Amendment_0007_Attachment_SAPQAPP.pdf

Prepared for:

U.S. Army Corps of Engineers

New England District 696 Virginia Road

Concord, MA 01742

Sampling and Analysis Plan/

Quality Assurance Project Plan Version: Final

Callahan Mine Superfund Site (MED980524128)

Operable Unit 3 – TP-1 Performance Assessment

Brooksville, Maine

November 29, 2016

Prepared by:

Credere Associates, LLC 776 Main Street

Westbrook, Maine 04092

Contract W912WJ-16-C-0013

Sampling and Analysis Plan/Quality Assurance Project Plan Version: Final

Callahan Mine Superfund Site, Operable Unit 3 – TP-1 Performance Assessment

Brooksville, Maine November 29, 2016 i

TABLE OF CONTENTS

1. TITLE AND APPROVAL PAGE .................................................................................... 1-1

1.1 Project Personnel and Stakeholders .............................................................................................. 1-2

2. INTRODUCTION.............................................................................................................. 2-1

2.1 Purpose .......................................................................................................................................... 2-1

2.2 Site Description ............................................................................................................................. 2-1

2.3 Site and Regulatory History .......................................................................................................... 2-1

3. WORK PLAN OBJECTIVES AND SCHEDULE.......................................................... 3-1

3.1 Statement of Objectives ................................................................................................................ 3-1

3.2 Schedule ........................................................................................................................................ 3-2

4. WORK PLAN..................................................................................................................... 4-1

4.1 Site Inspections ............................................................................................................................. 4-1

4.2 Bioreactor O&M ........................................................................................................................... 4-1

4.3 Bioreactor Flow Assessment ......................................................................................................... 4-1

4.4 Groundwater Level Gauging ......................................................................................................... 4-1

4.5 Water Quality Sampling ............................................................................................................... 4-2

5. METHODOLOGY ............................................................................................................ 5-1

5.1 Site Inspections ............................................................................................................................. 5-1

5.2 Bioreactor O&M ........................................................................................................................... 5-1

5.3 Bio-Reactor Flow Assessment ...................................................................................................... 5-2

5.4 Groundwater Level Gauging ......................................................................................................... 5-2

5.5 Water Quality Sampling ............................................................................................................... 5-3

5.6 Sample Handling ........................................................................................................................... 5-4

5.7 Decontamination ........................................................................................................................... 5-6

5.8 Investigation Derived Waste ......................................................................................................... 5-6

5.9 Field Documentation ..................................................................................................................... 5-6

6. REGULATORY CRITERIA AND DATA QUALITY OBJECTIVES ........................ 6-1

6.1 Surface Water Regulatory Criteria ................................................................................................ 6-1

6.2 Data Quality Objectives ................................................................................................................ 6-2

7. FIELD QUALITY ASSURANCE .................................................................................... 7-1

7.1 Field Documentation Review ....................................................................................................... 7-1

7.2 Equipment Calibration .................................................................................................................. 7-1

7.3 Quality Control Samples ............................................................................................................... 7-3

8. LABORATORY METHODOLOGY ............................................................................... 8-1

8.1 Methods of Analysis & Analytical Sensitivities ........................................................................... 8-1

8.2 Laboratory Instrument Calibration ............................................................................................... 8-2

8.2.1 Calibration Curve ............................................................................................................. 8-2

8.2.2 Calibration Verification Requirements ............................................................................ 8-2

8.3 Data Deliverables .......................................................................................................................... 8-2

9. LABORATORY QUALITY ASSURANCE .................................................................... 9-1 ii

9.1 Laboratory Quality Control and Corrective Action ...................................................................... 9-1

9.2 Data Validation ............................................................................................................................. 9-2

10. DATA TRANSMITTAL ................................................................................................. 10-1

10.1 Inspection Report ........................................................................................................................ 10-1

11. REFERENCES ................................................................................................................. 11-1

FIGURES

Figure 1 ......................................................................................... Project Organization Flow Chart

Figure 2 ................................................................................................................ Site Location Plan

Figure 3 ................................................................................................................. Detailed Site Plan

TABLES

Table 1-1 ........................................................ Project Personnel/Stakeholders and Responsibilities

Table 3-1 .................................................................................................................Project Schedule

Table 4-1 .................................................................. Wells for Gauging and Transducer Download

Table 4-2 ....................................................................................... Water Quality Sample Summary

Table 5-1 ............................................................................................. Credere Field SOP Summary

Table 5-2 ......................................................................Water Quality Sample Collection Summary

Table 6-1 .................................................................. Applicable Surface Water Regulatory Criteria

Table 7-1 ........................................................................................... Field Equipment Maintenance

Table 7-2 .............................................................................................. Field Equipment Calibration

Table 7-3 ...........................................................................................Field Quality Control Samples

Table 8-1 ................................ Laboratory Methods and Analytical Sensitivities for Surface Water

Table 9-1 .................................................................................... Laboratory QC Sample Frequency

Table 9-2 ............................................................... Laboratory Quality Control Acceptance Criteria

Table 9-3 ............................................................................................ Laboratory Corrective Action

APPENDICES

Appendix A ............................................................... Credere Field Standard Operating Procedures

Appendix B ........................................................ Example Site Inspection Checklist and Photo Log

Appendix C ....... Laboratory DOD-ELAP, NELAC, and Maine DEP Certification Documentation

Appendix D ................................................................... Laboratory Standard Operating Procedures iii

LIST OF ACRONYMS

ARA – Absolute Resource Associates

CCC - criterion continuous concentration

CCV – continual calibration verification

CENAE – Corps of Engineers New England Division

CERCLA – Comprehensive Environmental Response, Compensation, and Liability Act

CMC – criterion maximum concentration

Credere – Credere Associates, LLC

DEP – Department of Environmental Protection

DO – dissolved oxygen

DoD – Department of Defense

DOT – Department of Transportation

DQO – data quality objective

DS – drainage structure

EDD – electronic data deliverable

EGAD – Environmental and Geographic Analysis Database

ELAP – Environmental Laboratory Accreditation Program

EPA – U.S. Environmental Protection Agency gpm – gallons per minute

HD – horizontal drain

HNO3 – nitric acid

ICB – initial calibration blank

ICV – initial calibration verification

IS – internal standard

LCS – laboratory control sample

LCSD – laboratory control sample duplicate

LOQ – Limit of Quantification mL - milliliter

MS/MSD – matrix spike/matrix spike duplicate

MW – monitoring well

NaOH – sodium hydroxide

NAVD – North American Vertical Datum

NCP - National Oil and Hazardous Substances Pollution Contingency Plan

NOAA - National Oceanic and Atmospheric Administration

NPL – National Priorities List

NRWQC - EPA National Recommended Water Quality Criteria

NWS – National Weather Service

ORP – oxidation-reduction potential

OU – operable unit

O&M – operations & maintenance

PPE – personal protective equipment

PWS – Performance Work Statement

QA – quality assurance iv

QAPP – Quality Assurance Project Plan

LIST OF ACRONYMS (CONTINUED)

QC – quality control

SAP – Sampling and Analysis Plan

SEDD – Staged Electronic Data Deliverable

SOP – standard operating procedure

SWQC - Maine DEP Statewide Water Quality Criteria

TSS – total suspended solids

USACE – U.S. Army Corps of Engineers

YSI - Yellow Springs Instrument

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1. TITLE AND APPROVAL PAGE

TITLE:

SAMPLING AND ANALYSIS PLAN (SAP)/

QUALITY ASSURANCE PROJECT PLAN (QAPP)

PROPERTY:

Callahan Mine Superfund Site, Operable Unit (OU) 3

TP-1 Performance Assessment

Brooksville, Maine

MED980524128

Contract: W912WJ-16-C-0013

CONTRACTOR:

Credere Associates, LLC (Credere)

776 Main Street, Westbrook, Maine 04092

(207) 828-1272

LEAD ORGANIZATION:

U. S. Army Corp of Engineers (USACE), New England District (CENAE)

696 Virginia Road

Concord, Massachusetts 01742

(978) 318-8238

1/30/2017

Rip Patten Date

Credere Associates, LLC Program Manager

1/30/2017

Theresa Patten Date

Credere Associates, LLC Quality Control (QC) Manager

1-2

1.1 PROJECT PERSONNEL AND STAKEHOLDERS

A project organization flow chart is included as Figure 1. The following table summarizes project personnel and project stakeholders.

Table 1-1 Project Personnel/Stakeholders and Responsibilities

Name Title Organization Responsibilities Contact Information

Ed Hathaway Project Manager EPA Project Manager (617)918-1372

Hathaway.ed@epa.gov

Scott Greene Project Manager USACE Project Manager

(978) 318-8393

Scott.e.greene@usace.army.mil

Casey Haskell Project Technical

Lead USACE Project Manager

(978) 318-8398

Casey.j.haskell@usace.army.mil

TBD QA Manager USACE QA Manager TBD

Naji Akladiss Project Manager Maine DEP Regulator

(207) 287-7709

Naji.n.akladiss@maine.gov

Rip Patten, PE, LSP

Vice President, Engineer Credere Program Manager

(207) 828-1272 X35 rpatten@crederellc.com

Theresa

Patten, PE President, Engineer Credere QC Manager

(207) 828-1272 X39 tpatten@crederellc.com

Sean

McNamara, Ph.D.

Project Manager, Project Engineer Credere

Project Manager;

Field Task Manager

(207) 828-1272 X20 jnewcomb@crederellc.com

Mark Willis

Environmental

Safety & Health;

Industrial Hygienist

Credere

Site Health & Safety

Manager; Field

Personnel

(207) 828-1272 X29 mwillis@crederellc.com

Matthew

Kennedy

Environmental

Scientist Credere Field Personnel

(207) 828-1272 X21 mkennedy@crederellc.com

Sean Gannon Geologist Credere Field Personnel

(207) 828-1272 X26 sgannon@crederellc.com

Aaron Dewees Chemist

Absolute

Resource

Associates

Laboratory Manager

(603) 436-2001 aarond@absoluteresourceassociate s.com

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2. INTRODUCTION

Credere was retained by the USACE CENAE to prepare this SAP/QAPP for the Callahan Mine

Superfund Site, OU 3 located in Brooksville, Hancock County, Maine (the Site). This SAP has been prepared in accordance with USACE Requirements for the Preparation of Sampling and

Analysis Plans, EM 200-1-3 (USACE, 2001) and generally with the EPA Requirements for

Quality Assurance Project Plans (EPA, 2001). This SAP was developed in accordance with the

Performance Work Statement (PWS) prepared by CENAE dated July 12, 2016 (CENAE, 2016b). The work required under this PWS falls under the Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA) and is regulated by the National Oil and

Hazardous Substances Pollution Contingency Plan (NCP) and Maine DEP.

2.1 PURPOSE

The purpose of this SAP/QAPP is to provide guidance for generating data that is of the precision, accuracy, and completeness necessary for the intended end use of the data. SAP/QAPP approval will be obtained prior to initiating any field activities and documented by signatures on the

Section 1 Title and Approval Page.

2.2 SITE DESCRIPTION

The Callahan Mine is a 120-acre former lead, zinc and copper mine located in the village of

Harborside in the Town of Brooksville, Maine. The Site is located on the northwest corner of the Cape Rosier peninsula, and is bordered by the tidal estuary Goose Pond to the east and north, which is bordered by the Holbrook Island Sanctuary State Park and is adjacent to Penobscot Bay.

A Site Location Plan is included as Figure 2. Remedial design was completed in 2009 for the entire mine, known as OU 1. OU 3 is a component of the OU 1 remedial design and comprises the mine’s 21-acre tailings impoundment and associated access roads. It is estimated the impoundment consists of 716,000 cubic yards of tailings and waste rock (CES, 2016a).

2.3 SITE AND REGULATORY HISTORY

Exploration as a mine began in 1880 and continued intermittently through the 1970s with the mine being intensively quarried between 1968 and 1972. Sulfide ore was mined from the open pit mine in Goose Pond estuary. The ore was processed and concentrated onsite but shipped offsite for smelting. Waste tailings and tailings slurry were disposed onsite in the OU 3 tailings impoundment. Impoundment seeps were identified as a point source discharge of cadmium, copper, and zinc to surface water and sediment of the adjoining salt marsh and Goose Pond

(AMEC, 2014).

In September 2002, the Site was added to the EPA National Priorities List (NPL). The Site was assessed and a feasibility study was completed in 2009 to evaluate cleanup options. The OU 1 component of the OU 1 remedial design was completed between 2010 and 2013, with polychlorinated biphenyl and metals impacted soil placed within the tailings impoundment. OU

2-2

2 is also a component of the OU 1 remedial design and includes soil and groundwater contamination beyond the delineated contamination in OU 1. OU 2 is still being investigated.

The objectives of the OU 3 remedial design are to reduce point source discharges from the tailings impoundment, improve static and seismic stability of the slope of the tailings impoundment, and minimize truck traffic during remediation (AMEC, 2014). Phase I of the OU

3 remedial actions was completed to lower the groundwater table in the eastern portion of the tailing impoundment to allow for the relocation of tailings as part of the Phase II remedial actions. From July to November 2015, a 975-linear foot horizontal drain was installed along the eastern portion of the tailings impoundment (horizontal drain 2 [HD-2]) to lower the groundwater table and a compost bioreactor treatment system was installed to treat the dewatering flows as part of Phase I remedial actions (CES, 2016a). The Phase I remedial system has been assessed on a routine basis to inspect the physical condition of the systems, assess flow and treatment system effectiveness, and assess performance of the Phase I OU 3 remedial actions

(CES, 2016b).

Phase II of the OU 3 remedial actions may consist of installation of additional horizontal borings for dewatering of the tailings impoundment; construction of two additional compost bioreactors for treatment of dewatering flows; and excavation, regrading and capping of the tailings impoundment in order to reduce water recharge, infiltration and seepage. If executed, this work is anticipated to begin in 2017.

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3. WORK PLAN OBJECTIVES AND SCHEDULE

3.1 STATEMENT OF OBJECTIVES

The primary objective of this work plan is to assess and maintain the performance of the Phase I

OU 3 remedial actions. The following Site-specific objectives are established:

Inspect the OU 3 area for evidence of wear, settlement, erosion, etc. to identify areas requiring corrective action(s)

Maintain optimal operation of the horizontal drain HD-2 and compost bioreactor through inspection and subsequent maintenance, where necessary

Evaluate the dewatering performance of the horizontal drain HD-2 to achieve adequate groundwater level reduction (+- 46 feet North American Vertical Datum [NAVD]) along the eastern portion of the tailings impoundment to allow for Phase II remedial actions to begin

Assess the compost bioreactor treatment system performance to ensure effluent meets the

National Recommended Water Quality Criteria (EPA, 2016) and ambient water quality criteria in Chapter 584: Surface Water Quality Criteria for Toxic Pollutants (Maine DEP, 2012)

Assess the overall effectiveness of the Phase I OU 3 remediation systems using the increasing data set

3-2

3.2 SCHEDULE

The scope of work in Section 4.0 will be completed every 4 weeks between October 2016, and

November 2017. The following table summarizes the schedule for tasks to be completed:

Table 3-1 Project Schedule

Date Task

September 16, 2016 Submit Draft SAP/QAPP and APP

November 7, 2016 Receive comments

November 30, 2016 Incorporate comments and finalize SAP/QAPP and APP

Week of December 12, 2016 Perform initial inspection, operation and maintenance (O&M), flow assessment, gauging, and sampling

Week of January 9, 2017

Perform ongoing inspection, O&M, flow assessment, gauging, and sampling; and submit previous month’s health and safety record and Assessment and Maintenance

Report

Week of February 6, 2017

Week of March 6, 2017

Week of April 3, 2017

Week of May 1, 2017

Week of May 29, 2017

Week of June 26, 2017

Week of July 24, 2017

Week of August 21, 2017

Week of September 18, 2017

Week of October 16, 2017

Week of November 13, 2017

Week of December 11, 2017

Week of January 1, 2018

4-1

4. WORK PLAN

Credere has prepared the following work plan to meet the objectives outlined in Section 3.1 and in accordance with the PWS (CENAE, 2016b). Tasks outline below will be completed every 4 weeks from October 2016 through November 2017 according to the Schedule in Section 3.2. A

Detailed Site Plan showing pertinent Site features, and well and sample locations is provided as

Figure 3.

4.1 SITE INSPECTIONS

Site inspections will be completed every four weeks to ensure the Phase I OU 3 remedial actions are properly performing as intended. Site inspections will document changes to site features including wear, settlement, erosion, etc. and identify the need for corrective action(s), as needed.

The condition of the access roads, stormwater conveyance systems, discharge structures, piping and valves, compost bio-reactor, spillways, aeration ditches, monitoring wells, and active and previous unidentified seeps will also be inspected and documented. Any corrective action(s) performed or required will also be documented.

4.2 BIOREACTOR O&M

Credere will perform bioreactor O&M to optimize the efficiency of the system. Flow issues such as leaks, flow restrictions, and significant changes in flow rate will be diagnosed in the field to assess applicable maintenance requirements. Corrective actions taken or required will also be noted.

4.3 BIOREACTOR FLOW ASSESSMENT

The bioreactor treatment system will be assessed for flow at the bioreactor intake (DS-3), bioreactor effluent, and aeration pond #2 effluent to assess the hydraulic load on the system.

Changes in flow will be noted to assess the need for maintenance. Specifically, the system will be evaluated to assess the need for pressure jetting to remove sediment buildup in the horizontal drain HD-2.

4.4 GROUNDWATER LEVEL GAUGING

Groundwater level measurements will be conducted to evaluate the effectiveness of the horizontal drain HD-2 at dewatering the tailing impoundment to the targeted level (+- 46 feet

NAVD). Water level data will be collected in conjunction with local precipitation data to assess the rate of dewatering. Water levels will be measured manually and through download of transducer data from the wells in the following table:

4-2

Table 4-1 Wells for Gauging and Transducer Download

Monitoring Wells (MW) for Gauging Monitoring Wells for Transducer

Download and Manual Gauging

MW-603D MW-602S

MW-603S MW-602D

MW-605S MW-605D

MW-705 DW-1

MW-706 MW-604S

MW-707 MW-604D

OW-1131 OW-1140D

OW-1132 OW-1124A

OW-1140S OW-1142D

OW-1141D MW-610

OW-1141S

OW-1142S

4.5 WATER QUALITY SAMPLING

Water quality samples will be collected from four locations: the discharge structure influent, the bioreactor effluent, the aeration ditch effluent, and combined flow from the aeration ditch and stormwater ditch. The following table summarizes the water quality samples to be collected:

1 - Proposed analyses differ from those outlined in the PWS as these are the methods routinely performed by our preferred laboratory (Absolute Resource Associates [ARA]). Levels of quantification (LOQ) are the same or better as those in the methods requested in the PWS or the LOQs are sufficiently low to meet the regulatory criteria.

2 – Sample will only be collected when there is flowing water in the stormwater ditch to avoid sampling possible seeps for the upgradient waste rock pile.

3 – Dissolved metals are monitored to assess the metals concentrations bioavailable to aquatic biota.

DS-30 – Blind field duplicate sample

* - Location where matrix spike/matrix spike duplicate (MS/MSD) volume will be collected for all analyses.

Table 4-2: Water Quality Sample Summary

Sample Location Sample

ID

Justification Proposed Analyses1

Discharge Structure 3

(Compost Bioreactor

Influent)

DS-3

DS-30

Characterize raw water from the horizontal drain HD-2 prior to treatment

Dissolved Metals3 via EPA

Method 6020A

Sulfate via EPA Method

300.0

Total Sulfide via EPA

Method SM4500S2-D

Total Iron and Manganese via EPA Method 6020A

Total Suspended Solids via

EPA Method SM2540D

DO via EPA Method 360.1

Compost Bioreactor

Effluent

BCR*

Document level of treatment from bioreactor prior to aeration

Aeration Ditch 2

Effluent

AP-2

Confirm effluent from treatment system meets ambient water quality criteria prior to discharge (post-treatment water characterization) Combined Aeration

Ditch and Stormwater

Ditch Combined Flow

ADSD2

5-1

5. METHODOLOGY

Field activities will be completed in accordance with Credere’s Standard Operating Procedures

(SOPs) for the respective activity. Credere’s SOPs consider both EPA and Maine DEP SOPs and are at least as comprehensive as the procedures described therein. Credere field SOPs to be used as part of field activities described herein are summarized in Table 5-1 and are included in

Appendix A.

Table 5-1: Credere Field SOP Summary

SOP # Title Date/Revision

CA-1 Field Activity Documentation August 2, 2016, revision 1

CA-2 Equipment Decontamination Procedures March 17, 2016, revision 0

CA-10 Water Level and Product Measurements August 29, 2016, revision 0

CA-13 Surface Water and Sediment Sampling September 9, 2016, revision 0

5.1 SITE INSPECTIONS

Site inspections will be conducted by physically walking and inspecting the Site. A Site

Inspection Checklist will be completed in the field to document conditions and changes as well as corrective actions performed or required. Conditions will also be documented by photographs. Photographs will be taken during each inspection at similar stations and reported in a photo log to serve as a timeline of conditions, and any newly identified conditions that require documentation will be added as they are identified. Routine photographic stations to be taken during each site visit are identified on Figure 3. Field documentation will be completed in accordance with Credere SOP CA-1. The Site Inspection Checklist to be used in the field is provided in Appendix B.

Conditions at the time of each inspection will be compared to the previous month’s inspection checklist and photo log to identify changes in real time and efficiently act upon or report any required maintenance. An example photo log of the routine photo stations is also included in

Appendix B.

5.2 BIOREACTOR O&M

During each site inspection, Credere will perform bioreactor O&M to optimize the efficiency of the system. Flow issues such as leaks, flow restrictions, and significant changes in flow rate will be diagnosed in the field to assess applicable maintenance requirements. Corrective actions taken or required will also be noted. Expected O&M activities that will be conducted while onsite include:

Repairing any minor erosion on the bio-reactor embankment (e.g. raking woodchips or stone to fill)

Repairing any minor damage from animal activity (e.g. filling holes)

Ensuring sample ports and other fittings are free of debris and free flowing

Removing any debris (e.g. fallen trees or branches) from discharge areas

5-2

When flow rates indicate a need for back flushing and at the direction of USACE, back flushing will be subcontracted to NRC Corporation (formerly ENPRO) of Portland, Maine. If corrective actions at the Site require additional raw materials or non-routine labor or equipment such as more wood chips, replacement stone, the need for an excavator, etc., USACE will be contacted as soon as possible to determine the next course of action.

5.3 BIO-REACTOR FLOW ASSESSMENT

Influent Flow Assessment

The bioreactor influent flow will be calculated via rising head test performed inside the discharge structure 3 (DS 3). The influent flow will be measure by closing the gate valve for both the influent flow and effluent flow of the structure, removing sufficient water from the structure

(drawdown of 1 to 3 inches which corresponds to 17.58 to 52.74 gallons), reopening the influent gate valve and monitoring the time required to return to the beginning water level. In addition, flow rate check will be measured from a sample port in DS 3 by monitoring the time to fill a given volume. A graduated cylinder will be filled and the time to fill a volume will be recorded.

Flow rates will be calculated in gallons per minute (gpm) and recorded on the Site Inspection

Checklist in Appendix B.

Bioreactor Effluent, Aeration Pond 2 Effluent, and Combined Aeration Pond and

Stormwater Ditch Flow Assessment

Effluent flow will be measured by monitoring the time required to fill a given volume from the discharge point of each respective treatment section as indicated on Figure 3. A graduated cylinder will be filled and time required to fill the volume will be recorded. Flow rate will be calculated in gpm and recorded on the Site Inspection Checklist in Appendix B.

5.4 GROUNDWATER LEVEL GAUGING

Water levels will be collected from wells in Table 4-1 using a manual Solinst (or similar) water level indicator, or similar, in accordance with Credere SOP CA-10. Manual water levels will be recorded to the nearest 0.01 foot on the Site Inspection Checklist included in Appendix B. The water level indicator will be decontaminated between well locations in accordance with Section

5.7.

Water level data will also be downloaded from previously installed transducers using In-Situ software installed on a RuggedReader®. The following steps will be implemented to stop the transducer record, download the data, and restarted the record:

1. Turn on RuggedReader® and open Win-Situ Mobile©

2. Remove desiccant from the top of the vented troll cable in the well (if beads are pink, the desiccant will be replaced)

3. Connect the Troll Com (communication cable) to the RuggedReader® and the end of the troll cable

5-3

4. Hit “Connect to Device” button

5. Stop the log

6. Download the data

7. Reset the log and start logging

8. Remove Troll Com from Troll Cable in well and re-attach desiccant

9. Return Troll cable to well

Climate data (primarily including precipitation) will be downloaded from the closest National

Oceanic and Atmospheric Administration (NOAA), National Weather Service (NWS) Forecast

Office in Caribou, Maine, for the East Surry, Maine, weather station located approximately 18 miles northeast of the Site. Monthly precipitation data summaries with daily precipitation totals will be downloaded from the database at the following link:

http://w2.weather.gov/climate/xmacis.php?wfo=car.

5.5 WATER QUALITY SAMPLING

Water quality samples will be collected in general accordance with Credere SOP CA-13. Water will be collected from each sample point using a peristaltic pump. Tubing will be submerged at the sample point or water will be collected into a container from the drop point and pump from the container. Water will be pumped to a Yellow Springs Instrument (YSI) flow through cell at

100 to 200 mL per minute for 5 minutes; then dissolved oxygen (DO), oxidation reduction potential (ORP), specific conductivity, turbidity, temperature, and pH will be monitored for three readings spaced 3 to 5 minutes apart or at an interval to allow for complete exchange of water in the flow through cell. Turbidity samples will be collected directly from the flow drop location and measured using a separate Hach turbidity meter, or similar. The YSI multi-parameter sonde will be equipped with a membrane DO probe (i.e., YSI 600 or 556) in accordance with EPA method 360.1. Field parameters will be recorded on the Site inspection checklist included in

Appendix B. DO for the sampling round will be determined by taking the average of the three readings.

For the remaining analyses, samples will then be collected directly into laboratory provided containers prior to the flow through cell. If use of the peristaltic pump for collecting field parameters results in turbidity greater than 20 NTUs due to disturbance of sample point sediment, samples (particularly total analyses) will be directly collected from the discharge drop location after turbidity has been allowed to flush and reduced to less than 20 NTUs. Sulfate, sulfide, iron, manganese, and total suspended solids (TSS) will be sampled first followed by dissolved metals. Dissolved metals bottles will be field filtered with an in-line 0.45-micron filter. The samples will be submitted to ARA of Portsmouth, New Hampshire. ARA is an

Environmental Laboratory Accreditation Program (ELAP) and Maine certified laboratory. The following Table 5-2 summarizes the methods, required sample volume and containers, preservatives and holding times for the required analyses.

http://w2.weather.gov/climate/xmacis.php?wfo=car

5-4

NA - DO by method 360.1 will be collect using direct reading from YSI meter from the respective sample point per the method and averaged over three (3) consecutive readings. If flow is insufficient for direct readings, flow will be containerized in the YSI calibration cup for direct reading.

HNO3 - nitric acid

NaOH – sodium hydroxide

5.6 SAMPLE HANDLING

Sample Identification

Sample nomenclature will be consistent with the USACE New England Division Data

Management Plan (CENAE, 2016a). The four water quality samples will be identified according to the following:

Discharge structure 3 (compost bioreactor influent): DS-3

Compost bioreactor effluent: BCR

Aeration ditch 2 effluent: AP-2

Combined aeration ditch and stormwater ditch flow: ADSD

Each sample location identified will be followed the month and year of collection (-MMYY).

For example, the discharge structure influent sample collected in October 2016 will be:

DS-3-1016

Sample Labeling

Each sample container will be affixed with a self-sticking, waterproof, adhesive label. Each label shall be completed with a pen of indelible ink and contain the following information:

Client Name: Credere Associates, LLC

Site Name: Callahan Mine OU 3

Client Sample ID: DS-3-1016, for example

Date Collected: (month/day/year)

Sample Time: given in 24 hour format (for example: 1400)

Table 5-2: Water Quality Sample Collection Summary

Analysis EPA Method Sample Container Preservative Holding Time

Dissolved metals 6020A 500 milliliter (mL) poly, field filtered HNO3, pH<2, cool to 4°C 180 days

Total iron and manganese 6020A

500 mL poly, unfiltered HNO3, pH<2, cool to 4°C 180 days

Sulfate 300.0 125 mL poly cool to 4°C 28 days

Total Sulfide SM4500S2-D 125 mL poly NaOH and zinc acetate, pH>9, cool to 4°C 7 days

TSS SM2540D 125 mL poly cool to 4°C 7 days

DO 360.1 NA NA NA

5-5

Initials of Collector: Credere field sampler

Analytical method/analysis request

Preservative: (for example – None, NaOH)

Sample Chain of Custody

A sample chain of custody will be designed to assure each sample is accounted for at all times.

A chain of custody must be completed by the appropriate sampling and laboratory personnel for each sample. The objective of the sample custody identification and control system will be to assure the following:

Samples scheduled for collection are uniquely identified

The correct samples are analyzed and are traceable to their records

Samples are protected from loss, damage, or tampering

Alteration of samples (e.g., filtration, preservation) is documented

A forensic record of sample integrity is established

The chain of custody form includes the following:

Sample number and sample bottle identification number, where applicable

Names of the sampler(s) and the person shipping the samples

Purchase order number or project number

Name, telephone number, and fax number or email address of the contact person from

Credere

Project name (including specific portion of the Site if a large project)

Signature of the sampler

Date and time that the samples were collected

Names of those responsible for receiving the samples and the date and time received at the laboratory

Matrix of the sample

The number of containers for a particular sample

Analysis, container type, and preservative information

Corrections to a chain of custody will be made by putting one line through the incorrect entry and initialing and dating it. The chain of custody record will accompany the samples to the laboratory and a carbon copy of the chain of custody will be retained by the sampler. The chain of custody forms will be supplied by ARA with the data package and will be included with the monthly reports.

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Sample Handling

Samples will be stored on-site in coolers packed with ice until they are sent to the laboratory for analysis. Glass bottles will be packed snugly with packing materials to protect the containers from breakage. Ice will be added to the cooler, and the chain of custody form will be placed in the cooler in a waterproof bag. Samples will be placed in the coolers directly after sampling to prevent overexposure to sunlight and to keep them cool for preservation. Field personnel will be responsible for the security of the samples before they are shipped. Coolers and samples will be stored in a secure or monitored area on-site until they are shipped/transported to the laboratory.

During times of excessive heat or prolonged holding of samples, the field personnel are responsible to maintain the ice preservation and avoid the submersion of sample containers in water and obscuring the sample labels. Sample coolers will then be sealed with a custody seal and packing tape if using a courier service packing tape, then transported to the laboratory for analysis.

5.7 DECONTAMINATION

In general, non-disposable water level indicators and water quality sampling equipment will be decontaminated between wells and sample locations, respectively.

Sampling tools, and water level meters will be rinsed with potable water directly after collecting a sample or removal from a well while the equipment is still damp/wet. The outside of the tools, pumps/reel tape, and water level meter probes/reel tape will be scrubbed with the Liquinox or

Alconox/water wash using disposable paper towels to remove any material adhering to the equipment. The equipment will then be rinsed thoroughly with deionized water. The equipment will be allowed to dry, and the water level meter will be placed in a clean plastic bag or on clean poly sheeting for transport to the next well location or between use. Dedicated tubing will be used at each sample location.

5.8 INVESTIGATION DERIVED WASTE

Purge water generated during the rising head test at DS-3 and during purging of sample locations for field parameters will be discharged back into the structure or back to the given sample point after sampling. Pressure jetting fluids and solids will be collected into drums and water will be decanted to the top of the compost bioreactor. Solids will be disposed on the tailing impoundment at the designated disposal location. Therefore, no investigation derived waste will be generated.

5.9 FIELD DOCUMENTATION

Field Logbook

Field activities will have a dedicated field logbook, which will be reviewed for accuracy and completeness in accordance with Credere’s SOP CA-1 by the Project Manager and scanned into

5-7 the electronic project file with an appropriate file designation that includes the field activity and date at a minimum.

The daily entry will begin at the top of a new page and be printed legibly. Entries will be recorded using a 24-hour time clock and entered in the order that they occur. A new entry for each day will begin with the following:

Date and project at the top of the page

First and last name of Credere employee followed by initials and time of arrival onsite

Full names and initials of additional team members and the time of their arrival onsite

Scope of work for the day

Weather (e.g., temperature, precipitation, wind directions)

Subcontractors and duties (e.g., backwashing or maintenance)

Documentation of a safety acknowledgement or tool box meeting

If field activities extend beyond one page, each successive page shall have the date, project and initial of person doing logbook entries written at the top. If the logbook changes hands during a daily entry, the initial writer shall sign after their last entry and the full name and initials of the new writer shall be entered consecutively.

The final page of a daily entry shall have open lines marked diagonally with a strike and shall be signed and dated.

The following is a partial list of information typically recorded during field tasks:

Level of personal protective equipment (PPE)

Changes to PPE level

Changes in personnel

Sampling equipment serial numbers

Equipment calibration details

Decontamination procedures

Field screening results

Observations

Unusual circumstances

Problems encountered

Deviations from the work plan

Problem resolutions

Safety issues/accidents/near misses/discussions with contractors

Safety resolutions

Name and time onsite/offsite of anyone who enters the Site

Correspondence with project managers

Sample IDs

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Sample depths

Method of collection

Sample times

Sample analysis requested

Sample preservation

Sample volume collected

QA/QC samples

Sample duplicate locations

Site sketch

Changes in weather

Field Forms

Credere utilizes dedicated instrument calibration and Site inspection field forms to facilitate field data collection. Field forms will be referenced in the daily logbook entry. Procedures for data entry and error correction will be followed when using field forms. Field forms will be thoroughly completed and self-checked at the time of the field task to avoid missing information.

Use of field forms does not exclude the need for field notes. Field notes may not require sampling information that is included on the field forms; however, the general timeline of the day (e.g., the time a boring was started and complete, or the time a well began purging and was completed) should still be included in the field notes. Additionally, any deviations from the work plan or scope should also be documented in the field notes in addition to on the field forms.

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6. REGULATORY CRITERIA AND DATA QUALITY OBJECTIVES

The applicable regulatory criteria will be used to establish data quality objectives (DQOs) for the project.

6.1 SURFACE WATER REGULATORY CRITERIA

The following Table 6-1 summarizes the surface water regulatory criteria for the water quality sampling. The Maine DEP Statewide Water Quality Criteria (SWQC) for Toxic Pollutants

(Maine DEP, 2012), which is derived from the EPA National Recommended Water Quality

Criteria (NRWQC; EPA, 2016) with standards updated as recently as 2016. Both sets of standards are summarized below with some compounds referencing other documents, which are those referenced in the NRWQC. Criteria shown are for the marine/saltwater chronic or criterion continuous concentration (CCC), unless otherwise specified.

Table 6-1: Applicable Surface Water Regulatory Criteria

Analysis

(Method) Compound

EPA

NRWQC

(mg/L)

Maine DEP

SWQC

(mg/L)

Dissolved and Total Metals

(EPA Method 6020A)

Aluminum NE NE

Antimony 0.51 NE

Arsenic 0.036 0.036

Barium 0.21 NE

Cadmium 0.0078532 0.00885

Chromium 0.053 0.053

Cobalt 0.0011 NE

Copper 0.0025732 0.00373

Iron 0.051 NE

Lead 0.0077032 0.00852

Magnesium NE NE

Manganese 0.11 NE

Molybdenum 0.0231 NE

Nickel 0.0081182 0.00828

Potassium NE NE

Selenium 0.0718582 0.071

Silver 0.0016152,4 NE

Sodium NE NE

Vanadium 501 NE

Zinc 0.0766262 0.086

Sulfate (EPA Method 300.0) Sulfate NE NE

Total Sulfide (EPA Method SM4500S2-D) Sulfide NE NE

TSS (EPA Method SM2540D)

TSS

<10% increase from baseline5

NE

DO (EPA Method 360.1) DO >4.86 NE NE – not established 1 - Screening value from NOAA Screening Quick Reference Tables (Buchman, M. F., 2008) 2 - Conversion factor for dissolved metals applied to NRWQC.

3 - Criteria for hexavalent chromium provided conservatively. Standard for total chromium not established for saltwater.

4 - Criterion Maximum Concentration (CMC) used when CCC not established.

5 - Quality Criteria for Water 1986 (EPA, 1986) 6 - Ambient Aquatic Life Water Quality Criteria for DO (Saltwater): Cape Cod to Cape Hatteras (EPA, 2000)

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6.2 DATA QUALITY OBJECTIVES

The primary DQOs for all projects is to ensure a) measurements are representative of actual site conditions and all data resulting from field, sampling, and analytical activities be comparable, reproducible and generated in a scientifically valid and legally defensible manner; and b) judgments can be made against the applicable regulatory criteria as appropriate.

The analytical sensitivities noted in Section 8.1 are those achievable by the respective analytical methods by the intended analytical laboratory (ARA). The typical laboratory reporting limits for some compounds exceed the regulatory criteria for that compound (e.g., cobalt, copper, nickel, and silver indicated in bold on Tables 8-1). Therefore, the lowest reportable concentration by the laboratory (i.e., the LOQ) will be considered the regulatory criteria as that is the lowest achievable concentration for the compound in the analytical method.

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7. FIELD QUALITY ASSURANCE

Credere quality control is ensured through compliance with Credere’s Corporate Quality Control

Plan dated February 12, 2016 (Credere, 2016).

7.1 FIELD DOCUMENTATION REVIEW

All field documentation including field logbooks, field forms, and chains of custody will be reviewed for consistency, accuracy with regard to this SAP and completion. Review will be completed by the Project Manager. Additionally, site inspections will be facilitated through use of a standard form and photo log to streamline inspections and ensure all data is collected during each site visit. An example Site Inspection Checklist is included in Appendix B.

7.2 EQUIPMENT CALIBRATION

The following data collection equipment will be used during field activities:

Water level meter

RuggedReader®

Multi-parameter meter (YSI 600XL, or similar) with membrane electrode probe for DO capable of reading greater than 4.8 mg/L and pH, temperature, conductivity, and ORP

Turbidity meter

Preventative Maintenance

Equipment, instruments, tools, gauges, and other items owned by Credere and requiring preventive maintenance will be serviced in accordance with the manufacturer’s recommendations. It will be the responsibility of the operator to adhere to this maintenance schedule and to arrange for service as required. Service to the equipment, instruments, tools, gauges, etc. shall be performed by qualified personnel. Maintenance of field equipment from vendors is the responsibility of the vendors.

Maintenance records will be documented and traceable to the specific equipment, instruments, and tools. Critical spare parts will be stored for availability and use in order to reduce downtime.

In the event that an instrument needs to be replaced during the field program, replacement equipment will be obtained either from Credere’s equipment supply or from an equipment rental vendor, depending on availability.

Calibration and Corrective Action

Field analytical equipment will be checked and calibrated, if required, in accordance with the procedures and frequency summarized in below Table 7-1 and Table 7-2. The calibration procedures will conform to manufacturer’s standard instructions and equipment will be calibrated to within the allowable tolerances established by the manufacturer. Records of instrument calibration will be maintained by field personnel for each project/field mobilization.

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If proper calibration is not achieved, Credere will attempt to recalibrate the equipment until the allowable tolerances are met or the equipment will be repaired/replaced/substituted.

Table 7-1: Field Equipment Maintenance

Equipment Maintenance Frequency Acceptance

Criteria

Corrective

Action

Water Level

Indicator

Clean and visually inspect probe and tape

Daily before and after use

No visual defect;

conformance with manufacturer standards

Repair or use substitute equipment

RuggedReader®

Clean exterior and replace dust/dessicant caps

After use No debris or visual defect Re-clean or repair

Water Quality

Meters (YSI, turbidity, etc.)

Pre- and post-calibration daily, clean and visually inspect probes

Daily before and after use

No visual defect;

conformance with manufacturer standards

Repair or use substitute equipment

Table 7-2: Field Equipment Calibration

Equipment Maintenance Frequency Acceptance

Criteria

Corrective

Action

Water Quality

Meters (YSI, turbidity, etc.)

Calibrate DO, pH, Specific Conductivity, Turbidity and ORP probes per Operators’

Manual

Beginning of each field day with a check at the end of each field day.

pH = ± 10% of standard

Spec. Cond. = ±

10% of standard

ORP = ± 10% of standard

DO = ± 10% of temperature dependent DO saturation in DI water

Turbidity = ±

10% of true value

Recalibrate;

replace instrument if criteria exceeded

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7.3 QUALITY CONTROL SAMPLES

The following field quality control samples will be collected at the indicated frequencies.

Results will be evaluated using the indicated acceptance criteria and corrective action will be taken where necessary. The following Table 7-3 summarizes the QC samples, frequency, acceptance criteria, and corrective actions:

Table 7-3: Field Quality Control Samples

QC Sample Frequency Acceptance Criteria1 Corrective Action

(if necessary)

Blind Field Duplicate One per 20 or fewer samples per media

Relative percent difference between original sample and duplicate is <30% for water

Compare to appropriate action level and determine need for re-sampling or reanalysis

Temperature Blank One per cooler Cooled to 4°C

(± 2°C)

Qualify results or re-sample if temperature effects requested analyses 1 – Acceptance criteria should at a minimum match the requirements outline in the EPA National Functional

Guidelines, if more conservative, laboratory criteria may be substituted.

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8. LABORATORY METHODOLOGY

8.1 METHODS OF ANALYSIS & ANALYTICAL SENSITIVITIES

Laboratory analytical analysis will be performed by ARA, a Maine DEP, Department of Defense

(DoD) ELAP, and NELAC through the state of New Hampshire certified laboratory, at their laboratory in Portsmouth, New Hampshire. Certification documentation is included as

Appendix C. Referenced laboratory SOPs are included in Appendix D. Analytical sensitivities were compared to the regulatory criteria identified in Sections 6.1 to ensure the DQOs will be met. ARAs surface water analytical sensitivities are provided in the following Table 8-1:

Table 8-1: Laboratory Methods and Analytical Sensitivities for Surface Water

Analysis

(method, SOP) Compound

ARA LOQ

(mg/L)

ARA LOD

(mg/L)

Total and Dissolved Metals

(EPA Method 6020A, QA-5605)

Aluminum 0.01 0.01

Antimony 0.001 0.0001

Arsenic 0.005 0.001

Barium 0.01 0.0001

Cadmium 0.001 0.0001

Chromium 0.01 0.0001

Cobalt 0.01 0.0001

Copper 0.01 0.0001

Iron 0.01 0.001

Lead 0.005 0.0001

Magnesium 0.1 0.001

Manganese 0.01 0.0001

Molybdenum 0.01 0.001

Nickel 0.01 0.0001

Potassium 0.1 0.1

Selenium 0.01 0.0001

Silver 0.005 0.00005

Sodium 0.1 0.01

Vanadium 0.01 0.001

Zinc 0.01 0.001