KGS_2016a_Quality_Assurance_Project_Plan_for_LTM_Devens.pdf

Quality Assurance Project Plan Annual Long-Term Monitoring and Maintenance

Program

Former Fort Devens Army Installation, Devens, MA

June 2016

Prepared for:

U.S. Army Corp of Engineers

New England District Concord, Massachusetts

Prepared by:

KOMAN Government Solutions, LLC 160 East Main St., Suite 2F Westborough, MA 01581

Contract No.: W912WJ-15-C-0002

QUALITY ASSURANCE PROJECT PLAN

ANNUAL LONG-TERM MONITORING AND

MAINTENANCE PROGRAM

FORMER FORT DEVENS ARMY INSTALLATION

DEVENS, MA

Revision 2

June 2016

CERTIFICATION:

I hereby certify that the enclosed Report, shown and marked in this submittal, is that proposed to be incorporated with Contract Number W912WJ-15-D-0002. This Document was prepared in accordance with U.S. Army Corps of Engineers Scope of Work and is hereby submitted for Government Approval.

Reviewed By:

KGS Project Manager Date

Received By:

USACE Project Manager Date

TABLE OF CONTENTS

QAPP WORKSHEET #1 AND #2

QAPP WORKSHEET #3

QAPP WORKSHEET #4, 7 & 8

QAPP WORKSHEET #5

QAPP WORKSHEET #6

QAPP WORKSHEET #9

QAPP WORKSHEET #10-1 LONG TERM MONITORING PROGRAM

DEVENS SITE DESCRIPTION AND HISTORY

GROUNDWATER HYDROLOGY

LONG TERM MONITORING PROGRAM

QAPP WORKSHEET #10-2

QAPP WORKSHEET #10-3

QAPP WORKSHEET #11

QAPP WORKSHEET #12

QAPP WORKSHEET #13

QAPP WORKSHEET #14

QAPP WORKSHEET #15

QAPP WORKSHEET #16

QAPP WORKSHEET #17-1

COLLECTION OF GROUNDWATER SAMPLES

QAPP WORKSHEET #17-2

QAPP WORKSHEET #17-3

PHASE 1 – DEMONSTRATE PLUME CAPTURE

PHASE 2 – EVALUATE REMEDY PERFORMANCE

QAPP WORKSHEET #18

QAPP WORKSHEET #19 AND #30

QAPP WORKSHEET #20

QAPP WORKSHEET #21

QAPP WORKSHEET #22

QAPP WORKSHEET #23

QAPP WORKSHEET #24

QAPP WORKSHEET #24-1

QAPP WORKSHEET #24-2

QAPP WORKSHEET #24-3

QAPP WORKSHEET #24-4 AND 5

QAPP WORKSHEET #24-6

QAPP WORKSHEET #24-7

QAPP WORKSHEET #24-8

QAPP WORKSHEET #24-9

QAPP WORKSHEET #24-10

QAPP WORKSHEET #24-11

QAPP WORKSHEET #24-12

QAPP WORKSHEET #24-13

QAPP WORKSHEET #24-14

QAPP WORKSHEET #24-15

QAPP WORKSHEET #24-16

QAPP WORKSHEET #24-17

QAPP WORKSHEET #24-18

QAPP WORKSHEET #24-19

QAPP WORKSHEET #24-20

QAPP WORKSHEET #24-21

QAPP WORKSHEET #24-22

QAPP WORKSHEET #24-23

QAPP WORKSHEET #25

QAPP WORKSHEET #26 & 27

QAPP WORKSHEET #28-1

QAPP WORKSHEET #28-2

QAPP WORKSHEET #28-3

QAPP WORKSHEET #28-4

QAPP WORKSHEET #28-5

QAPP WORKSHEET #28-6

QAPP WORKSHEET #28-7

QAPP WORKSHEET #28-8

QAPP WORKSHEET #28-9

QAPP WORKSHEET #28-10

QAPP WORKSHEET #28-11

QAPP WORKSHEET #28-12

QAPP WORKSHEET #28-13

QAPP WORKSHEET #28-14

QAPP WORKSHEET #28-15

QAPP WORKSHEET #28-16

QAPP WORKSHEET #28-17

QAPP WORKSHEET #28-18

QAPP WORKSHEET #28-19

QAPP WORKSHEET #28-20

QAPP WORKSHEET #28-21

QAPP WORKSHEET #28-22

QAPP WORKSHEET #28-23

QAPP WORKSHEET #29

QAPP WORKSHEET #31, 32 & 33

QAPP WORKSHEET #34

QAPP WORKSHEET #35

QAPP WORKSHEET #36

QAPP WORKSHEET #37

LIST OF FIGURES

Figure 1.1a Former Fort Devens Army Installation Site Location Figure 1.1b Sudbury Annex Site Location Figure 2 Area of Contamination 57-Area 2 Figure 3 Area of Contamination 57-Area 3 Figure 4 Area of Contamination 69W Figure 5 Area of Contamination 43G Figure 6 Devens Consolidation Landfill Figure 7 Area of Contamination 32/43A Figure 8 Area of Contamination A7 Figure 9 Area of Contamination 50 Figure 10 Northern Impact Area and Shepley's Hill Landfill

APPENDICES

APPENDIX A Field Sampling SOPs APPENDIX B Laboratory SOPs (CD only)

Title: Former Fort Devens Program QAPP Revision Number: 2

Revision Date: June 2016 Page ii of 174

ADR automated data review AES atomic emission spectroscopy AOC area of contamination ARAR applicable or relevant and appropriate requirement ASTM American Society for Testing and Materials

BEC BRAC Environmental Coordinator BFB 4-bromofluorobenzene BRAC Base Realignment and Closure BTEX benzene, toluene, ethylbenzene, and xylene

°C degrees Celsius CA Corrective Action CCB continuing calibration blank CCC calibration check compounds CCV continuing calibration verification CERCLA Comprehensive Environmental Response, Compensation and Liability Act COB close of business CoC chain of custody COC contaminant of concern COD chemical oxygen demand COR Contract Officer Representative CRI contract required detection limit verification standard CVAA cold vapor atomic absorption

%D percent difference DCL Devens Consolidation Landfill Devens Former Fort Devens Army Installation DFTPP decafluorotriphenylphosphine DO dissolved oxygen DoD Department of Defense DQE data quality evaluation DQI data quality indicators DQO data quality objective DRO Diesel Range Organics

EB equipment blank ECD electron capture detector EDD electronic database deliverable EDMS electronic data management system ELAP Environmental Laboratory Accreditation Program EM Engineer Manual EPH extractable petroleum hydrocarbons

LIST OF ACRONYMS AND ABBREVIATIONS (continued)

FD field duplicate FIA flow injection analysis FID flame ionization detector

GC/MS gas chromatography/mass spectrometry

H&S H&S Environmental, Inc.

HAZWOPER Hazardous Waste Operations and Emergency Response HGL HydroGeologic, Inc.

HPLC high performance liquid chromatography

IC ion chromatography ICAL initial calibration ICB initial calibration blank ICP inductively coupled plasma ICS interference check sample ICV initial calibration verification ID No. Identification Number IS internal standard

KGS Koman Government Solutions, LLC

L liter LC liquid chromatography LC/MS/MS liquid chromatography/mass spectrometer/mass spectrometer (tandem) LCS laboratory control sample LCSD laboratory control sample duplicate LD laboratory duplicate LOD limit of detection LOQ limit of quantitation LTM long-term monitoring LTMM Long-Term Monitoring and Maintenance LTMMP Long-Term Monitoring and Maintenance Plan LTMP Long-Term Monitoring Plan

MA Massachusetts MassDEP Massachusetts Department of Environmental Protection MB method blank MCP Massachusetts Contingency Plan µg/L micrograms per liter µS/cm microsiemens per centimeter mg/L milligrams per liter mL milliliter MNA monitored natural attenuation MS matrix spike MSD matrix spike duplicate

NA not applicable NAE North Atlantic Division – New England District NCP National Contingency Plan NELAP National Environmental Laboratory Accreditation Program NFG National Functional Guidelines No. Number

OSHA Occupational Safety and Health Administration

.pdf portable document format PAH polynuclear aromatic hydrocarbon PARCCS precision, accuracy, representativeness, comparability, completeness, and sensitivity PCB polychlorinated biphenyl PCE tetrachlorethene PFCs Perfluorinated compounds PID photoionization detector PM project manager PMP Project Management Plan PQL practical quantitation limit PQO project quality objectives PWS Performance Work Statement

QA quality assurance QAPP Quality Assurance Project Plan QC quality control QM Quality Manual QSM Quality Systems Manual for Environmental Laboratories

%R percent recovery %RSD percent relative standard deviation r correlation coefficient RAO remedial action objective RC response complete RCRA Resource Conservation and Recovery Act ROD Record of Decision RPD relative percent difference RRF relative response factor

SARA Superfund Amendments and Reauthorization Act of 1986 SEDD Staged Electronic Data Deliverable SIM selected ion monitoring SOP standard operating procedures Sovereign Sovereign Consulting, Inc.

SPCC system performance check compound SS Site Supervisor

SVOC semivolatile organic compound SWETS Stone & Webster Environmental Technology and Services

TAL Test America Laboratory TB Trip Blank TBD to be determined TCE trichloroethene TDS total dissolved solids TPH total petroleum hydrocarbons TSS total suspended solids

UFP Uniform Federal Policy U.S. United States USACE U.S. Army Corps of Engineers USEPA U.S. Environmental Protection Agency USFWS U.S. Fish and Wildlife Services UST underground storage tank UV ultraviolet

VOA volatile organic analysis VOC volatile organic compound VPH volatile petroleum hydrocarbons

QAPP WORKSHEET #1 AND #2

Title and Approval Page

Site Name/Project Name: Former Fort Devens Army Installation (Devens) Site Location: Devens, MA, and Sudbury, MA Title: Program UFP-QAPP for LTM Program; Shepley’s Hill Site Investigation and PFC PA Revision Date: Junr 2016 Operable Units: Area of Contamination (AOC) 32 & 43A, 43G, 57, 69W, South Post Impact Area (SPIA), DCL, Sudbury Annex AOC A7, AOC 50 and Shepley’s Hill Landfill Contractor Name: Koman Government Solutions, LLC (KGS) Contract Number: W912WJ-15-D-0002 Contract Title: Environmental Remediation Services – Former Fort Devens Army Installation

1. Identify guidance used to prepare the Quality Assurance Project Plan (QAPP):

Uniform Federal Policy (UFP)-QAPP; AOC-specific Record of Decision (ROD); AOC-specific 5-Year Reviews; U.S. Environmental Protection Agency (USEPA) Region I Data Validation Guidelines; Department of Defense (DoD) Quality Systems Manual (QSM) for Laboratories, Version 5.0.

2. Identify regulatory program: USEPA Region 1 – Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), Superfund Amendments and Reauthorization Act of 1986 (SARA), Resource Conservation and Recovery Act (RCRA), and National Contingency Plan (NCP) programs.

3. Identify approval entity: USEPA Region 1 and USACE.

4. Indicate whether the QAPP is or Generic. (circle one)

5. List plans and reports from previous investigations that are relevant to this QAPP:

Shepley’s Hill Landfill – 2015 Annual Report (KGS, April 2016) 2015 Operations and Maintenance and Monitoring Report/AOC 50 (KGS, March 2016).

2015 Annual Report – Long Term Monitoring/Former Fort Devens Army Installation (KGS, February 2016) Long Term Monitoring and Maintenance Plan Update/Shepley’s Hill Landfill – Revised

(Sovereign, September 2015) 2015 Five Year Review for Former Fort Devens Army Installation/BRAC Legacy Site

(September 2015) Generic Quality Assurance Project Plan, Annual Long Term Monitoring and Maintenance

Program/Former Fort Devens Army Installation. (KGS, June 2015)

6. List organizational partners (stakeholders) and connection with lead organization:

U.S. Army Corps of Engineers US EPA Region I, Project Specific

Massachusetts Department for Environmental Protection (MassDEP), Mass Development, Restoration Advisory Board, and Base Realignment and Closure (BRAC) Team.

7. List data users:

KGS, USACE-NAE, BRAC team, USEPA Region 1, and MassDEP.

Penny Reddy Contracting Officer’s Representative/ Project Manager U.S. Army Corps of Engineers

Mark Koenig Project Chemist U.S. Army Corps of Engineers

Edward M. King, P.E.

Program Manager Koman Government Solutions

Elizabeth Anderson, PE Senior Project Manager Koman Government Solutions

Laurie Ekes Project Chemist Koman Government Solutions

QAPP WORKSHEET #3

Distribution List for Devens

QAPP

Recipients Title Organization Telephone Number E-mail Address

Edward King Program Manager KGS

(508) 366- 7442 eking@komangs.com

Elizabeth Anderson Project Manager (PM) KGS

(508) 366- 7442 eanderson@komangs.com

Patrick Schauble Corporate QC Manager KGS

(508) 366- 7442 pschauble@komangs.com

Elizabeth Anderson

Health and Safety (KGS) Manager KGS

(508) 366- 7442 eanderson@komangs.com

Kevin Anderson Site KGS Officer KGS

(508) 366- 7442 kanderson@komangs.com

Laurie Ekes Project Chemist KGS

(508) 366- 7442 lekes@komangs.com

Denise Tripp PM Geosyntec

(978) 206- 5713 Dtripp@geosyntec.com

Jerry Lanier PM Test America Savannah

(912) 354- 7858 Jerry.lanier@testamericainc.com

Penelope Reddy PM USACE

(978) 318- 8160 Penelope.reddy@usace.army.mil

Mark R. Koenig Project Chemist USACE

(978) 318- 8312 mark.r.koenig@usace.army.mil

Robert Simeone BRAC Environmental Coordinator (BEC) US Army

(978) 796- 2205 robert.j.simeone.civ@mail.mil

Carol Keating Remedial PM USEPA Region I

(617) 918- 1393 Keating.Carol@epa.gov

David Chaffin Federal Sites Program Mass Dep

(617) 348- 4005 David.chaffin@state.ma.us

Christine A. P.

Williams Remedial PM USEPA Region I

(617) 918- 1384 Williams.Christine@epa.gov mailto:lekes@hsenv.com

QAPP WORKSHEET #4, 7 & 8

Personnel Training, Responsibilities and Sign-off Sheet

ORGANIZATION: KGS

Name Project Title Specialized Training/Certifications Responsibilities Signature/Date

Edward King Program Manager Licensed professional engineer (PE), Hazardous Waste Operations and Emergency Response (HAZWOPER) 40-hour Training; 8-Hour Refresher;

cardiopulmonary resuscitation (CPR) and first aid/AED

Oversight responsibility for contractual and technical performance.

Elizabeth Anderson Project Manager Licensed PE, HAZWOPER 40-hour Training; 8-Hour Refresher; CPR and first aid/AED

Manages project technical and contractual requirements; coordinates between senior management, USACE-NAE, stakeholders, and project staff

Kevin Anderson Field Team Leader Manager

HAZWOPER 40-hour Training; 8- Hour Refresher; CPR and first aid/AED

Supervises field sampling and coordinates all field activities; serves as the site KGS coordinator.

Laurie Ekes Project Chemist HAZWOPER 40-hour Training; 8- Hour Refresher; CPR and first aid/AED

Verifies that the UFP-QAPP analytical requirements are met by the laboratory and field staff. Also provides direction regarding requirements for corrective actions for field and analytical issues; evaluates and releases validated analytical results to the KGS project team.

ORGANIZATION: Army/USACE

Name Project Title Specialized

Training/Certifications Responsibilities Signature/Date

Robert Simeone BRAC Environmental Coordinator

Unknown BRAC Environmental Coordinator for Devens Environmental Remediation.

Penny Reddy Technical Lead Unknown USACE Project Manager for Devens Environmental Remediation

Responsibilities Signature/Date

Mark Koenig Project Chemist HAZWOPER 40-hour Training; 8- Hour Refresher

Coordinates with KGS project chemist. Reviews field activities and laboratory data.

ORGANIZATION: Test America

Responsibilities Signature/Date

Jerry Lanier Project Manager Not applicable Primary point of contact for Test America Laboratory. Receives direction from KGS Project Chemist. Responsible for ensuring the UFP-QAPP requirements are met by the laboratory.

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

QAPP WORKSHEET #5

Project Organizational Chart

U.S. Army Corps of Engineers® New England District

Project Managers E. Anderson – KGS

BRAC

Environmental

Coordinator Massachusetts Department of

Environmental Protection U.S. Environmental Protection Agency

Restoration Advisory Board Massachusetts Development

Subcontractors

DRILLERS

Test America - Savannah Test America – Denver

Test America – Sacramento Katahdin

Program Manager E. King – KGS

Contracts Manager E. King - KGS

QA/QC Manager P. Schauble – KGS

Project Chemist L. Ekes – KGS

Site Health and Safety K. Anderson – KGS

Key Technical Support Personnel

KGS field personnel

QAPP WORKSHEET #6

Communication Pathways

Communication Drivers

Responsible Entity

Name Phone Number Procedure (Timing, Pathways, etc.)

Communication with USACE (lead agency)

USACE Program Manager

Penny Reddy (978) 318-8160 Primary point of contact with USACE.

Coordinates contracting actions.

Provides direction to KGS.

Communication with

BRAC

BRAC EC Robert Simeone (978) 796-2205 Primary point of contact for Fort Devens.

Communication with

EPA

EPA RPM Carol Keating (617) 918-1393 Primary point of contact for EPA.

Provides technical and regulatory input and recommendations to

USACE.

Communication with MassDEP

MassDEP RPM David Chaffin (617) 348-4005 Primary point of contact for MassDEP. Provides technical and regulatory input and recommendations.

Communication with

KGS

KGS PM Elizabeth Anderson

(508) 366-7442 Primary point of contact for KGS.

Provides project management input and recommendation to USACE PM.

Receives direction from USACE.

Progress of field program

KGS Kevin Anderson

(508) 366-7442 Conveys progress of field activities.

Communication with KGS PM.

Oversees onsite safety activities.

Communication with KGS project Chemist

Test America Laboratory project Manager

Jerry Lanier (912) 354-7858 Coordinates laboratory staff to assure timely deliverables. Communicates QA/QC issues with project chemist.

Approves release of analytical data from laboratory.

Review and release of analytical data

KGS Project Chemist

Laurie Ekes (508) 366-7442 Verifies the UFP_QAPP analytical requirements are met by the laboratory and field staff. Coordinates sampling activities with analytical laboratory.

Evaluates and releases analytical results to the KGS PM.

QAPP WORKSHEET #9

Project Scoping Session Participants Sheet

Project Name Annual Long-Term Monitoring (LTM) Program, PFCs Preliminary Assessment and Shepley’s Hill Landfill Supplemental Investigation

Projected Date(s) of Sampling June 2016

Project Manager Elizabeth Anderson

Site Name: Former Fort Devens Army Installation and Shepley’s Hill Landfill

Site Locations Devens, MA

Date of Session: Planning session will be prior to sampling.

Scoping Session Purpose: To plan, coordinate and schedule field activities for upcoming sampling events as detailed in worksheets #10-1, 10-2 and 10-3.

Name Title Affiliation Phone # E-mail Address Project Role Elizabeth Anderson Project Manager KGS (508) 366-7442 eanderson@komangs.com Project Manager

Comments/Decisions:

Action Items:

Consensus Decisions:

QAPP WORKSHEET #10-1 LONG TERM MONITORING PROGRAM

Devens Site Description and History

Devens is located in the towns of Ayer and Shirley in Middlesex County, and Harvard and Lancaster in Worcester County, Massachusetts, approximately 35 miles northwest of Boston, Massachusetts (Figure 1.1a). The installation occupied approximately 9,260 acres. Prior to the official base closure, Devens was divided into the North Post, Main Post, and South Post. Route 2 divides the South Post from the Main Post. The Nashua River runs through the North, Main, and South Posts. The area surrounding Devens is largely rural residential property.

Camp Devens was established in 1917 as a temporary training area for soldiers during World War I.

Prior to 1917, the area was occupied by residential homes and farmland. In 1932, the site was named Fort Devens and made a permanent installation with the primary mission of commanding, training, and providing logistical support for non-divisional troop units. The installation also supported the Army Readiness Regional and National Guard units in the New England area.

Devens was used for a variety of training missions between 1917 and 1990. Pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986, Devens was placed on the National Priorities List on November 21, 1989, due to environmental contamination at several sites.

Devens was identified for cessation of operations and closure under Public Law 101-510, the Defense Base Realignment and Closure (BRAC) Act of 1990, and officially closed in March 1996.

As part of the Devens BRAC program, portions of the property formerly occupied by Fort Devens were retained by the U.S. Army (Army) for reserve forces training and renamed the Devens Reserve Forces Training Area (DRFTA). Areas not retained as part of DRFTA were, or are in the process of being, transferred to new owners for reuse and redevelopment.

The Sudbury Annex occupies approximately 4.3 square miles in the Massachusetts towns of Hudson, Marlborough, Maynard, Stow and Sudbury. Hudson Road divides the installation into a larger northern section, and a smaller southern section (Figure 1.1b). The Sudbury Annex became part of Fort Devens, now the DRFTA, in 1982. The Sudbury Annex was removed from the National Priorities List (NPL) in January 2002. At that time, 2,205 acres were transferred to the U.S. Fish and Wildlife Service, 4.1 acres were transferred to the U.S. Air Force, and 71.4 acres were transferred to the Federal Emergency Response Agency. In June 2002, all known monitoring wells at the former annex were decommissioned except for those at the one AOC remaining in the LTMM program (AOC A7).

A total of 325 environmental investigation sites have been addressed at Devens under CERCLA.

Twenty-one sites were defined as AOCs, 63 were defined as Study Areas (SA) and 241 sites were defined as Areas Requiring Environmental Evaluation (AREE) sites. Each of the 241 AREE sites has been addressed in final No Further Action (NFA) Decision Documents. Sixty of the 63 SA sites have been addressed in final NFA Decision Documents and the remaining three SA sites have been addressed in final RODs.

Groundwater Hydrology Devens is located in eastern Massachusetts approximately 25 miles north of Worcester, Massachusetts. The proximity of the Atlantic Ocean, Long Island Sound, and the Berkshire Hills plays an important role in determining the weather and climate of the Devens area.

Groundwater elevation data is collected during each LTM sampling event. Groundwater flow directions are evaluated and are essential in understanding contaminant migration pathways and evaluating the effectiveness of the monitoring well network. Groundwater hydrology is discussed in detail in respective AOC Annual Reports.

Long Term Monitoring Program The LTM Program instituted at Devens is a result of the individual Record of Decision (ROD) documents issued for each Area of Concern (AOC). The AOCs include:

• AOC 57;

• AOC 69W;

• AOC 43G;

• AOCs 32 and 43A;

• Devens Consolidation Landfill (DCL);

• Sudbury Annex (AOC 9)

• AOC 50;

• Shepley’s Hill Landfill

AOC 57 is located between Barnum Road and Cold Spring Brook on the northeast side of what was formerly the Main Post of Devens and what was used primarily as a storage and maintenance area for military vehicles. The main portion of the site is a former solar panel manufacturing facility.

The active portions of AOC 57 consist of Area 2 and Area 3 (Figures 2 and 3).

AOC 69W is located at the northeast corner of the intersection of Jackson Road and Antietam Street on the northern portion of what was formerly the Main Post at Devens. AOC 69W consists of the former Devens Elementary School (Building 215) and its associated parking lot and adjacent lawn, extending approximately 300 feet northwest to Willow Brook (Figure 4).

AOC 43G is located in the central portion of the former main post of Devens and consists of the former Army Air Force Exchange Service (AAFES) gas station and historical post gas station. This AOC remains entirely within the Army Garrison property (Figure 5).

DCL is located in the former Main Post of Devens and constructed at the location of the former golf course driving range. It was constructed between 2000 and 2002 to provide an on-site landfill for debris from six individual remedial areas (Figure 6).

AOCs 32 and 43A were known as the Defense Reutilization and Marketing Office (DRMO) Yard, and the petroleum, oils and lubricant (POL) storage areas, respectively. AOC 32 consisted of three fenced areas (DRMO west yard, DRMO east yard, and tire recycling area) along Cook Street. AOC 43A was located across Market Street from AOC 32. AOC 43A consisted of a fenced lot located within an industrial area and served as the distribution point for all gasoline and other fuels at Devens from the 1940s to 1996 (Figure 7).

Sudbury Annex (AOC A7) is located at the former Sudbury Training Annex in Sudbury, Massachusetts. Site AOC A7 is the only site remaining at the Sudbury Annex that requires environmental monitoring. AOC A7 is a former waste disposal site in the northern portion of the former training annex. A Resource Conservation and Recovery Act (RCRA) Subtitle C landfill cap was installed in 1996 (Figure 8).

AOC 50 is located on the northeastern boundary of the former Moore Army Airfield (MAAF), within the former North Post portion of Fort Devens. Sources of groundwater contamination at AOC 50 include two World War II fueling systems, a drywell formerly connected to the parachute shakeout tower, and the PCE drum storage area; these sources are collectively referred to as the AOC 50 Source Area (Figure 9). The AOC 50 Source Area is comprised of less than two acres and surrounds Buildings 3803 (the former parachute shop), 3840 (the former parachute shakeout tower), 3824 (a gazebo), and 3801 (the former 10th Special Forces airplane parachute simulation building).

The primary area of groundwater contamination at AOC 50 is referred to as the Southwest Plume, which extends from the Source Area approximately 3,000 feet (ft) downgradient to the Nashua River.

SHL encompasses approximately 84 acres in the northeast corner of the main post of the former Fort Devens. The landfill is bordered to the northeast by Plow Shop Pond (PSP), to the west by Shepley’s Hill, to the south by recent commercial development, and to the east by land formerly containing a railroad roundhouse. Nonacoicus Brook, which drains PSP, is located north of the landfill in the NIA (Figure 10).

Groundwater and/or surface water samples will be collected from the AOCs listed above on a semi-annual and/or annual basis in the Spring and Fall. The rationale for the established LTM program is discussed in worksheet #17-1. The LTM sampling locations and analytical parameters are summarized on Tables 18-1 in Worksheet#18.

Specific details of the long term monitoring programs for each AOC are detailed in separate Long Term Monitoring Plans; Final Long Term Monitoring and Maintenance Plan (LTMMP) for Former Fort Devens Army Installation and Sudbury Annex (Sovereign/HGL, February 2015); Draft Final Long Term Monitoring Plan (LTMP) Area of Contamination 50 (HGL, March 2012); and Final Long Term Monitoring and Maintenance Plan (LTMMP) Update, Shepley’s Hill Landfill (Sovereign, September 2015). Figures depicting individual AOCs are included in the LTM Plans.

Leachate samples will be collected annually from the DCL to verify compliance with the requirements of the Mass Development Industrial Waste Discharge Permit No. 017. Landfill gas monitoring will also be performed at the Former Sudbury Training Annex AOC A7.

QAPP WORKSHEET #10-2

Base wide Preliminary Assessment for PFCs

1.0 Introduction

As noted in EPA's fact sheet on Emerging Contaminants dated March 2014, PFCs can be found in fire-fighting foams used by the Department of Defense (DoD). EPA's review of the Devens facility indicates that there are a number of areas where foams containing PFCs could have been stored, used and released including: the Moore Army Airfield Drum Storage Area (Area #30), Fire Fighting Training Area (Area #31), Training Area 6D (Area #46), Building 2680 (Former Gas Station Site, Area #54), and South Post Impact Area (SPIA) storage and training areas.

Additional Work is needed to determine if there has been a release of PFCs from these area or other possible areas where PFCs may have been stored and/or used.

Therefore, EPA is requiring that a Base-Wide Preliminary Assessment (PA) be conducted in accordance with paragraph 2.6 of the FFA that includes these areas and any other areas where PFCs were stored and/or used at the former Fort Devens and the South Post Impact Area (SPIA).

Select groundwater wells at Fort Devens will be sampled and analyzed for select PFCs (see Table 15-1). In addition, the on-base potable water supply wells near the South Post Impact Area (SPIA) and off base public water supply wells will also be sampled and analyzed for PFCs to ensure they are safe for human consumption. The off base public water supply wells are located near the areas where foams containing PFCs may have been used; these wells include the MacPherson well serving Devens and the Town Forest well serving West Groton.

Groundwater samples will be collected in support of this PA; the rationale for the PFC sampling is discussed in Worksheet#17-2. The sampling locations for the PFC PA include the water supply wells listed previously. Additional sampling locations are to be determined.

QAPP WORKSHEET #10-3

Supplemental Site Investigation - Shepley’s Hill Landfill

Background SHL encompasses approximately 84 acres in the northeast corner of the main post of the former Fort Devens. The landfill is bordered to the northeast by PSP, to the west by Shepley’s Hill, to the south by recent commercial development, and to the east by land formerly containing a railroad roundhouse. Nonacoicus Brook, which drains PSP, is located north of the landfill in the NIA (Figure 10).

SHL was reportedly operating by the early 1940s; however, evidence from test pits within the landfill suggests earlier usage, possibly as early as the mid-nineteenth century. The landfill contains a variety of waste materials including, but not limited to, incinerator ash, demolition debris, asbestos, sanitary wastes, and glass. The maximum depth of the refuse occurs in the central portion of the landfill and is estimated to extend about 40 feet below ground surface (bgs). The volume of waste in the landfill has been estimated at over 1.3 million cubic yards (cy), of which approximately 160,000 cy (11%) is below the water table.

The Massachusetts Department of Environmental Protection (MassDEP) approved the landfill closure plan in 1985. The landfill was closed in five phases between 1987 and 1993 in accordance with 310 Code of Massachusetts Regulations (CMR) 19.000. Closure consisted of capping the landfill with a 30 to 40-mil polyvinyl chloride (PVC) membrane, covering the cap with soil and vegetation, and installing gas vents. Closure also included installation of wells to monitor groundwater quality around the landfill and construction of drainage swales to control surface water runoff.

A Feasibility Study (FS) and Record of Decision (ROD) resulted in a remedy that required long term monitoring including maintenance of the existing landfill cap and groundwater monitoring. As described in the ROD (USAEC, 1995), the remedial action objectives (RAO) are to:

• Protect potential residential receptors from exposure to impacted groundwater migrating from the landfill having chemicals in excess of maximum contaminant levels (MCLs); and,

• Prevent impacted groundwater from contributing to the contamination of Plow Shop Pond sediments in excess of human health and ecological risk-based concentrations.

The ROD required the Army to perform groundwater monitoring and five-year reviews to evaluate the effectiveness of the selected remedial action, which at the time relied heavily on the landfill cap to attain groundwater cleanup goals by 2008 and to reduce potential exposure risks. If groundwater contaminant concentrations, primarily arsenic, met risk-based performance standards (cleanup goals) over time, the ROD did not require further action; however, if cleanup goals were not met, the ROD required implementation of a groundwater extraction contingency remedy component for arsenic treatment. Due to continued contaminant concentrations greater than MCLs, the Army installed and began operating a groundwater extraction and treatment system in March 2006 as a contingency remedy component to address groundwater contamination emanating from the northern portion of the landfill (CH2M Hill, 2005a). Since 2008, the system has been operated at full capacity and in 2015 achieved an average on-line extraction rate of 50.0 gpm.

A low-permeability groundwater barrier wall was installed between the SHL and AOC 72 as part of a Non-Time Critical Removal Action (NTCRA) from August to September 2012 to mitigate arsenic flux to Red Cove/PSP by groundwater flow from the SHL.

Long Term Monitoring continues at SHL as discussed in Worksheet #10-1. However, after review of the fourth Comprehensive Five Year Review (H&S, 2015), the EPA identified issues with the existing extraction and treatment system and additional work is necessary to determine whether the SHL remedial action is protective of human health and the environment.

Introduction and Purpose This supplemental Site investigation is to be conducted at Shepley’s Hill Landfill in response to EPA’s request to determine that the selected remedial action at SHL is protective of human health and the environment. The field work for this supplemental investigation will be performed in Two Phases:

Phase 1-Demonstrate Plume Capture -The Army shall collect data sufficient to demonstrate that the existing extraction and treatment system as designed, constructed and operated provides sufficient containment/capture of the contamination migrating from SHL.

This phase will be carried out both in the field by collecting profile and groundwater samples and through evaluation of the groundwater flow model. The field steps include:

• delineation of the capture zone based on hydraulic and geochemical data;

• delineation of the lateral and vertical extent of the contaminant plume upgradient of the extraction system and

• delineation of the lateral and vertical extent of the contamination downgradient of the extraction system along Scully Road.

Phase 2 -Evaluate Remedy Performance - After EPA determines that sufficient containment has been achieved, the Army shall collect sufficient monitoring data collected on a quarterly basis for five (5) years to adequately evaluate whether the operation of the containment system, coupled with Monitored Natural Attenuation (MNA), will result in restoration of groundwater in the downgradient impacted area (i.e. North Impacted Area (NIA) in a time frame that is reasonable.

The long term monitoring program may be modified, as necessary, to assure the protectiveness of the remedy.

This phase consists of two steps to be performed by collecting groundwater samples;

• Collect and analyze geochemical (wells) and hydrologic (piezometers) data for a minimum of five years to evaluate remedy’s ability to achieve cleanup goals and ensure long-term protectiveness;

• Perform a study to determine the site specific background level of arsenic in groundwater.

The sampling design and rationale for the SHL SI is discussed in Worksheet #17-3 and proposed sampling locations are summarized in Tables 18-3a and 18-3b in Worksheet #18.

QAPP WORKSHEET #11

Data Quality Objectives

Data Quality Objectives (DQOs) define the type, quantity, and quality of data that are needed to answer project-specific questions and support project-specific decisions.

State the Problem – Worksheets 10-1, 10-2 and 10-3 define the objectives of the sampling programs planned for Fort Devens.

Identify the goals of the Studies –The LTM data will be used to prepare Annual reports. Annual reports will include a description of LTM activities, a summary of groundwater sampling results and an assessment of groundwater and surface water elevation data as applicable. Conclusions and recommendations shall be made regarding the effectiveness of the remedial actions.

The Basewide PA for PFCs at Fort Devens will be used to determine the presence or absence of PFCs and to determine whether continued monitoring will be required.

The data from the supplemental investigation at Shepley’s Hill Landfill will be used to evaluate the remedial action at SHL with respect to the protectiveness of human health and the environment.

Identify Information Inputs – Groundwater samples are needed to meet the objectives of the LTM, Shepley’s SI and the Basewide PA for PFCs. Groundwater samples will be collected from monitoring wells. Vertical profile groundwater samples will be collected in support of some SHL SI tasks. The sampling designs and rationales for each investigation are presented in Worksheets #17- 1, 17-2 and 17-3 (Sampling Design and Rationale). AOC specific samples and required analyses are presented in Tables 18-1, 18-2 and 18-3. A complete listing of the target analytes is provided in Tables 15-1 and 15-2 in Worksheet #15 (Reference Limits and Evaluation).

Define the Boundaries of the Studies - Worksheets #17-1, 17-2 and 17-3 (Sampling Design and Rationale) describe the field investigation activities planned for the LTM, PFC PA and SHL SI.

Tables included with Worksheet #18 (Sampling Locations and Methods) summarize the number of samples and the analytical parameters necessary for the LTM AOCs, the basewide PFC PA and the Shepley’s SI. SOPs for field sampling and analytical procedures are presented in Worksheets #21 (Field SOPs) and #23 (Analytical SOP References). The field SOPs are provided in Appendix A.

The Laboratory SOPs (SOPs) are presented in Appendix B. LTM fieldwork is scheduled for Spring (May/June) and Fall (September/October), the Shepley’s SI field work is scheduled for June and July and the PFC sampling is scheduled for May/June and may be sampled concurrently with the LTM sampling.

Develop the Analytics Approach - Analytical methods are planned to be definitive quality data.

Definitive data are defined as data that are suitable for final decision making. The comparison of detected concentrations against screening levels (Table 15-1) will be used to support the project-specific decisions. Data are generated using rigorous analytical methods, in this case, approved, ELAP certified laboratory standard operating procedures (SOPs), provided in Appendix B.

Definitive data are not restricted in their use unless quality problems require data qualification resulting in unusable data. Definitive data will be suitable to meet the DQOs.

Specify Performance and Acceptance Criteria – Performance and acceptance criteria for all analytical methods are summarized in Table 15-1. Table 15-1 also compares method LOQs and DLs against project action levels.

Develop the Plan for Obtaining Data - The KGS team will complete the field sampling activities and collect the data on behalf of the Army. LTM groundwater samples and Shepley’s SI profile and groundwater samples will be submitted to Test America Laboratory in Savannah, GA. Groundwater samples collected for the PFC PA will be submitted to Test America, Sacramento, CA. All data will be managed by KGS for the Army.

Information generated from field activities will be documented on appropriate forms and will be maintained at KGS’s Westborough, Massachusetts office. These include chain-of-custody records, field books, well construction forms, boring logs, location sketches, and site photographs. In addition, notes from critical project meetings and telephone conversations will be filed. Adobe pdf copies of all field records will be stored electronically in KGS project network.

Laboratory data will be reported in analytical packages (produced in .pdf format) that will, at a minimum, contain all necessary information to allow for validation in accordance with the USEPA Stage 2A as described in Guidance for Labeling Externally Validated Laboratory Analytical Data for Superfund Use (USEPA, 2009) (see Worksheets #34 through #36). Electronic database deliverables (EDDs) will meet the requirements of Automated Data Review (ADR) A1 and A3 files. All EDDs will be uploaded and stored on the Devens Main Base electronic data management system (EDMS) file. Field data and observations will be recorded in bound logbooks or electronically on sampling log sheets. Well stabilization parameters will be recorded on pre-printed field sheets.

USACE, EPA, MassDEP, KGS and stakeholders will use the data to support the project-specific decisions to be made, as outlined in Worksheets #10-1, 10-2 and 10-3.

QAPP WORKSHEET #12

Measurement Performance Criteria

Measurement performance criteria (MPC) have been established for the groundwater analytical parameters for this project. The required MPCs for each analytical parameters are presented in the following Worksheets:

• Worksheet #15 – “Reference Limits and Evaluation” for reporting limit objectives

• Worksheet #24 – “Analytical Instrument Calibration” for respective instrument calibration requirements.

• Worksheet #28 – “Analytical Quality Control and Corrective Actions” for the requirements of laboratory QA/QC activities.

• Worksheet #35 – “Data Verification and Validation Inputs” for data review and validation process.

The quality of the data to be collected for the project will be verified using appropriate MPC established for both sampling procedures and analytical methods. The criteria will relate to the specific AOC target compounds lists and reporting limit objectives. The MPCs follow those defined in the DoD Quality Systems Manual (QSM) Version 5.0 (DoD 2013). The sampling procedures and the quality of the laboratory results will be evaluated for compliance with project-specific DQOs through a review of overall PARCCS in accordance with procedures described in Worksheet #37 (Data Usability Assessment).

QAPP WORKSHEET #13

Secondary Data Criteria and Limitations Table

Secondary Data Data Source Types of Data How Data Will Be Used Limitations on Data Use

Annual LTM Program Reports

Annual Reports for individual AOCs; AOC 32 and 43A, AOC

43G, AOC 57, AOC69W, SPIA,

DCL, Sudbury Annex, Shepley’s Hill Landfill and

AOC50.

Historical groundwater, surface water, sump water and leachate sampling summary data for respective AOCs: 2000 through current.

Compared to historical results to identify spatial and temporal trends at respective AOCs.

None, except as identified for individual data points in the associated data quality evaluation (DQE).

LTMM Plans Current LTMMPs for all AOCs. LTMM Program groundwater sampling summary and analytical data.

Compared to current results to identify spatial and temporal trends at respective AOCs

None

DCL Permit Compliance

Industrial Pretreatment Self- Monitoring Reports

Landfill leachate data: October 2006 through current.

Identify changes in discharge concentrations

None, except as identified for individual data points in the associated DQE

QAPP WORKSHEET #14

Summary of Project Tasks

Field Sampling Tasks:

Sampling Tasks are summarized in Worksheets #10 and presented in detail in Worksheets #17-1, 17-2 and 17-3. Field Sampling SOPS are provided in Appendix A. Water level measurements are recorded for each AOC prior to each sampling event.

Analysis Tasks:

Laboratory analyses – Laboratory analyses for sampling events included in this QAPP are listed in Worksheets #15 and #19. AOC specific analytical requirements are included in Tables 18-1, 18-2 and 18-3.

Field analyses – All groundwater samples are collected following the low flow sampling procedure. Water quality parameters The will be measured for each well at 5 minute intervals, until stabilization and immediately prior to sampling. These parameters include:

pH, turbidity, conductance, dissolved oxygen (DO), oxidation-reduction potential (ORP), and temperature.

Quality Control Tasks:

Quality control samples will be collected at the frequency specified in Worksheet #20. AOC specific QC samples for the LTM program have been specified in Tables included in the LTMMP (2015). Laboratory QC tasks are defined in laboratory SOPs (Appendix B) and are summarized in Worksheets #24.

Secondary Data:

See Worksheet #13.

Documentation and Records:

All field observations and sampling records will be entered into bound logbooks. Chain of custody (CoC) forms, investigation records, air bills, well stabilization parameter logs, field instrument calibration logs, and investigation-derived waste records will be prepared and retained in project files.

Analytical Data Reports:

Analytical data packages will be required to contain all data required to perform data review in accordance with Tier II data validation protocols as defined by the Region I USEPA. Sufficient documentation must be provided to allow for calibration, QC, blank, and other relevant information to be related to all associated sample analyses. Project completeness will be evaluated during data verification. Data verification and validation criteria are summarized in Worksheets #34, 35, and 36.

QAPP WORKSHEET #14

Summary of Project Tasks

Assessment/Audit Tasks:

The laboratory’s certification status and compliance with the most recent version of the DoD QSM were reviewed prior to contract award; the laboratory’s precision, accuracy, and sensitivity performance was comparable to or better than the project requirements.

Data Review Tasks:

The Automated Data Review software (ADR.Net) will be used to review the analytical data. The laboratory will produce SEDD Stage 2a data deliverables, consistent with DOD QSM valid values that have been screened against the ADR.Net project eQAPP provided by KGS. The laboratory will provide KGS with error-free SEDD Stage 2a deliverables (.xml file with warning log files). The KGS project chemist will prepare a data validation report incorporating the ADR.net report output.

QAPP WORKSHEET #15

Reference Limits and Evaluation Table

One of the primary goals of the UFP-QAPP is to select appropriate analytical methods to achieve DLs, limit of detections (LOD), and/or limit of quantitation (LOQs) that will satisfy the overall project DQOs (as defined in Worksheet #11 [Data Quality Objectives]).

Table 15-1 shows the target compound lists for groundwater sampling compared to MassDEP GW-1 standards. AOC specific cleanup goals are listed in the LTMMP and meet or exceed MCP GW-1 standards. Table 15-2 Lists the contaminants of concern and discharge limit criteria for the annual DCL leachate monitoring.

Table 15-1 Analytical Method Reporting Limits and Control Limits

Laboratory Specific Laboratory Control Limits

Method Analyte Description

CAS

Number

Cleanup Goals

(ug/L)1 LOQ MDL LOD Units %R Low

%R High

RPD

Organic Analyses 8260B_DOD5 (VOCs) 1,1,1,2-Tetrachloroethane 630-20-6 5.0 1.00 0.370 1.00 ug/L 78 124 20 1,1,1-Trichloroethane 71-55-6 200 1.00 0.370 1.00 ug/L 74 131 20 1,1,2,2-Tetrachloroethane 79-34-5 2.0 1.00 0.620 1.00 ug/L 71 121 20 1,1,2-Trichloroethane 79-00-5 5.0 1.00 0.330 1.00 ug/L 80 119 20 1,1-Dichloroethane 75-34-3 70 1.00 0.380 1.00 ug/L 77 125 20 1,1-Dichloroethene 75-35-4 7.0 1.00 0.360 1.00 ug/L 71 131 20 1,1-Dichloropropene 563-58-6 1.00 0.340 1.00 ug/L 79 125 20 1,2,3-Trichlorobenzene 87-61-6 5.00 2.50 5.00 ug/L 69 129 20 1,2,3-Trichloropropane 96-18-4 1.00 0.390 1.00 ug/L 73 122 20 1,2,4-Trichlorobenzene 120-82-1 70 5.00 2.50 5.00 ug/L 69 130 20 1,2,4-Trimethylbenzene 95-63-6 1.00 0.470 1.00 ug/L 76 124 20 1,2-Dibromo-3-Chloropropane 96-12-8 5.00 1.10 2.00 ug/L 62 128 20 1,2-Dichlorobenzene 95-50-1 600 1.00 0.370 1.00 ug/L 80 119 20 1,2-Dichloroethane 107-06-2 5.0 1.00 0.500 1.00 ug/L 73 128 20 1,2-Dichloroethene, Total 540-59-0 2.00 0.740 1.00 ug/L 79 121 20

Table 15-1 Analytical Method Reporting Limits and Control Limits

Laboratory Specific Laboratory Control Limits

Method Analyte Description

CAS

Number

Cleanup Goals

(ug/L)1 LOQ MDL LOD Units %R Low

%R High

RPD

1,2-Dichloropropane 78-87-5 5.0 1.00 0.670 1.00 ug/L 78 122 20 1,3,5-Trimethylbenzene 108-67-8 1.00 0.310 1.00 ug/L 75 124 20 1,3-Dichlorobenzene 541-73-1 100 1.00 0.430 1.00 ug/L 80 119 20 1,3-Dichloropropane 142-28-9 1.00 0.340 1.00 ug/L 80 119 20 1,4-Dichlorobenzene 106-46-7 5.0 1.00 0.460 1.00 ug/L 79 118 20 2,2-Dichloropropane 594-20-7 1.00 0.370 1.00 ug/L 60 139 20 2-Butanone (MEK) 78-93-3 4,000 10.0 3.40 10.0 ug/L 56 143 20 2-Chlorotoluene 95-49-8 1.00 0.270 0.500 ug/L 79 122 20 2-Hexanone 591-78-6 10.0 2.00 5.00 ug/L 57 139 20 4-Chlorotoluene 106-43-4 1.00 0.450 1.00 ug/L 78 122 20 4-Isopropyltoluene 99-87-6 1.00 0.480 1.00 ug/L 77 127 20 4-Methyl-2-pentanone (MIBK) 108-10-1 350 10.0 2.10 5.00 ug/L 67 130 20 Acetone 67-64-1 10.0 7.00 10.0 ug/L 39 160 20 Benzene 71-43-2 5.0 1.00 0.430 1.00 ug/L 79 120 20 Bromobenzene 108-86-1 1.00 0.500 1.00 ug/L 80 120 20 Bromoform 75-25-2 4.0 1.00 0.430 1.00 ug/L 66 130 20 Bromomethane 74-83-9 10 5.00 2.50 5.00 ug/L 53 141 20 Carbon disulfide 75-15-0 2.00 0.430 2.00 ug/L 64 133 20 Carbon tetrachloride 56-23-5 5.0 1.00 0.330 1.00 ug/L 72 136 20 Chlorobenzene 108-90-7 100 1.00 0.260 0.500 ug/L 82 118 20 Chlorobromomethane 74-97-5 1.00 0.450 1.00 ug/L 78 123 20 Chlorodibromomethane 124-48-1 1.00 0.320 1.00 ug/L 74 126 20 Chloroethane 75-00-3 5.00 2.50 5.00 ug/L 60 138 20 Chloroform 67-66-3 70 1.00 0.500 1.00 ug/L 79 124 20 Chloromethane 74-87-3 1.00 0.400 1.00 ug/L 50 139 20 cis-1,2-Dichloroethene 156-59-2 70 1.00 0.410 1.00 ug/L 78 123 20 cis-1,3-Dichloropropene 10061-01-5 1.00 0.400 1.00 ug/L 75 124 20

Laboratory Specific Laboratory Control Limits

Method Analyte Description

CAS

Number

Cleanup Goals

(ug/L)1 LOQ MDL LOD Units %R Low

%R High

RPD

Dibromomethane 74-95-3 1.00 0.350 1.00 ug/L 79 123 20 Dichlorobromomethane 75-27-4 3.0 1.00 0.440 1.00 ug/L 79 125 20 Dichlorodifluoromethane 75-71-8 1.00 0.600 1.00 ug/L 32 152 20 Ethylbenzene 100-41-4 700 1.00 0.330 1.00 ug/L 79 121 20 Ethylene Dibromide 106-93-4 1.00 0.440 1.00 ug/L 75 127 20 Hexachlorobutadiene 87-68-3 5.00 2.50 5.00 ug/L 66 134 20 Isopropylbenzene 98-82-8 1.00 0.350 0.500 ug/L 72 131 20 Methyl tert-butyl ether (MTBE) 1634-04-4 70 10.0 0.300 0.500 ug/L 71 124 20 Methylene Chloride 75-09-2 5.00 2.50 5.00 ug/L 74 124 20 m-Xylene & p-Xylene 179601-23-1 1.00 0.350 1.00 ug/L 80 121 20 Naphthalene 91-20-3 5.00 2.50 5.00 ug/L 61 128 20 n-Butylbenzene 104-51-8 1.00 0.470 1.00 ug/L 75 128 20 N-Propylbenzene 103-65-1 1.00 0.380 1.00 ug/L 76 126 20 o-Xylene 95-47-6 1.00 0.230 0.500 ug/L 78 122 20 sec-Butylbenzene 135-98-8 1.00 0.420 1.00 ug/L 77 126 20 Styrene 100-42-5 100 1.00 0.270 0.500 ug/L 78 123 20 tert-Butylbenzene 98-06-6 1.00 0.450 1.00 ug/L 78 124 20 Tetrachloroethene 127-18-4 5.0 1.00 0.740 1.00 ug/L 74 129 20 Toluene 108-88-3 1,000 1.00 0.480 1.00 ug/L 80 121 20 trans-1,2-Dichloroethene 156-60-5 100 1.00 0.370 1.00 ug/L 75 124 20 trans-1,3-Dichloropropene 10061-02-6 1.00 0.420 1.00 ug/L 73 127 20 Trichloroethene 79-01-6 5.0 1.00 0.480 1.00 ug/L 79 123 20 Trichlorofluoromethane 75-69-4 1.00 0.420 1.00 ug/L 65 141 20 Vinyl acetate 108-05-4 2.00 0.810 1.00 ug/L 54 146 20 Vinyl chloride 75-01-4 2.0 1.00 0.500 1.00 ug/L 58 137 20 Xylenes, Total 1330-20-7 10,000 2.00 0.230 0.500 ug/L 79 121 20 1,2-Dichloroethane-d4 (Surr) 17060-07-0 81 118

Laboratory Specific Laboratory Control Limits

Method Analyte Description

CAS

Number

Cleanup Goals

(ug/L)1 LOQ MDL LOD Units %R Low

%R High

RPD

4-Bromofluorobenzene (Surr) 460-00-4 85 114 Dibromofluoromethane (Surr) 1868-53-7 80 119 Toluene-d8 (Surr) 2037-26-5 89 112

RSK_175 Ethane 74-84-0 1.10 0.550 1.10 ug/L 75 125 30 Dissolved Gases Ethylene 74-85-1 1.00 0.500 1.00 ug/L 75 125 30 Methane 74-82-8 0.580 0.290 0.580 ug/L 75 125 30 Methane (TCD) 74-82-8 390 39.0 77.0 ug/L 75 125 30

8081B_D5 4,4'-DDD 72-54-8 0.20 0.0500 0.00630 0.0130 ug/L 56 143 30 Pesticides 4,4'-DDE 72-55-9 0.05…