the project’s final report. The overall findings will also be summarized in the project report. Data verification activities will be performed by Laboratory Data Consultants, Inc., in accordance with Worksheets #34 and 35

(Appendix A).

5.2.2 Data Validation

Data validation will be conducted on the confirmation sampling analytical data. All analytical data shall be independently validated using Tier III for ten percent of samples and Tier II for the remaining samples. Findings will be issued in a Data Validation Report and presented as an appendix to the project’s final report. Overall findings will also be summarized in the project report. If serious quality control issues are noted during the Tier III validations, than the percent of data requiring

Tier III validation will be increased as needed. Data validation activities will be performed by

Laboratory Data Consultants, Inc., in accordance with Worksheet #36 (Appendix A).

5.2.3 Usability Assessment

The usability assessment considers whether the collected data meet the project DQOs as they relate to the decision to be made and evaluates whether data are suitable for making that decision. All types of data are relevant to the usability assessment. The usability assessment is the final step of the data review and can be performed only on data of known and documented quality. The DQO process for this project is presented on Worksheets #10, 11, and 17 (Appendix A). The usability assessment process is provided on Worksheet #37 (Appendix A).

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6.0 REFERENCES

DoD, 2013. DoD Quality Systems Manual Version 5.0. DoD and DOE Consolidated QSM for

Environmental Laboratories. Based on ISO/IEC 17025:2005(E) and The NELAC Institute

(TNI) Standards, Volume 1 (September 2009). July.

ECC, 2011. October 2010 Draft Final Long-Term Monitoring Plan Amendment. U.S. Army Natick

Soldier Systems Center, Natick, Massachusetts. February 28.

IDQFT, 2005. UFP-QAPP Manual, March.

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APPENDIX A

WORKSHEETS

Natick, Massachusetts Revision Number: 02

Revision Date: 1.20.16

Worksheet #1: Title Page

(UFP-QAPP Manual Section 2.1)

(EPA 2106-G-05 Section 2.2.1)

Document Title

Unified Federal Policy-Quality Assurance Project Plan for Environmental Remediation Services, U.S.

Army Soldier Systems Center, Natick Massachusetts

Lead Organization

U.S. Army Mission and Installation and Contracting Command (MICC)

Preparer’s Name and Organizational Affiliation

Nathan Farrar, Plexus Scientific Corporation (Plexus)

Preparer’s Address, Telephone Number, and Email Address

5510 Cherokee Ave., Suite 350, Alexandria, VA 22312; (540)315-2641; nathaniel.farrar@plexsci.com

Preparation Date (Day/Month/Year)

15 October, 2015

Stakeholders:

a. U.S. Army (including SSC and the Army Environmental Command [AEC])

b. USEPA Region 1

c. Massachusetts Department of Environmental Protection (MassDEP)

d. Restoration Advisory Board mailto:nathaniel.farrar@plexsci.com

Natick, Massachusetts Revision Number: 02

Revision Date: 1.20.16

Worksheet #2: Approval Page

(UFP-QAPP Manual Section 2.1)

(EPA 2106-G-05 Section 2.2.1)

Investigative Organization’s Project Manager: _______________________________________________

Signature Michael Brewin, Plexus Scientific Corporation

Investigative Organization’s Project QA Manager: ____________________________________________

Mark G. Bagel, Plexus Scientific Corporation

Investigative Organization’s Project Chemist: ________________________________________________

Claire Costello, Plexus Scientific Corporation

Other Approval Signatures: _________________________________________________

Vicky Collom, ALS Environmental

Natick, Massachusetts Revision Number: 02

Revision Date: 1.20.16

Worksheet #3: Distribution List

(UFP-QAPP Manual Section 2.3.1)

Recipients Title Organization Telephone Number Email Address

Mr. Derrick R. Lopez COR and Environmental Support Manager (ESM)

USAEC 210-466-1872

derrick.r.lopez2.civ@mail.mil

James B. Connolly Environmental Scientist SSC 508-233-5550 james.b.connolly.civ@mail.mil

Christine Williams Regulator US EPA – New

England 617-918-1384 williams.christine@epamail.epa.gov

Joanne Dearden Regulator MassDEP 617-292-5788 Joanne.Dearden@state.ma.us mailto:Clayton.m.dayoc.civ@mail.mil mailto:williams.christine@epamail.epa.gov mailto:Joanne.Dearden@state.ma.us

Natick, Massachusetts Revision Number: 02

Worksheet #4: Personnel Qualifications and Sign-off Sheet

(UFP-QAPP Manual Sections 2.3.2)

(EPA 2106-G-05 Section 2.2.1)

ORGANIZATION: Plexus Team

Name Project Title/Role Signature/Date

Jeff Sgambato Program Manager

Michael Brewin Project Manager

Mark Bagel Quality Manager

Margaret Mikulich Safety Manager

Katie Thomas Field Team Task Manager

Claire Costello Project Chemist

ORGANIZATION: ALS Environmental.

Name Project Title/Role Signature/Date

Vicky Collom Quality Assurance Manager

*Signatures indicate personnel have read and agree to implement this QAPP as written

Natick, Massachusetts Revision Number: 02

Revision Date: 1.20.16

Worksheet #5: Project Organization

(UFP-QAPP Manual Section 2.4.1)

Natick, Massachusetts Revision Number: 02

Revision Date: 1.20.16

Worksheet #6: Communication Pathways

(UFP-QAPP Manual Section 2.4.2)

(EPA 2106-G-05 Section 2.2.4)

Communication Driver

Organization Name of

Responsible Person

Contact Information

Procedure (Timing, pathway, documentation, etc.)

Project Related Technical Issues

Plexus Michael Brewin 571-527-1620 Field staff communicates with the Plexus PM and the COR on the same day.

Plexus PM communicates with the COR on the same day.

COR communicates with US EPA within 24 hours.

Standard form of communication is cell phone or email.

Field progress reports

Plexus Michael Brewin 571-527-1620 Field Staff sends daily/QC/Safety reports to the PM by noon the following day.

Plexus PM sends daily/QC/Safety reports to the COR within 24 hours.

Standard form of communication is email.

Safety issues Plexus Margaret Mikulich, Health and Safety Coordinator

301-908-3639 Field Staff communicates with the COR, Plexus PM, and H&S Coordinator immediately.

H&S Coordinator communicates with Occupational Safety and Health Administration (OSHA) as needed within…