[·n:] TETRA TECH

August 15, 2012

Roy Crossland START Project Officer U.S. EPA-TLC 8600 NE Underground Drive, Pillar 253 Kansas City, Missouri 64161

Subject: Addendum No.2 to the Quality Assurance Project Plan Highway 3 PCE Site, Le Mars, Plymouth County, U.S. EPA Region 7 START, Contract No. EP-S7-06-0l, Task Order No. 0292 Task Monitor: Susan Fisher, EPA On-Scene Coordinator

Dear Mr. Crossland:

Tetra Teen EM Inc. is submitting the attached addendum to the Quality Assurance Project Plan for the Highway 3 PCE Site in Le Mars, Iowa. If you have any questions or comments, please contact the project manager at (816) 412-1 7 41.

~Ted Faile, PG, CHMM START Program Manager

Enclosure

Tetra Tech EM Inc. 4 15 Oak Street. Kansas City. MO 641 06 Tel 816.412.1741 Fax 816.410. 1748 www.tetratech.com X9004. 11.0292.000 ADDENDUM NO.2 TO THE QAPP Highway 3 PCE Site Le Mars, Plymouth County, Iowa Task Order No. 0292

This document will serve as an addendum to the Quality Assurance Project Plan (QAPP) dated June I 0, 2011, for the Highway 3 PCE Site in Le Mars, Iowa; Attachment I includes the June 2011 QAPP, subsequent addendum to the QAPP from October 2011, and the Environmental Protection Agency (EPA) approval memorandum. Additional investigation activities at this site under Task Order 0292 were deemed necessary to assess potential contamination outside of the dry cleaning building located near the southeast corner of the intersection of Highway 3 and Central A venue. The additional field activities are based upon tetrachloroethylene (PCE) and other volatile organic compounds (VOCs) results obtained from the Phase I and II sampling events conducted during 2011. The Tetra Tech EM Inc. (Tetra Tech) Superfund Technical Assessment and Response Team (START) will undertake sampling activities during the week of September I 0, 2012. The original QAPP submitted by Tetra Tech START under Task Order 0228 remains the primary guidance document for this activity; however, modifications to the original QAPP are necessary, as described below.

SAMPLING STRATEGY AND METHODOLOGY

Under this task order, START will conduct sampling of indoor air, sub-slab soil gas, and subsurface soil to assess the presence ofPCE and other VOCs that may present a threat to human health. The proposed sampling scheme for this project includes approximately 5 indoor air, 5 sub-slab soil gas, and 20 subsurface soil samples. Procedures for collecting the sub-slab soil gas and subsurface soil samples are outlined in the original QAPP submitted by Tetra Tech START under Task Order 0228. Indoor air sampling procedures will follow guidelines established in EPA Standard Operating Procedures (SOP) presented below in this QAPP Addendum.

Indoor Air Sampling

Five indoor air sampling locations will be selected in buildings adjacent to the dry cleaning building located near the southeast corner of the intersection of Highway 3 and Central A venue. At each location, a Summa canister will be fitted with a passive flow regulator to enable collection of an air sample for a continuous 24-hour period. All Summa sampling will be conducted in accordance with EPA Emergency Response Team SOP 4231.1704- Summa Canister Sampling, and EPA Region 7 SOP 2313.04- Air Sampling with Stainless Steel Canister. Pertinent data, including analyses to be performed and exact sample locations, will be recorded on field sheets for each sample.

X9004.11.0292.000 Prior to indoor air sampling, START will contact all owners and/or tenants of proposed indoor air sampling locations and request that any stored chemical materials and fuels that may contribute VOCs to indoor air be either :;ealed in plastic bags or removed from the premises several days prior to sampli ng to minimize introduction ofVOCs from other sources (i.e., other than from a subsurface source). A building survey form will be completed at each structure where sampling is to take place to document any cond itions that may affect indoor air sampling results.

J=- I 5- /t... Ted Faile, PG, CHMM, START Program Manager Date 2 -!5-/2- Kathleen Homer, START Quality Assurance Manager Date

Susan Fisher, EPA Region 7 Project Manager Date

Diane Harris, EPA Region 7 Quality Assurance Coordinator Date

X9004.11 .0292.000 ATTACHMENT 1

X9004.11.0292.000 (.. it:] TETRA TECH

June 10, 2011

Mr. Roy Crossland START Project Officer U.S. Envirorunental Protection Agency, Region 7 901 North slh Street Kansas City, Kansas 66101

Subject: Quality Assurance Project Plan Highway 3 PCE Site, Le Mars, Plymouth County, Iowa U.S. EPA Region 7 START 3, Contract No. EP-S7-06-0l, Task Order No. 0228 Task Monitor: Todd Davis, Targeted Brownfields Assessment Coordinator

Dear Mr. Crossland:

Tetra Tech EM Inc. is submitting the attached Quality Assurance Project Plan (QAPP) for a Preliminary Assessment at the Highway 3 PCE Site in Le Mars, Iowa. If you have any questions or comments, please contact the project manager at (816) 412-1751.

Sincerely, {)JtJ~ H~~ Scroggin ,. START Project Manager ~~ Ted Faile, PG, CHMM START Program Manager

Enclosures

Tetra Tech E:.lvl Inc. 415 Oak Street Kansas City. MD 64106 Tel 816.4121741 Fa:-: 816.410.1748 WW¥1.tetratech.com X9004.11.0228.000 QUALITY ASSURANCE PROJECT PLAN FOR A PRELIMINARY ASSESSMENT AT THE HIGHWAY 3 PCE SITE LE MARS, IOWA

Superfund Technical Assessment and Response Team (START) Contract No. EP-S?-06-01, Task Order 0228

Prepared For:

U.S. Environmental Protection Agency Region 7 Superfund Division 901 N. 5"' Street Kansas City, Kansas 6610 I

June 10, 20 II

Prepared By:

Tetra Tech EM Inc. 415 Oak Street Kansas City, Missomi 64106 (816) 412-1741 CONTENTS

Section/Table Page

QUALITY ASSURANCE PROJECT PLAN FORM ...... 1

TABLE I: SAMPLE SUMMARY ...... 5

TABLE2: DATA QUALITY OBJECTIVE SUMMARY ...... 6

APPENDICES

Appendix

A SITE-SPECIFIC INFORMATION FOR THE HIGHWAY 3 PCE SITE

B FIGURES

C GUIDELINES FOR INSTALLATION AND RETRIEVAL OF PASSIVE SOIL GAS MODULES

X9004.!1.0228.000 Region 7 Superfund Program Addendum to the Generic QAPP for the Superfund Site Assessment and Targeted Brownficlds Assessment Programs (July 2007) for the Highway 3 PCE Site, Le Mats Iowa .. ··- . ; .:; ;., :·:~ '.'; ._, •.. ' -·~. ' _;_--;· C• ·· ... ,· ·:. .. ,.. -:.· · -':· ·:···.Pro'CCUrifoirilntion:·•·:: ,:. ·:· •'· ·.. ·. Project Name: Highwar.l PCE Site City: Le Mars !State: Iowa EPA Project Mana er: T~ddD~vis START Project M:mneer: Tom Scro~t?;in Approved By: 'lv

18] Description attached. D Description in referenced report: Title Date

1.4 Projectffnslt Description: 18] CERCLAPA D CERCLASI D Brownfields Assessment D Removal Action D Other (description attached): D Pre-CERCLIS Screening D Reffioval Site Evaluation Other Description:

Schedule: Field work _is scheduled to be conducted in July 2011. · D Description in referenced report: Title Date 1.5 Quality Objectives and Criteria for Measurcritcnt Data: a. Accuracy: 181 Identified in attached table. b, Precision: J 18] Identified in attached table. c. Representativeness: 181 Identified in attached table. d, Completeness*: 18] Identified in attached table. e, COlllP!!fabiliLy: 181 Identified in attached table. Other Description:

*A completeness goal of 100 percent has been established for this project. However, if the completeness goal is not met, EPA may still be able to make decisions based on any or all of the remaining validated data. No "critical samples" have been identified for this project. 1.6 Special Training/Certification Re-quirements: 18] OSHA 1910 18] Special Equipment!Instrument Operator (describe below): D Other (describe below): START field personnel will be experienced in passive soil gas, active soil gas; and direct-push technology groundwater sampling . . 1.7 Documentation and Records: 18] Field Sheets 18] Daily Log 181 Trip Report 18] Area Maps D Video 18] Chain of Custody 18] Health and Safety.Plan D Letter Report 18] Photos 18] Sample documentation will follow EPA Region 7 SOP 2420.05. 18] Other: Analytical information will be handled according to procedures identified in Table 2.

X9004, I 1.0228.000 1 Region 7 Superfund P.-ogram Addendum to the Generic QAPP for the Superfund Site Assessment and Targeted Brownfields Assessment Programs (July 2007) for the Highway 3 PCE Site, Le Mars, Iowa 2.0 Measurement and Data Acquisition: 2.1 Sampling Process Design: D Random Sampling D Transect Sampling [8] Biased/Judgmental Sampling D Stratified Random Sampling D Search Sampling [8] Systematic Grid D Systematic Random Sampling !8:1 Definitive Sampling D Screening wo/ Definitive Confirmation D Screening w/ Definitive Confirmation D Sample Map Attached !8:1 Other (Provide rationale behind each sample): See Appendix A for additional sampling information.

The proposed sampling scheme will be judgmental with definitive laboratory analysis, in accordance with the Guidance f or Peiforming Site InspecJions Under CERCLA, OSWER Directive #9345.1-05, September 1992. Judgmental sampling is the subjective (biased) selection of sampling locations based on historical information, visual inspection, and the best professional judgment of the sampler(s). See Appendices A and B for additional site-specific infonnation and site maps.

The proposed number of samples is a balance between cost and coverage, and represents a reasonable attempt to meet the study objectives while staying within the budget constraints of a typical Preliminary Assessment of this type.

Sample Summary Location Matrix #of Samples* Analvsis Suspected source areas Soil gas 38 PCE Suspected source areas and affected buildings Sub-slab Soil gas Uoto6 VOCs Downgradient PCE plume Groundwater Upto20 VOCs *NOTE: Number is approximate and may change depending on site conditions and access. QC samples are not included with these totals. See Table I for a complete sample summary. 2.2 Sample Methods Requirements:

Matrix Sampling Method EPA Region 7 SOPfs) or other Method Soil gas samples will be collected using passive soil gas modules. These modules will Guidelines for Installation and Retrieval be lowered approximately 3 feet (ft.) below ground surface (bgs) into pre-drilled holes Passive Soil Gas of Passive Soil Gas Modules as part of a grid system in the soil near suspected source areas. After a period of (Appendix C) I 0-14 days, the modules will be collected for laboratory analysis. Sub-slab soil gas samples will be collected via disposable polyethylene tubing lowered through a drill hole in the foundation. Evacuated stainless steel Summa* canisters will Active Sub-slab Soil Gas Draft EPA SOP for Sub-Slab Sampling be used to collect soil gas samples for analysis for VOCs. Calibrated flow regulators will allow the canisters to fill over a 24-hour period. Groundwater samples will be collected downgradient of the potential source areas, Groundwater from both the alluvial aquifer and Buried Channel aquifer, in order to further delineate EPA SOP 4230.07 & 3230.13 the oeographical extent of the documented PCE plume. D Other Description: 2.3 Sample Ha ndling and Custody Requirements: [8] Samples will be packaged and preserved in accordance with procedures defined in Region 7 EPA SOP 2420.06. [8] COC will be maintained as directed by Region 7 EPA SOP 2420.04. D Samples submitted to the EPA Region 7 laboratory will be accepted according to Region 7 EPA SOP 2420.01 . [8] Other (Describe): Samples submitted to START-contracted laboratories will be accepted according to procedures established by the laboratories.

2.4 Analytical Methods Requirements: [8] Identified in attached table. [8] Rationale: The requested analyses have been selected based on historical information about the area and program experience with similar types of sites. 0 Other (Describe):

2.5 Quality Control Requirements: D Not Applicable [8] Identified in attached table. [8] In accordance with the Generic Quality Assurance Project Plan for the Superfund Site Assessment and Targeted Brown fields Assessment Programs (updated July 2007). 181 Field QC Samples: For this investigation, field QC samples will.include three media blanks for soil gas, one Summa canister field blank for sub-slab soil gas samples, one water trip blank, one water field blank, and one water rinsate blank. The media blanks will be used to assess any VOC contamination in the sample collection media. The water trip blank will be used to assess presence of transportation-introduced contamination, while the water field blank will be used to assess contamination introduced during field sampling activities. The rinsate blank will be used to assess cross­ contamination introduced from sampling equipment. Evaluation of blank samples depends on the levels of contamination found in environmental samples to determine whether environmental samples are representative. D Other (Describe):

X9004.11.0228.000 2 Region 7 Superfund Program Addendum to the Generic QAPP for the Superfund Site Assessment and Targeted Brownfields Assessment Programs (July 2007) for the Hi2hway 3 PCE Site, Le Mars, Iowa 2.6 Instrument/Eq uipment Testing, Inspection, and Maintenance Requirements: D Not Applicable 1:8] In accordance with the Generic Quality Assurance Project Plan for the Superfund Site Assessment and Targeted Brownfields Assessment Programs (updated July 2007). 1:8] Testing, inspection, and maintenance of analytical instrumentation will proceed in accordance with the previously referenced SOPs and/or manufacturers' recommendations. Testing, inspection, and maintenance of field instruments will proceed in accordance with manufacturers' recommendations.

2.7 Instrument Calibration and Frequency: D Not Applicable 1:8] In accordance with the Generic Quality Assurance Project Plan for the Superfund Site Assessment and Targeted Brownfields Assessment Programs (updated July 2007). 1:8] Calibration of laboratory and field equipment will be performed as described in the previously referenced SOPs and/or manufacturers' recommendations. D Other (Describe):

2.8 Inspection/Acceptance Requir-ements for Supplies and Consumables: D Not Applicable 1:8] In accordance with the Generic Quality Assurance Project Plan for the Superfund Site Assessment and Targeted Brownfields Assessment Programs (updated July 2007). 1:8] All sample containers will meet EPA criteria for cleaning procedures for low-level chemical analysis. Sample containers wilt have Level II certifications provided by the manufacturer in accordance with pre-cleaning criteria established by EPA in Specifications and Guidelines for Obtaining Contaminant-Free Containers. D Other (Describe):

2.9 Data Acquisition Requirements: D Not Applicable 1:8] In accordance with the Generic Quality Assurance Project Plan for Superfund Integrated Assessment and Targeted Brownfields Assessment Program (updated July 2007). 1:8] Data or information obtained previously that pertains to the area (including other analytical data, reports, photos, maps, etc., that are referenced in this QAPP) has been compiled by EPA and/or its contractor(s) from other sources. Some of that data have not been verified by EPA and/or its contractor(s); however, that unverified infonnation will not be used for decision-making purposes by EPA without verification by an independent professional qualified to verify such data or infonnation. D Other (Describe):

2.10 Data Management: D All EPA Region 7laboratory data acquired will be managed in accordance with Region 7 EPA SOP 2410.01. 1:8] Other (Describe): All data acquired by the START-contracted laboratories will be managed in accordance with procedures established by the laboratories.

3.0 Assessment and Oversil! ht: 3.1 Assessment and Response Actions: 1:8] Peer Review 1:8] Management Review D Field Audit D Lab Audit D Assessment and response actions pertaining to analytical phases of the project are addressed in Region 7 EPA SOPs 2430.06 and 2430.12. 1:8] Other (Describe): Assessment and response actions pertaining to analytical phases of the project will be addressed in accordance with procedures established by the START-contracted laboratories.

3.1A Corrective Action:

1:8] Corrective actions will be at the discretion of the EPA project manager whenever problems appear that could adversely affect data quality and/or resulting decisions affecting future response actions pertaining to the area. D Other (Describe):

3.2 Reports to Management: D Audit Report 1:8] Data Validation Report D Project Status Report D None Required

1:8] A trip report describing the sampling techniques, locations, problems encountered (with resolutions to those problems), and summary of analytical results will be prepared by START and submitted to the EPA. 1:8] Reports will be prepared in accordance with the Generic Quality Assurance Project Plan for the Superfund Site Assessment and Targeted Brown fields Assessment Programs (updated July 2007). D Other (Describe):

X9004. I I .0228.000 3 Region 7 Superfund Program Addendum to the Generic QAPP for the Superfund Site Assessment and Targeted Brownfields Assessment Programs (July 2007) for the Highway 3 ·peE Site, Le Mars, Iowa 4.0 Data Validation and Usability: 4.1 Data Review, Validation, and Verification Requirements: 0 Identified in attached table. [8] Data review and verification will be perfonned in accordance with the Generic Quality Assurance Project Plan for the Superfund Site Assessment and Targeted Brownfields Assessment Programs (updated July 2007). [8] Review and verification of data generated by the EPA Region 7 laboratory will be perfonned by a qualified analyst and the laboratory's section manager as described in Region 7 EPA SOPs 2430.06, 2430.12, and 2410.10. [8] Other (Describe): Review and verification of data generated by START-contracted laboratories will be perfonned by a qualified START chemist.

4.2 Validation and Verification Methods: 0 Identified in attached table. [8] The data generated by the EPA Region ?laboratory will be validated in accordance with Region 7 EPA SOPs 2430.06, 2430. 12, and 2410.10. [8] The EPA project manager will inspect the data to provide a final review. The EPA project manager will review the data, if applicable, for laboratory spikes and duplicates, laboratory blanks, and field blanks and duplicates to ensure the data are acceptable. The EPA project manager will also compare the sample descriptions with the field sheets for consistency, and will ensure appropriate documentation of any anomalies in the data. [8] Other (Describe): Data generated by START-contracted laboratories will be validated by qualified START personnel.

4.3 Reconciliation with User· Requirements: 0 Identified in attached table. [8] If data quality indicators do not meet the project's requirements as outlined in this QAPP, the data may be discarded andre-sampling or re-analysis of the subject samples may be required by the EPA project manager. 0 Other (Describe):

X9004.11.0228.000 4 Region 7 Superfund Program Addendum to the Generic QAPP for the Supe•fund Site Assessment and Targeted Brownfields Assessment Programs (July 2007) for the Hie:hwav 3 PCE Site in Le Mars, Iowa Table 1: Sample Summary Project Name: Highway 3 PCE Site Location: Le Mars, Iowa; See Appendix B, Figure I START Project Manager: Tom Scroggin Activity/ASR #: NA Date: June 2011 No. of Depth or other Requested Sampling Matrix Location Purpose Analytical Method Samples Descriptor Analvsis Methods To assess contamination in soil Passive Suspected Source Near suspected See 38 gas vapors that could intrude PCE Modified Method 8260 Areas source areas Appendix C Soil Gas into the overl ying structures To assess contamination in Draft EPA Active Beneath bui !dings sub-slab soil gas vapors that SOP for 6 Sub-slab affected by PCE Below slab VOCs T0-15 could intrude into the overlying Sub-Slab Soil Gas plumes structures Sampling To assess contamination in In areas Between the vadose groundwater downgradient of downgradient of zone and underlying 4230.07, 20 Water the suspect source areas, and VOCs EPA Method 3230.13 the suspected aquitard of the two 4230.15 further delineate the extent of source areas aquifers in question the groundwater plume QC Samples Passive To assess PCE contamination in 3 Soil Gas Media blank N/A PCE N/A Modified Method 8260 sample collection media Module Active To assess VOC contamination I Sub-Slab Field Blank potentially introduced during Ambient air VOCs NA T0-15 Soil Gas preliminary assessment To assess PCE contamination I Water Trip Blank NA VOCs NA 3230.13 from transportation of samples To assess PCE cross- contamination from direct-push I Water Rinsate Blank NA VOCs NA 3230.13 technology (DPT) sampling equipment To assess PCE contamination I Water Field Blank potentially introduced during NA VOCs NA 3230.13 preliminary assessment

X9004.11.0228.000 5 Region 7 Superfund Progt·am Addendum to the Genet·ic QAPP for the Superfund Site Assessment and Tat-geted Brownfields Assessment Pt·ograms (July 2007) for the Highway 3 PCE Site in Le Mars, Iowa Table 2: Data Quality Objective Summary Project Name: Highway 3 PCE Site Location: Le Mars, Iowa; See Appendix B, Figure I START Project Mana er: Torn Scroggin I Activity/ASR #: NA Date: June 201 1 Data Quality Measurements Sample Data Analytical Analysis Handling Manage-ment Method Accuracy Precision Representativeness Completeness Comparability Procedures Procedures SOIL GAS Judgmental sampling, Standardized Per Per I 00%; no critical See Section See Section based on professional procedures for sample VOCs See Table l analytical analytical samples have 2.3 ofQAPP 2. 10ofQAPP judgment of the sampling collection and method method been defined form. form. team analysis will be used. WATER Judgmental sampling, Standardized Per Per 100%; no critical See Section See Section based on professional procedures for sample VOCs See Table l analytical analytical samples have 2.3 of the 2.10 of the judgment of the sampling collection and method method been identified QAPPform. QAPPfonn. team analy_sis will be used.

X9004. 11 .0228.000 6 APPENDIX A

SITE-SPECIFIC INFORMATION FOR THE HIGHWAY 3 PCE SITE LE MARS, PLYMOUTH COUNTY, IOWA INTRODUCTION

The Tetra Tech EM Inc. (Tetra Tech) Superfund Technical Assessment and Response Team (START) has been tasked by the U.S. Enviromnental Protection Agency (EPA) Region 7 Superfund Division to conduct a Preliminary Assessment (PA) at the Highway 3 PCE Site in Le Mars, Plymouth County, Iowa (see Appendix B, Figure 1). This PAis being conducted to assess contamination in soil gas and groundwater that may originate fi·om a subsurface source.

This quality assurance project plan (QAPP) identifies site-specific features and addresses elements of the sampling strategy and analytical methods proposed for this PA. An assessment of the data acquired will determine if additional Superfund response is warranted.

SITE DESCRIPTION

The site involves a plume of tetrachloroethene (PCE) first detected during an April 2008 Le Mars Coal Gas Plant site investigation. Two subsequent direct-push technology (DPT) groundwater sampling campaigns were completed to assist in a Pre-Comprehensive Enviromnental Response, Compensation, and Liability Information System (CERCUS) investigation to define the extent of the PCE plume, and trace back the migration pathway to potential source areas. Five source areas were identified during the Pre-CERCUS investigation: a fonner dry cleaning operation, an active dty cleaning operation, two machine shops, and the Chicago St. Paul & Omaha Railroad, which passes through a potential source area at the site. The site and its potential source areas are confined by Plymouth Street () to tbe nortb, Central Street to the west, and Lincoln Street Southeast (SE), which passes diagonally from the southwest at Central Street to the northeast at Plymouth Street. The approximate coordinates for the center of the site are 42.792604 degrees north latitude and 93.166066 degrees west longitude.

The PCE plume was detected primarily in the upper portion of the alluvial aquifer from 25 to 29 feet below ground surface (bgs), which is underlain by a glacial till aquitard, the Buried Channel aquifer, and subsequently the Dakota Fotmation aquifer (HydroGeoLogic, Inc. [HGL] 2009). The plume likely originates within the above-referenced site boundaries (study area), although as noted in the HGL repott, multiple PCE sources could be contributing to groundwater contamination. From the study area, the plume travels toward the northeast in the alluvial aquifer at concentrations ranging ii"om 9. I to 370 micrograms per liter (J.lg/L). PCE was also detected at three different times in one monitoring well within the Buried Channel aquifer during the long-term monitoring of the Le Mars Coal Gas Plant,

X9004.!1.0228.000 indicating possible migration between the alluvial aquifer, which flows notthwest, and the Buried Channel aquifer below, which flows southeast (HGL 2009).

One intent of this PAis to identify to which of the above-referenced potential source areas, if any, the PCE plume is attributable by use of Gore-Sorber (or similar) passive soil gas sampling media. Other intents of the assessment are to undettake sub-slab vapor intrusion analysis of affected buildings overlying the PCE plume, to assess health risks to employees who work in these buildings, and to better defme the extent of the PCE plume via groundwater sampling using DPT.

SAMPLING STRATEGY AND METHODOLOGy

Under the approach to this project involving phased investigation, START will conduct sampling of soil gas adjacent to and downgt·adient of potential source areas to assess the presence ofPCE dw·ing Phase I. This will include passive soil gas sampling surrounding buildings within possible source areas of the PCE plume. The proposed sampling scheme for this project is judgmental (based on the best professional judgment of the sampling team), in accordance with the Guidance for Pelforming Site Inspections Under CERCLA, Office of Solid Waste and Emergency Response (OSWER) Directive #9345.1-05, September 1992. Soil gas sampling locations will be selected based on area of influence (AOI) of the soil gas sampling media, access to public right-of-ways and private parking lots, and access to buildings overlying the PCE plume. Proposed passive soil gas sampling locations are shown on Figure 2 of Appendix B.

Phase II ofthe sampling campaign will include active, sub-slab, Summa"' canister soil gas sampling within buildings (identified during the Phase I sampling) where soil gases from the tmderlying PCE plume may be migrating into ambient air. DPT groundwater samples will also be collected to better defme the migration pathway of the PCE plume and to delineate its hydrogeological extent. Phase II of the sampling will occur after START receives and assesses results from the Phase I sampling.

Sampling and analytical procedures will follow standard operating procedures (SOP) outlined in the QAPP, and will involve collection of the following samples: (I) soil gas vapors from locations near suspected source areas, (2) sub-slab soil gas vapors from beneath buildings overlying the PCE plume, and (3) groundwater samples downgt·adient of source areas collected using DPT. Sample locations for Phase I sampling are illustrated on Figure 2. Selection of sub-slab active soil gas sampling locations will be based on data obtained during Phase I of the investigation, and therefore these locations are not included on the attached figures. DPT groundwater sampling locations are shown on Figure 3 of Appendix B. Pertinent data will be recorded in a logbook and with photo documentation. Descriptions of the sampling strategy and procedures to be implemented are presented below.

X9004.11.0228.000 2 Passive Soil Gas Sampling (Phase I)-A sampling grid with 50- by 50-foot cells will be established in the public right-of-ways struting at the intersection of Plymouth Street and Central Street. Spacing between nodes on opposing sides of Plymouth Street and Central Street will be placed at 80-foot intervals to avoid placing passive soil gas samples within the street. The nodes will be placed on sidewalks and parking areas sunounding the buildings located within the study area. At each node of the grid (38 locations), a soil gas sample will be colJected using a passive soil gas module (module). These sampling grid sizes were chosen based on existing site data, anticipated aerial extent of site contaminants in the vapor phase, and the AOI of the soil gas modules.

A 0.5- to l-inch-diameter hole will be drilled with use of an electric rotmy hammer-drill at each node location to a depth of approximately 3 feet bgs. A module will then be secured to a string or cord, attached to an impenneable cork, and lowered into the hole using a stainless steel insertion rod. The cork will be tamped flush with the surface to seal the hole at locations that are not under concrete or asphalt parking areas. For locations that are under concrete or asphalt parking areas, the cork will be placed below any filJ material (sand and gravel) that may be encountered immediately under the concrete or asphalt. In addition, a temporruy concrete or bentonite patch will be placed over each location at a parking area or sidewalk. FolJowing the module exposure period of 10-14 days, the module will be removed from the hole and sent to the lab for analysis. Pettinent data, including analyses to be perfo!T11ed and exact sample locations, wilJ be recorded on field sheets for each sample.

Sub-Slab Soil Gas Sampling (Phase 11)-Up to six active sub-slab soil gas sampling locations will be selected inside various buildings that may be potential source areas for PCE, or that may be affected by vapor intrusion. At each of these locations, snb-slab smnples will be colJected by penetrating the concrete floor in the basement or other accessible portion of the foundation with a rotary hammer drill and concrete bit. Disposable 0.25-inch-diameter polyethylene tubing will be lowered tlU"ough the drill hole into the sub-slab material, and then the tubing mmulus will be sealed with cement grout. A Swaglok® fitting will be attached to the top of the tubing to alJow its connection to an evacuated Summa canister for srunpling. The Summa canister will be fitted with a flow regulator to enable colJection of sub-slab vapor samples over a continuous 24-hour period. Sub-slab vapor sampling will be conducted in accordance with procedures in the draft SOP for lnstalJation of Sub-Slab Vapor Probes and Sampling Using EPA Method T0-15 to Suppott Vapoi·Intmsion Investigations. Selection of sub-slab soil gas sampling locations will be based on data obtained during Phase I of the investigation.

X9004. I 1.0228.000 3 Groundwater Sampling (Phase H)-Groundwater samples will be collected from up to 10 temporary monitoring well locations, possibly fi·om two depths at each location. Samples will be collected through polyethylene tubing connected to a peristaltic pump or check valve. Purge water will be disposed of on the ground surface. As each well is purged, field parameters will be monitored continuously using a water quality instrument. A water sample will be collected after all field parameters have stabilized, ensuring the sample is representative of aquifer conditions. Samples will be analyzed by the onsite HAPSITE laboratory for volatile organic compounds (VOC). Some samples will also be collected in four 40-milliliter (mL) volatile organic analysis (VOA) vials preserved with hydrochloric acid to a pH <2, and then sent to EPA Region 7 laboratory for defmitive VOC analysis. Selection of groundwater sampling locations will be determined based on data obtained during Phase I of the investigation.

QUALITY CONTROL

To evaluate sample quality control (QC), three module media blanks, one Summa canister field blank, one water trip blank, one water field blank, and one equipment rinsate blank will be collected as specified in Section 2.5 of the QAPP form.

Investigation-derived waste (IDW) consisting primarily of used tubing, etc., will be disposed of as uncontaminated solid waste. Issues pertaining to decontamination of personnel and sampling equipment will be addressed in a site-specific Health and Safety Plan (HASP) to be developed by START.

ANALYTICAL METHODS

For this Preliminary Assessment, all passive soil gas modules and active sub-slab soil gas using Swnma canisters will be analyzed by a START-contracted laboratory. All water samples will be analyzed by the on-site HAPSITE mobile laboratory for VOCs, and up to 20 groundwater samples will be submitted to EPA Region ?laboratory for definitive VOC analysis by EPA SW-846 Method 8260. All samples will be analyzed according to SOPs and methods referenced on the QAPP form, with standard turnaround times requested. Appropriate containers and physical/chemical preservation techniques will be employed during the field activities to help verifY that representative analytical results are obtained.

X9004.11.0228.000 4 REFERENCES

HydroGeoLogic, Inc., (HGL). (2010). Pre-CERCUS Assessment Repmt, Highway 3 PCE Site, Le Mars, Iowa. May 14.

X9004.11.0228.000 5 APPENDIXB

FIGURES Highway 3 PCE Site N Le Mars, Iowa A Figure 1 0 1,000 2,000 Site Location Map

Feet 1-wt:ITETRA TECH EM INC.

Source: USGS Le Quad, 1985 Legend e Gore-sorber sample location N State highway Figure 2 A Gore-sorber Sample Loca tion Map Street 0 75 150 M Tetrachloroethene (PCE) plume ~- Feet TECH EM INC. Legend Highway 3 PCE Site N Le Mars, Iowa e Previous groundwater sampe location II& Tetrachlorocthene (PC E) plume ppb Parts per billion e Proposed groundwater sample location bgs Below ground surface A Figure 3 State highway Feet 0 7S 150 Groundwater Sample Location Map Street NO Non-detected result ~- Fcot ~TETRA TECH EM INC. APPENDIXC

GUIDELINES FOR INSTALLATION AND RETRIEVAL OF PASSIVE SOIL GAS MODULES GORE™ SURVEYS ENVIRONMENTAL SIT E ASSESSMENT

FOCUSING YOUR REMEDIATION EFFORTS.

Soil Gas & Sub-slab Soil Gas Sampling Storage, Installation and Retrieval Guidelines

NOTE: If you have any questions regarding installation and retrieval, please call: Jay Hodny, Jim Whetzel or Hilary Tretheway (41 0) 392-7600 GENERAL

Always obtain utility clearance before any subsurface sampling.

Soil Gas & Sub-slab Soil Gas For soi l gas sa mpling, the GORE™ Modules can be placed on the surface under a cover or installed to any depth, in uncased or cased holes, and can include vertical profiling. The installation hole is sealed effectively against air infiltration with natural cork which is impermeable to gases and liquids. The prescribed practice is to place the passive sampler (i.e., the adsorbent) at the desired sampling depth. Generally, for soi l gas sampling, depths of three feet or more are favored to minimize the effects of surface and near-surface variables (e.g., soil temperature, barometric pressure, air pollution, natural organic content) on the soil gas signal of interest.

Similarly, subslab soil gas can be co llected by placing the module at the slab/ so il interface, at depth beneath the slab, or both, in permanent or temporary insta llation holes. The installation hole is advanced through the slab, and sealed with the cork after module insertion. Alternatively, exterior subslab sampling can be achieved by ad vancing the installation hole at an angle to reach beneath the slab from the outside of the structure.

For soi l gas and subslab soil gas sampling, the installation is flush with the surface with no sampling equipment remaining on the surface. Site activities (e.g., dry cleaner, refinery, aircraft runway opera tions, etc.) can continue uninterrupted.

Site activities which may disturb the natural soil gas migration should not be conducted during the time when the GORE™ Modules are in the subsurface. Such activities include, but are not limited to, installation/ operation of soil vapor extraction systems, drilling (e.g., air-rotary), excavation, air sparging, etc.

The following items are provided by Gore: • ' , cardboard shipping container(s), partitioned box(es) containing individually numbered GORE™ Modules- (DO NOT DI SCARD SHIPPING CONTAINER OR PARTITIONED BOXES), • insertion rod (please return after use; bundle sections together with a rubberband do not use tape) , • corks with screw eyes, • string, • Chain of Custody and Installation/Retrieva l Log • custody sea Is • these instructions.

STORAGE GORE™ Modules are carefully cleaned, sealed, and stored after manufacturing. They must remain sealed in their vials in the shipping boxes until deployment and after retrieva l. DO NOT store near potential sources of organic vapors such as petroleum fuels and exhaust. solvents, adhesives, paints, etc.

REQUIRED TOOLS/ SUPPLIES A narrow diameter hole (approximately 1/2 to 1-inch; 2.5cm) is drilled or driven to the desired sampling depth. Simple hand tools such as a slam bar or rotary hammer drill are used to create the installation hole in soi l. A hammer drill or similar coring tool is required to advance the hole through a slab. Direct-push or auger-type tools are usually needed for deeper insta llations.

1 of 4 Additional tools (to be supplied by the customer) required for installation may include: • equipment to lay out and mark sample locations (scaled map. measuring tapes, pin flags, GPS unit); • disposable gloves and equipment decontamination supplies • slide hammer/tile probe (slam bar) or electric rotary hammer drill (AC power outlet or portable generator and extension cords) with carbide-tipped bits or augers (1/2 to 1-inch; 2. 5cm diameter, three feet; 1 meter or more, in length). • Optional: concrete patching material

If sample locations need to be hidden to prevent damage/loss by vandalism or animals, push the cork farther into the hole, place a metal washer or nut on top of the cork, and cover with soil and sod. Use a metal detector to locate modules for retrieval.

Natural cork is impermeable to gases and liquids, providing an effective seal against infiltration of ambient air. For additional security, a thin layer of concrete patching material can be applied over the cork.

The following vendors supply installation hole drilling equipment. The information is provided as a courtesy anddoes not represent any en d orsement o f t h ese pro d ucts or supp1I'1ers: Item Supplier Phone No. * Slide Hammer/Tile Probes Forestry Supplies (800) 64 7-5368 * Carbide Drill Bits (36" long) 1. Kerfoot Technologies. Inc. 1. (508) 539-3002 2. the Blade Runner 2. (610) 444-6708 * Rotary Hammer Drill SKILL-BOSCH Power Tools (800) 334-5730 *Art's Manufacturing Supply (dba AMS) has all these items (800) 635-7330

TRIP BLANKS An additiona I number (specified) of GORE™ Modules are included as trip blanks. The customer selects which modules to be used/treated as trip blanks, and notes this on the Chain of Custody and Installation/Retrieval Log. These modules remain unopened, travel to and from the site during installation and retrieval, while in storage away from Gore's facility, and in transit to/from Gore's facility.

MODULE INSTALLATION • The sample grid can be laid out beforehand (recommended) or during the module installation. Do not use spray paint or similar materials to mark locations, or drill through locations marked with spray paint. • To facilitate the installation of the modules, it is recommended that the string and corks be prepared prior to going to the field. As an example, for a three foot installation, cut a piece of the supplied string to a length of approximately 7.0 feet or 2.25 meters. Tie the ends of the string together using a non-slip knot (square knot is suggested, Figure 1 ). Pass the looped string through the eyelet in the cork and pull it back through itself. Wrap the remainder of the string around the cork and secure the string/cork combination with a rubber band. The cork and cord are now ready to attach to the module after the installation hole is created. Square knot instructions (Figure 1) 7. Take an end ofthe string in each hand. 2. Pass the left-hand string over the right-hand string and wrap it around the right-hand string. 3. Take the string end that is now in your right hand, place it over the string end in your left hand and wrap it around that string. 4. Pull the string carefully to tighten the knot. Figure 1 . Square Knot

2 of 4 • We do not recommend installation of modules within 15 feet (5 meters) of monitoring wells, utility trenches or other conduits, unless that is the sampling objective. These features may act as preferential pathways for soil vapor migration. The results may not be representative of the subsurface contamination. • Drive/drill the narrow installation hole at the desired pre-marked location. In sandy soils, occasionally the hole w ill collapse after the drill or tile probe is removed. Adding deionized water to the sandy soil will temporarily compact the soil and keep the hole open for module insertion. • Wearing clean surgical gloves, remove module from the numbered jar and re-seal the jar. The barcode on the jar lid should correspond with the serial number on the module- please verify. • Attach the string and cork to the module by passing the looped string through the loop on the module and pull the string/cork back through itself. • Place the insertion rod into the pre-cut pocket at the base of the module and lower the assembly into the hole. If you encounter resistance remove the module and ream the hole and re-insert the module. • Once deployed to the desired depth, press the insertion rod against the side of the hole and twist slightly to release the module. Remove the rod and push any excess cord into the hole and plug it with the cork. • Indicate the module number, date and time of installation and any pertinent comments on the installation/retrieval log. Write the module seria l number on the site map adjacent to the appropriate map location. • To minimize sample location errors, it is preferable to record the GORE™ Module serial number on the field map. However, if another sample numbering system is used, information relating the sample number system to the GORE™ Module serial numbers must be provided either on the Installation and Retrieval Log, or in a separate table. • Clean the tile probe or drill bit and the insertion rod prior to use at the next location. Replace the surg ical gloves as necessary. • Following module installation, the modules selected as trip blanks should be kept in the sample box provided and stored as described above in "STORAGE" until sampler retrieva l.

MODULE RETRIEVAL • Following the module exposure period identi fy and check each location in the field using the site map. • Remove the cork with a penknife, screwdriver or corkscrew. Grasp the cord and pu ll the modul e from the ground; verify the module ID number. Cut off and discard the cork and cord. Place the entire module into its labeled jar and secure the lid. • Use caution when screwing down the lid on the samplejars. Clean any soil/ debris from the threads ofthejar and lid, and make sure no part of the module is pinched between the jar and lid. Be sure the seal is t ight. Over-tightening may cause breakage. • Affix a custody seal to the side of the jar and jar lid. Do not cover the barcode with the seal. • Place thejar in the supplied partitioned box. • Complete the module retrieval date/time on the Installation/Retrieval log.

PACKAGING FOR RETURN • Place boxes with modules back into outer shipping container using appropriate packing materials to protect fragile contents. • Do not use Styrofoam "peanuts" as packing material. Bubble packing is acceptable. • Label box to indicate fragi le contents. • There is no need to return the shipment in coolers with ice. • Return the GORE'MModules , insertion rod and paperwork (preferably by overnight courier) to:

Screening Modules Laboratory W.L. Gore & Associates, Inc. 100 Chesapeake Blvd. Elkton, MD 21921 Phone: (410) 392-7600 Attn: NOTIFY LAB IMMEDIATELY UPON DELIVERY!!

IMPORTANT: Samples should not be shipped for weekend or holiday delivery.

3 of4 Soil Gas and Sub-slab Soil Gas Sampling

"

After insertion, impermeable cork sealed

Initial insertion Slide hammer Rotary hammer drill

c: .!!!.·~:~fi.!t: Note: Dry cleaner operations continue, no obstructions on surface after installation.

Rotary hammer drill

www.gore.com/surveys W. L. Gore & Associates, Inc. Sale Offices: 100 Chesapeake Blvd. Europe: +49·89-4612·2198 P.O. Box 10 San Francisco: 1-415·648·0438 !60Rttr" Elkton, MD 21922·0010 Creative Technologtes Worldwide Tel. 1-410392-7600 Email: [email protected] Fax. 1·410·506·4870

The optimal performance of any GOfe product Is dependent upon how it is incorporated in the final device Please contact one of our technical safes associates for application assistance. 4 of4 .. GORE and designs are trademarks of W. L. Gore & Associates 0 2009 W. L Gore & Associa tes, Inc. llfll7.11 092509 ['"it:] TETRA TECH

October 6, 2011

Mr. Roy Crossland START Project Officer U.S. Environmental Protection Agency, Region 7 901 North s'h Street Kansas City, Kansas 66101

Subject: Addendum to Quality Assurance Project Plan Highway 3 PCE Site, Le Mars, Plymouth County, Iowa U.S. EPA Region 7 START, Contract No. EP-S7-06-01, Task Order No. 0228 Task Monitor: Todd Davis, Targeted Brownsfields Assessment Coordinator

Dear Mr. Crossland:

.. · Tetra Tech EM Inc. is submitting the attached addendum to the Quality Assurance Project Plan for a Preliminary Assessment at the Highway 3 PCE Site in Le Mars, Iowa. If you have any questions or comments, please contact the project manager at (816) 412-1784.

Sincerely, ~#~th Adam Watkins START Project Manager ~ Ted Faile, PG, CHMM START Program Manager

Enclosure

Tetra Tech EM Inc. 415 Oak Street, Kansas City. MO 64106 Tel 816.4121741 Fi!x 816.410.1748 w.vw.tet!1ltech.com X9004.!!.0228.000 ADDENDUM TO THE QAPP Highway 3 PCE Site Le Mars, Plymouth County, Iowa Task Order No. 0228

This document will serve as an addendum to the Quality Assurance Project Plan (QAPP) dated June 10, 2011, for the Highway 3 PCE Site in Le Mars, Iowa. Additional Phase II field activities at this site were deemed necessary to assess potential contamination outside of the dry cleaning building located near the southeast comer of the intersection of Highway 3 and Central Avenue. The additional field activities are based upon tetrachloroethylene (PCE) and trichloroethylene (TCE) results obtained from the Phase I passive soil gas sampling event conducted during August 20i 1. The Tetra Tech EM Inc. (Tetra Tech) Superfund Technical Assessment and Response Team (START) will undertake sampling activities during the week of October 17, 2011. The original QAPP submitted by Tetra Tech START under Task Order 0228 remains the primary guidance document for this activity; however, modifications to the original QAPP are necessary, as described below. All sampling procedures will follow guidelines established in the U.S. Environmental Protection Agency (EPA) Standard Operating Procedures (SOP) presented in the original QAPP, or stated in the sampling descriptions below.

Sub-Surface Soil Sampling

A total of two soil borings will be advanced; one on the north side and one on the south side of the above-mentioned dry cleaning building. Exact locations will be field determined; however, general locations are based on tetrachloroethylene (PCE) and trichloroethylene (TCE) soil gas data obtained during Phase I of the Preliminary Assessment.

At both locations, a 2-inch-diameter soil core will be collected within an acetate liner with the use of a direct-push technology (DPT) rig from the surface to a depth of approximately 8 feet below ground surface (bgs). T11e acetate liner will be cut open, and soil cores will be screened with a photo-ionization detector (PID) and visually inspected for staining. Up to 3 samples from each boring will be collected from sections of the soil core depicting the highest readings from the PID, or from areas of observed staining. If no staining is present and volatile organic compounds (VOC) are not detected with the PID, up to 3 samples will be collected from each boring at default interval depths of 0.0-0.5 feet, 2.0-4.0 feet, and 6.0-8.0 feet bgs. All soil samples will be sent to EPA Region 7 laboratory for VOC analysis. Submittal of samples to the laboratory is expected on October 21, 2011.

X9004.11.0228.000 Pe1tinent data, including analyses to be performed, sample locations, and depths, will be recorded on field sheets for each sample. Turnaround times wiii remain as stated in the original QAPP. All locations will be backfilled with granular bentonite. For locations in asphalt parking areas, borings will be capped with an asphalt patch.

Date /0-6-11 Ted Faile, PG, CHMM, START Program Manager Date

'fivttw.r,at\ A.l!tnwr Jo ~& -tr Kathleen Homer, START Quali1y Assurance Manager Date

Todd Davis, EPA Region 7 Project Manager Date

Diane Harris, EPA Region 7 Quali1y Assurance Coordinator Date

X9004.11.0228.000 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 7 901 NORTH 5TH STREET KANSAS CITY, KANSAS 66101

JUN Z 8 2011 MEMORANDUM

SUBJECT: Quality Assurance Project Plan for Highway 3 PCB Site; Le Mars, Plymouth County, Iowa - Approved . - ~ FROM: Diane Harn(D~ Regional Quality Assurance Manager ENSV/10

TO: ToddDavis EPA Project Manager SUPRIIANE

The review ofthe subject document prepared by Tetra Tech, dated June 10, 2011, has been completed according to uePA Requirements for Quality Assurance Project Plans for Environmental Data Operations, "EPA QA/R-5 March2001.

The document is approved; it complies with R-5 and addresses the key issues satisfactorily.

If you have any questions, please contact me at x7258, or the lead reviewer, Gabrielle Thompson at x7569.

R7QAO Document Number: 2011214

.. II IJU ~CUh "'\ USD f iltl 1\ Jtegion 7 SuperfDIId Program Addendum to tbe Generie QAPP for the Superfund Site A.ueament and TIIJ'&eted Browoflelds Assessment PrograDJI (July 2007) for the m_g_hway 3 PCE Site, Le Man. Iowa ProJeet Informs non: !Project Name: PCE Site City: Le Mars (State: Iowa EPA Proleet Ma!lalter: Tfldd O.vis - SI'ART Proj_eet M~er: Tom Scrown lAooroved Bv: ''/~ L/ { --~lltr;ii~:!!'d~e~:~~~AR~T~Pro~oi~ect. · ~~~~/~----~llDate~:~C,t...::i-/I~'IJ::...-~·/;L-1--l 1-Aooroved Bl#: ::;;!o!.'~-~.~ Prepared For: EPA Region 7 Superfund Division Title:ISTARTProgramM.anager (Date: t<:-Jo -// Aooroved Bv: 'f:li lr1Lt ~ · - Prepared By: Tom Scroggin I~~~~:jn~6e~: ~s!rAti,~rr~·~ cn~ .~~t:::=====:JI~D~ate~:~tr;L:,n- "[JtrC~rJ~-::· I1q 1 Date: June 2011 lAnoroved Bv: - 7...i-//Lf~ ,. ~,.. 7..0- t 1 Tltle:I~:Pro]ect~ager (Date: li!A::J~D~:c..DirD::,:V:.:,ed::,.::.BYl..:::~...,--1-!1(~ l -!- \.1~1/ltJ..ILI! MG.._~( N~m~I~.H' .J ""'"P.,"L,------r=-~:::-:--:-:-:::"'7':':~rlTetra Teth START Project Number: X9004.11.0228.000 Title: EPA Region 7QACoordinator (Date: DIJ/t:LQ/Q(JJI 1.0 Project Management: 1.1 Distribution Ll.st. !EPA-Region 7: Todd Davis, EPA Project Manager Tetra Tech. START: Tom Scroggin, ProjectMmagcr Diane Harris, EPA RC!Uon 7 QA Coordinator Katlly_ Homer: OA Manucr 1.2 Project/fuk Orpnlzatfon frodd Davis, of the EPA Region 7 Superfund Division, will serve as the EPA project manager for the activities described in this QAPP. Tom Scroggin, of h'ctra Tech EM Inc., Cfetra Tech). will serve as the START project manager for field activities. 1.3 Problem Definition/Background: Description: This site-specific Quality Assurance Project Plan form is prepared as an addendum to the Generic Quality Assurance Project Plan for Superfund Site Assessment and Targeted Brownfields Assessment Programs (updated July 2007), and contains site-specific data quality objectives for the sampling activities described herein.

t8l Description attached 0 Description in referenced report: ------:::-:-:-----­ Title Date

1.4 Pfoject/fask Description: 181 CERCLA PA 0 CERCLASI 0 Brownfields Assessment 0 Removal Action 0 Other (description attached): 0 Prc-CERCLIS Screening 0 Removal Site Evaluation k:>ther Description:

Schedule: Field work !s scheduled to be conducted in July 2011.

0 Description in referenced report: ------­ Title Date 1.5 Quality Objectives and Criteria for Meuorement Data: a. Accuracv: Idet~tified in attached table. b. Precision: Identified in attached table. c. Rcnrcsentativeness: Identified in attached table. d. Comnletcness•: Identified in attached table. e. Comnarabilitv: Identified in attached table. 9th« Description:

• A completeness goal of 100 pc=t has been established for this project However, ifthe completeness goal is not met, EPA may still be able to make decisions based on any or all of the remaining validated data. No "critical samples" have been identified for this project. 1.6 Spedal Traloiog/Certllic:ation Requlremenu: t81 OSHA 1910 ~ Special Equipment/Instrument Operator (describe below): 0 Other (describe below): START field personnel will be experienced in passive soil gas, active soil gas, and direct-push technology groundwater sampling.

1.7 Documentation and Reconb: 181 Field Sheets 181 Daily LOg 181 Trip Report 181 Area Maps 0 Video 181 Olain of Custody 181 Health and Safi:t)i.Pian 0 Letter Report 181 Photos 181 Sample documentation will follow EPA Region 7 SOP 2420.0S. 181 Other: Analytical information will be handled BCCOrding to procedures identified in Table 2.

X9004.1l.0228.000 1 Memorandum

From: Todd H. Davis, EPA Site Assessment Manager

To: Rom Scroggin, Tetra Tech Project Manager

Date: June 24, 2011

RE: QAPP Comments, Highway 3 PCE Site, Le Mars, Plymouth County, Iowa

Add a sentence or paragraph to the narrative description detailing how pavement or foundations will be repaired after sampling is conducted for the benefit of the City of Le Mars, Iowa.