SDMS DocID 2088134
FIVE YEAR RE VIEW FOR GIRARD POINT MANAGEMENT AREA AT PHILADELPHIA NAVAL BUSINESS CENTER PHILADELPHIA, PENNSYLVANIA
BASE REALIGNMENT AND CLOSURE (BRAC) COMPREHENSIVE LONG-TERM ENVIRONMENTAL ACTION NAVY (CLEAN) H CONTRACT
CONTRACT NUMBER N62467-92-D-1296 CONTRACT TASK ORDER 0081
Prepared for: Department of the Navy Engineering Field Activity North East Environmental Branch Code EV2 Naval Facilities Engineering Command 10 Industrial Highway, Mail Stop #82 Lester, Pennsylvania 19113-2090
APPRO
Captain Robe^B. Date Commanding Officer EFANE DEPARTMENT OF THE NAVY ENGINEERING FIELD ACTIVITY, NORTHEAST NAVAL FACILITIES ENGINEERING COMMAND 10 INDUSTRIAL HIGHWAY MAIL STOP, #82 LESTER, PA 19113-2090 IN REPLY REFER TO
5090 EV21/MD June 21, 2004
Mr. Harry Harbold 3H550 Hazardous Site Cleanup Division EPA Region III Philadelphia, PA 19103-2029
Dear Mr. Harbold:
SUBJECT: FINAL FIVE YEAR REVIEW FOR GIRARD POINT DRIVE; JULY 15, 2003, PHILADELPHIA NAVAL BUSINESS CENTER, PHILADELPHIA, PA
A copy of the subject report is submitted for your records. The Navy will now proceed with implementing the remaining recommendations as listed in this report.
If you should need additional information or have any questions please contact Michele DiGeambeardino at 610-595-0567 extension 117.
Sincerely,
MICHELE DIGEAMBEARDINO Remedial Project Manager By direction of the Commanding Officer FIVE YEAR REVIEW FOR GIRARD POINT MANAGEMENT AREA AT PHILADELPHIA NAVAL BUSINESS CENTER PHILADELPHIA, PENNSYLVANIA
Preparedfor: Department of the Navy EFA North East Naval Facilities Engineering Command 10 Industrial Highway Mail Stop No. 82 Lester, Pennsylvania 19113-2090
Prepared by: Stone & Webster, Inc., A Shaw Group Company 3 Executive Campus Cherry Hill, NJ 08002 (856) 482-3000
Under contract with: EA Engineering, Science, and Technology 11019McCormickRoad Hunt Valley, Maryland 21031 (410)584-7000
Contract No. N62472-92-D-1296 Contract Task Order No. 0081
November 2003 FINAL EA Project No. 296.0081 Shaw Project No. 04291.18.50 FIVE YEAR REVIEW FOR GIRARD POINT MANAGEMENT AREA AT PHILADELPHIA NAVAL BUSINESS CENTER PHILADELPHIA, PENNSYLVANIA
Contract No. N62472-92-D-1296 Contract Task Order No. 0081
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Novnuber2003 FINAL EAPngcct No. 296.0081 Shaw Project No. 04291.1830 Project J.O. 04291.18.50 Table of Contents Revision: Final Pageiv
TABLE OF CONTENTS
1.0 PURPOSE AND SITE BACKGROUND 1 1.1 Purpose 1 1.2 Site Background 1 1.3 Human Health and Ecological Risk Assessments 2
2.0 REMEDIAL OBJECTIVES 4 2.1 Long Term Ground-Water Monitoring Program 5
3.0 FIVE-YEAR RE VIEW 8 3.1 Site Inspection and Photo-documentation 8 3.2 Bank Stabilization 8 3.3 Permeable and Vegetated Cover 9 3.4 Restricted Access and Institutional Controls 10 3.5 Long Term Ground-Water Monitoring 10
4.0 CONCLUSIONS AND RECOMMENDATIONS 14
5.0 STATEMENT OF PROTECTIVENESS 14
6.0 REFERENCES 15 Project J.O. 04291.18.50 Table of Contents Revision: Final Page iv
LIST OF TABLES No. Table Name 3-1 Comparison of Maximum EEQ OM Dilution for 1996-1997, 1998, 2000,2001, and 2003 Sampling Rounds - Girard Point Management Area
LIST OF FIGURES No. Figure Name 1-1 Site Plan 1 -2 Site Location Map
LIST OF APPENDICES Appendix Title A Record of Decision B Goals Paper C Photo Log - 2003 Five Year Review D GPMA LTM Trend Lines - 2003 Five Year Review Project J.O. 04291.18.50 Five-Year Review Revision: Final Pagel
1.0 PURPOSE AND SITE BACKGROUND
1.1 Purpose A Record of Decision (ROD) for the Girard Point Management Area (GPMA) was prepared by the United States Department of the Navy (Navy) and signed on 30 December 1998 (Navy, 1998). A copy of the ROD entitled Record of Decision, Girard Point Management Area is presented in Appendix A. The selected remedy stipulated in the ROD included base-wide institutional controls that included prohibitive ground water use for human consumption, restrictive future use (i.e., no permanent residential uses), and specific restrictions on construction or development of an outdoor playground). In addition, the specific selected remedy for the GPMA included early removal actions at designated areas prior to remedial construction, construction of a vegetated soil' cover on approximately 21 acres of the 25-acre GPMA, construction of a bituminous concrete pavement cover on the remaining 4 acres, long-term shallow ground-water monitoring (LTM), establishment of site- specific institutional controls (i.e., deed notification prohibiting excavation without prior written approval by the Pennsylvania Department of Environmental Protection (PADEP), and five-year reviews to evaluate whether additional remedial actions are required. This initial five year review marks five years since issuance of the ROD. The review also coincides with the end of the first five- year monitoring period of the long-term ground-water monitoring.
1.2 Site Background
The GPMA is a peninsula located in the northwest area of the Philadelphia Naval Business Center (formerly the Philadelphia Naval Base) at the confluence of the Schuylkill and Delaware Rivers as shown on Figures 1-1 and 1-2. The 1-95 Girard Point Bridge, spanning the Schuylkill River, passes directly over and bisects the site.
The GPMA is a generally flat, vegetated/paved, 25-acre site historically used for the treatment, storage, and disposal of solid wastes generated at the Philadelphia Naval Base. Portions of the area were created by landfilling associated with these waste management activities. Landfills at the site contain construction debris, incinerator ash, suspected foundry slag/sand, spent blasting grit used for paint removal, and municipal waste, as well as, soil and fill materials (river dredge materials).
Because the individual sites that comprise the GPMA share a similar site history and proposed future use, a Conceptual Site Model for the Girard Point Management Area (Stone & Webster, 1996) and a Site Characterization Report for the Girard Point Management Area (Stone & Webster, 1997b) were prepared to combine the available data, characterize the nature and extent of the site's constituents of potential concern (COPCs), and evaluate the risks posed by the site to the potential receptors. The proposed future use of the GPMA is currently as an 89-acre light industrial park, the Girard Point Industrial Park , consisting of warehousing and light industrial facilities.
To evaluate the nature and extent of the COPCs at the site and the risk posed by the site to the potential receptors, GPMA was divided into two operable units: Zones A and B. Zone A consists of the two site landfills at Installation Restoration Program (IR) Sites 4 and 5. This zone covers an area of 11.2 acres and contains approximately 280,000 cubic yards of fill. Zone B consists of a former 1.25-acre
Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\042911850\task6A_5YEAR\FINALSYEARGPMA.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 2 transformer storage area (IR Site 3), a former 4-acre Resource Conservation and Recovery Act (RCRA) storage facility (the North West Parking Lot (NWPL)), the former Girard Point incinerator (Building 668), and a 7-acre area formally used to store spent blasting grit (referred to as the area west of the NWPL). Zone B covers an area of 13.2 acres and contains approximately 86,000 cubic yards of fill. The zones, as described above, were delineated for risk assessment purposes. Prior to issuance of the ROD, the site was divided into zones for purpose of remedial alternative discussion. This wifl be discussed further in Section 2.0.
1.3 Human Health and Ecological Risk Assessments Based on the human health and ecological risk assessments presented in the Site Characterization Report for the Girard Point Management Area, unacceptable risks were quantified for potential huftian receptors located in Zones A and B, and qualified for ecological receptors located throughout the GPp/LA (Stone & Webster, 1997b). The reader is directed to the Site Characterization Report for the Gir,ard Point Management Area (Stone & Webster, 1997b) for specific information on the human health and ecological risk assessments. A brief description is presented below.
The quantitative human health risk assessment concluded that the following exposures resulted in risks above the United States Environmental Protection Agency (EPA) accepted risk levels for cancer and/or noncancer effects:
Zone A ' • Incidental ingestion of and dermal contact with beryllium and copper in subsurface soil' by construction workers • Incidental ingestion of lead in subsurface soil by construction workers ZoneB • Dermal contact with polychlorinated biphenyls (PCBs) in surface soil by maintenance workers, occasional users/trespassers, and construction workers
• Incidental ingestion of and dermal contact with 2,3,7,8-Tetrachlorodibenzofuran (TCDF) and beryllium in surface soil by maintenance workers
• Incidental ingestion of lead in surface soil by maintenance workers, occasional users/trespassers, and construction workers
• No unacceptable risk was estimated for exposures to COPCs in ground water. Incomplete exposure pathways were assumed for surface water and sediment and therefore no risks were estimated.
It was noted in the Site Characterization Report for the Girard Point Management Area (Stone & Webster, 1997b) that asbestos was detected in Zones A and B, and although human health risk associated with asbestos cannot be quantified, the presence of asbestos fibers in soil poses potential risk via inhalation.
Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\042911850\task6A_5 YEAR\FINAL5 YEARGPMA.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 3
The qualitative ecological risk assessment performed throughout the GPMA concluded that there was is the potential for unacceptable risk resulting from the following exposures:
• Ingestion of metals in surface soil, plant material, and insects by insectivorous birds
• Ingestion of metals in surface soil and plant material by granivorous birds
• Ingestion of, and dermal contact with metals, semivolatile organic compounds (SVOCs), including polycyclic aromatic hydrocarbons (PAHs), pesticides, and PCBs in surface soil and plant material by herbivorous small mammals.
No complete exposure pathways were identified for ecological receptors to subsurface soil, ground water, surface water, or sediment.
Philadelphia Naval Business Center Girard Point Management Area Five Year Review l£GJNO ..... SoJCom _._._ Stuninom Concrete Powncnl MMCKU NtMa M moM now nL FIGURE 1-2 SITE LOCATION MAP GIRARO POINT MANAGEMENT AREA A STOC t KKTCI OMNNMTA llOmOCT Ml 3IVO! />»\ ontr »t« DOM ABrK;^HH6MVP|Ct-5.IKiH 89/18/63 I?:M:M PU Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 4 2.0 REMEDIAL OBJECTIVES To accelerate cleanup of the GPMA the Girard Point Management Plan (Stone & Webster, 1995) was developed in 1995 using the EPA directive, Presumptive Remedy for CERCLA Municipal Landfill Sites (EPA, 1993). The presumptive remedy approach was used as a tool to define the remedial goals and select the remedies that address the most significant exposure pathways. One of the objectives of the presumptive remedy strategy is to shorten the feasibility study process by targeting remedial options considered during the screening of alternatives and detailed analysis. Because treatment or the removal of the GPMA landfill material were considered impractical due to the heterogeneity and volume of the landfill material, the primary remedial components were source control and containment. It should be noted that, as discussed in Section 1.2 above, the quantitative human health risk assessment was conducted on two operable units of the GPMA (Zone A and Zone B). However, the selected remedy per the ROD designated a vegetated soil cover throughout the entire GPMA (Zone A) with exception of the NWPL. The NWPL was designated as Zone B and was covered with bituminous concrete pavement. This decision to incorporate a vegetated soil cover on the majority of the GPMA was in response to a comment from the US Department of the Interior (See Appendix A). One of the goals of the Navy and other trustees was to establish suitable wildlife habitat/corridor along the Schuylkill River and Reserve Basin Inlet. The selected remedy for Zone A of the GPMA, based on the screening of alternatives and the detailed analysis as presented in the Feasibility Study for Girard Point Management Area (Stone & Webster, 1997c) was construction of a permeable cover consisting of a geotechnical permeable liner and a vegetated soil cover, establishing institutional controls, and implementing a long term monitoring (LTM) program for ground water. As discussed in the Proposed Plan for Girard Point Management Area (Navy, 1998) and the ROD (Navy, 1998), this remedy prevents exposure of soils to receptors thereby limiting human and environmental health risks. Remediation of surface soil containing PCBs at IR Site 3 was completed during September 1996 in compliance with a revised ROD signed in December 1995. The following Early Removal Actions were also implemented prior to initiation of the remedy specified in the ROD, to focus remediation on the most critical areas of concern and to facilitate source control and containment. Early Removal Action at Building 668 Removal and disposal of contaminated surface soil at Building 668. Bank Stabilization Along the Shoreline of IR Sites 4 and 5 Shoreline erosion of landfill material to the Schuylkill River was identified as a pathway for COPCs migration. A river bank stabilization project was completed along the banks of IR Sites 4 and 5 to provide a mechanism for river bank stabilization and containment of fill materials. Construction activities consisted of placement and compaction of rock aggregate and installation of geotextile materials, rock armor, and gabion walls. Philadelphia Naval Business Center Guard Point Management Area Five Year Review div42\brac\0429J1850\task6A_5Y£AR\FrNAL5YEARGPMA.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 5 Decontamination of Building 668 and Demolition of the Adjoining Incinerator Stack Samples of incinerator ash were reported to contain concentrations of cadmium in excess of the regulatory waste classification limits. Removal and disposal of the ash material and the inoperable incinerator units, and demolition and disposal of the incinerator stack were completed. Storm- Water Sewer Engineering Survey Including Line Cleaning A possible migratory pathway identified in the Conceptual Site Model for the Girard Point Management Area (Stone & Webster, 1996) was the storm water sewer system and the surrounding porous fill. The system discharges directly to the Schuylkill River and the entrance to, the Philadelphia Naval Base Reserve Basin and is subject to tidal influence and potential ground-water infiltration. An engineering survey was performed to evaluate the physical condition of the system. In addition, line cleaning was conducted to facilitate a closed circuit television survey with videotaping. Underground Storage Tank Removal Removal and closure of a 12,000-gallon fuel product underground storage tank, located at the northeast corner of Building 668, was completed in 1997. 2.1 Long Term Ground-Water Monitoring Program A LTM program was implemented, as a component of the selected remedy, to address potential environmental concern related to leaching of landfill material and the potential discharge of COPCs from the shallow ground water to the Schuylkill River and the entrance to the Philadelphia Naval Base Reserve Basin. The existing eighteen GPMA ground-water monitoring wells were divided into two groups; four wells located in the upgradient flow direction (i.e., upgradient wells) and fourteen wells located in the GPMA and downgradient flow direction (i.e., downgradient wells). Quarterly ground-water sampling of the eighteen shallow wells, using EPA low-flow sampling procedures was conducted during the weeks of 8 July 1996, 4 October 1996, 24 February 1997, and 5 May 1997. Ground-water samples were collected using peristaltic pumps and analyzed for EPA Target Compound List/Target Analyte List (TCL/TAL) parameters. TCLTAL analyses included volatile organic compounds (VOCs), SVOCs, pesticides, PCBs, cyanide, and total (unflltered) metals. Analysis for total dissolved solids was also performed. Based on the results of the first round of ground-water samples, it was concluded that the dissolved (filtered) metals and asbestos analyses were unwarranted. A letter report dated 17 July 1997 presented a one year status report detailing the quarterly sampling results (i.e., baseline), and recommendations addressing future ground- water monitoring (Stone & Webster, 1997a). Ground- water data from the four quarterly sampling rounds were compared to EPA Region in human health Risk Based Concentration (RBC) tap water screening criteria and EPA freshwater chronic Ambient Water Quality Criteria (AWQC). As discussed in the Site Characterization Report for the Girard Point Management Area (Stone & Webster, 1 997b), the quantitative health human risk assessment concluded that no unacceptable human health risk was estimated for exposures to COPCs in ground water. Incomplete exposure pathways were assumed for surface water and sediment. As a result, no associated human health risks were estimated. Therefore, comparison to RBC tap water screening criteria was assumed to be non-essential for future ground-water monitoring needs. Eleven metals were identified as the primary COPCs hi ground water based on that the baseline comparison to the AWQC (EPA, 1993c). Maximum Environmental Effect Quotient (EEQ) values Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\042911850\task6A_SYEAR\FINAL5YEARGPMA.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 6 were calculated to aid in the comparison and review of the results. Each maximum EEQ was calculated by dividing the maximum reported concentration by the associated AWQC. According to the EEQ screening approach, if the EEQ exceeds unity, a potential for ecological risk exists. However, dilution factors associated with ground-water discharge to the Schuylkill River were not considered during the preliminary comparison to AWQC and calculation of the EEQs. These dilution factors which were estimated to be one to five orders of magnitude (Stone & Webster, 1997b) reduce concentrations of COPCs to below the AWQC screening levels and EEQs to less than unity. Based on conclusions presented in the Site Characterization Report for the Girard Point Management Area (Stone & Webster, 1997b), a Goals Paper (Stone & Webster, 1998c) was prepared to discuss overall objectives of the LTM,program, how these objectives were consistent with the Proposed Plan for Girard Point Management Area (Navy, 1998), ROD, and exit strategies for the LTM program. A copy of the Goals Paper is presented in Appendix B. Data Quality Objectives (DQOs) were developed in accordance with EPA Guidance for the Data Quality Objectives Process (EPA, 1994) as part of the Goals Paper (Stone & Webster, 1998c). Based on use of the DQOs development process and the data evaluation presented in the Goals Paper (Stone & Webster, 1998c), the number of wells sampled and list of COPCs were reduced to ten monitoring wells and nine metals (arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, and zinc), respectively. The following decision rule and recommendations were established to verify that the nine metals remain at concentrations that do not pose a potential for ecological risk: • Evaluate the existing ground-water data baseline for seasonality. • If discernible seasonality is not present, maximum concentrations of the July and October 1996 sampling rounds and February and May 1997 sampling rounds will be used to represent 1996 and 1997 annual concentrations, respectively. • Annual sampling of the ten monitoring wells and analysis of nine metals for duration of five years. This approach is consistent with conclusions presented in the Feasibility Study (Stone & Webster, 1997d) and the Proposed Plan (Navy, 1998), and federal and state regulations • The .monitoring endpoint will therefore be based on consensus by the Base Realignment and Closure Act (BRAC) Cleanup Team (BCT) that the decision rule stated in the Goals Paper (Stone & Webster, 1998c) has been satisfied. That rule says: "If maximum EEQs for nine metals (arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, and zinc) remain below unity (when considering dilution factors of one to five orders of magnitude) during a five- year period, then the GPMA ground-water monitoring program will be terminated." • Confirmation sampling will be conducted on any of the ten monitoring wells sampled during the annual sampling rounds, if a maximum EEQ exceeds unity (considering a dilution factor of three orders of magnitude). If confirmation sampling EEQs exceed unity (considering a dilution factor of three orders of magnitude), then the EEQs will be evaluated considering dilution factors of four and five orders of magnitude. PADEP will be contacted if confirmation sampling is conducted. Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\0429II850\task6A_5YEAR\FrNAL5YEARGPMA.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page? • If the decision rule is not met, PADEP will be contacted, ground-water monitoring will be conducted beyond the initial five-year period, and a ground-water monitoring decision tree will be developed. Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\04291I850\task6A Project J.O. 04291.18.50 Five-Year Review Revision: Final PageS 3.0 FIVE-YEAR REVIEW 3.1 Site Inspection and Photo-documentation Stone & Webster conducted site inspections of the GPMA during each of the four LTM program sampling rounds. Changes in site changes were documented in annual reports prepared for the LTM program. In addition, site conditions during the July 2003 annual sampling event were photo-documented, as presented in Appendix C. A panoramic view of the GPMA from the top of Building 993 (See Figure 1-2) is presented in Photos No. 1 through 13. Photo-documentation of specific site conditions/changes is discussed below. The Navy contracted Foster Wheeler Environmental Corporation (FWENC) to design and construct the soil cover and asphalt pavement throughout Zones A and B, respectively. FWENC had completed the vegetated soil cover and asphalt pavement prior to the November 1998 annual LTM round, and was in the process of planting trees and shrubs along the river bank of Zone A (Stone & Webster, 2003). In addition, FWENC was contracted to extend existing ground-water monitoring wells to account for installation of the soil cover. All wells were to be resurveyed (horizontally and vertically) after the site work was completed, and the locks keyed-alike (Stone & Webster, 2003). To date, the modified ground-water monitoring wells have not been re- surveyed. Flush-mounted wells do not have locks, but have protective watertight covers. One of the flush-mounted has been damaged by vehicular traffic (See Photo 14). As discussed in the 2000 Annual Report, the City of Philadelphia stored abandoned motor vehicles throughout the area north of the GPMA. Damage to two of the upgradient monitoring wells (GPMA-LTM-1 and GPMA-LTM-2) was apparently caused by placement of the motor vehicles (See Photos 15 - 17). The motor vehicles were removed sometime prior to the 2001 sampling round. However, further damage to the well casing and surface seal of GPMA-LTM-2 was noted. Upon inspection, soil could be heard infiltrating the well. A field decision was made not to collect a sample at the location because the integrity of the well had been compromised. Stone & Webster conducted a follow up site inspection on 10 November 2003. It was noted that the damaged upgradient monitoring wells (GPMA-LTM-1 and GPMA-LTM-2) were repaired by the Navy following the July 2003 sampling round (See Photos 18 and 19). 3.2 Bank Stabilization Bank stabilization was completed prior to construction of the vegetated soil cover. Stabilization was accomplished by means of wire gabion baskets filled with quarried rock extending from the ebb tide elevation to the top of bank. The area stabilized encompassed the area near the Philadelphia Naval Base Reserve Basin inlet bridge, extending along the inlet to the Schuylkill River, and further extending north along the Schuylkill to the end of the GPMA property (See Photos 20 - 25). Philadelphia Naval Business Center. Girard Point Management Area Five Year Review div42\brac\04291I8SO\task6A_5YEAR\FlNAL5YEARGPMA.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 9 The purpose of the stabilization was to prevent contaminated sediments from eroding along the T shoreline and deposition into the Schuylkill River. To prevent migration of soil through the baskets, the baskets are lined on the land side by geofabric. _ Visual inspection of the bank stabilization was performed at the time of each annual ground- water sampling event. The 2001 inspection revealed two missing baskets at the toe of the bank _ under the 1-95 Girard Point Bridge; the location where the baskets are missing can only be seen at ebb tide (See Photo 26). The baskets were probably dislodged or torn apart by ice flows or floating debris (See Photo 27). The Navy will replace these gabion baskets as part of bank — stabilization maintenance. In addition, a guide for the trash gate cable, located at the eastern portion of IR Site 5 was never — installed. The absence of the guide has caused damage to the top of the gabion wall and the cable (See Photos 28 and 29). However, it was noted during the 10 November 2003 site inspection that the Navy has addressed this site condition by placement of a protective steel sheet on top of — the gabion wall (See Photo 30). Despite the small amount of damage, the bank stabilization continues to be in an overall good ~~ state of repair with no other signs of instability. The goal of preventing contaminated sediment from being transported into the Schuylkill River is being accomplished. 3.3 Permeable and Vegetated Cover In 1998, IR Sites 4 and 5 were covered with a geotextile/permeable liner and a vegetated soil _ cover. The liner acts as a boundary between the then existing landfill cover and clean fill. The landfill liner is covered by a minimum of twenty four inches of soil suitable to support vegetation. (See Figure 1-2). The landfill liner and vegetated soil cover encompass an area of — approximately 21 acres. Within fifty feet of the river bank, the site was graded landward to reduce flow of sediment from the landfill to the river. A visual inspection of the vegetated soil cover and bituminous concrete pavement was performed each annual ground-water sampling. The soil cover is well vegetated with tall weeds, new tree plantings, wildflowers, and grass (See Photos 1-13, and 31 - 34). No outward signs of erosion ~~ were observed in the drainage swales (See Photos 31 and 32) or damage or cracks in the bituminous concrete pavement. However, the tall weeds prevented a thorough inspection at the time of the 2003 inspection. A few deciduous trees planted in the 50-foot zone adjacent to the river bank have died and should be replaced (See Photo 35). There were no areas observed which indicated that the integrity of the permeable soil cap was at risk. Mowing of the area has not been performed to maintain the wildlife habitat. However, it was noted during the July 2003 annual inspection that the tall vegetation has obstructed the gas line warning sign (See Photo 36). The underground gas line crosses the Philadelphia Naval Base Reserve Basin Inlet at the former IR Site 5. Periodic mowing adjacent to this sign and debris removal from drainage swales to prevent blockage of the outfall pipe (See Photo 37) are required. — Philadelphia Naval Business Center Girard Point Management Area Five Year Review — div42\brac\0429U850\task6A_SYEAR\F[NAL5YEARGPMA.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 10 3.4 Restricted Access and Institutional Controls The GPMA was transferred to the City of Philadelphia under the Base Realignment and Closure Act on 30 March 2000. Access to the GPMA is limited by a locked fence (See Photo 13) that extends along the eastern, northern, and northwestern perimeters, and the Schuylkill River, and Philadelphia Naval Base Reserve Basin Inlet (See Figure 1-2). However, an uncontrolled opening to the GPMA exists at a railroad access north of the NWPL. Vehicular traffic is unlikely to maneuver over the track, but the GPMA is accessible by pedestrians. As stipulated in the ROD, the selected remedy was based on the following base-wide and site- specific institutional controls: / Base-wide Institutional Controls • Ground water withdrawn from wells shall not be used or made available for human consumption. • GPMA shall not be used or developed for any permanent residential uses. • Any construction or development of an outdoor childcare playground will include the placement of two feet of clean fill material, or other cover as approved by the Pennsylvania Department of Environmental Protection (PADEP), between the underlying soil and the surface of the childcare playground prior to commencement of any use of the outdoor area as a playground. Site-specific Institutional Controls • An Institutional Control such that excavation shall not be accomplished without prior written approval of PADEP. 3.5 Long Term Ground-Water Monitoring Pursuant to the base-line ground-water sampling performed during 1996-1997; four subsequent sampling events have occurred: November 1998, May 2000, August 2001, and July 2003. The following reports were prepared to show the results of the sampling: • 1998 Annual Report — Long Term Monitoring Program for Girard Point Management Area at Philadelphia Naval Business Center, Philadelphia Pennsylvania. • 2000 Annual Report - Long Term Monitoring Program for Girard Point Management Area at Philadelphia Naval Business Center, Philadelphia Pennsylvania • 2001 Annual Report - Long Term Monitoring Program for Girard Point Management Area at Philadelphia Naval Business Center, Philadelphia Pennsylvania Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\0429118SO\task6A_5YE.AR\F!NAL5YEARGPMA.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 11 • 2003 Annual Report - Long Term Monitoring Program for Girard Point Management Area at Philadelphia Naval Business Center, Philadelphia Pennsylvania A summary of the maximum detected EEQs of each of the sampling rounds for the suite of wells is shown in Table 3-1. See the 2003 Annual Report for a more complete discussion. As can be observed in the table, the decision rule, agreed upon by the Navy and stated in the Goals Paper (Stone & Webster, 1998) and Section 2.1, has been met. Therefore, the monitoring program can be concluded. In addition, the following observations were noted in the 2003 Annual Report, in reference to the five years of ground water monitoring: • Maximum concentrations of arsenic, cadmium, chromium, nickel, and selenium never required more than one order of magnitude dilution to achieve an EEQ of less than unity subsequent to the base line sampling period. • Maximum lead concentrations required one order of magnitude dilution to achieve an EEQ of less than unity for the most recent round of sampling and never required more than two orders of magnitude dilution during the five-year period. • Maximum zinc concentrations required two orders of magnitude dilution to achieve an EEQ of less than unity for each sampling period during the five-year period. • Maximum copper concentrations required three orders of magnitude dilution to achieve an EEQ of less than unity for the first time since the base line sampling event. All other sampling rounds required two orders of magnitude dilution to achieve an EEQ of less than unity for the maximum copper concentration. • Maximum mercury concentrations required two orders of mercury dilution to achieve an EEQ of less than unity. Mercury was the only metal to require more than three orders of magnitude dilution for a particular sampling event (May 2000) to achieve an EEQ of less than unity, though the subsequent confirmation round only required three orders of magnitude dilution to achieve an EEQ of less than unity. • Based on the baseline and five-year data, definitive increasing or decreasing maximum concentration trend cannot be interpreted for arsenic, cadmium, chromium, lead, mercury, and selenium. • Subsequent to the baseline period, maximum concentrations of copper, nickel, and zinc have increased; it is not certain if the increase is a trend or if the values are within the expected range of maximum concentrations. Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\042911850\task6A_5YEAR\FlNAL5YEARGPM4.doc Project J.O. 04291.18.50 Five-Year Review Revision: Final Page 12 • Nickel and chromium have maximum concentrations detected in the most recent round that were reported above the baseline detected concentrations. Each of these metals only required one order of magnitude dilution to achieve an EEQ of less than unity. • Except for arsenic (GPMA-LTM-3) and chromium (GPMA-LTM-4), maximum concentrations of the metals were detected in downgradient well GPMA-LTM-5. This is consistent with the August 2001 results, except that maximum concentration of lead was found in downgradient well GPMA-LTM-7 and selenium was detected in downgradient well GPMA-LTM^. • Trend analysis performed for the maximum EEQ of each metal for a particular sampling event and the year of the sampling event is included as Appendix D. As can be seen from the analysis, in particular the coefficient of determination (R2), very little of the variation of the EEQ can be explained by the year of the sampling event. Only the trend analyses for arsenic and selenium have significant values. That is to say, a portion of the variance (58% for arsenic and 48% for Selenium) for the EEQ can be explained by the year in which the sampling took place. The remainder of the trend analyses show very little correlation between time and maximum EEQ. Both arsenic and selenium indicate a declining trend. Ftntaddpba Nival Btsioss Center Girmrd Point Management Area Rve Year Review is IE£I5 1 ~ 6" 1 3 C Q Z 'B ^^ O ^^ CT* " ^ ^*^J '"^ s^ <-< rn" "- (N — Ci- 1a; L_ 1- C s ~ ^ •— C ^^ ^o •- "2 £ * CX P C W 5 £ s~^ U .E -2 ^t ^^^ ^"^ ^ ^ §^^ CT (N 5^^ $ Q G CS ^ cs E 5 w •= oo S w Q ^ (N ri Q 06 S o .Hi O 00 *J o 0 0 a ON O Ills w ^ o 2* u l1!^^ £ EPh £u rE"e S s « (2 c/2 w U £ | § | | *x cx* « r-. W "c1 ON W ° | 4.0 CONCLUSIONS AND RECOMMENDATIONS Remediation activities at the GPMA occurred between 1995 and 1998. Bank stabilization was performed to limit the transport of contaminated sediment from the landfill to the river and reserve basin inlet. Inspection of the bank stabilization indicated that it has been, and should remain effective. No indications of bank erosion have been observed during the five year period. The stabilization is in need of a small repair in one area (beneath the 1-95 Girard Point Bridge). As discussed in Section 3.2 above, the Navy will replace these gabion baskets as part of bank stabilization maintenance. In addition, a guide for the trash gate cable, located at the eastern portion of IR Site 5 was never installed. The absence of the guide has caused damage to the top of the gabion wall and the cable. However, it was noted during the 10 November 2003 site inspection that the Navy has addressed this site condition by placement of a protective steel sheet on top of the gabion wall. The landfill has been covered with over twenty four inches of non-contaminated fill, graded, and vegetated to prevent overland flow from transporting sediment offsite. In general, the vegetation has provided dense coverage to the landfill area. Replacement of a few trees in the 50-foot zone adjacent to the bank stabilization is recommended. Periodic mowing adjacent to a gas line warning sign and debris removal from drainage swales to prevent blockage of the outfall pipe are also recommended. The LTM program has been implemented for five years with four sampling rounds. Results from the sampling and analysis indicate that the "decision rule" has been met. Hence, it is recommended that the LTM program be concluded and that the shallow ground-water monitoring wells be abandoned in compliance with PADEP regulations. 5.0 STATEMENT OF PROTECTIVENESS It is concluded based on the site inspections and evaluation of LTM data that the remedy and conditions stipulated in the ROD for this site remain protective of human health and the environment. The next five-year review is scheduled for September 2008 in accordance with the ROD. Philadelphia Naval Business Center. Girard Point Management Area Five Year Review div42\brac\0429n850\uak6A 5YEAR\FlNAL5YEARGPMA.doc Project: J.O. 04291.18-50 References Revision: Final Page 15 6.0 REFERENCES Department of the Navy, 1998a. Proposed Plan for Girard Point Management Area, Philadelphia Naval Complex, Philadelphia, Pennsylvania. June 1998. . 1998b. Record of Decision. Stone & Webster. 1996. Conceptual Site Model for the Girard Point Management Area, Philadelphia Naval Base, Philadelphia, Pennsylvania. April 1996. , 1997a. Site Characterization Report for the Girard Point Management Area at Philadelphia Naval Base, Philadelphia, Pennsylvania. September 1997. . 1997b. Feasibility Study for Girard Point Management Area at Philadelphia Naval Base, Philadelphia, Pennsylvania. October 1997. . 1998a. Goals Paper Ground-Water Monitoring Program for Girard Point Management Area at Philadelphia Naval Base, Philadelphia, Pennsylvania. 30 June 1998. . 1998b. Long Term Ground-Water Monitoring Plan for Girard Point Management Area at Philadelphia Naval Base, Philadelphia, Pennsylvania. 9 December 1998. 1999. 1998 Annual Report - Long Term Ground-Water Monitoring Program for Girard Point Management Area at Philadelphia Naval Business Center, Philadelphia, Pennsylvania. 6 August 1999. . 2000. Draft 2000 Annual Report - Long Term Ground-Water Monitoring Program for Girard Point Management Area at Philadelphia Naval Business Center, Philadelphia, Pennsylvania. 25 September 2000. . 2001. Draft 2001 Annual Report - Long Term Ground-Water Monitoring Program for Girard Point Management Area at Philadelphia Naval Business Center, Philadelphia, Pennsylvania. 25 November 2001. . 2003. Draft 2003 Annual Report - Long Term Ground-Water Monitoring Program for Girard Point Management Area at Philadelphia Naval Business Center, Philadelphia, Pennsylvania. September 2003. United States Environmental Protection Agency (EPA), 1993, Office of Solid Waste and Emergency Response, Directive No. 9355.049FS, Presumptive Remedy for CERCLA Municipal Landfill Sites. EPA/540/F93/035. September, 1993. . 1994. USEPA Office of Research and Development, Guidance for the Data Quality Objectives Process. EPA/600/R96/055. September, 1994. Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\042911850\task6A_5YEAR\FlNAL5YEARGPMA.doc PtojectJ.O. 04291.1850 Appendix A Revision: Final APPENDIX A RECORD OF DECISION Naval Business Coder CSrard Point! Hve Year Review EPA/ROD/R03-99/108 1999 EPA Superfund Record of Decision: USN PfflLA NAVAL SHIPYARD EPA ID: PA4170022418 OU01 PHILADELPHIA, PA 12/30/1998 ,'\ \J 12-•;••;= •/ RECORD OF DECISION GIRARD POINT MANAGEMENT AREA PHILADELPHIA NAVAL COMPLEX DECEMBER 1998 Pagei U.S. Department of the Navy - Northern Division November 1998 RECORD OF DECISION Girard Point Management Area Philadelphia Naval Base Philadelphia, Pennsylvania TABLE OF CONTENTS Contents Page Number DECLARATION FOR THE RECORD OF DECISION i 1) SITE NAME, LOCATION AND DESCRD7TTON 2) SITE HISTORY AND ENFORCEMENT ACITVTnES a. Site Use and Response History b. Enforcement History 3 3) COMMUNITY PARTICD7ATTON 4 4) SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 5 5) SUMMARY OF SITE CHARACTERISTICS 5 a. Nature and Extent 5 b. Fate and Transport 5 6) SUMMARY OF SITE RISKS 7 7) DEVELOPMENT AND SCREENING OF ALTERNATIVES 10 8) DESCRIPTION OF ALTERNATIVES 12 9) SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 14 10) THE SELECTED REMEDY 16 11) STATUARY DETERMINATIONS 17 12) STATE ROLE 13) RESPONSIVENESS SUMMARY 14) REFERENCES 20 LIST OF FIGURES Figure No. Title 1 GPMA - Site Location Map Philadelphia Naval Complex Girard Point Management Area - Record of Decision •' ~ "V in. FIGURE 1 SITE LOCATION MAP CIRARD POINT MANAGEMENT AREA A srac i ami DMmarc Konor » SDMCQ oanriu,UMM It 0*7X11 • Page ii U.S. Department of the Navy - Northern Division November 1998 RECORD OF DECISION DECLARATION SITE NAME AND LOCATION Girard Point Management Area Philadelphia Naval Complex Philadelphia, Philadelphia County, Pennsylvania STATEMENT OF BASIS AM) PURPOSE This decision document presents the selected remedial action for the Girard Point Management Area (GPMA), at the Philadelphia Naval Complex in Philadelphia, Pennsylvania which was chosen in accordance with the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and to the extent possible the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based upon the contents of the administrative record for this site. Both the United States Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Protection (PADEP) concur with the selected remedy. DESCRIPTION OF THE SELECTED REMEDY The Navy has identified the selected remedy at the Girard Point Management Area at the Philadelphia Naval Complex in Philadelphia, PA (Figure 1). The Navy's selected remedy is based on the following already established Base-wide Institutional Controls: ••'• Ground water withdrawn from wells shall not be used or made available for human consumption (Base-wide Institutional Control) GPMA shall not be used or developed for any permanent residential uses (Base-wide Institutional Control). v/» Any construction or development of an outdoor childcare playground will include the placement of 2 ft of clean fill material, or other cover as approved by PADEP, between the underlying soil and the surface of the childcare playground prior to commencement of any use of the outdoor area as a playground (Base-wide Institutional Control). Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page iii U.S. Department of the Navy - Northern Division November 1998 The following remedy has been selected specifically for the Girard Point Management Area: • A vegetative cover of the landfill area (Zone A). This will consist of a permeable geomembrane and a minimum two feet soil cover to reduce dermal and inhalation pathway. Vegetation will provide a buffer from between the Schuylkill River and any industrial activity, and will consist of native grasses and shrubs. • Asphalt paving of an adjacent parking lot to reduce dermal and inhalation pathway. (Zone B). • Removal of surface soils surrounding the incinerator. • Dismantle the incinerator stack incinerator units and decontaminate and the incinerator building. • Long Term Shallow Ground Water monitoring in accordance with an EPA and PADEP reviewed Long Term Monitoring Plan An Institutional Control such that excavation shall not be accomplished without prior written approval of PADEP. Five-year reviews will be conducted to evaluate whether additional remedial actions are required A report will be generated detailing each five-year review evaluation. DECLARATION STATEMENT Pursuant to the duly delegated authority, I hereby determine, pursuant to Section 106 of CERCLA, 42 U.S.C. § 9606 that this remedial action is necessary to ensure protection of human health and the environment, and that this alternative complies with federal and state requirements that are legally applicable or relevant and appropriate to the site. Joseph M. Roche Date BRAC Environmental Coordinator Philadelphia Naval Complex Girard Point Management Area - Record of Decision Pagel U.S. Department of the Navy - Northern Division November 1998 1) SITE NAME, LOCATION AND DESCRIPTION The GPMA is a peninsula located in the northwest area of the Philadelphia Naval Base at the confluence of the Schuylkill and Delaware Rivers. See Figure 1 for Philadelphia Naval Base Site Location Map and Figure 2 for the GPMA Site Location Map. This generally flat vegetated 25 acre site includes two landfills - Installation Restoration Program (IR) Sites 4 and 5, a former transformer storage area (IR Site 3), a former Resource Conservation and Recovery Act (RCRA) storage facility, and the former Girard Point incinerator (Building 668). The GPMA was historically used for the treatment, storage, and disposal of solid wastes generated at the Philadelphia Naval Base. Portions of the area were created by landfilling associated with these waste management activities. Evidence of landfilling activities is supported by soil borings and test pit excavations which have confirmed the presence of construction debris, incinerator ash, suspected foundry slag/sand, blasting grit used for paint removal, and miscellaneous municipal waste as well as soil and fill materials (river dredge materials). To accelerate cleanup of the Girard Point Management Area (GPMA) the Girard Point Management Plan was developed in 1995 using the United States Environmental Protection Agency (EPA) directive, "Presumptive Remedy for CERCLA Municipal Landfill Sites". One of the objectives of the presumptive remedy strategy is to shorten the Feasibility Study (FS) process by targeting remedial options considered during the screening of alternatives and detailed analysis. Treatment and/or removal of the landfill material were considered impractical due to the heterogeneity and volume of the landfill material, therefore the primary remedial components are source control and containment. According to the presumptive remedy strategy, landfills with a content of more than 100,000 cubic yards would normally not be considered for excavation and removal. Landfill covers or caps address source control and containment under the presumptive remedy strategy. The following early removal actions were implemented to focus investigations and remediation on the most critical areas of concern, and to facilitate source control and containment: • Bank stabilization along the shoreline of IR Sites 4 and 5, • Storm-water sewer engineering survey including line cleaning, • Underground storage tank removals, and • Implementation of the presumptive remedy strategy. In order to evaluate the nature and extent of the Constituents of Potential Concern (COPC) at the site and the risks posed to potential receptors, GPMA was divided into two operable units: Zones A and B. Zone A, which is a landfill that contains municipal-type wastes, consists of IR Site 4 and IR Site 5. This zone covers an area of 11.2 acres and includes approximately 280,000 cubic yards of fill. Zone B consists of IR Site 3, Budding 668, the North West Parking Lot (NWPL), and the area West of the NWPL. Zone B covers an area of 13.2 acres and includes approximately 86,000 cubic yards of fill. The 1-95 Girard Point bridge, spanning the Schuylkill River, passes directly over and bisects the site. Two federally listed endangered species are known to inhabit the area at or near the GPMA. The peregrine falcons have nested on the 1-95 Girard Point bridge and the shortnose sturgeon are known to inhabit the Delaware River near Philadelphia and probably present at the mouth of the Schuylkill River. The nearest civilian residential population, a section of south Philadelphia, is Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 2 U.S. Department of the Navy - Northern Division November 1998 located approximately 1-1/2 miles to the northeast. Also located to the northeast are a public golf park and a city park, Roosevelt Park. The park and golf course are located within 1/2 mile of the site. The site was marshlands until it was covered with fill material between 1940 to 1970. The general land area surrounding the GPMA is densely populated within one mile to the northeast and heavily industrialized within one mile to the north with oil refining and petrochemical plants. The 100 year flood elevation line is 10 ft above mean sea level (msl) referenced to the National Geodetic Vertical Datum of 1929 (NGVD 1929). Elevations of the riverbank along the GPMA range from 15-18 ft above msl along the southwest portion of the GPMA at IR Site 4 to 10-12 ft msl along the south portion of the GPMA at IR Site 5. In 1994, wetlands were delineated at the Philadelphia Naval Base. Wetland locations were identified along the northwest comer of the GPMA during a 1994 study. A more complete description of the sites can be found in the Site Characterization Report (Stone & Webster, 1997). Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 3 U.S. Department of the Navy - Northern Division November 1998 2) SITE HISTORY AND ENFORCEMENT ACTIVITIES Site Use and Response History IR Site 4 comprises a landfill area of approximately 6 acres. Site history and aerial photography reviews indicated waste disposal activities occurred between 1940 and 1970. Construction of the Girard Point Incinerator (i.e., Building 668) at the eastern border of IR Site 4 in the early 1940s marked the beginning of waste management operations within the GPMA. Incinerator ash and debris generated at Building 668 were reportedly disposed by filling within the immediate area of Building 668. Solid wastes that could not be incinerated, such as metal debris and concrete, were also placed in IR Site 4. These fill materials were identified in the Remedial Investigations (RT) as the main source of COPC. Stone & Webster issued the Final RI report for ER. Site 4 in May 1997. An early removal action consisting of a bank stabilization project was completed at IR Site 4 to mitigate potential human health and ecological risks. An initial concern identified at the site was the alleged disposal of 50 to 60 pallets of gas cylinders of unknown contents just after World War H A former shipyard employee who was part of the working crew assigned to the burial of the cylinders identified their potential existence. After extensive review of records, interviews, and geophysical investigations in the area, excavation was accomplished at the most likely burial area in September 1992. This area was excavated and field inspected, but no cylinders were found. Upon completion of the excavation activities and field inspection, the Navy concluded, "there are no cylinders buried at IR Site 4 and according to the agreement (with the EPA), the Navy will no longer pursue the search for cylinders at the site." IR Site 5 is a landfill that covers approximately 5 acres and contains mostly waste blasting grit, along with construction debris, miscellaneous debris that was not incinerated at Building 668, and incinerator ash. IR Site 5 shares a similar landfilling history with IR Site 4 in that filling operations occurred from the early 1940s until 1970. Fill material at IR Site 5 was found to range in depth from 7 to 14 ft below ground surface (bgs). Stone & Webster issued the Final RI report in May 1997. Bank stabilization for IR Site 5 was completed in 1997. Other than IR Sites 4 & 5, the remaining of Girard Point was used for waste storage. A detailed description of the site use and response histories can be found in the Final Remedial Investigation Report IR Site 4 (Stone & Webster, 1997a), Final Remedial Investigation Report (Stone & Webster, 1997b), and the Final Site Characterization Report (Stone & Webster, 1997c). A list of the previous reports can be found in Table 1-1 Summary of Previous Reports in the Final Site Characterization Report. ENFORCEMENT HISTORY The U.S. Navy is responsible for addressing environmental concerns at the Philadelphia Naval Complex, pursuant to Section 120 of CERCLA. Investigation and cleanup of DOD sites, such as the Philadelphia Naval Complex, are funded through the Department of Defense. Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 4 U.S. Department of the Navy - Northern Division November 1998 3) COMMUNITY PARTICIPATION The Navy has kept the community and other interested parties apprised of site activities through Restoration Advisory Board (RAB) meetings, which involve community representatives in the clean-up program. The Navy released a community relations plan which outlined a program to address community concerns and keep citizens informed. Public participation requirements of CERCLA Section 113(k)(2)(B)(i-v) and 117 were met in the remedy selection process. The administrative record is available for public review at the Philadelphia Naval Business Center, Building 501. The Navy published a notice and brief analysis of the Proposed Plan in the Philadelphia Inquirer May 28, 1998, South Philadelphia review on May 28, 1998 and Southwest Philadelphia Review on May 29,1998. On June 25,1998, the Navy held an informational poster session to present the results of the RI and the cleanup alternatives presented in the FS and to present the Proposed Plan and answer any questions. The session was held at the Holy Spirit Parish house, 1900 Greary Street, Philadelphia. The Navy held a 30 day public comment period which ended July 2,1998 to accept public comment on the alternatives presented in the FS and the Proposed Plan and on any other documents previously released to the public. This Record of Decision presents the selected remedial action for GPMA of the Philadelphia Naval Complex in Philadelphia, Pennsylvania, chosen in accordance with the procedures established by CERCLA, as amended by SARA. The decision for the site is based on the Administrative Record, which was available for public review at the Philadelphia Naval Business Center, Building 501 (pass Office) South Broad Street, Philadelphia Pennsylvania. Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 5 U.S. Department of the Navy - Northern Division November 1998 4) SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION The selected remedy was developed by combining components of different source control and management of mitigation alternatives to obtain a comprehensive approach for site remediation. The selected remedy for Zone A consists of a permeable cover, which consists of a geotextile/permeable liner and a vegetated soil cover. The liner will mark the location of the waste, but not eliminate infiltration of water. The cover will consist of two feet of soil, which will be vegetated with native grasses and shrubs. This remedy prohibits exposure with the soil to protect human health and the environment. It also provides a vegetated buffer between the Schuylkill River (and its ecology) and the area adjacent to GPMA, which is proposed for heavy industrial reuse in the City of Philadelphia's Reuse Plan dated September 1994. The selected remedy for Zone B, which consists of paving returns, the area to its former use as a parking lot and prohibits exposure with the soil to protect human health and the environment. Within Zone B, the removal of soils and decontamination of the incinerator remove possible source areas and eliminate exposure to these areas. The institutional controls, five-year reviews and long term monitoring plan will ensure that the remedy, will continue to be protective of human health and the environment. 5) SUMMARY OF SITE CHARACTERISTICS The Final Site Characterization Report contains an overview of the site investigation conducted at the GPMA. The notable findings of the site investigation are summarized below. Nature and Extent COPC weir, identified in surface soil, subsurface soil and ground water samples collected throughout the GPM.A. COPC were identified as those analytes detected above media specific human and ecological risk-based concentrations as presented in the Final Site Characterization Report. COPC identified for human health and ecological risk assessment at the GPMA included semi-volatile organic compounds (SVOC), pesticides, polychlorinated biphenyls (PCB), metals, dioxins, and asbestos. SVOC, PCB, metals, dioxins, and asbestos were detected in surface and subsurface soil samples at concentrations above screening levels. Pesticides were only detected at concentrations above screening levels in surface soil. The main source of COPC is landfill material, although in this highly industrialized area sources from other industries cannot be ruled out Differences between vertically adjacent samples and the absence of similar COPC in nearby and/or downgradient ground-water samples suggest that the COPC are being retained in the fill and are not migrating through soil to the ground water or off-site. COPC identified in ground water included SVOC, pesticides, PCB, and metals. Maximum detected concentrations were detected in wells located throughout the GPMA - both upgradient and within the landfilled area, Zones A and B. Fate and Transport As part of the Final Site Characterization Report, a risk assessment was conducted to estimate the potential risks to human health posed by the waste attributable to the GPMA. The report also estimated the ecological risks from GPMA. The physical-chemical characteristics of the COPC and Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 6 y U.S. Department of the Navy - Northern Division November 1998 / site conditions identified the potential for site COPC migration. The site COPC will likely adhere or j adsorb to soil particles reducing their mobility in the environment and the potential for migration of COPC offsite. According to the Final Site Characterization Report, transport of COPC may be _ possible via the following pathways: • surface soil to surface water via erosion, _ • ground water to surface water via ground-water discharge, • surface soil to shallow aquifer ground water to deep aquifer ground water via infiltration, and • Surface and subsurface soil to air via fugitive dust generation. COPC transported through erosion of surface soil to the Schuylkill River or the Reserve Basin Inlet _ is no longer likely to occur due to the implementation of bank stabilization at Zone A. In addition, the site topography slopes away from the Schuylkill River and Reserve Basin Inlet therefore, COPC would likely be transported toward the interior of the site. __ Transport of the COPC via ground-water movement may discharge COPC into the Schuylkill River. However, transport via ground-water movement are impeded by mechanisms such as natural _ attenuation and dispersion. The potential for downward migration of COPC via water infiltration through surface soil to ground — water would be limited by the low permeability of the native soil, native soil thickness, and low hydraulic gradients across the native soil. As indicated in ground water and constituent transport models presented in the Site Characterization Report, COPC are not likely to migrate to the deep — aquifer over the next 100 years. The most significant pathway for COPC transport away from the GPMA is fugitive dust migration, — which may potentially be inhaled. COPC may migrate as they adsorb to soil particles, which may become airborne as a result of on-site construction or excavation. A complete discussion of site characteristics can be found in the Remedial investigation Report: IR Site 4, the Remedial Investigation Report: IR Site 5, and the Site Characterization Report. Philadelphia Naval Complex. Girard Point Management Area - Record of Decision Page? U.S. Department of the Navy - Northern Division November 1998 6) SUMMARY OF SITE RISKS The Site Risks were estimated based on the following already established Base-Wide Institutional Controls: ! Ground water withdrawn from wells shall not be used or made available for human consumption (Base-wide Institutional Control) ! GPMA shall not be used or developed for any permanent residential uses (Base-wide Institutional Control). ! Any construction or development of an outdoor childcare playground will include the placement of 2 ft of clean fill material, or other cover as approved by PADEP, between the underlying soil and the surface of the childcare playground prior to commencement of any use of the outdoor area as a playground (Base-wide Institutional Control). Human Health The quantitative human health risk evaluation for the GPMA considered two zones, Zone A which considered the presumptive remedy of a cover and Zone B which assumed no cover. Both zones were evaluated independently to determine quantitative risks to human health as a result of exposure to soil. Risk associated with exposure to ground water was evaluated for the entire GPMA. The HHRA assessed the toxicity, or degree of hazard, posed by contaminants related to the site and involved describing the routes by which humans and the environment could come in contact with these substances. Separate calculations were made for those substances that can cause cancer (carcinogenic) and for those than can cause non-cancerous, but adverse, health effects. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) established acceptable levels of carcinogenic risk ranging from one excess cancer case per 10,000 people exposed to one excess cancer case per 1,000,000 people exposed. This translates to a risk range between one in 10,000 and one in 1,000,000 additional cancer cases. Expressed as a scientific notation, this risk range is between 1 .OE-04 and 1 .OE-06. Remedial action may be warranted at a site when the calculated cancer risk level exceeds 1.OE-04. However, since EPA's clean-up goal is generally to reduce the risks to 1 .OE-06 or less, EPA may take action where the risk is within the range between 1 .OE-04 and 1 .OE-06. The NCP also states that sites could pose a health threat due to a non-cancerous, but otherwise hazardous, substance. EPA defines non-carcinogenic threat by the ratio of the contaminant concentration at the site that a person may encounter to the established safe concentration. If the ratio, called the Hazard Index (HI), exceeds one (1.0), there may be concern for potential non- carcinogenic health effects associated with exposure to the chemicals. The HI identifies the potential for the most sensitive individuals to be adversely affected by the non-carcinogenic effects of chemicals. As a rule, the greater the value of the HI, the greater the level of concern. Potential human health risks associated with exposure to the COPC were estimated quantitatively through the development of several hypothetical exposure pathways. These pathways were developed to reflect the potential for exposure to COPC based on the potential future uses and location of the GPMA. The most foreseeable uses are warehousing of light industrial activities. Zone A exposures were not evaluated under a current use scenario since it was assumed that the presumptive remedy, which includes a cover, would be implemented. The future use scenario Philadelphia Naval Complex Girard Point Management Area - Record of Decision r Page? U.S. Department of the Navy - Northern Division November 1998 assumes the presumptive remedy has been implemented, RI data were used to characterize the human health risks. Exposure parameters for each exposure route and receptor were estimated under average exposure (AE) and reasonable maximum exposure (RME) assumptions. Zone A For Zone A, it was assumed the presumptive remedy of a landfill cover was installed and institutional controls would be in place. With this remedy assumed to be in place, only the risk to construction workers was evaluated. The exposure routes evaluated in the HHRA included ! Incidental ingestion of surface soil ! Inhalation of suspended particulate from the surface soil during excavation and construction work. All TCL and TAL data were validated and used for the HHRA. The analytical results were screened using current EPA Region III Risk-Based Concentration (RBC) screening levels. Representative concentrations for each contaminant of potential concern (CoPC) were calculated using the latest risk assessment guidance from EPA. The following table provides the total noncancer and cancer risks at Zone A. Table 1 - Zone A - Total Reasonable Maximum Exposure Risks Exposed Group Noncancer Cancer Construction/Utility Workers 25.46 3.75 x ID'3 This exceeds the EPA Hazard Index of 1.0 for noncancer risk and the recommended risk range of 1 .OE-4 to 1 .OE-6 for cancer risks. ZoneB During the investigation, the presumptive remedy was not assumed at Zone B, therefore total non-cancer and cancer risks were estimated as a result of the potential of exposure of maintenance workers, occasional users/trespassers, and construction/utility workers to ! Incidental ingestion of surface soil ! Inhalation of suspended particulate from the surface soil Lead was also considered a CoPC at Zone B. The following table provides the total noncancer and cancer risks at Zone B. The majority of models assessing risks associated with exposure to lead in soil have been developed for residential scenarios where individuals are exposed continuously, on a daily basis. Recently the Technical Review Workgroup for Lead put together a revised lead model to assess lead soil risks to individuals such as construction workers, maintenance workers, etc. This approach uses a methodology to relate soil lead intake to blood lead levels (BLL) of fetuses in pregnant women. These are presumed to be the most sensitive population. Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 9 U.S. Department of the Navy - Northern Division November 1998 Table 2 - Zone B Total Reasonable Maximum Exposure Risks (Before Removal of Incinerator Soils) Exposed Group Non-cancer Cancer Blood Lead Level* Construction/Utility 7.69 2.551 x 571.54 Worker io- Maintenance 2.70 1.20x 119.07 Workers 104 Occasional 439 2.551 x 119.07 Users/Trespassers io- (adolescents) *Blood Lead Level Values in ug/dL (micrograms per deciliter) This exceeds the EPA Hazard Index of 1.0 for noncancer risk, the recommended risk range of 1 .OE-4 to l.OE-6 for cancer risks, and lOug/dL as a reference blood lead level. It was noted in the investigation that removal of surface soil around the incinerator would reduce the Human Health Risk for the entire Zone B. Below are the calculated risks assuming these soils would be removed to a level below the highest COPC level in the remainder of Zone B. Table 3 - Zone B Total Reasonable Maximum Exposure Risks (After Removal of Incinerator Soils) Exposed Group Non-cancer Cancer Blood Lead Level* Construction/Utility 0.51 6.50 xlO'5 19.70 Worker Maintenance 0.20 7.30 xlO"4 4.11 Workers Occasional 0.51 4.28 x 10'5 4.11 Users/Trespassers (adolescents) *Blood Lead Level Values in ug/dL (micrograms per deciliter) In both areas the BLL for the construction worker was estimated to be above the lOugl dL reference level. The re-evaluation of Zone B does not eliminate the potential risk from exposure to asbestos in soil. Philadelphia Naval Complex Girard Point Management Area - Record of Decision I Page 10 U.S. Department of the Navy - Northern Division November 1998 T Ecological T A qualitative ecological risk assessment considered the GPMA as a whole. Potential receptors considered in this assessment included insectivorous birds, granivorous birds, and herbivorous T small mammals. Exposure to CoPC resulted in unacceptable risk to ecological receptors. Risk to : insectivorous birds resulted from exposure to CoPC through dermal contact with surface soil, and __ ingestion of surface soil, plant material and insects. Exposure pathways for granivorous birds were included dermal contact with surface soil & ingestion of surface soil and plant materials, especially seeds, nuts and fruit. The majority of potential excess risk resulted from exposure to ^ other CoPC, such as PAH and pesticides via dermal contact or ingestion of soil. ' ; ; : Herbivorous small mammals are exposed to CoPC through ingestion of surface soil and plant material, dermal contact with surface soil and ingestion and inhalation of fugitive dust from " surface soil. Erosion control measures have been implemented along the banks of GPMA. These control -r- measures consist of riprap and gabions, which extend horizontally beyond the limit of low tide and \ vertically to the top of the steep slopes of the riverbank The riprap and gabions provide minimal habitat for invertebrates and limit access to river sediment. Access to the inter-tidal zone by — terrestrial animals is also limited by the barren, vertical nature of the gabions. Therefore, direct i constituent release from site surface soils to sediment has been eliminated. In summary the ecological assessment identified the surface soil as posing unacceptable risk through incidental ingestion, dermal contact, and inhalation of dust as well as ingestion of plant material and insects. y 7) DEVELOPMENT AND SCREENING OF ALTERNATIVES Statutory Requirements/Response Objectives Under its legal authorities, EPA's primary responsibility for Superfund is to undertake remedial actions that are protective of human health and the environment. Section 121 of CERCLA established several other statuary requirements and preferences, including: a requirement that an EPA sponsored - remedial action, when complete, must comply wi A all federal and more stringent state environmental standards, requirements, criteria or limitations, unless a waiver is invoked; a requirement that EPA select a remedial action that is cost-effective and that utilizes permanent solutions and alternative — treatment technologies or resource recovery technologies to the maximum extent practicable; and a preference for remedies in which treatment which permanently and significantly reduces the volume, toxicity or mobility of the COPC is a principal element over remedies not involving such treatment. Response alternatives were developed to be consistent with these Congressional mandates. i Based on the reported results and physical characteristics of the GPMA, the principal migration pathways to potential exposures of COPC are limited to soil. Remedial action obj ecti ves (RAO) were identified based on the COPC, environmental media, exposure routes, and potential for risk to human and/or ecological receptors. RAOs were identified for both Zones A & 6 as those which: Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 11 U.S. Department of the Navy - Northern Division November 1998 1. Prevent direct contact and ingestion of soils; 2. Prevent inhalation of airborne asbestos from soil; and 3. Prevent direct contact and ingestion of COPC by ecological receptors. Response actions were developed to meet the RAO. Technologies and process options identified to address the response actions were, then screened considering effectiveness, implementability, and cost associated with achieving the RAO. Remedial technologies and process options were considered in each of three general response action categories: No Action with Monitoring, Limited Action, and Containment Technology and Alternative Development and Screening CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In accordance with these requirements, a range of alternatives were developed for the site. Section 2 of the FS, identified, assessed and screened technologies based on implementability, effectiveness, and cost These technologies were combined into source control and management of migration alternatives. Section 3 of the FS presented remedial alternatives developed by combining the technologies identified in the previous screening process in the categories identified in Section 300.430 (e) (3) of the NCP. The purpose of the initial screening was to narrow the number of potential remedial actions for further detailed analysis while preserving a range of options. Each alternative was then evaluated and screened in Section 4 of the FS. In summary, five of the remedial alternatives screened in Section 2 were retained for detailed analysis Table identifies the five alternatives that were retained through the screening process, as well as those that were eliminated from further consideration. Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 12 U.S. Department of the Navy - Northern Division November 1998 8) DESCRIPTION OF ALTERNATIVES This Section provides a narrative summary of each alternative evaluated. A detailed tabular assessment of each alternative can be found in Table 4.1 of the FS. Long-term shallow ground-water monitoring, as well as site and security inspections are included in all five alternatives. Institutional controls mat provide legal notification of property condition are specified in all but Alternative 1. Long-term shallow ground water monitoring is included in Alternatives 1 and 2. Brief descriptions of each remedial alternative are presented below. It is assumed removal of the incinerator soils and incinerator decontamination will be accomplished to remove source areas in Alternatives 3,4 & 5. Alternative 1: No Action with Monitoring The No Action alternative consists of maintaining current site conditions. However, long-term ground-water monitoring and site inspection will be performed. No remedial actions will be undertaken to reduce potential human health and ecological risk. This alternative serves as a comparative baseline (i.e., existing conditions) alternative, as required by CERCLA. Monitoring programs include ground water sampling on a quarterly basis for the first year and annually thereafter, periodic air monitoring, site and security inspections, and 5-year reviews to evaluate whether additional remedial actions or continued monitoring are required. A report would be generated detailing each five-year review evaluation. This alternative would not meet any of the RAOs. Alternative 2: Limited Action The Limited Action alternative consists of developing and implementing institutional controls, in addition to the monitoring programs described in Alternative 1. Institutional controls (i.e., legal notification of property condition) will be implemented to limit future deterioration of site conditions and to restrict access. This alternative would meet RAOs for 1) direct contact and ingestion of soils and 2) prevent inhalation of airborne asbestos from soil, but would not 3) prevent direct contact or ingestion of COPCs by ecological receptors. This action would also make the area useable for future use. Alternative 3: Permeable Cover The Permeable Cover alternative consists of a geotextile/permeable liner and a vegetated soil cover. The liner will mark the location of the waste, but not eliminate infiltration of water. The cover will consist of two feet of soil which will be vegetated with native grasses and shrubs. This remedy prohibits exposure with the soil to protect human health and the environment. This alternative consists of the following remedial actions: ! Site preparation and modifications to the existing storm-water sewer system and utilities; ! Minor site grading and placement of a geotextile/permeable liner to establish a boundary between existing surface soil and clean fill. This liner will be covered by a 24 inch layer of soil; ! Establishment of institutional controls to restrict access and to minimize deterioration of site conditions; and Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 13 U.S. Department of the Navy-Northern Division November 1998 ! Implementation of long-term monitoring and site inspection programs, as described in Alternative 1. This alternative would meet all RAOs. Alternative 4: Impermeable Cap/Asphalt Layer An impermeable cap which consists of a 12-inch layer of clean fill/soil, covered by a 4-inch asphalt layer. The impermeable asphalt cap would isolate the soil from potential receptors. This alternative consists of the following remedial actions: ! Site preparation, and re-construction of existing storm-water sewer system; ! Construction of additional storm-water sewer lines; ! Minor site grading, supplemental soil filling, and placement of binding and wearing asphalt layers; ! Implementation of institutional controls to restrict access and to minimize deterioration of site conditions; and, ! Implementation of long-term monitoring and site inspection programs, as described in Alternative 1. This alternative would meet all RAOs. Alternative 5: Impermeable Cap/Geomembrane An impermeable cap, which consists of a geomembrane liner and a 2.5 ft soil cover, required for frost protection, will be placed over Zone A. This impermeable cap would isolate COPC in surface and subsurface soil from potential receptors. This alternative consists of the following remedial actions: ! Site preparation, and re-construction of storm-water sewer system; ! Installation of new storm-water sewer lines; ! Minor site grading and placement of a 6-inch support layer, a geomembrane, a 30-inch layer of sandy soil for drainage, frost protection, and revegetation. Environmental restoration would consist of grass and shallow-rooted shrubs since the geomembrane would prohibit installation of deep-rooted trees. Therefore, natural succession to a mature forest would be prohibited since tree roots may impair the geomembrane. Environmental restoration reduces labor cost associated with mowing grass cover and the use of pesticides; ! Implementation of institutional controls to restrict access and to minimize or prevent deterioration of site conditions; and ! Implementation of long-term monitoring and site inspection programs., as described in Alternative 1. This alternative would meet all RAOs. Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 14 U.S. Department of the Navy - Northern Division November 1998 9) SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES Section 121 (b) (1) of CERCLA presents several factors that at a minimum EPA is required to consider in its assessment of alternatives. Building upon these specific statuary mandates, the NCP articulates nine evaluation criteria to be used in assessing the individual remedial alternatives. A detailed analysis was performed on the alternatives using the nine evaluation criteria in order to select a site remedy. The first two threshold criteria described below must be met in order for the alternatives to be eligible for selection in accordance with the NCP. The next five criteria are utilized to compare and evaluate the elements of one alternative to another that meet the threshold criteria, The last two are the modifying criteria used on the final evaluation of remedial alternatives generally after EPA has received public comment on the PJ/FS and Proposed Plan. The following is a summary of the comparison of each alternative's strength and weakness with respect to the nine evaluation criteria. These criteria are given below and summarized in Table 6: Overall Protection of Human Health and the Environment -addresses whether remedies are protective of human health and the environment. A remedy is protective if it adequately eliminates, reduces, or controls all current and potential site risks posed through each exposure pathway at the site. Compliance with ARAR - is one of the statutory requirements for remedy selection. However, CERCLA allows selecting a remedy that will not attain applicable or relevant and appropriate requirements (ARARs) if certain conditions exist Long-term Effectiveness and Permanence - refers to the magnitude of residual risk and the ability of a remedy to maintain reliable protection of human health and the environment over time after cleanup goals have been met. Reduction of Toxicity, Mobility, or Volume - addresses remedies that employ treatment as a principal element by ensuring that the relative performance of the treatment technologies will be assessed. This criterion examines the magnitude, significance, and irreversibility of reductions. Cost - includes capital costs and annual operations and maintenance costs incurred over the life of the remedial action. The present worth cost of the five alternatives are: Alternative 1 $511,000, Alternative 2 $812,000, Alternative 3 $4,429,000, Alternative 4 $5, 257,000, and Alternative 5 $7,404,000. Short-term Effectiveness -refers to the short-term impacts of the remedy on the neighboring community, workers, or surrounding environment This includes potential threats to human health and the environment associated with the removal, treatment, and transportation of hazardous substances. Implementability - is the technical and administrative feasibility of a remedy, as well as the availability of materials and services needed to implement the selected solution. State Acceptance - indicates whether the State concurs with, opposes, or has no comment on the preferred remedy. Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 15 U.S. Department of the Navy - Northern Division November 1998 Community Acceptance - will be addressed in the Responsiveness Summary. For a more detailed comparative analysis of remedial alternatives see Table 4-1 in the FS, (Stone & Webster 1997d). Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 16 U.S. Department of the Navy - Northern Division November 1998 10) THE SELECTED REMEDY The selected remedy was developed by combining components of different source control and management of mitigation alternatives to obtain a comprehensive approach for site remediation. The selected remedy for Zone A, Alternative 3, consists of a permeable cover, which consists of a geotextile/permeable liner and a vegetated soil cover. The selected remedy for Zone A consists of a permeable cover, which consists of a geotextile/permeable liner and a vegetated soil cover. The liner will mark the location of the waste, but not eliminate infiltration of water. The cover will consist of two feet of soil, which will be vegetated with native grasses and shrubs. This remedy prohibits exposure with the soil to protect human health and the environment. It also provides a vegetated buffer between the Schuylkill River (and its ecology) and the area adjacent to GPMA, which is proposed for heavy industrial reuse in the City of Philadelphia's Reuse Plan dated September 1994. The selected remedy for Zone B, Alternative 4, which consists of paving the area returns, the area to its former use as a parking lot and prohibits exposure with the soil to protect human health and the environment. The removal of soils and decontamination of the incinerator remove possible source areas and eliminate exposure to these areas. The institutional controls, five-year reviews, and long term monitoring plan will ensure that the remedy will continue to be protective of human health and the environment. Based on current information, this alternative appears to provide the best balance of the nine evaluation criteria specified by the EPA and outlined above. Description of Remedial Components This Alternative Involves the installation and long-term maintenance of a permeable cover at Zone A and paving at Zone B to mitigate potential risks to potential human and ecological receptors. The installation will consist of the following activities: ! The existing storm-water sewer system will be upgraded. Catch basins and manholes will be cleaned and repaired as necessary. The inlet of catch basins will be raised to the ground surface. Enlargement of the inlet collecting surface area of the catch basins may also be required. Temporary sediment control measurements around the catch basin will be installed to rninimize sediment transport into the existing sewer system. ! Temporary staging areas will be constructed and vegetation, cover material (asphalt, concrete, etc.), and/or debris will be removed, as necessary for design. ! A geotextile/permeable liner will be placed over the existing soil. This liner will be covered by a minimum of 24 inches of soil suitable for supporting vegetation. ! The site will be graded and a vegetative cover (i.e., grass seeding and trees) will be added. ! Institutional controls will consist of placing legal notification of site conditions and limit on-site activities and minimize deterioration of site conditions. ! The following Institutional Controls Ground water withdrawn from welts shall not be used or made available for human consumption (Base-wide Institutional Control) GPMA shall not be used or developed for any permanent residential uses (Base-wide Institutional Control). Philadelphia Naval Complex Guard Point Management Area - Record of Decision Page 17 U.S. Department of the Navy - Northern Division November 1998 Any construction or development of an outdoor childcare playground will include the placement of 2 ft of clean fill material, or other cover as approved by PADEP, between the underlying soil and the surface of the childcare playground prior to commencement of any use of the outdoor area as a playground (Base-wide Institutional Control). Excavation shall not be accomplished without prior written approval of PADEP. ! A long-term shallow ground water monitoring program will be implemented Installation of the covering systems at Zone A will take approximately six to eight months to complete, following design and construction contract award. The ground water monitoring program will involve collecting developing a long term monitoring program, which will be reviewed by EPA and PADEP. Maintaining the permeable cover and individual zone conditions will take two to three weeks per year, which will include repairs to the permeable cover and inspection and maintenance of the existing bank stabilization. To the extent required by law, the Navy will review the site at least once every five years after the initiation of remedial action at the site, since COPC will remain at the site to assure that the remedial action continues to protect human health and the environment. 11) STATUARY DETERMINATIONS The remedial action selected for implementation at the GPMA is consistent with CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of human health and the environment, attains ARARs to the extent practicable and is cost effective. The selected remedy does not satisfy the statutory preference for treatment that permanently and significantly reduces the mobility, toxicity or volume of COPC as a principal element. The Selected Remedy is Protective of Human Health and the Environment The remedy will mitigate the risks posed to human health and the environment by controlling exposures to human and environmental receptors through engineering and institutional controls such as: a permeable cover, access restrictions, institutional controls, and site inspections and monitoring. The Selected Remedy and ARARs This remedy will not attain applicable or relevant and appropriate federal and state requirements that apply to GPMA, since soil that reportedly contains concentrations of COPC above the cleanup standards will not be removed.. However, ARARs were attained to the extent practicable Environmental laws from which ARARs for the selected remedial action are derived, and the specific ARARs are listed in Tables 2-2,2-3, and 2-4 in the FS. These tables are also found in the back of this document. A discussion of why these requirements are applicable or relevant and appropriate may be found in the FS Report in Section 2.0. The primary location-, chemical-, and action-specific ARAR are summarized below: Location-Specific ! Soil - This alternative will not comply with the ARAR in terms of mitigating the presence ofCPC 4 ! Wildlife - This alternative will comply with the requirements of the Endangered Species Act of 1973. This alternative will provide preventative measures to protect native biota from the Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 18 U.S. Department of the Navy - Northern Division November 1998 T potential effects of exposure to COPC. Remedial activities for the site will be designed to T protect against adverse effects to the biota and sensitive habitats. ! Floodplains - The 100-year flood elevation line is 10 ft. Elevations of the river bank along _ the GPMA range from 15 to 18 ft along the southwestern portion of the GPMA at IR Site 4 to 11 to 12 ft along the southern portion of the GPMA at IR Site 5 after bank stabilization. This alternative will meet protection from water of the 100 year flood _ ! Ground -water - ARAR for water quality will be used to evaluate monitoring data generated by the implementation of mis alternative. Chemical-Specific ! Soil - Pennsylvania's Act 2 Statewide Human Health Standards for Non-residential soil are _ the primary chemical-specific ARAR. Tie Permeable Cover alternative will not comply with this ARAR, as soil that reportedly exceeds these clean-up standards will not be removed. Action-Specific : ! Action-specific ARAR identified during the development of this alternative, focus on distributing information to workers and the community before implementing this alternative. — Other action-specific ARAR applicable to this alternative include the federal Clean Air Act and the Pennsylvania Air Pollution Control Act and Regulations, which outline standards of air pollution control. Concentrations of airborne fugitive dust and asbestos may exceed — standards during construction. Since the presumptive remedy was utilized, all of the ARARs were not met. The Selected Remedial Action is cost-effective hi the Navy's judgment, the selected remedy is cost effective, (i.e., the remedy affords overall effectivenessproportional to its costs). In selecting this remedy, the Navy identified alternatives that are protective of human health and the environment, and will attain ARARs to the extent practical. The Navy evaluated the overall effectiveness of each alternative by assessing the relevant three criteria: long term effectiveness and permanence, reduction in toxicity, mobility, and volume through __ treatment, and short-term effectiveness, in combination. The relationship of the overall effectiveness to this remedial alternative was determined to be proportional to its costs. The principal capital cost components for the Permeable Cover alternative, $2,278,000, will be associated with the installation _ of the permeable geotextile cover and fence, and the legal notification of site conditions and/or deed restrictions. The O&M costs incurred by implementing this alternative will be for performing monitoring and site inspection programs, and maintaining the fence and the vegetation cover. The annual cost for the initial two years was estimated to be $ 167,000, followed by annual costs for each of the remaining years of $ 117,000. The total present worth for this alternative was calculated using an interest rate of 5 percent and assuming that O&M activities will extend for a period of 30 years. This resulted hi a present worth cost of $4,429,000. The Selected Remedy Utilizes Permanent Solutions and Alterative Treatment or Resource Recovery Technologies to the Maximum Extent Practicable The selected remedy was evaluated using the best balance of trade-offs among alternatives in terms of: 1) long-term effectiveness and permanence, 2) reduction of toxicity, mobility or volume through treatment, 3) short-term effectiveness, 4) implementability, and 5) cost. The selected Philadelphia Naval Complex Girard Point Management Area -Record of Decision Page 19 U.S. Department of the Navy - Northern Division November 1998 remedy provides the best balance of trade-offs among the alternatives. Listed below is a summary of the five criteria used to evaluate the alternatives: Long-term Effectiveness and Permanence Implementation of the selected Alternative will reduce risk to potential receptors. COPC will be contained by a permeable covering, thereby minimizing contact between COPC and human and ecological receptors. The long-term monitoring and site inspection programs will document the continued effectiveness of this alternative. The long-term effectiveness of this alternative is expected to be high, but the permanence of this alternative will depend upon continual maintenance of the permeable covering system. Reduction of To3ricity, Mobility, or Volume Through Treatment The Permeable Cover alternative does not include any treatment or removal and off-site disposal activities, rather this alternative is designed to isolate soil from receptors. Consequently, this alternative will not reduce the toxicity, mobility, or volume of COPC through treatment However, the toxicity of COPC will be reduced over time through attenuation and degradation. Overall, the Permeable Cover alternative will not satisfy the regulatory preference for treatment as a possible component of a remedial actioa Short-term Effectiveness While implementing mis alternative, mere may be elevated risks to workers and to the environment. Potential elevated risk to workers will result from inhalation of fugitive dust To reduce this risk, workers performing the installation activities may be required to utilize personal protective equipment and/or minimize their exposure to COPC in fugitive dust. Short-term risks to the community will be minimal due to the distance from the site to residential housing. Additional protection measures (e.g. dust control) would be used to mitigate the risks. Short-term impacts to the environment will be minimized, to the extent possible, through the use of common erosion controls such as sedimentation barriers. Concentrations of COPC will not be reduced to a level protective of potential receptors and mis alternative will not provide the controls necessary to reduce the concentrations of COPC in soil. Implementability Technical Feasibility - Construction of a permeable covering will be moderately difficult to implement The implementation of this alternative will require the use of equipment and services commercially available from local vendors. Components and items associated with this alternative are commonly available. Accessibility to the site by the necessary vehicles is also available. The Permeable Cover alternative will not limit or interfere with potential future remedies. Administrative Feasibility - Implementation of the Permeable Cover alternative, including installation of the cover and the supervision of the monitoring programs, will require approval and close coordination with local, state and federal agencies. The implementation of institutional controls and access restrictions associated with this alternative will require administrative and regulatory support from local, state and federal agencies. No administrative difficulties are expected with the implementation of the Permeable Cover alternative. Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page 20 U.S. Department of the Navy - Northern Division November 1998 Cost Capital Cost - The principal capital cost components for the Permeable Cover alternative, $2,278,000, will be associated with the installation of the permeable geotextile cover, and the development and installation of deed notifications and/or zoning restrictions. O&M Cost - The O&M costs incurred by implementing this alternative will be for performing ground-water monitoring and site inspection programs, and maintaining the fence and the vegetation cover. The annual cost for the initial two years was estimated to be $167,000, followed by annual costs for the remaining years of $117,000. Present Worth - The total present worth for this alternative was calculated using an interest rate of 5 percent and assuming that O&M activities will extend for a period of 30 years. This resulted in a present worth cost of $4,429,000. A summary of costs and assumptions for this alternative are presented in the FS. The Selected Remedy does not Satisfy the Preference for Treatment which Permanently and Significantly Reduces the Toiicity, Mobility, or Volume of the COPC as a Principal Element The principal element of the selected remedy is source control, which addresses soil. Since the presumptive remedy is utilized, the selected remedy does not satisfy the statutory preference for treatment as a principal element. Treatment and/or removal of the landfill material were considered impractical due to the heterogeneity and volume of the landfill material, therefore the primary remedial components are source control and containment 12) STATE ROLE PADEP has reviewed the various alternatives and has indicated its support for the selected remedy. State has also reviewed the IR Site 4 RI Report, IR Site 5 Report, IR Site 3 ROD , Site Characterization Report, and FS to determine if the selected remedy is in compliance with applicable or relevant and appropriate state environmental laws and regulations. PADEP concurs with the selected remedy for the GPMA. Philadelphia Naval Complex Girard Point Management Area - Record of Decision Page21 U.S. Department of the Navy - Northern Division November 1998 LIST OF ACRONYMS AND ABBREVIATIONS AE Average exposure ARARs Applicable or Relevant and Appropriate Requirements bgs Below ground surface BRA C Base Realignment and closure Account CERCLA Comprehensive Environmental Response compensation and Liability Act COPC Constituents of Potential Concern DERA Defense Environmental Restoration Account EPA United States Environmental Protection Agency FS Feasibility Study ft Feet GPMA Girard Point Management Area HI Hazard Index IR Installation Restoration Program msl Mean sea level NCP National Oil and Hazardous Substances Pollution Contingency Plan NGVD1929 National Geodetic Vertical Datum 1929 NWPL North West Parking Lot O&M Overhead and Maintenance PADEP Pennsylvania Department of Environmental Protection PAH pofynuclear A romatic Hydrocarbons PCS Polychlorinated Biphenyls QA\QC Quality Assurance\Quality Control RAB Restoration Advisory Board RAO Remedial Action Objectives RCRA Resource Conservation and Recovery Act RfD Reference Dose RI Remedial Investigation RME Reasonable Maximum Exposure SVOC Semi-Volatile Organic Compounds TRC Technical Review Committee UST Underground Storage Tank L- t Philadelphia Naval Complex Girard Point Management Area - Record of Decision Alternative Cost Justification Atemativ* 1: No Action with Monitoring $511,000 Identified only as a base line for comparison. The No Action alternative consists of maintaining current site conditions. However, long-term ground-water and Total This action would meet none of the RAOs. air monitoring and site Inspection will be performed. No remedial actions wfll be undertaken to reduce potential human health and ecological risk. This alternative serves as a comparative baseline (I.e., existing conditions) alternative, as required by CERCLA. Monitoring programs will be performed on a quarterly basis for the first year and annually thereafter. Five year reviews will be conducted Alternative 2: Umltod Action $812,000 This action would limit any access to the site. This alternative The Limited Action Alternative consists of developing and Implementing institutional controls, and Implementing Total would meet RAOs for 1) direct contact and Irtgmtlon of soils and long-term ground-water and air monitoring, and site Inspection programs. Institutional controls (legal notification 2) prevent Inhalation of airborne asbestos from soil, but would not of site conditions and/or zoning restrictions, fencing and signs) win be Implemented to limit future deterioration of 3) prevent direct contact or Ingestlon of COPCs by ecological site conditions and to restrict access, In addition to the monitoring and site Inspection programs described In receptors. This action would also make the area useable for Alternative 1. future use. AMemaUve 3: Permeable Cover Zone A This was the chosen alternative for Zone A, as It meets all RAOs. The permeable cover consists of a geotexHIe/ permeable liner and a vegetated soil cover. This alternative $3.190.000 consists of the fotowing remedial actions: ZoneB Site preparation and modifications to the existing storm-water sewer system and utilities; $1,239 • Minor site grading and placement of a geotaxtHa/permeable liner to establish a boundary between existing surface toll and dean fid. This liner wHI be covered by a 24-Inch layer of son/dean fill; Total • Establishment of Institutional controls to restrict access and to minimize deterioration of site conditions; and $4.429,000 Implementation of long-term monitoring and site Inspection programs described In Alternative 1.. Five-year reviews wHI be conducted. Atematko 4: Impermeable Cap/Asphalt layer Zone A This option meets all RAOs, however, for Zone A. this option An Impermeable cap which consists of a 12-Inch layer of son/clean fill, covered by a 4-Inch asphalt layer. The $3.787.000 would eliminate all wildlife habitat, and viewed as Inconsistent Impermeable asphalt cap will Isolate the soil from potential receptors. This alternative consists of the following ZoneB with and contrary to Navy trustee protection responsibilities. remedial actions: $1.470,000 Therefore, this alternative was chosen for Zone B which was an Site preparation, and re-construction of existing storm-water sewer system; existing parking lot. Construction of additional storm-water sewer lines; Total Minor site grading, supplemental soil filling, and placement of binding and wearing asphalt layers; $5.257.000 Implementation of Institutional controls to restrict access and to minimize deterioration of site conditions; and Implementation of long-term monitoring and site Inspection programs described In Alternative 1. ARemettoeS: Impermeable CaplOeomembmne Zone A This option would meet all RAOs, but an Impermeable cover An Impermeable cap, which consists of a geomembrane liner and a 2.5 ft son cover, required for frost protection. This $5,331.000 described by this alternative was not required. Impermeable cap wilt Isolate the COPC In surface and subsurface soil. This alternative consists of the following ZoneB remedial actions: $2.073,000 Site preparation, and re-construction of storm-water sewer system; • Installation of new storm-water sewer tinea; Total • Minor site grading and placement of a 6-Inch support layer, a geomembrane, a 30-Inch layer of sandy soil for $7.404,000 drainage, frost protection, and re-vegetation. Environmental restoration would consist of grass and shallow- rooted shrubs since the geomembrane would prohibit Installation of deep-rooted trees. Therefore, natural succession to a mature forest would be prohibited since tree roots may Impair the geomembrane Environmental restoration reduces labor cost associated with mowing grass cover and the use of pesticides; Implementation of Institutional controls to restrict access and to minimize or prevent deterioration of site conditions; and Implemerrtation of lonortenn monitoring and site Inspection programs described In Alternative 1. Cost Is total present worth for 30 years at 5 percent. Present worth Is defined as expenditures that occur over time by discounting future costs to a common base year. Table 4 Comparison of Alternatives, Costs & Justification Remedial Protection of Compliance Long- Reduction Short-term Implementability Cost State Community Alternatives Human withARARs Term inTMVw Effectiveness Ranking Acceptance Acceptance Health and Ranking Effectiven through Ranking Ranking Environment ess Treatment Ranking Ranking Ranking Alternative 1 - Poor Poor Poor No Poor Good $511,000 Poor No Community No Action Treatment Total Comments Alternative 2 - Poor Poor Poor No Moderate Good $812,000 Poor No Community Limited Action Treatment Total Comments Alternative 3 - Good Moderate Moderate No Moderate Good Zone A Good No Community Permeable Cover Treatment $3,190,000 Comments ZoneB $1,239 Total $4,429,000 Alternative 4 - Good Moderate Moderate No Moderate Moderate Zone A Good No Community Impermeable Treatment $3,787,000 Comments Cover/Asphalt ZoneB Layer $1,470,000 Total $5,257,000 Alternative 5 - Good Moderate Moderate No Moderate Moderate Zone A Good No Community Impermeable Treatment $5,331,000 Comments Cover/Geomemb ZoneB rane $2,073,000 Total $7,404,000 Good indicates the alternative meets the intent of the criteria. Moderate indicates the alternative partially meets the intent of the criteria. Poor indicate the alternative does not meet the intent of the criteria. To be Determined indicates this criteria will be evaluated following the public comment period. (a) TMV indicates Toxicity, Mobility and Volume. TABLE 5 COMPARATIVE RANKING OF ALTERNATIVES TO NINE CERCLA CRITERIA I I Page 23 U.S. Department of the Navy - Northern Division November 1998 13) RESPONSIVENESS SUMMARY The public comment period for the Proposed Plan ended on July 2,1998 with no public written and only one verbal comment received. The oral comment was made via telephone and requested consideration be given to reusing the incinerator as a crematory. The caller was referred to PEDC for possible reuse consideration. EPA & PADEP have commented on a draft version of this document and their comments have been incorporated. Response to EPA Comments dated June 19, 1998 (letter attached) Responses have been italicized. 1. Comment: Under Section 1- Introduction, long term monitoring is applicable to shallow ground water only and institutional controls restrict use of ground water as a potable source. Response: The Navy agrees with this comment, and the ROD has been prepared to reflect this. 2. Comment: Section 3 identifies institutional controls to protect construction workers as part of the response action but protection of construction workers is not identified as part of the proposed alternative described in Section 1. Since removal of contaminated soil will still result in unacceptable blood-lead levels for construction workers (see Table 3) then institutional controls for prohibition of residential use and protection of construction workers are required. Response: The ROD indicates that GPMA shall not be used or developed for any permanent residential uses (Base-wide Institutional Control), and excavation shall not be accomplished without prior written approval of PADEP. 3. Comment: Page 2 - The year or time frame when removal actions were implemented will be useful. Response: The Navy agrees and has made the changes to the ROD. 4. Comment: Page 3 - A more definitive cleanup level for surface soils surrounding the incinerator and the contaminants to be removed would be more useful than a risk ratio comparison. Page 24 U.S. Department of the Navy - Northern Division November 1998 Response: The Navy agrees and has made the changes to the ROD. 5. Comment: It would be helpful to identify the number of acres covered by landfill cover for Zone A and the asphalt cover for Zone B. It is not clear from the text and the attached drawing is not legible. Response: The acreage is included in the ROD along with a clearer drawing. 6. Comment: Page 4, last paragraph - Table 2 refers to Zone B, not Zone A as stated in the text. Response: The Navy agrees and has made the changes to the document. 7. Comment It is not clear from Table 2 and 3 that Building 668 refers to incinerator soil. Response: The Navy agrees and has clarified this in the ROD. Page 25 U.S. Department of the Navy ^Northern Division November 1998 Response to PIDC Comments dated June 19, 1998 (letter attached) Responses have been italicized. 1. Comment: This inspection (of landfill caps) should be part of the Navy's proposed plan for monitoring. Also, the Navy should take responsibility for long term inspection and maintenance of the bank stabilization. The Navy completed the bank stabilization to contain and control the contaminated area's runoff into the surrounding rivers. Response: We agree inspection of the cover and bank stabilization should be part of the monitoring and maintenance, and will be the responsibility of the Navy as long as it owns the property. Subsequent, responsibility for maintenance may be a matter of discussion during the development of a property transfer agreement. 2. Comment: Finally, the Navy's plan should include demolition of the incinerator building with the stack. The building's poor roof drainage, leaky roof and openings around the windows and doors provide ample opportunity for water and moisture to infiltrate the building thus becoming a safety threat for implosion. Response: Demolition will only encompass the stack. A structural engineering evaluation (Stone & Webster, May 1997) was accomplished which indicated that the structural integrity of the incinerator is currently intact and may become be a hazard only if left to deteriorate for an indefinite period of time. As the City intends to demolish the incinerator, maintenance and inspection will be accomplished until transfer of the property. I I T Page 26 U.S. Department of the Navy - Northern Division November 1998 Response to DOI Comments dated June 18, 1997 (letter attached) Responses have been italicized. Comment: Recently, the U.S. Fish and Wildlife Service's representative to the EPA Region 3 Biological Technical Assistance Group informed us that the Navy is re-considering it's initial thoughts about the landfill cover and may propose to place asphalt over the entire landfill areas. You would agree that replacing the vegetative cover in the landfill areas with an asphalt cover would eliminate all wildlife habitat, and further that this could be viewed as inconsistent with and contrary to our joint protection responsibilities [NCP Section 300.600(b)(2) and (3)] as co- trustees for natural resources (e.g., migratory birds) affected by this decision. Response: Only the area previously a parking lot, will have an asphalt cover. The remainder of the landfill cover -will be a vegetative cover. Page 27 U.S. Department of the Navy - Northern Division November 1998 Response to PADEP Comments dated May 28,1998 (e-mail attached) 1. Comment: Page 1: "Restriction on Excavation without Prior Pennsylvania Department of Environmental Protection (PADEP) Approval". Please rewrite as: "Restriction on Excavation without Prior Approval in Writing by the Pennsylvania Department of Environmental Protection (PADEP)". Response: The wording has been revised as requested. 2. Comment: Please rewrite the sentence to say that "The general land area surrounding the GPMA is NOT densely populated. "Please correct this statement in the Site Background section. The area IS heavily industrialized. Response: This section has been corrected. 3. Comment: "The site was initially marshlands and was reclaimed by extensive filling between 1940 to 1970". Please rewrite this sentence in the Site Background section. How about" The site was marshlands until it was covered with fill material" ? Response: The wording has been revised as suggested 4. Comment: How and where will the incinerator stack and incinerator units be removed and disposed off-site? Response: First all the ash will be removed form the stack and incinerator units. The units will then be cut-up in place and disposed The exterior of the stack will be completely wetted with a water spray. A crane with grapple or clamshell attachments shall be used to dismantle the stack in sections from the top down. The stack debris will be immediately placed in trucks for off-site disposal. r Page 28 U.S. Department of the Navy - Northern Division November 1998 14) REFERENCES Remedial Investigation Report: ER. Site 4 at Philadelphia Naval Base, Stone & Webster Environmental Technology & Services, Final, May 1997 (Stone & Webster 1997a) Remedial Investigation Report: IR Site 5 at Philadelphia Naval Base, Stone & Webster Environmental Technology & Services, Final, May 1997 (Stone & Webster 1997b) Site Characterization Report Girard Point Management Area at Philadelphia Naval Base, Stone & Webster Environmental Technology & Services, Final, September 1997 (Stone & Webster 1997c) Feasibility Study for Girard Point Management Area at Philadelphia Naval Base, Stone & Webster Environmental Technology & Services, Final, October 1997 (Stone & Webster 1997d) Engineering Evluation/Cost Analysis for Building Decontamination/Demolition Girard Point Incinerator - Building 668, Stone & Webster Environmental Technology & Services, Final, May 1997 (Stone & Webster 1997e) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 841 Chestnut Building * ****• Philadelphia, Pennsylvania 19107-4431 June 2,1998 Mr. Emil Klawitter Northern Division Naval Facilities Engineering Command 10 Industrial Highway Mail Stop m2 Lester, Pennsylvania 19113-2090 Dear Mr. Klawitter: As we discussed today by telephone, EPA has the following comments regarding the draft Proposed Plan for the Girard Point Management Area: 1. Under Section 1-Introduction, long term ground water monitoring is applicable to shallow ground water only and institutional controls restrict use of ground water as a potable source. 2. Section 3 identifies institutional controls to protect construction workers as part of the response action but protection of construction workers is not identified as part of the proposed alternative described in Section 1. Since removal of contaminated soil will still result in unacceptable blood-lead levels for construction workers (see Table 3) then institutional controls for prohibition of residential use and protection of construction workers are required. 3. Page 2-The year or time frame when the removal actions were implemented would be useful. 4. Page 3-A more definitive cleanup level for surface soils surrounding the incinerator and the contaminants to be removed would be more useful than reference to a risk ratio comparison. 5. It would be helpful to identify the number of acres covered by landfill cover for Zone A and the asphalt cover for Zone B. It is not clear from the text and the attached drawing is not legible. 6. Page 4, last paragraph-Table 2 refers to Zone B, not Zone A as stated in the text. 7. It is not clear from Table 2 and 3 that Building 668 refers to incinerator soil. Customer Service Hotline: 1-800-438-2474 You may contact me at 215-566-3203 if you wish to discuss these comments further. Sincerely, Harry Hafoold Federal Facilities Branch cc: Sarah Pantemidou OFFICE OF DEFENSE CONVERSION PMKfeipMi Industrial Dmtopmrf Corporation June 19,1998 Mr. Emil Klawittcr, Project Manager Northern Division, Naval Facilities Engineering Command Environmental Division, Code 1821 10 Industrial Highway, Mail Stop 82 Lester, PA 19113-2090 Dear Mr. Klawitter: The City of Philadelphia is pleased to have the opportunity to comment on the Proposed Plan Girard Point Management Area. The City of Philadelphia has concerns with the Navy's preferred alternative because it does not correctly specify that the Navy is responsible for the integrity of the 2 caps and the bank stabilization. The Proposed Plan indicates that EPA's presumptive remedy guidance for the closure of CERCLA Municipal Waste Land Fills has been utilized. As I'm sure your are aware, this guidance requires the inspection and maintenance of land fill caps. This inspection and maintenance program should be part of the Navy's proposed plan for monitoring. Also, the Navy should take responsibility for long term inspection and maintenance of the bank stabilization. The Navy completed the bank stabilization to contain and control the contaminated area's runoff into the surrounding rivers. Finally, the Navy's plan should include demolition of the incinerator building with the stack. The building's poor roof drainage, leaky roof and openings around windows and doors provides ample opportunity for water and moisture to infiltrate the building thus becoming a safety threat for implosion. 2600 Ontre Square West, 1500 Market Street Philaddphia, PA 19102 21W96-8Q20 215-977-9618(0 Mr. Emil Klawitter June 19,1998 Page two Please feel free to contact me at (215) 496-8184 with any questions. Sincerely yours, Naomi A.Robinson Environmental Specialist cc: Julie Van Nostern LoriFlynn Sarah Pantelidou, PADEP Harry Harbold, EPA United States Department of the Interior OFFICE OF THE SECRETARY Office of Environmental Policy and Compliance Custom House, Room 244 200 Chestnut Street IN REPLY REFER TO Philadelphia, Pennsylvania 19106-2904 9 June 18, 1997 Emil Klawitter, P.E. Naval Facilities Engineering Command 10 Industrial Highway Mail Stop #82 Lester, Pennsylvania 19113-2090 Dear Mr. Klawitter: Thank you for providing this office with a copy of your April 7 memorandum which summarizes the April 1 meeting discussion on ecological issues that concern the Philadelphia Naval Base. We appreciate the opportunity to participate in this meeting and field review, and we agree that the meeting was productive and informative. During the field visit portion of the meeting you pointed out the landfill areas (Sites 4 and 5) which comprise the majority of the Girard Point management Area. Although we did not spend much time walking through these areas, our observations of the vegetation correspond generally to the information presented in Section 3 of the November 21, 1996 draft Characterization Report. The existing vegetation is comprised of herbaceous and woody species that ranges from sparse to moderately dense, young growth. Although plans for remediating the landfills remain incomplete, you indicated that the Navy intends to propose that part (half?) of the landfill areas be covered with asphalt with the remainder maintained in vegetation. You also indicated that the Navy would be interested in obtaining the Department's assistance in developing a suitable revegetation plan. Recently, the U.S. Fish and Wildlife service's representative to the EPA 3 Biological Technical Assistance Group informed us that the Navy is re-considering it's initial thoughts about the landfill cover and may propose to place asphalt over the entire landfill areas. You would agree that replacing the vegetative cover in the landfill areas with an asphalt cover would eliminate all wildlife habitat, and further that this could be viewed as inconsistent with and contrary to our joint protection responsibilities [NCP Section 300.600 (b) (2) and (3)] as co-trustees for natural resources (e.g., migratory birds) affected by this decision. I would appreciate an indication as to how the Navy intends to fulfill its trust responsibilities at Girard Point and how the Department of the Interior may be of assistance. A potentially useful contact in this matter is LCDR Dave Fields, Special Assistant for Ship and Air Systems, Environmental Protection Division, Chief of Naval Operations (Code N452), Crystal Plaza Five, Room 654, 2211 South Clark Place, Arlington, Virginia, 222445108, telephone: 703-604-5419, telefax: 703-602-5364. We are informed that LCDR Fields has been tasked to prepare guidance on the Navy's trustee role in such situations. Thank you for your assistance in this matter. Sincerely, Don Henne ' Regional Environmental Officer cc: D. Rosenberger, NRTR, OEPC, WASO D. Densmore, FWS, State College, PA T. Fannin, FWS, Hadley, MA c:\wp51doc\philnav.tru To: JOE M ROCHE,EMIL E KLAWITTER To: PANTELIDOU.SARAHOal.pader.gov From: SMTP Cc: GATEWAYSNORTHDIVCOM[ I have reviewed the draft Proposed Remedial Action Plan for the Girard Point Management Area, Philadelphia Naval Complex, Philadelphia, Pennsylvania. I have the following comments: 1. Page 1: "Restriction on Excavation without Prior Pennslyvania Department of Environmental Protection (PADEP) Approval". Please rewrite as' "Restriction on Excavation without Prior Approval in Writing by the Pennsylvania Department of Environmental Protection (PADEP)*. 2. Page 2 : Please rewrite the sentence to say that "The general land area surrounding the GPMA is NOT densely populated." Please correct this statement in the Site Background section. The area IS heavily industrialized. 3. Page 2: "The site was initially marshlands and was reclaimed by extensive filling between 1940 to 1970". Please rewrite this sentence in the Site Background section. How about "The site was marshlands until it was covered with fill material" ? 4. Page 3: Fourth paragraph: How and where will the incinerator stack and incinerator units be removed and sidposed off-site? This concludes my comments. APPENDIX B GOALS PAPER Philadelphia Naval Business Center Girard Point Management Area Five Year Review div42\brac\042911850\task6A 5YEAR\FINAL5YEARGPMA.doc LONG TERM GROUND-WATER MONITORING PLAN FOR GIRARD POINT MANAGEMENT AREA AT PHELADELPfflANAVAL BASE PHILADELPHIA, PENNSYLVANIA Preparedfor: Department of the Navy Northern Division Naval Facilities Engineering Command 10 Industrial Highway MaiiStopNo. 82 Lester, Pennsylvania 19113-2090 Preparedly: Stone & WebsterEnvironmental Technology & Services 3 Executive Campus, P.O. Box 5200 Cherry Hill, NJ 08034 (609)482-3000 Under contract with: EA Engineering, Science, and Technology 15 Loveton Circle Sparics, Maryland 21152-9201 (410)771-4950 ContractNo. N62472-92-D-1296 Contract Task Order No. 0081 9 December 1998 FINAL EA Project No. 296.0081 S&WProjectNo. 04291.18.10 LONG TERM GROUND-WATER MONITORING PLAN FOR GIRARD POINT MANAGEMENT AREA AT PHILADELPHIA NAVAL BASE PHILADELPHIA, PENNSYLVANIA Contract No. N62472-92-D-1296 Contract Task Order No. 0081 David S.Doyle y Date CTO Manager cyu 98 Charles R. Flynn, Jr. PR.D..PH Date 9 December 1998 FINAL EA Project No. 296.0081 S&W Project No. 04291.18.10 Project J.O. 04291.18.10 Table of Contents Revision: Final PigcTOC-1 Stone & Webster Envtroomcntal Technotojy A Services 1. PURPOSE AND SITE BACKGROUND 1-1 1.1 PURPOSE ,. - l-i 12 SITE BACKGROUND „ : _ „ 1 -l 1.2.1 Human Health and Ecological Risk Assessments - 1-2 13 SUMMARY OF OPTIMIZATION CONCEPTS .. _ — - —1-3 1.3.1 Remedial Goals. - : ~ 1-3 1.3.2 Ground-Water Data Baseline _ ~ 1-3 1.3.3 Goals Paper „„ - - ..-1-4 2. GROUND-WATER MONITORING PLAN 2-1 2.1 GENERAL „ „„.... .~...~ „ - „ ...... ~~ 2-1 2.2 MONITORING WELL SELECTION — ™ — ~ 2-1 2.3 SAMPLING FREQUENCY. - - 2-1 2.4 ANALYTES™ _ 2-2 2.5 PRE-SAMPLING ACTIVITIES _ ~ - , 2-2 2.5.1 Coordination with Laboratory. 2-2 2.5.2 Equipment „ _ 2-2 2.5.3 Monitoring Well Inspection, Security, and Access.„ 2-3 2.6 SAMPLING METHODOLOGY - 2-3 2.6.7 Documentation 2-4 2.6.2 Initial Well Opening 2-4 2.6.3 Water Level Measurements 2-4 2.6.4 Well Purging 2-4 2.6.5 Field Analyses. , 2-5 2.6.6 Sample Containers. Preservatives, and Holding Times 2-5 2.6.7 Sample Collection 2-6 2.6.8 Sample Labels '. _ 2-6 2.6.9 Chain of Custody 2-7 2.6.10 Shipping 2-7 2.6.11 Decontamination 2-7 2.7 QUALITY ASSURANCE/QUALTTY CONTROL ;2-8 2.8 REPORTING REQUIREMENTS „ _ 2-8 2.8.1 Data Management 2-8 2.8.2 LTM Report Format. 2-9 3. EVALUATION OF GROUND-WATER DATA 3-1 3.1 EVALUATION OF 1996-1997 GROUND-WATER DATA BASELINE „....;. 3-1 3.1.1 Seasonally. 3-1 3.1.2 Evaluation. 3-2 3.1.3 Confirmation Sampling. „ 3-3 32 MONITORING ENDPCHNT AND OPTIMIZATION 3-4 4. REFERENCES 4-1 Plaladdiihk N«nl Bate: Gtiwl Point Mm(c«nea( Aica Long Tenn Ground-Water Monkaring PUn Project; J.O. 04291.18.10 TaMe of Contents Revision: Final P»gcTOC-2 Stone * Webster Environmental Technology & Services T f ACRONYMS AND ABBREVIATIONS AWQC EPA Ambient Water Quality Criteria BCT BRAC Cleanup Team BGS Below Ground Surface BRAC Base Realignment and Closure Act . CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CLP EPA Contract Laboratory Program COC Chain of Custody COPCs Constituents of Potential Concern CRDLs Contract Required Detection Limits CTO Contract Task Order DOW Depth of Well DQOs Data Quality Objectives DTW Depth of Well DUP Duplicate EA EA Engineering, Science and Technology EEQ Environmental Effect Quotient EPA United States Environmental Protection Agency FT Feet GPMA Girard Point Management Area HN03 Nitric Acid DDLs Instrument Detection Limits IR Installation Restoration Program LTM Long Term Ground-Water Monitoring LTMP Long Term Ground-Water Monitoring Plan MS Matrix Spike MSD Matrix Spike Duplicate NFESC Naval Facilities Engineering Service Center NWPL Northwest Parking Lot ORP Oxidation Reduction Potential PADEP PennsylvaniaDepartment of Environmental Protection PAHs Polycyclic Aromatic Hydrocarbons PCBs PoIychlorinatedBipbenyls pH Chemical Measurement Philadelphia Naval B*sc Gtnrf Point Management Ana Long Tcnn Ground-Water Monitoring Wan Project: J.O. 04291.18.10 Tabfe of Contents Revision: Final PageTOC-l Stone a Webster Environment Technotefy A Services LIST OF TABLES / No. Table Name Location in Plan ' -r 1-1 DQOs for the GPMALTM Program Section! 2-1 Ground- Water Monitoring Well Information Section 2 2-2 Analytical Methods Section 2 - 2-3 Laboratory Reporting Limits Section 2 2-4 Field QC Samples Section 2 MV LIST OF FIGURES No. Figure Name Location in Plan ~ 1-1 Site Locus Map, Girard Point Management Area Section 1 1-2 Site Location Map, Girard Point Management Area Section 1 2-1 Ground-Water Monitoring Well Location Plan Section 2 LIST OF APPENDICES I Appendix Title A USEPA Contract Laboratory Program Statement of Work for Inorganics Analysis, Multi-Media Multi-Concentration B USEPA Region I - Low Stress (low flow) Purging and Sampling Procedures for the Collection of Ground Water Samples from Monitoring Wells C Ground-Water Sampling Checklist D Examples of Ground-Water Field Analysis Forms E Examples of Evaluation Tables Philadelphia Nivit Base Girard Point Mtwgement Area tone Tom Grou»J-W«ler Mooaorint Pirn dt*42\brac\M29Uttoa&4. MtmprSMoc Project: J.O. 0429l.IS.IO Table of Contents Revision: Find P»geTOC-3 Stone A Web ottTectaolocy ft Services pro Pbotoionization Detector PVC Polyvinyl Choride QA/QC Quality Assurance/Quality Control RB Equipment Rinsate Blank RBC EPA Region HI Human Health Risk Based Concentrations RCRA Resource Conservation and Recovery Act ROD Record of Decision Stone & Webster Stone & Webster Environmental Technology & Services SVOCs Semi-Volatile Organic Compounds TAL EPA Target Analyte List TCL EPA Target Compound List VOCs Volatile Organic Compounds micrograms per liter PMaddpKt tovri Bar GwJ ft** Mw^onaK Am LM« Tenn Ground- V/»a Maahara« ftoi ;! ' Project J.O. W291.18.10 ', _ Purpose and Site Background " Revision: Final _ . , ' Page 1-1 A Stone fcWtbsterEnvironn*iiU>Tecftnototyfc Services I. PURPOSE AND SITE BACKGROUND _ ., 1.1 Purpose Stone & Webster Environmental Technology & Services (Stone & Webster), under contract to EA _ . , Engineering, Science and Technology (EA), developed this Long Term Ground-Water Monitoring Plan (LTMP) for the Girard Point Management Area (GPMA). Implementation of a Long Term Ground- Water Monitoring (LTM) program was identified in the Conceptual Site Model for the Girard Point _ < •- Management Area1 as one of the remedial goals for the GPMA (Stone & Webster, 1996a). The objectives of the monitoring plan, were identified in the Goals Paper, Ground-Water Monitoring Program for Girard Point Management Area3 (Stone & Webster, 1998c). The purpose of this LTMP is to document the wells selected for monitoring, analytical parameters, monitoring frequency, and the methods of data acquisition, handling, reporting, analysis, and _ ' • interpretation. This LTMP also presents a framework for future modifications based on the results of monitoring and data trends. It was prepared under the terms of Contract Number N62472-92-D-1296 and the Navy's Statement of Work for Contract Task Order (CTO)No. 0081. ' 1.2 Site Background _ The GPMA is a peninsula located in the northwest area of the Philadelphia Naval Base3 at the confluence of the Schuylkill and Delaware Rivers as shown on Figures 1-1 and 1-2. The 1-95 Girard Point bridge, spanning the Schuylkill River, passes directly over and bisects the site. \ The GPMA is a generally flat, vegetated, 25-acre site, historically used for the treatment, storage, and disposal of solid wastes generated at the Philadelphia Naval Base. Landfilling created portions of the _ f' area associated with these waste management activities. Landfills at the site contain construction debris, incinerator ash, suspected foundry slag/sand, spent blasting grit used for paint removal, and municipal waste as well as soil and fill materials (river dredge materials). The individual sites that comprise the GPMA share a similar site history and proposed future use. Therefore, a Conceptual Site Model (Stone & Webster, 1996a) and a Site Characterization Report for — the Girard Point Management Area4 (Stone & Webster, 1997c) were prepared to combine the available data, characterize the nature and extent of constituents of potential concern (COPCs) throughout the GPMA, and evaluate the risks posed to potential receptors. The future use of the ~ GPMA is light industrial, consisting of warehousing and light industrial facilities; as part of the proposed 89-acre Girard Point Industrial Park. 1 Hereinafter referred to as the Conceptual Site Model 2 Hereinafter referred to as the Goals Paper 3 Renamed as the Philadelphia Naval Business Center. Formerly referred to as die Philadelphia Naval Base, Philadelphia Naval Shipyard, and Philadelphia Naval Complex. 4 Hereinafter referred to as the Site Characterization Report PhUaddphU Nivil Bee: GimxJ Point Mmccment Area Long Tenn Ground-Wtfcr Monitoring Man Project: J.O. 04291.18.10 ' Purpose and Site Background Revision: Fina' Page I-; T A Stone & Webster Envircmiiieml Technology & Soviets ______^__ In order to evaluate the. nature and extent of the COPCs at the site and the risk posed to potential receptors, GPMA was divided into two operable units: Zones A and B. Zone A, consists of the two site landfills at Installation Restoration Program (IR) Sites 4 and 5 and a 7-acre area formally used to store — . spent blasting grit (referred to as the area west of the Northwest Parking Lot [NWPL]). This zone covers ah area of approximately 19 acres. Zone B consists of a former transformer storage area (IR Site 3), former Resource Conservation and Recovery Act (RCRA) storage facility (the NWPL], and the — former Girard Point incinerator (Building 668). Zone B covers an area of approximately 6 acres. Landfilling created portions of Girard Point associated with these waste management activities. Zones A and B contained approximately 366,000 cubic yards of fill. ~~ 1.2.1 Human Health and Ecological Risk Assessments Based on the human health and ecological risk assessments, presented in the Site Characterization Report (Stone & Webster, 1997c), unacceptable risks were quantified for potential human receptors in Zones A and B and qualified for ecological receptors throughout the GPMA. It was assumed as part of ~" the human health risk assessment presented in the Site Characterization Report (Stone & Webster, 1997c) that the selected presumptive remedy was implemented at Zone A5. Human health risks associated with Zone A surface soil were not addressed since the presumptive remedy included ~" installation of an effective soil cover. The quantitative human health risk assessment concluded that the exposure to beryllium, copper, and ~" lead concentrations hi Zone A soil resulted in risks above the United States Environmental Protection Agency (EPA) accepted risk levels for cancer and/or noncancer effects. No unacceptable risk was estimated for exposures to COPCs in ground water. Incomplete exposure pathways were assumed for surface water and sediment, therefore no risks were estimated. The majority of risk-driving concentrations of COPCs at Zone B were located in the vicinity of Building "" 668, the former incinerator. The human health risk assessment was re-evaluated at Zone B assuming the completion of an Early Removal Action including the excavation of surface soil along the northern and _ eastern perimeter of Building 668 (Stone & Webster, 1997c). The re-evaluation resulted in the estimation of no significant risk to human receptors with the exception of potential for exposure to airborne asbestos from the NWPL and the area west of me NWPL. • _ The qualitative ecological risk assessment throughout the GPMA concluded that there is potential for unacceptable risk resulting exposure to COPCs (metals, semivolatile organic compounds (SVOCs) including polycyclic aromatic hydrocarbons (PAHs), polychlorinatedbiphenyls (PCBs), and pesticides) in surface soil. No complete exposure pathways were identified for ecological receptors to subsurface soil, ground water, surface water, or sediment - The presumptive remedy approach was used as a too! to define the remedial goals and select remedies that address the most significant exposure pathways. This approach was developed using die EPA directive, Presumptive Remedy for CERCLA Municipal Landfill Sites (EPA, 1993b). Philadelphia N«val Base: CBntrd Point Mtnagemeat Arc* Long Tom Ground-WMer Monitoring Plan i ' Page 1-3 i A Stone ft Wcbaer Environmental Technology ft Services f1 13 Summary of Optimization Concepts i 4 7.5.7 Remedial Goals I, The selected remedy for Zone A of the GPMA, based on screening of alternatives and the detailed analysis as presented in the Feasibility Study for Girard Point Management Area6 (Stone & Webster, 7' 1997d) and the Proposed Plan for Girard Point Management Area' (Navy, 1998) is construction of a : permeable cover consisting of geotechnical permeable liner, a vegetated soil cover, establishing institutional controls, and implementing a LTM program. This remedy prevents exposure of soil to ' ' receptors therefore prohibiting human and environmental health risks. Treatment and/or removal of the GPMA landfill material were considered unpractical due to the heterogeneity and volume of the , t landfill material, therefore the primary remedial components were source control and containment ] (Stone & Webster, 1997d). Remediation of surface soil containing PCBs at IR Site 3 was completed during September 1996 in compliance with a revised ROD signed in December 1995. Early Removal Actions were also implemented to focus remediation on the most critical areas of concern, and to facilitate source control and containment. Removal and disposal of surface soil at Building 668 and installation of asphalt pavement at the NWPL and a portion of the area west of the NWPL have been initiated to address the potential exposure to airborne asbestos and surface soil COPCs.. 7.5.2 Ground-Water Data Baseline A ground-water monitoring program had been implemented, as a component of the selected remedy, to address potential environmental concern related to leaching of landfill material and discharge of COPCs from the shallow ground water to the Schuylkill River and the entrance to the Philadelphia . Naval Base Reserve Basin. The existing 18 GPMA ground-water monitoring wells were divided into 2 groups; 4 wells located in the upgradient flow direction (i.e., upgradient wells) and 14 wells located in the GPMA and downgradient flow direction (i.e., downgradient wells). Quarterly ground-water sampling of the 18 shallow wells, using EPA low-flow sampling procedures was conducted during the weeks of 8 July 1996,4 October 1996,24 February 1997, and 5 May 1997. Ground-water samples were collected using peristaltic pumps and analyzed for EPA Target Compound List/Target AnalyteList (TCL/TAL) parameters. TCL/TAL analyses included volatile organic compounds (VOCs), SVOCs, pesticides, PCBs, cyanide, and total (unfiltered) metals. Analysis for total dissolved solids was also performed. Based on the results of the first round of ground-water samples, it was concluded that dissolved (filtered) metals and asbestos analyses were unwarranted. A letter report dated 17 July 1997 presented a one year status report detailing the quarterly sampling • results (i.e., baseline), and recommendations addressing future ground-water monitoring (Stone & Webster, 1997a). Ground-water data from the four quarterly sampling rounds were compared to EPA Region III human health Risk Based Concentration (RBC) tap water screening criteria and EPA freshwater chronic Ambient Water Quality Criteria (AWQC). As discussed in Section 12.1, the 6 Hereinafter referred to as the Feasibility Study 7 Hereinafter referred to as the Proposed Plan UtiUddphia Naval Btse: Girard Point Maugoneht Aitm Long Tern Ground-Waer Monitoring Plw Stone ft Webster Environments! Technology A Soviets quantitative health human risk assessment concluded that no unacceptable human health risk was estimated for exposures to COPCs in ground water. Incomplete exposure pathways were assumed for surface water and sediment, therefore no associated human health risks were estimated. Therefore, comparison to RBC tap water screening criteria was assumed to be unessential for future ground-water monitoring needs. Eleven (11) metals were identified as the primary COPCs in ground water based on that comparison to the AWQC (EPA, 1993c). Maximum Environmental Effect Quotient (EEQ) values were calculated to aid hi comparison and review of the results. Each maximum EEQ is calculated by dividing the maximum reported concentration by the associated AWQC. According to the EEQ screening approach, if the EEQ exceeds unity, a potential for ecological risk exists. However, dilution factors associated with ground-water discharge to the Schuylkill River were not considered during the preliminary comparison to AWQC and calculation of the EEQs. These dilution factors which were estimated to be one to five orders of magnitude (Stone & Webster, 1997b) reduce concentrations of COPCs to below the AWQC screening levels and EEQs to less than unity. J.3.3 Goals Paper Data Quality Objectives (DQOs) were developed in accordance with EPA Guidance for the Data Quality Objectives Process (EPA, 1994), as part of the Goals Paper (Stone & Webster, 1998c). Table 1-1 presents a brief description of each step and how it was addressed as part of the GPMA ground-water monitoring program. Based on use of the DQOs development process and data evaluation presented in the Goals Paper (Stone & Webster, 1998c), the number of wells sampled and list of COPCs were reduced to 10 monitoring wells arid 9 metals (arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, and zinc), respectively. As stated in Table 1-1, the following decision rule and recommendations were established to verify that the nine metals remain at concentrations that do not pose a potential for ecological risk: • Evaluate the existing ground-water data baseline for seasonality. • If discernible seasonality is not present, maximum concentrations of the July and October 1996 sampling rounds and February and May 1997 sampling rounds will be used to represent 1996 and 1997 annual concentrations, respectively. • Annual sampling of the 10 monitoring wells and analysis of 9 metals for a duration of 5 years. This approach is consistent with conclusions presented in the Feasibility Study (Stone & Webster, 1997d) and the Proposed Plan (Navy, 1998), and federal and state regulations • The monitoring endpoint will therefore be based on consensus by the Base Realignment and Closure Act (BRAC) Cleanup Team (BCT) that the decision rule stated in Table 5-1 has been satisfied. That rule says: "If maximum EEQs for nine metals (arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, and zinc) remain below unity (when considering dilution factors of one to five orders of magnitude) during a five-year period, then the GPMA ground- water monitoring program will be terminated." / Philadelphia Ncvd Btse: Cinrd Point Mmgement Area Long Tom Ground-W«erMoohorin| Pl« Project; J.O. 04291.18.10 Purpose and She Background Revision: Rn*J r * Page 1-5 . i A Stooe & Webster Environmental Technology i Services . ]. • Confirmation sampling will be conducted on any of the 10 monitoring wells sampled during • ' the annual sampling rounds, if a maximum EEQ exceeds unity (considering a dilution factor of 3 orders of magnitude). If confirmation sampling EEQs exceed unity (considering a dilution | factor of 3 orders of magnitude), then the EEQs will be evaluated considering dilution factors : of four and five orders of magnitude. PADEP will be contacted if confirmation sampling is t. conducted. • If the decision rule is not met, PADEP will be contacted, ground-water monitoring will be ,, conducted beyond the initial five-year period, and a ground-water monitoring decision tree will be developed. PhOadelphU Naval Bate: Gkard Pofatt Management Area Long Tenn Ground-Water Monitoring Plan Project J.O. 04291.18.10 Purpose and Site Background Revision: Final Page 1-6 Stone ft Webster Environmental Technology A Senrtoei TABLE M DQOs for the GPMA LTM Program Step Description GPMA Relevance Stepl: Review prior studies and Site Characteristic Report (Stone & Webster, 1997b), Feasibility Study (Stone & Webster, 1997c), and Proposed State the existing information to Plan for Girard Point Management Area (Navy, 1998) have defined the human health and ecological risks of the Problem gain a sufficient GPMA. The "problem" is defining the objectives (i.e., goals) and endpoint of the LTM program. Primary decision understanding to define maker is the BCT and relevant deadlines are unknown. the problem. Identify primary decision maker and relevant deadlines. Step 2: Identify what questions GPMA LTM program has been focused on potential risks associated with diffuse ground-water to surface water Identify the the study will attempt to discharge and aquatic receptors. The overall goals of the LTM program arc collection of representative ground-water Decision resolve, and what actions samples from the existing shallow ground-water monitoring for analysis of COPCs, calculation and evaluation of may result maximum EEQs considering dilution factors, and verification that the COPCs remain at concentrations that do not pose a potential for ecological risk. ' Step 3: Identify information A ground-water data baseline was established based on four quarterly sampling rounds conducted from July 1996 to Identify the (e.g., sources, action May 1997 in order to address potential environmental concern related to leaching of landfill material and discharge of Inputs to level information, COPCs from the shallow ground water to the Schuylkill River and the entrance to the Philadelphia Naval Base the analytical methods Reserve Basin. Data were screened and EEQs calculated using AWQC to address ecological risk. According to the Decision requirements) needed to EEQ screening approach, if the EEQ exceeds unity (i.e., one), a potential for ecological risk exists. However, resolve the decision dilution factors associated with ground-water discharge to the Schuylkill River were not considered during the statements). preliminary comparison to AWQC and calculation of the EEQs. These dilution factors which were estimated to be one to five orders of magnitude (Stone & Webster, 1997b) could reduce concentrations of COPCs to below the AWQC screening levels and EEQs to less than unity. Ground-water data collected from shallow monitoring wells during the pending LTM program will be evaluated using EEQs and dilution factors. Step 4: Specify the time periods Ten (10) of the 18 existing shallow ground-water monitoring wells will be used to monitor concentrations of COPCs. Define the and spatial area to which COPCs consist of nine metals: arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, and zinc. The Study decisions will apply. July 1996-May 1997 ground-water data baseline will be evaluated for seasonally. If discernible seasonality is not Boundaries Determine when and present, sampling will be conducted annually (i.e., once per calendar year). where data should be collected. Philadelphia Naval Base: Girwd Point Management Area 4 Long Term Groond-Wmpr Mon!"* "- Plan,, ' -— { — j ^ " = T? II £ « .2 § '= : o> II l| II . 8 ll 11 n { C £ f / X ^EF>,JrT XX / X /••--JJ^ M wre 1-1 Site Locus Map Philadelphia Naval Base Girard Point Management Area Stone & Webster Engineerir% Corporation Cherry Hill, NJ Scale; 1 In.- 2000 ft for NGVD 1929 Philadelphia Naval Base Date: 1994 Source: USGS 7.S Minute Philadelphia Qgadrangle I.O. 04291.01.40 J--, LECtKO ' ' vj Im 8 • Bkirinow Concrete Pwmwl ' 'i FIGURE 1-2 SITE LOCATION MAP GIRARD POINT MANAGEMENT AREA i msra twwMW* itoiawf /«sown /l>V\ MWt HU.W OMM Project J.O. 04291.18.10 Ground Water Monitoring Plan Revision: Final Page 2-1 A Stone & Webster Environment*! Technology & Service 2. GROUND-WATER MONITORING PLAN 2.1 General Underlying the GPMA is a shallow unconfihed aquifer consisting of fill material and Recent Alluvium deposits. Shallow ground-water velocity is estimated at 26 feet/year in a southerly direction across the GPMA with a bias towards the Schuylkill River. Ground water in the shallow unconfined aquifer becomes tidally influenced as it approaches the shoreline. Ground-water level observations reported at one of the IR Site 4 wells (4-MW-4) were that the river tidal cycle and ground-water level cycle were out of phase (i.e., high tide corresponds to low ground-water level in 4-MW-4 and vise versa). Stone & Webster concluded that for every 5 to 8 feet (ft) of river elevation, there is a corresponding 1 to 2 ft response in the ground-water level of 4-MW-4 (Stone & Webster, 1997b). An underlying confined aquifer is separated from the shallow water table aquifer by a layer of silt that ranges from 30 to 55 ft in thickness. Stone & Webster calculated the rate of downward ground-water movement to be 0.2 ft/year. Conclusions of ground-water modeling were that COPCs would not reach the underlying confined aquifer in 100 years (Stone & Webster, 1997c). 23, Monitoring Well Selection Ten (10) monitoring wells have been selected from the 18 existing wells based on conclusions of the Goals Paper. Three wells have been selected to monitor ground water as it travels from the upgradient direction (i.e., northern boundary of the GPMA), one well located downgradient of the NWPL and east of the center of the GPMA to monitor ground water as it moves across the center of the site, and six downgradient wells located at IR Sites 4 and 5, in areas containing the greatest fill depths and adjacent to the surface water bodies, of concern (Schuylkill River and the entrance to the Reserve Basin). Monitoring well locations and ground-water flow direction is shown on Figure 2-1. Table 2-1 lists the wells selected for monitoring and relevant survey information. 23 Sampling Frequency Ground-water samples from the 10 monitoring wells listed in Table 2-1 will be collected annually. The first annual sampling round was conducted in November 1998. Remaining annual sampling rounds will be conducted in the spring of each year (April/May), in accordance with the procedures outlined below, Due to tidal influences discussed in Section 2.1, annual samples will be collected during low tide. The rationale is that ground-water elevations of those wells located along the riverbank are at the highest elevation during low tide. Therefore, sampling at low tide may result in collection of ground water during maximum contact with the fill material, maximum sample volume, and potentially the lowest turbidity values. In addition, weather data including amount of precipitation, barometric pressure, and high and low daily temperatures for the 30-day preceding each annual sampling round will be reported in each sampling report. This information which is available from the National Weather Bureau will be evaluated to further assess climatic affects on the shallow ground-water aquifer. PhBwlelphttNcval Base: Gwri Pofot Maageracnt Are* Long Tom Ground-W*cr Monhoring W« JtvJ2\lmKW29U8\tajtJ.3\ltmprvS.doc Project J.O, 04291.18.10 l Ground Water Monitoring Plan Revision: Final—r Page 2-1 ! A Stone & Webster Environmental Technology & Service 2.4 Anatytea Ground-water samples will be collected and submitted to an off-site laboratory for analysis of nine — metals. Table 2-2 specifies each analyte and the associated analytical method and method number. Analytical methods proposed for use during the LTM program are consistent with those used during the baseline ground-water study at GPMA. _ Copies of EPA Contract Laboratory Program (CLP) analytical methods are provided in Appendix A. Instrument detection limits (IDLs) and Contract Required Detection Limits (CRDLs) for each ianalyte _ are listed in Table 2-3. AWQC are also included in Table 2-3 for comparison purposes. AWQC are potentially applicable ground-water standards for GPMA. CRDLs should be below applicable standards if data are to be considered useable. In three cases (i.e., cadmium, copper, and mercury), — the CRDLs are not below the associated AWQC. IDLs for cadmium and copper are below AWQC. Laboratories will report analyte concentrations that are below the CRDL but above the IDL. These data are usually qualified but provide the data user with valuable information, especially in situations — where the applicable standard is below the CRDL, but above the IDL. 2.5 Pre-Sampling Activities 2.5.7 Coordination with Laboratory Sampling activities will be closely coordinated with the contract laboratory. The laboratory will be contacted approximately two weeks prior to commencement of sampling. Arrangements will be made with the laboratory to prepare and deliver laboratory sample supplies to a specified location. ~ Sample supplies to be provided by the laboratory include: 1) sample containers ~~ 2) preservatives 3) labels 4) chain of custody (COC) forms ~ 5) custody seals 6) sample coolers . _ 2.5.2 Equipment The following equipment is required to conduct low-flow ground-water sampling: 1) copy of the LTMP 2) waterproof bound logbook 3) laboratory sample supplies (See Section 2.5.1) 4) extra coolers and packing 5) peristaltic pumps 6) Teflon®-lined polyethylene tubing : 7) 500-milliliter glass beakers/graduated cylinder _ 8) gloves and safety goggles 9) water, level indicator - Philadelphia N*vaIB«se:CHrwd Pobit Mmtemct* Aict — Long Term Ground-Water Monitoring Pba /? Project J.O. 04291. J8.IO «•„ . Ground W«cr Monitoring Plan Revision: FraaJ __', • " Page2-3 Stone A Webster Environment!! Technology & Service 10) flow through cell equipped with: pH meter thermometer conductivity meter oxidation reduction potential (ORP) meter dissolved oxygen meter turbidity meter 1 l)photoionization detection (PID) meter 12) deionized water 13) decontamination supplies 14) graduated purge water container (minimum 5 gallons) 15) keys to well locks 16) ice or blue ice packs 17)ziplocbags 18) indelible marker 19) tape 2.5.5 Monitoring Well Inspection, Security, and Access Monitoring well locations are shown on Figure 2-1. Monitoring wells will be inspected for evidence of damage or tampering. Observations will be recorded in the field logbook. Each well has a keyed-alike lock. Monitoring wells are located on property owned by the United States Navy. Access to the property is controlled and arrangements must be made for entry through Northern Division. 2.6 Sampling Methodology Typically, ground-water sampling entails two phases: 1) monitoring well evacuation (i.e., purging) procedures to allow representative ground water to enter the well followed by; 2) ground-water sampling procedures. Conventional purging and ground-water sampling procedures were designed with emphasis on assessment of water quality of highly productive homogeneous drinking water aquifers. In contrast, remedial investigation monitoring wells are typically installed in low-yield heterogeneous geologic formations. One of the concerns of conventional high-flow water well purging and sampling procedures was increased turbidity within the well. EPA therefore established the low-flow (minimal drawdown) ground-water sampling procedures for collection of representative samples at remedial investigation sites that present a variety of hydrogeologic settings. Details, as well as advantages and disadvantages of low-flow (minimum drawdown) sampling procedures are discussed in the EPA document, Low-Flow (Minimal Drawdown) Ground-Water Sampling Procedures (EPA, 1996). As discussed in Section 1.3.2, the GPMA ground-water data baseline was established using peristaltic pumps and EPA low-flow sampling procedures. Stone & Webster prepared a memorandum report (Stone & Webster, 1998b) describing advantages and disadvantages of available LTM sampling equipment. The Navy decided that non-dedicated peristaltic pumps be used for the ground-water program at the GPMA. Philadelphia N*v«t Best: Ginrd Point Management A^a Long Term Ground-Wafer Monitoring Plan Project J.O. 04291.18.10 Ground Wacr Monitoring Plan Revision: Final Psgc2-4 A Stone &Webgtf Environmental Tcchno>Q8y& Service The wells to be sampled are listed in Table 2-1. Each well will be sampled in accordance witi EPA Region I, Low Stress (Low Flow) Purging and Sampling Procedure for the Collection of Ground Water Sampled from Monitoring Wells' (EPA, 1996b), and the requirements of this LTMP. The EPA Low Flow Procedure is included in Appendix B. A checklist of sampling steps to be followed is included in Appendix C. 2.6.1 Documentation Data collected in the field shall be recorded in a waterproof, bound, field logbook. Data will be recorded in the logbook using black indelible ink. Refer to Section VII Field Logbook of the EPA Low Flow Procedure (See Appendix B) for a summary of information that should be recorded in the logbook. Data will be transferred from the logbook to Field Analysis Forms (See Appendix D) for inclusion in the yearly report. 2.6.2 Initial Well Opening Upon removing the well casing protective cover and the locking cap, any odors noted will be recorded. Immediately upon removing the well cover, the headspace of the well shall be monitored for total VOCs using a PID. 2.6.3 Water Level Measurements Prior to well purging or sampling, ground-water elevation measurements will be made usipg an electronic water level indicator. Water levels will be recorded from a known reference point on the top of the well (i.e., polyvinyl chloride (PVC) casing) and will be recorded to the nearest 0.01 ft. The probe will be decontaminated using distilled water between sample points. The depth to water will be measured in each well using the decontaminated water-level indicator. Depth to water will be determined with as little physical disturbance of the water in the wells as possible (i.e., do not lower the probe below the water surface any iurther than necessary). Water level measurements for all monitoring wells included in the program shall be taken on the same day during low tide. Due to tidal influences, depth to water should be measured in the six wells located along the shoreline in as short a time period as reasonably possible. It is recommended that two people measure the depth to water in these wells simultaneously (i.e., each person collects water level measurement from three wells). 2.6.4 Well Purging Prior to sampling, each well will be purged in accordance with Section IV Purging and Sampling Procedures, Subsections I through 3, of the EPA Low Flow Sampling Procedure (See Appendix B) The purpose of well purging is to remove stagnant well water so that a representative sample can be obtained. Water drawdown during purging shall be less than 0.3 ft. * Hereinafter referred to as the EPA Law Flow Sampling Procedure Phn«driphl«N«vilB«sc:Girwd Point Mmttanca Are* Long Term Ground-Wrta Monitoring Pfan ProjectJ.O. 04291.18.10 Ground Water Monitoring Plan Revision: Final Page 2-5 Stone & Webster Environment*! Technology & Service Wells will be purged using an adjustable rate, low flow peristaltic pump. This will be accomplished by connecting the tubing to the pump, lowering the tubing into the well so that the lower (intake) end of the tubing is located at approximately the midpoint of the saturated well screen, and pumping the well water into the purge water container. Tubing which comes into contact with well water must be constructed of a material that will not alter sample integrity. New clean polyethylene tubing will be used for each well during each sampling round. Purging shall continue until field parameters have stabilized. The purging flow rate shall be reduced to the minimum capabilities of the pump (i.e., 0.1 to 0.2 liters/minute) to ensure stabilization of indicator parameters. Drawdown within the well during purging will not exceed 0.3 ft, as measured using decontaminated water level indicator. 2.6.5 Field Analyses Field analyses will be conducted in accordance with Section IV Purging and Sampling Procedures, Subsection 4, of the EPA Low Flow Sampling Procedure. (See Appendix B). All field equipment shall be calibrated at the beginning of each day of use. Standard equipment will include a pH meter, thermometer, conductivity meter, ORP meter, dissolved oxygen meter, turbidity meter, PID, and water level indicator. All measurements, except turbidity, must be obtained using a flow-through cell. Probes used to measure field parameters shall be decontaminated between each sample point in accordance with manufacturer specifications. 2.6.6 Sample Containers, Preservatives, and Holding Times Required Sample Containers, Preservatives, and Holding Times for Groundwater Samples Parameter Method Container Preservative Holding Time Metals EPA CLP One Nalgene HNO3topH<2 Six months except mercury ILMO 4.0 Plastic Liter Bottle (28 days) HNOj 10 percent nitric acid solution Containers - Pre-cleaned, certified sample containers will be obtained from the laboratory and shall not be reused. Preservatives - Sample containers will be pre-preserved by laboratory personnel. All samples will be kept in a sample cooler with ice until delivery to the laboratory. The laboratory will re-check the pH prior to analysis to ensure that the laboratory-prepared preservatives were not compromised. Holding Times - The time between sample collection and initiation of laboratory analyses is dictated by the analytical method. Any analysis of samples after the prescribed holding time should undergo additional scrutiny. Philadelphia Ntvil Base Ginrd Point Mwjemeat Are* Long Terra Ground-Wtfer Monitoring PUo Project J.O. 04291.18.10 Ground Water Monitoring PIan— Revision: Fina Page2-< A Stone ft Webster Environmental Technology ft Service 2.6.7 Sample Collection After purging the well, water samples will be collected by allowing the water to discharge gently '— down the inside of the sample container with minimal turbulence to prevent aeration and agitation. Samples will be collected directly from the Teflon® lined polyethylene tubing. New clean tubing will be used for each well for each sampling round. Sample collection will be in accordance with ~ Section IV Purging and Sampling Procedures, Subsection 5, of the EPA Low Flow Sampling Procedure (See Appendix B). ^ 2.6.8 Sample Labels Sample information will be written on identification labels using indelible ink. The completed labels "" will be securely attached to the sample container and protected by wrapping with clear plastic tape. Information to be entered on each tag includes: 1) GPMALTM 2) Sample identification (see below) 3) Date samples was collected ~~ 4) Time samples was collected 5) Name of person collecting the sample 6) Analysis to be performed ~~ 7) Preservation Samples will be given a unique identification as follows: The 10 wells selected for the LTM program will be reassigned new identification numbers to distinguish the LTM sampling rounds from previous investigative sampling and baseline data. The new identification numbers will be: Old Identification Upgradient/Downgradient Site Location New Identification Number ,. Well Number GPMA-MW-1 Upgradicnt Well Off-Site, North of GPMA GPMA-LTM-1 GPMA-MW-2 Upgradient Well Off-Site, North of GPMA GPMA-LTM-2 NWPL-MW-1 Upgradient Well Off-Site, North of NWPL GPMA-LTM'-S NWPL-MW-4 Downgradient Well NWPL GPMA-LTMU 4-MW-5 Downgradient Well IRSite4 GPMA-LTM-5 4-MW-3 Downgradient Well IRSite4 GPMA-LTM-6 4-MW-4 Downgradient Well IRSite4 GPMA-LTM-7 5-MW-3 Downgradient Well IRSiteS GPMA-LTM^8 5-MW-8 Downgradient Well IRSiteS GPMA-LTM-9 5-MW-2 Downgradient Well IRSiteS GPMA-LTM-1 0 Sample numbers for each annual sampling rounds will be as follows: Month-Year-New Identification Number or Quality Assurance/Quality Control (QA/QC) Sample Identification (e.g., 05-99-GPMA-LTM-l) FhiUddpUi Nivri B«e: Gbwd Point Mvuvement Area Long Term Ground-W«tcr Monitoring Pttn ProjcctJ.O. 04291.J8.IO J • Ground Water Monitoring Plan Revision: Final Page 2-7 Stone ft Webster Environment*! Technology & Service QA/QC Sample Identification Duplicate - DUP Matrix Spike- MS Matrix Spike Duplicate- MSD , Equipment Rinsate Blank RB 2.6.9 Chain of Custody The purpose of COC procedures is to document the identity of the sample and its handling from its first existence as a sample until analysis and data reduction are completed. Custody records trace a sample from its collection through aU transfers of custody until the analytical laboratory receives it. Internal laboratory records then document the custody of the sample through its final disposition. An example of a COC form is included in Appendix D. Adherence to COC procedures is required for all sampling events. A sample is considered to be under a person's custody if it is in a person's physical possession, in view of the person after taking possession, and secured by that person so that no one can tamper with it, or secured by that person in an area that is restricted to authorized personnel. As few individuals as possible will handle each sample to reduce the possibility of error, confusion, and/or damage. COC seals shall be completed by the sampling team and placed across the top of the cooler in a manner that would require breaking the seal in order to remove the lid. The laboratory will supply the seal. The laboratory normally supplies the COC record. A COC will be secured to the inside lid of the cooler. When transferring the possession of samples, the individuals, relinquishing and receiving the samples will sign, date, and note the tune on the COC. This record documents transfer of custody of samples from the sampler to another person or to the laboratory. 2.6.10 Shipping Sample containers will be securely packed in insulated coolers containing ice and packing material. Shipment to the laboratory will be in a manner that ensures timely receipt and maintenance of appropriate sample preservation conditions. Samples shall be logged in at the laboratory no later than 48 hours after being collected from the monitoring well. 2.5.77 Decontamination Reusable equipment, such as the water level indicator and flow through cell, will be decontaminated with potable water and deionized water, or in accordance with manufacturer specifications. New clean tubing will be used for each well for each sampling round, therefore, decontamination will not be required for the tubing. Water used for decontamination will be deposited on the ground surface away from catch basins, drains, and surface waters. Decontamination water shall be minimal. Naval Btsc Gktri Mm Management Area Long Term Groimd-WaCcr Monitoring Plan Project J.O. 04291.18.10 Ground Wetcr Monitoring Plan Revision: Final- Page 2-8 A Stone fcWtfartefEnvifocmcnm Technology A Savkx 2.7 Quality Assurance/Quality Control Quality assurance/quality control (QA/QC) samples will be collected through the LTM program to ensure that high quality data are collected. Data quality is evaluated with respect to accuracy, representativeness, completeness, and comparability. QA/QC requirements for laboratory analyses include: • Collection and analysis of QC samples • Use of a Naval Facilities Engineering Service Center (NFESC) laboratory for analysis Table 2-4 identifies field QC samples that will be used during the LTM program at GPMA. The selected off-site laboratory will also perform internal QC procedures to ensure that high quality data are produced. Laboratory QC will be consistent with CLP. 2.8 Reporting Requirements Ground-water data will be collected and summarized hi a report format on a yearly basis. The yearly ground-water monitoring report will satisfy the following objectives: • present sampling and analytical methodologies; • present data in a concise tabular format; • verify that the nine metals remain at concentrations that do not pose a potential for ecological risk; • optimize the LTM program; and • present other recommendations and conclusions regarding the LTM program. Once every five years data will be collectively summarized and presented in a 5-year report. 2.8.1 Data Management Data collected during the sampling rounds will meet the DQOs specified in Section 1.3.3. Collected data will be converted into an electronic format. The following commercially available software, will be used during data processing: Word Processing Microsoft Word for Windows 95 Version 7.0a or current Data Tables and Graphing Microsoft Access for Windows 95 Version 7.0 or current Spreadsheet Applications Microsoft Excel for Windows 95 Version 7.0 or current Drafting/Computer Aided Design AutoCAD Release 13.0 or MicroStation Release or current PMIadelpHtNavii Btse: Giwd Pofat Mmtgement Am Long Term Ground-Wtfer Monitoring Plan _ . ; 1 ProjectJ.O. 0429J.JS.JO '• I . Ground Water Monitoring Plan Revision: Final • f t Page 2-9 • i i .A Stone & Webster EnvifoorocnUl Technology A Soviet ______^ ' p 2. A 2 LTM Report Format A proposed table of contents for the yearly LTM report for GPMA is listed below. It is anticipated r »-j that as the LTM program evolves, the table of contents will be revised and optimized. Regardless of - ]; report format, the report will continue to meet the objectives identified in Section 2.8. - »'i LTM PROGRAM YEARLY REPORT TABLE OF CONTENTS 1.0 Introduction : • • 1.1 Objectives - . . 2.0 Site Description 2.1 Summary of Changes in Site Conditions * * 3.0 Geology and Hydrogeology i . 4.0 Applicable Screening Criteria 5.0 Sampling and Analysis Methodology 5.1 General * * 5.2 Sampling Procedures 5.3 Analytical Methods 6.0 Results 6.1 Maximum Environmental Effect Quotient Values 6.2 Data Summary 7.0 Optimization Strategies 8.0 Conclusions and Recommendations 8.1 Progress Toward Endpoint References Acronyms TABLES 5-1 Summary of Ground-Water Monitoring Wells - GPMA LTM Program -. • 5-2 Summary of Analytical Parameters 5-3 Summary of Ground-Water Field Sampling Log 6-1 Maximum EEQs for Annual (Month/Year) Sampling Round - • 6-2 Maximum EEQs for GPMA LTM Program (1996-2003) FIGURES 2-1 Site Location Plan 2-2 Site Plan _ . 7-1 Optimization Decision Tree APPENDICES A Ground-Water Sampling Logs * . B Analytical Data , . Fhiladetphb*^B*M:Gtf*4ftMXMttafeii)a«Ait» _ Long Terra Ground-Vtocr Monitoring PIw Project J.O. 04291.18.10 Ground Water Monitoring Plan Revision: Final Page 2-12 A Stone & Webster Environmental Technology & Service TABLE 2-1 GROUND-WATER MONITORING WELL INFORMATION GIRARD POINT MANAGEMENT AREA MONITORING DOWBGS DTW DTWBGS PVCWELL NAD 83 (ft) NAD 83 (ft) SCREEN GROUND TOPOFPVC. GROUND- WELL No. DIAMETER NORTHING (PA- EASTING (PA- INTERVAL BGS ELEVATION CASING WATER («) (ft) (ft) (INCHES) SOUTH) SOUTH) ELEVATION ELEVATION (ft) 4-MW-l 18 4.98 2.77 4 214709 2685325 3-18 11.86 14.07 9.09 4-MW-2 IS 8.46 5.77 4 214470 2685390 3-18 12 Jl 15.0 634 4-MW-3 20 11.74 9A9 4 214504 2685078 5-20 1452 17.17 5v43 4-MW-4 20 1175 10.60 4 214284 2685205 5-20 15.05 17.20 4.45 4-MW-5 20 10.27 8JH 4 214761 2685005 5-20 16.14 18J6 8.W 5-MW-l 13.11 6.80 SIS 4 21 4658 2685725 8.40-13.40 13.40 14.95 8.15 5-MW-2 1X75 7.01 439 4 214541 2686036 7.75-1X75 11.70 13.73 6,71 S-MW-3 13J2 170 7.11 4 214393 2685655 8J2-13J2 13.0 1439 5J9 5-MW-6 14.70 6.74 4.74 4 214735 2686032 • 9.7-14.7 13.0 15.0 8.26 5-MW-7 13.40 6.20 4.65 4 214704 2685877 8.4-13.4 12.9 14.45 8.25 5-MW-8 13.5 SJ2 PMIadelphii Nival Base: Girard Point Management Ares Long Term Ground-Water Monitoring Plan '-1 "'"H 'H "~ Project J.O. 04291.18.10 - i. Ground Water Monitoring Plan Revision: Final r * Page 2-13 - i i Stone & Webster Environmental Technology & Service -.'j' Notes to Table 2-1 DOW Depth of Well DTW Depth to Water BGS Below Ground Surface * Elevation is at top of steel casing. All other elevations are at top of PVC casing T ? * . 1. The 10 selected LTM wells are in bold face. 2 Information based on May 1997 sampling round. f • 3. All elevations are based on PhiladelphiaNaval Shipyard datum. • ; 4. Well survey and monitoring well data are compiled from a variety of sources and may contain inconsistencies. Modifications to ground and top of PVC casing elevations will occur due to _ ! landfill cover installation. 5. It is recommended that all well locations and elevations be re-surveyed (horizontally and vertically) after site work is completed. 6. The following vertical datum survey conversion information is provided for general use only at the GPMA. The actual differences between survey datura are location specific. North American Vertical Datum 1998 (0.0 ft) North American Datum 1983 (0.0 ft) 0.98 ft. 1.09ft. Mean Sea Level (0.0 ft) National Geodetic Vertical Datum 1929 2.84 ft. Philadelphia Naval Shipyard Datum (0.0 ft) PHladdpKt N«wl Btse: Gmrt Point Mamjeroent Area Long Term Ground-Wtter Monitoring Plan dM2torttcW2911Steak4.3\itmprv5.doc Project J.O. 04291.18.10 Ground Water Monitoring Plan Revision: Final Page 2-14 "1 Stone A Wcbfler Enviimuiiciiut Technology A Service TABLE 2-2 ANALYTICAL METHODS ANALYTE ANALYTICAL METHOD METHOD NUMBER arsenic atomic absorption - furnace 2062 CLP-M ' cadmium atomic emission - ICP 200.7 CLP-M chromium, total atomic emission - ICP 200.7 CLP-M copper atomic emission - ICP 200.7 CLP-M lead atomic absorption - furnace 239.2 CLP-M mercury atomic absorption - cold vapor 245.1 CLP-M nickel atomic emission - ICP 200.7 CLP-M selenium atomic absorption - furnace 270.2 CLP-M zinc atomic emission - ICP 200.7 CLP-M Notes ICP - Inductively Coupled Plasma M - Modified Pbiladelpbia Nivd B»e: (nmd Poim Mntgemeiit Area Long Tom Ground-Water Monitoring Plan Project J.O. 04291.18.10 Ground Water Monitoring Plan Revision: Final Page 2-15 . 1 Stone £ Webster Environment^ Technology & Service 1.1 TABLE 2-3 LABORATORY REPORTING LIMITS ANALYTE IDL(ng/L) CRDLQig/L) AWQC •J. (Hg/L) arsenic 2.0 10.0 190 . r cadmium 1.0 5.0 1.1 chromium, total 2.0 10.0 11 copper 2.0 25.0 12 lead 2.0 3.0 3.2 mercury 0.2 0.2 0,012 nickel 5.0 40.0 160 selenium 3.0 5.0 5 zinc 8.0 20.0 110 Notes Hg/1 micrograms per liter IDLs are laboratory and instrument specific. IDLs presented in this table are from EA laboratories Philadelphia Nival B«e: Gtrard Point Mwgonent Arc* Lone Term Gn>ua Stone ft Webster Environmental Technology & Services TABLE 2-4 FIELD QC SAMPLES QC Sample Definition Purpose Frequency Duplicate Multiple grab samples, collected To demonstrate the precision of the 10 percent of field samples separately, that equally represent a sampling and analytical methods media at a given location and time Equipment Rinsate Blank Deionized water is poured over To demonstrate the effectiveness of I/sampling device/sampling sampling equipment following decontamination techniques. event or I/week whichever decontamination. is greater Philadelphia Naval Base: Girard Point Management Area Long Term Ground-Wan* Monl»iw BJ'Lp I » "^ !M ft. FIGURE 2-1 MONITORING WELLS 'FOR' GPMA LTM PROGRAM OK »«mrn wwioin nnaocr M aims rfi.VMtrtt.im • INI Irani t: II Ur»» Project J.O. 04291.18.10 Evaluation of Ground-Water Data Revision: Final Page3-l A Store & Webster Environmental Technology & Service _^______3. EVALUATION OF GROUND-WATER DATA 3.1 Evaluation of 1996-1997 Ground-Water Data Baseline 3.1.1 Seasonally Stone & Webster examined the seasonal concentration of metals over the four sampling periods/seasons (i.e., July 1996/Summer, October 1996/Autumn, February 1997/Winter, and May 1997/Spring) for the nine COPCs. The purpose of the review was to identify broad seasonal trends in concentrations for each metal and for the individual wells. The limited number of samples that were observed above the detection limit hampered the review. Arsenic There were 54 observations of detectable concentrations from a total of 17 different wells. There were five wells with detectable concentrations during the July sampling period. However, there were no clear trends in 10 wells with detectable concentrations in each of the 4 sample periods. Cadmium There were 23 observations of detectable concentrations from a total of 9 different wells. None of these occurred during the October sampling period. For four out of five wells there were three seasons with above detection limit concentrations; with February and May concentrations being greater than those hi July. Chromium. Copper, and Nickel Three of the nine metals were observed at concentrations above the detection limit in only one to three wells and usually not in every sampling period. These three metals (chromium, copper, nickel) were observed at detectable concentrations in well GPMA-MW-3 in May; and copper and nickel were observed at detectable concentrations in well 4-MW-5 in each sample period with no recognizable pattern in concentration. Copper was also observed at concentrations above the detection limit in February and May in well 4-MW-4. Except for a slightly greater detection frequency during February and May, no other seasonal trends in concentrations of these three metals were observed. There were 19 observations of detectable concentrations from a total of 9 different wells. Detectable concentrations of lead were observed during all four sampling periods in well 4-MW-4. The February and May lead concentrations in this well were greater than the July and October concentrations. In contrast, well 4-MW-l detectable concentrations of lead were observed during July and October. Detectable concentrations of lead were observed in well 4-MW-5 during the July, October, and February sampling periods. There was no recognizable trend in the concentrations in this well during those three seasons. Detectable concentrations of lead were observed during only one of the four sampling periods in the other six wells (NWPL-MW-1, NWPL-MW-2, NWPL-MW- 3, 4-MW-3, 5-MW-l, GPMA-MW-3). Four occurrences were observed during the July sampling period, and one each during May and October. The overall conclusion is that there was no consistent seasonal trend in concentrations of lead at the site. Philadelphia Naval Base: Gtnrd Point Management Area Long Term Ground-Water Monitoring Plan Project J.O. 04291.18.10 Evaluation of Ground- Wtter Data Revision: Final Page 3-2 A Stone ftWtbster Environmental Technology A Sqvice ______^____ Mercury There were 14 observations of detectable concentrations from a total of 11 different wells. Although, mercury was rarely reported at concentrations above the detection limit, it was more frequently observed (i.e., 10 of the 14 detectable concentrations) during the February sampling period. ' Selenium There were 16 observations of detectable concentrations from a total of 8 different wells. Detectable concentrations of selenium were observed during all four sampling periods. The highest detectable concentrations of selenium were observed during July in five of the eight wells. At well QPMA- MW-3 detectable concentrations of selenium were observed for the three sampling periods other than July. For two of the eight wells, detectable concentrations of selenium were observed only during the February or May sampling periods. Zinc : There were 33 observations of detectable concentrations from a total of 15 different wells. Although there was a higher incidence of detection during May and July (23 observations) than during October and February (10 observations), there was no clear pattern of seasonal variations. In the case of wells 4-MW-l, 4-MW-2,4-MW-5, and GMPA-MW-2 there were multiple observations were made, but no seasonal trend among the wells. 3.J.1.1 Conclusions There appears to be a trend for higher concentrations of mercury in the February sampling period, higher concentrations of selenium in July, and lower concentrations of cadmium in October. These trends are based only on a qualitative review of the limited numbers of samples of each metal which were observed in concentrations above the detection limit. The other six metals (arsenic, chromium, copper, lead, nickel, zinc) exhibited no clear or consistent trends in seasonal concentrations. As stated above, the limited number of samples with detectable concentrations hampered this review for trends in seasonal concentrations. In addition, the reader should be advised that other following factors, such as, weather conditions prior to and during each sampling period, variability in sampling techniques, sampling procedures, and analytical analyses were not considered. 3.1.2 Evaluation As discussed in Section 1 and shown on Table 1-1 of the Goals Paper (Stone & Webster, 1998c), maximum EEQs for the 1996-1997 ground-water data baseline are less than unity for the nine metals when dilution factors of three orders of magnitude are considered. It was therefore concluded that the maximum concentrations of the nine metals would not pose a potential for ecological risk. LTM program data will be evaluated to verify that the nine metals remain at concentrations that do not pose a potential for ecological risk. Maximum EEQs of the nine metals would be evaluated considering dilution factors. The LTM program will be reviewed after each complete sampling round to evaluate current ground-water quality, optimize the sampling program, and document current site conditions. An annual report would be prepared to document this evaluation. A list of the anticipated data summary tables required during data evaluation is as follow: PhUadc IphitNivil tec: Gtrerd Point NUrugetnent Area Loos Tenn Ground-Wuer Monitoring Plan • — Project J.O. 04291.1*. f'O Evaluation of Ground-Water Data Revision: Final Page 3-3 Stone & Webster Environmental Technology ft Service Table Tale Primary Purpose of Table Summary of Ground-Water Identify each monitoring well sampled, the reason why it is Monitoring Wells - GPMA LTM included in the LTM program, and its location relative to Program pertinent site features. Summary of Analytical Parameters Identify the analytical parameters sampled in each monitoring well. Summary of Ground-Water Field Document pertinent field measurements and sampling Sampling Log information. Maximum EEQs for Annual Table will be similar to Table 1.1 presented in the Goals (Month/Year) Sampling Round Paper, but will only include nine metals (arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, and zinc) Maximum EEQs for GPMA LTM Document maximum EEQs for the 1996-1997 ground-water Program (1996-2003) data baseline and the five annual sampling rounds (1999- 2003), assuming remediation activities are completed in 1998. Graphs showing plotted maximum EEQs, maximum concentrations, and/or monitoring well locations of maximum values can also be provided, if required. Examples of evaluation tables are presented in Appendix E. 3.1.3 Confirmation Sampling Confirmation sampling will be conducted on any of the 10 monitoring wells sampled during the annual sampling rounds, if a maximum EEQ exceeds unity (considering a dilution factor of 3 orders of magnitude). The particular monitoring well that was reported to contain the maximum results will be identified. In addition, data will be reviewed to see if there are other wells that were reported to contain concentrations of that particular COPC in excess of the EEQ (considering a dilution factor of three orders of magnitude). A ground-water sample will be collected from those particular monitoring wells within 90 days of the annual sampling round and analyzed for the specific COPC in question. For example, if a ground-water sample collected from a IR Site 4 well (4-MW-4) is reported to contain a maximum concentration of lead in excess of the associated EEQ (considering a dilution factor of three orders of magnitude), then the EEQ values for lead from the rune remaining monitoring wells will be calculated and evaluated. Confirmation sampling and laboratory analysis for lead will be conducted for 4-MW-4 and any monitoring wells that reported a EEQ for lead greater than unity (considering a dilution factor of three orders of magnitude). If confirmation sampling EEQs exceed unity (considering a dilution factor of three orders of magnitude), then the EEQs will be evaluated considering dilution factors of four, and five orders of magnitude. PADEPwill be contacted if confirmation sampling is conducted. A decision to increase the LTM program-sampling frequency to semi-annual rounds (i.e., twice in one calendar year) will be made based on this evaluation. It is anticipated that this decision will be dependent on the number and locations of those monitoring wells that exceed unity and relative percent change in concentration between the 1996-1997 ground-water data baseline, preceding annual sampling round, and current sampling round. Philadelphia Naval Base: Gtnri Point Management Aiea Long Term Ground-Water Monitoring Plan ProjectJ.O. 04291.18.1C.! Evaluation of Ground-Water Data Revision: Final Page 3-4 — Stone & Webster Environmental Technology * Senrfce 33, Monitoring Endpoint and Optimization The monitoring endpoint will be based on consensus by the BCT that the decision rule stated 14 Table 4-1 has been satisfied. That rule says: "If maximum EEQs for nine metals (arsenic, cacjmium, chromium, copper, lead, mercury, nickel, selenium, and zinc) remain below unity (when considering dilution factors of one to five orders of magnitude) during a five-year period, then the GPMA ground- water monitoring program will be terminated," If the decision rule is not met, PADEP will be contacted, ground-water monitoring will be conducted beyond the five-year period, and a ground-water monitoring decision tree will be developed. The decision tree is a logic diagram comprised of decision rules. The purpose of the decision tree will be to provide a standardized and appropriate method for optimizing future data collection activities. If sampling is extended beyond the five-year period, data collected as part of the ground-water monitoring program will be reviewed periodically using the decision tree to determine which elements are appropriate to maintain and continue. It is assumed that additional research and guidance documents addressing optimization issues will become available during the monitoring period. At a minimum the ground-water monitoring decision tree will be developed using the following guidance documents: • Final Long-Term Monitoring Optimization Guide, Version J.I; prepared by the Air Force Center for Environmental Excellence (AFCEE) - Consultant Operations Division; October 1997; and • Ridley, M.N., V;M. Johnson, and R.C. Tuckfield, 1995. Cost Effective Sampling of Ground Water Monitoring Wells; prepared for submittal to HAZMACON 1995, San Jose, CA, April 4- 6,1995; February 1995. Decision rules used to build the decision tree specify the conditions under which a specific action to continue or modify the ground-water monitoring program will be taken or a decision made. Decision rules evoke a "yes" or "no" answer and will be used to optimize the following parameters: • number of wells sampled; • location of wells sampled relative to important site features; • analytical parameters selected; and • sampling frequency. Decision rules will take into account DQOs and the end-use of data. The decision rules developed for the GPMA will also specify a ground-water monitoring endpoint that is consistent with the original decision rule. To facilitate use of the ground-water monitoring program decision tree, data collected as part of ground-water monitoring program will need to be reduced and evaluated. The form that reduced data take will be critical to a streamlined evaluation. It is anticipated that tables similar to those identified in Section 3.1.2 will play a major role hi facilitating data evaluation. Ftribddpbu Naval Bex: Guard Point Management Area Long Term Ground-Water Monitoring Pint ^A^ Steoe&Wcb$iefEnvgoomenUlTedmok>gy& Services 4. REFERENCES AFCEE, 1997. Final Long-Term Monitoring Optimization Guide, Version LI; prepared by the Air Force Center for Environmental Excellence (AFCEE) - Consultant Operations Division. October 1997. EA Engineering, Science, and Technology (EA), 1998. Base-Wide Ground-Water Study, Philadelphia Naval Base, Philadelphia, Pennsylvania, 14 January 1998. Ridley, MR, V.M. Johnson, and R.C. Tuckfield, 1995. Cost Effective Sampling of Ground Water Monitoring Wells; prepared for submittal to HAZMACON 1995, San Jose, CA, April 4-6, 1995; February 1995. Stone & Webster. 1996a. Conceptual Site Model for the Girard Point Management Area, Philadelphia Naval Base, Philadelphia, Pennsylvania. April 1996. - . 1997a. July 1996, October 1996, February 1997 and May 1997 Ground-Water Sampling Memorandum Report (BRACL-96). 17 July 1997. - . 1997b. Remedial Investigation Report: IR Site 4 at Philadelphia Naval Base, Philadelphia, Pennsylvania. May 1997. -- . 1997c. Site Characterization Report for the Girard Point Management Area at Philadelphia Naval Base, Philadelphia, Pennsylvania. September 1997. - . 1997d. Feasibility Study for Girard Point Management Area at Philadelphia Naval Base, Philadelphia, Pennsylvania. October 1997. -- . 1998a. Long Term Monitoring (LTM) Methods and Strategies Memorandum Report (BRAC L-108). 6 April 1998. - . 1998b. Final Long Term Monitoring (LTM) Ground-Water Sampling Equipment Memorandum Report (BRAC L-l 09). 7 April 1 998. - . 1998c. Goals Paper Ground-Water Monitoring Program for Girard Point Management Area at Philadelphia Naval Base, Philadelphia, Pennsylvania. 30 June 1998. United States Department of the Navy, 1998. Proposed Plan Girard Point Management Area, Philadelphia Naval Complex, Philadelphia, Pennsylvania. June 1998. United States Environmental Protection Agency (EPA), 1 993a. The USEPA Region III Modifications to the Laboratory Data Validation Functional Guidelines for Evaluating Inorganic Analyses. April 1993. -- . I993b. USEPA Office of Solid Waste and Emergency Response, Directive No. 9355.049FS, Presumptive Remedy for CERCLA Municipal Landfill Sites. EPA/540/F93/035. September, 1993. - . 1993c. USEPA Office of Science and Technology, Office of Water, Water Quality Criteria, September, 1993. - . 1994. USEPA Office of Research and Development, Guidance for the Data Quality Objectives Process. EPA/600/R96/055. September, 1994. - . 1 995a. USEPA Contract Laboratory Program, Statement of Work for Inorganics Analysis, Multi- media Multi-concentrationlLMO 4.0. EPA/540/R95/121. PfcaadelphtaNtvrf Base: Ginrd Point Management Ait* LtrngTennGfound-Wtfer Monitoring ?ba Project: J.O. 04291.18.10 T References Revision: Final Page 4-2 Stone ft Webster Environment!! Technology & Soviets -. 1995b. USEPA Region III, Innovative Approaches to Data Validation. June, 1995. j -. 1996a. USEPA Office of Solid Waste and Emergency Response, Low-Flow (Minimal Drawdown) Ground-Water Sampling Procedures. EPA/540/S95/504. April, 1996. _ . 1996b. USEPA Region I, Low Stress (low flow) Purging and Sampling Procedure for the Collection of Ground Water Samples from Monitoring Wells. 3 0 July 1996 Revision 2. Philadelphia Naval Bate: Girard Point Management Area Long Term Ground-Water Monitoring Plan APPENDIX A USEPA CONTRACT LABORATORY PROGRAM STATEMENT OF WORK FOR INORGANICS ANALYSIS, MULTI-MEDIA MULTI-CONCENTRATION ILMO4.0 EPA/540/R95/121 PhiJ*ldp»u*N«vd Base: Gtnrd Point MmtffmeM Area LoogTenn Oound-W*er Moottoring Pto Offiotof EnvreormnU Protection oldWtelt«nd •upofund USEPA CONTRACT I LABORATORY PROGRAM Statement of Work for Inorganics Analysis, Multi-media Multi-concentation * •. * ILM04.0 i I. REPROOUCEO BY U.S. DEPARTMENT OF COMMEflCE NATIONAL TECHNICAL INFORMATION SERVICE SPRINGFIELD, VA 22161 Exhibit 0 ZCr-ACS »AKT A » mPgCTtVgLY g-* *tA8MX-ATOKTe PtttlTOM gMCTKOMSTKTC METHOD Method 200.7 CLP-M* IKDUCTIVZLY COUWJED PLASMA-ATOMIC KMZISZOH *KCTKOH£TRZC HZTHOD FOR TftACX XLXKENT AMALTSZS OF VATXA AMD WASTM 1. Scene and Application 1.1 Dissolved elements are determined in filtered and acidified staple*. Appropriate steps oust be taken in all analyses to ensure that potential interferences are taken into account. This is especially true when dissolved solids exceed 1500 »g/L. (See 4.) 1.2 Total elements are determined after appropriate digestion procedures are perforated. Since digestion techniques increase the dissolved solids content of the sanples, appropriate steps anist be taken to correct for potential interference effects. (See 4.) 1.3 Table 1 lists elements along with recommended wavelengths and typical estimated instrumental detection limits using conventional pneumatic nebulization. Actual working detected limits are sample dependent and as the sample matrix varies, these concentrations Bay also vary. In tine, other elements may be added as more information becomes available and as required. 1.4 Because of the differences between various makes and models of satisfactory instruments, no dstailed instrumental operating instructions can be provided. Instead, the analyst is referred to the instructions provided by the manufacturer of the particular instrument. 2. Summary of Method The method describes a technique for the simultaneous or sequential multielement determination of trace elements in solution. The basis of the method is the measurement of atomic emission by an optical spectroscopic technique. Samples are nebulired and the aerosol that is produced is , transported to the plasma torch where excitation occurs. Characteristic atonic-line emission spectra are produced by a radio-frequency inductively coupled plasma (ICP). The spectra are dispersed by a grating spectrometer and the intensities of the lines are monitored by a photosensitive device. The photoeurrents from the photosensitive device are processed and controlled by a computer system. A background correction technique is required to compensate for variable background contribution to the determination of trace elements. Background must be measured adjacent to analyte lines on samples during analysis. The position selected for the background intensity measurement, on either or both sides of the analytical line, will be determined by the complexity of the spectrum adjacent to the analyte line. The position used must be free of spectral interference and reflect the same change in background intensity as occurs at the analyte wavelength measured. Background correction is not required in cases at Jin* broadening where a background correction measurement would actually degrade the analytical result. The CLP-M modified for the Contract Laboratory Program. 0-16 ILH04.0 exhibit 0 XCF-ACS possibility of additional interferences named in 4.1 (and tests for their presence ss described ia 4.2) should also b« recognized and appropriate corrections made. The toxicity or carcinogenlcity of each reagent used la this method has not been precisely defined; however, each chemical compound should be treated as a potential health hazard. The laboratory is responsible for Maintaining a current awareness file of OSHA regulations regarding the safe handling of the chemicals specified in this method. A reference file of material handling data sheets should be made available to all personnel involved in the chemical . analysis. Interference^ 4.1 Several types of interference effects may contribute to inaccuracies in the determination of trace elements. they can be summarized as follow* i 4.1.1 Spectral interferences can be categorized as 1} overlap of a spectral line fron another element; 2) unresolved overlap of molecular band spectra; 3} background contribution from continuous or recombination phenomena} and 4) background contribution from stray light from the line emission of high concentration elements. The first of these effects can be compensated by utilizing a computer correction of the raw data, requiring the monitoring and measurement of the interfering element- The second effect may require selection of an altsrnate wavelength. The third and fourth effects can usually be compensated by a background correction adjacent to the analyte line. In addition, users of simultaneous multi-element instrumentation must assume the responsibility of verifying the absence of spectral interference from an element that could occur in a sample but for which there is no channel in the instrument array. Listed in Table 2 are some interference effects .for the recommended wavelengths given in Table 1. The data in Table 2 are intended tor use only as a rudimantary guide for the indication of potential spsctral interferences, for this purpose, linear relations between concentration and intensity for the analytas and the interferents can be assumed. The interference information, which was collected at the Ames Laboratory**, is expressed as analyte concentration equivalents (i.e., false analyte concentrations) arising from 100 mg/L of the inter fersnt element. The suggested uee of this information is as follows t Assume that arsenic (at 193.696 nm> is to be determined in a sample containing approximately 10 mg/t of aluminum. According to Table 2, 100 mg/t of aluminum would yield a false signal for arsenic equivalent to. approximately 1.3 mg/t. Therefore, -10 mg/L of aluminum would result in a false signal for arsenic equivalent to approximately 0.13 mg/t. The reader i« cautioned that other analytical systems may exhibit somewhat different levels of interference than those shown in Table "Ames Laboratory, USOOE, Iowa State University, Ames, Iowa 50011. 0-17 ILM04.0 T •y Cxhlblt 0 ICP-ATS 2, and that the interference affects must be evaluated for each individual system. Only those interferents listed were Investigated . — and the blank spaces in Table 2 indicate that measurable interferences were not observed fro* the interfarent concentration* listed in Table ' 3. Generally, interferences were discernible if they produced peaks or background shifts corresponding to 2-5% of the peaks generated by — the analyte concentrations also listed in Table 3. At present, information on the listed silver and potassium wavelengths is not available but it has been reported that second order energy — from the magnesium 363.231 na wavelength interferes with the listed potassium line at 766.491 am. • ' 4.1.2 Physical interferences are generally considered to be effects •— associated with the sample nebulitation and transport processes. Such '. properties as change in viscosity and surface tension can cause * significant inaccuracies especially in samples which may contain high dissolved solids and/or acid concentrations. The use of a peristaltic '.— pump may lessen these interferences. Zf these types of interferences [ are operative, they must be reduced by dilution of the sample and/or utilization of standard addition techniques. Another problem which can occur from high dissolved solids is salt buildup at the tip of the 1— nebulizer. This affects aerosol flow rate causing instrumental drift. *L Wetting the argon prior to nebulization, the use of a tip washer, or sample dilution has been used to control this problem. Also, it ha* ' been reported that better control of the argon flow rat* improves instrument performance. This is accomplished with the use of otass L: flow controllers. 4.1.3 Chemical interferences are characterized by molecular compound (^ formation, ionization effects and solute vaporization effects. Normally these effects are not pronounced with the ZCf technique, however, if observed they can be minimized by careful selection of f— operating conditions (that is, incident power, observation position, L, and so forth), by buffering of the sample, by matrix matching, and by. standard addition procedures. These types of interferences can be r highly dependent on matrix type and the specific analyte element. \—' t> 4.2 Prior to reporting concentration data for the analyte elements, the Contractor shall analyze and report the results of the JCP Serial Dilution Analysis. The • . ZCP Serial Dilution Analysis shall be performed on a sample from each group of {"— samples of a similar matrix type (i.e., water, soil) and concentration (i.e.., low, medium} or for each Sample Delivery Group, whichever is more frequent. Samples identified as field blanks cannot be used for Serial Dilution . Analysis. | — ta Zf the analyte concentration is sufficiently high (minimally a factor of 50 above the instrumental detection limit in the original sample), the serial , dilution (a five fold dilution) shall then agree within 10% of the original 1 — determination after correction for dilution. Zf the dilution analysis for one • L» or more analytes is not within lOt, a chemical or physical interference effect must be suspected, and the data for all affected analyses in the samples received associated with that serial dilution must be flagged with an "E" on FORM IX-ZN and FORK I-IN. t 0-18 IW04.0 |_ •CO -co Ixhibit 0 ICT-AM 5. Apparatus CO S.I Inductively Coupled flasma-Atoaic Saiesion Spectrometer. t\f\ "• ' S.I.I Computer controlled atomic emission spectrometer with background til correction. - 5.1.2 Radio frequency generator. 5.1.3 Argon gas supply, welding grade or better. *. 5.2 Operating conditions — Because of the differences between various makes and f i i Models of satisfactory instruments, no detailed operating instructions can be provided. Instead, the analyst should follow the instructions provided by the o manufacturer of the particular instrument. Sensitivity, instrumental detection limit, precision, linear dynamic range, and interference effects must be investigated and established for each individual analyte line on that particular instrument. All measurements must be within the instrument linear ranoe where correction factors era valid. It is the responsibility of the analyst to verify that the instrument configuration end operating condition* used satisfy the analytical requirements and to maintain quality control data confirming instrument performance and analytical results. 6. Reaoents and Standards, 6.1 Acids used in the preparation of standards and for sample processing must be --0 ultra-high purity grade or equivalent. Redistilled acids are acceptable. 6.1.1 Acetic acid, cone, (sp gr 1.06). 6.1.2 Hydrochloric acid, cone, (sp gr 1.19). 6.1.3 Hydrochloric acid, (1+1): Add 500 mL cone. HC1 (sp gr 1.19) to 400 -rfl. mL deionited, distilled water and dilute to 1 liter. 6.1.4 Nitric acid, cone, (sp gr 1.41). 6.1.5 Kitric acid, (1+1) * Add 500 mL cone. BNO3 (sp gr 1.41) to 400 mL deionised, distilled water and dilute to 1 liter. r\ 1 6.2 Deionited, distilled watert Prepare by passing distilled water through e —I LJ mixed bed of cation and anion exchange resins. Ose deionited, distilled water '- for the preparation of all reagents and calibration standards and as dilution rf water. " The purity of this water must be equivalent to ASTK Type II reagent I * I water of Specification 0 1193. ~ J I - 6.3 Standard atock solutions may be purchased or prepared from ultra high purity f i grade chemicals or metals. All salts must be dried for 1 hour at 105° C ,* If unless otherwise specified. H? [ J . . D-19 ILM04.0 IT exhibit 0 XCT-AES (CAOTXOM: Xany metal ealta are extremely toxic and Bay be fatal if •wallowed. Mash bands thoroughly after handling.) Typical atock aolutibn preparation . procedure* follow: €.3.1 Aluminum solution* etock, I mL. • 100 ug Alt Dissolved 0.100 9 of aluminum metal in an acid mixture of 4 mL of (1*1) BC1 and 1 mL of cone. . HNOj in a beaker. Van gently to effect solution. When solution is complete, transfer quantitatively to a liter flask, add an additional 10 mL of (1*1) BC1 and dilute to 1000 mL with deionixed, distilled water. 6.3.2 Antimony solution stock, 1 mL « 100 ug Sot Dissolve 0.26CT g K(6bO)C4R4oG in deionized distilled water, add 10 mL (1+1) BCl and dilute to 1000 mi with deionixed, distilled water. (.3.3 Arsenic solution, Stock, 1 mL • 100 ug ABI Dissolve 0.1320 g of As^Oj in 100 mL of deionized, distilled water containing 0.4 g Kaoa. Acidify the solution with 2 aL cone. HKO3 and dilute to 1,000 aL with deionized, distilled water.' 6.3.4 Barium solution, stock, 1 aL * 100 ug Bat Dissolve 0.1516 g (dried at 250°c for 2 hrs} in 10 mL deionixed, distilled water with 1 mL (1*1) HC1. Add 10.0 mL (1+1) KC1 and dilute to 1,000 nL with deionited, distilled water. 6.3.5 Beryllium solution, stock, 1 aL • 100 uc Bet Do not dry. Dissolve 1.966 g B«S04'4H20, in deionixed, distilled water, add 10.0 'ml cone. HN03 and dilute to 1,000 mL with deionixed, distilled water. 6.3.6 Boron solution, stock, 1 mL • 100 ug B: Do not dry'. Dissolve O.S716 g anhydrous H3BO3 in deionixed, distilled water and dilute to 1,000 nL. U»t a reagent meeting ACS specifications, keep the bottle tightly stoppered and store in a desiccator to prevent the entrance of atmospheric moisture. 6.3.7 Cadmium solution, stock, 1 mL • 100 ug Cd: Dissolve 0.1142 g CdO in a minimum amount of (1+1) HNOj. Heat to increase rate of dissolution. Add 10.0 mL cone. HN03 and dilute to 1,000 nL with deionixed, distilled water. €.3.8 Calcium solution, stock, 1 mL • 100 ug Cat Suspend 0.2498 g CaCO3 dried at 180°c for 1 h before weighing in deionixed, distilled water and dissolve cautiously with a minimum amount of (1+1) HHO3. Add 10.0 mL cone. HH03 and dilute to 1,000 mL with deionixed, distilled water. :RT 6.3.9 Chromium solution, stock, 1 nL » 100 ug Crt Dissolve 0.1923 g of CrO3 in deionized, distilled water. When solution is complete acidify with 10 mL cone. KNO3 and dilute to 1,000 mL with deionixed, distilled water. 6.3.10 Cobalt solution stock, 1 oL * 100 ug Coi Dissolve 0.1000 g of cobalt i metal in a minimum amount of (1+11 HKO3. Add 10.0 mL (1+1) HCl and dilute to 1,000 mL with deionized, distilled water. m- 0-20 ILM04.0 *'I JCxhiblt 0 ZCP>AXS 6.3.11 Copper solution, stock, 1 mL • 100 ug Cut Dissolve 0.1252 7 CuO in a I minimum amount of (1+1) HN03. Add 10.0 mL cone. HHO3 and dilute to 1,000 mL with deionized, distilled water. 6.3.12 Iron solution, stock, 1 ml. * 100 ug fet Dissolve 0.1430 g f*2°3 ^ • If warm mixture of 20 *L {!•*>!> HC1 and 1 at. at cone. BNO3. Cool, add an l| additional S mi of cone. MW3 and dilute to 1,000 mL with deionized, -, distilled water. 6.3.13 Lead solution, stock, 1 mL • 100 ug fbt Dissolve 0.1599 g Pb(N03}2 in a minimum amount of (1+1) BHO3. Add 10.0 mL of cone. HN03 and dilute to 1,000 mL with delonized, distilled water. , 6.3.14 Magnesium solution, stock, 1 mL • 100 ug Hgt Dissolve 0.16S8 y HgO in a mlnimua amount of (l-»-l) KMOj. Add 10.0 «L cone. HHOj and dilute to 1,000 to. with deionixed, distilled water. * 6.3.15 Kanganes* solution, stock, 1 otL - 100 ug Knt Dissolve 0.1000 g of manganese until in the acid mixture, 10 ml cone. HC1 and 1 ol cone. KNO3, and dilute to 1,000 mi with deionizcd, distilled water. * 6.3.16 Molybdenum solution, stock, 1 n£. - 100 ug Mo: Dissolve 0.2043 g (KH4)2Ko04 in deionized, distilled water and dilute to 1,000 nL. 6.3.17 Nickel solution, stock, 1 ml - 100 ug Hi: Dissolve 0.1000 g of nickel metal in 10 aL hot cone. HH03, cdol and dilute to 1,000 oL with deionized, distilled water. 6.3.IB Potassium solution, stock, 1 ml. - 100 ug Ki Dissolve 0.1907 g KC1, dried at 110°C, in deionized, distilled water. Dilute to 1,000 mL. 6.3.19 Selenium solution, stock, 1 al. • 100 ug Set Do not dry. Dissolve 0.1727 g H2S«03 (actual assay 94.6%) in deionizad, distilled water and dilute to 1,000 mL. 6.3.20 Silica solution, stock, 1 mL - 100 ug SiOjt Do not dry. Ditcolve 6.4730 g K«2Si03-9H2O in deionized, distilled water. Add 10.0 mL cone. HM03 and dilute to 1,000 mL with deionized, distilled water. 6.3.21 Silver solution, stock, 1 wl - 100 ug Agt Dissolve 0.1S75 g AgK03 in 100 mL of deionized, distilled water and 10 «L cone. H»O3. Dilute to 1,000 mL with deionized, distilled water. 6.3.22' Sodium solution, stock, 1 mL • 100 ug Nat Dissolve 0.2542 g Had in deionized, distilled water. Add 10.0 mL cone. KNO3 and dilute to 1,000 mL with deionized, distilled water. 6.3.23 Thalliun solution, stock, 1 mL * 100 ug Tit Dissolve 0.1303 g T1NO3 in deionized, distilled water. Add 10.0 mL cone. HNO3 and dilute to 1,000 mL with deionized, distilled water. D-21 1LH04.0 txhibit C ICT-AIS 6.3.24 Vanadium eolution, stock, 1 mL • 100 wg V» Dissolve 0.2297 KH4VO3 in a minimum amount of cone. WOj. Beat to increase rate of r"^ dissolution. Add 10.0 mL cone. KNOj and dilute to i,OOO mL with deionixed, distilled water. 6.3.25 Sine eolation, stock, 1 mL • 100 «g tnt Dissolve 0.1245 g tnO in a '— minimum amount of dilute KNOj. Add 10.0 mL cone. BHOj and dilute to l.OOO mL with deioniced, dietilled water. 6.4 Mixed calibration standard solutions — Prepare mixed calibration standard "~" solutions by combining appropriate volumes of the stock solutions in volumetric flasks. (See 6.4.1 thru 6.4.5.) Add 3 mL of (1+1) KMOj'and 10 sL j of (1+1) BCl and dilute to 100 mL with deioniced, distilled water. (See iron in 6.4.8.) Prior to preparing the mixed standards, each stock solution should ~~ be analyzed separately to determine possible spectral interference or the presence of impurities. Care should be taken when preparing the mixed standards that the elements are compatible and stable. Transfer the mixed standard solutions to a FIP fluorocarbon or unused polyethylene bottle for ' ~~ storage. Fresh mixed standards should be prepared as needed with the realization that concentration cm change on aging. Calibration standards \ • must be initially verified using a quality control sample and monitored weekly for stability (see 6.6.3). Although not specifically required, some typical ~ calibration atandard combination* follow when using those specific wavelengths ( listed in Table 1. J 6.4.1 Mixed standard solution I — Manganeee, beryllium, cadmium, lead, and ~ sine. | 6.4.2 Mixed standard solution II — Barium, copper, iron, vanadium, and J cobalt. - 6.4.3 Mixed standard solution III — Molybdenum, silica, arsenic, and . ( selenium. \ £.4.4 Mixed standard solution IV — Calcium, sodium, potassiun, aluminum, \ chromium and nickel. V 6.4.5 Mixed standard solution V — Antimony, boron, magnesium, silver, and i~ thallium. | XOTSi If the addition of silver to the recommended acid combination results in an initial precipitation, add 15 mL of deionixed distilled • " water and warm the flaek until the eolution clears. Cool and dilate r to 100 mL with deionixed, distilled water. For this acid combination V. the silver concentration should be limited to 2 mg/L. Silver under these conditione is stable in a tap water matrix for 30 days. Higher * concentrations of silver require additional HCl. 5 6.5 Two types of blanks are required for the analysis. The calibration blank («•• Exhibit E) is used in establishing the analytical curve while the reagent ' blank (preparation blank, Exhibit E) is used to correct for poseible . ' contamination resulting from varying amounts of the acids used in the sample *• processing. D-22 ' ILM04.0 txhibit 0 ICP-MS 6.5.1 The calibration blank is prepared by diluting 2 ml of (1+1) BXO3 and 10 «£. of (1+1) RC1 to 100 mL with deionixed, distilled water. Prepare a sufficient quantity to be used to flush the syste* between standards and samples. 6.5.2 The reagent blank (or preparation blank - see exhibit I) mat contain all the reagents and in the same volumes as used in the processing of the samples. The reagent blank must be carried through the complete procedure and contain the same acid concentration in the final solution as the sample solution used for analysis. 6.6 Zn addition to the calibration standards, an instrument check standard, an interference check sample and a quality control sample are also required for the analyses (see Exhibit C). 6.6.1 The instrument check standard for continuing calibration verification is prepared by the analyst by combining compatible elements at a concentration equivalent to the mid-points of their respective calibration curves. 6.6.2 The interference check sample is prepared by the analyst, or obtained from £PA A* available. 6.6.3 The quality control sample for the initial calibration verification should be prepared in the same acid matrix aa the calibration standards and in accordance with the instructions provided by the supplier. 7. Proeedurf 7.1 Set up instrument with proper operating parameters established in Section 5.2. The instrument must be allowed to becosne thermally stable before beginning. This usually requires at leait 30 rain, of operation prior to calibration. 7.2 Initiate appropriate operating configuration of computer. ' 7.3 Profile and calibrate instrument according to instrument manufacturer's recommended procedures, using mixed calibration standard solutions such as those described in Section 6.4. flush the system with the calibration blank (6.5.1) between each standard. (MOTZt Tor boron concentrations greater than 500 ug/L extended flush times of 1 to 2 minute* may be required.) 7.4 Begin-the sample run flushing the system with the calibration blank solution (6.5.1) between each sample. (See HOTt in 7.3.) Analyze the Instrument check standard (6.6.1) and the calibration blank (6.5.1) each 10.analytical samples. 7.5 A minimum of two replicate exposures is required for standardization and all QC and cample analyses. The average result of the multiple exposures for the standardization and all QC and sample analyses shall be used. 0-23 . tLK04.0 f txhlbit D ICT-JUCJ 8. Calculation 8.1 Reagent blanks (preparation blank*} (hall be treated at specified In exhibit X. 5.2 If dilation! were perforated, the appropriate factor. shall be applied to eaaple value*. 8.3 Unit* shall "be clearly specified. 9. pyalitv Control 9.1 Quality control shall be performed a* specified in Xxhibit X. 1 : I 0-24 XLX04.0 I*••• Exhibit 0 ICP-AZS TABU 1 - MCOKHEWDEO KAVtUEHCTHS AMD ESTIMATED INSTRUMENTAL DETECTION LDUTS Estimated Detection Element Wavelength, na(l) Limit, ug/L(2) Mum in urn 308.215 45 Antimony 206.833 32 Arsenic 193.696 S3 Bariua 455.403 2 Beryllium 313.042 0.3 Boron 249.773 S Cadmium 226.502 4 Calcium 317.933 10 Chromium 267.716 7 Cobalt 228.616 7 Copper 324.754 6 Iron 259.940 7 Lead 220.353 42 Magnesium 279.079 30 Manganese 257.610 2 Molybdenum 202.030 8 Nickel 231.604 IS Potassium 766.491 See(3) Selenium 196.026 75 Silica (Si02) 266.158 58 Silver 328.068 7 Sodium 588.995 29 Thallium 190.864 40 Vanadium 292.402 8 tine 213.856 2 - (1) The wavelengths listed are recommended because of their sensitivity and overall acceptance. Other wavelengths may be substituted if they can provide the needed sensitivity and are treated with the same corrective techniques for spectral interference. (See 4.1.1.) The use of alternate wavelengths must be reported (in run) with the sample data. (2} The estimated instrumental detection limits as shown are taken from •Inductively Coupled Plasma-Atomic Emission Spectroscopy-Prominent Lines," EPA- 600/4-79-017. They are given as a guide for an instrumental limit. The actual method detection limits are sample dependent and may vary as the sample matrix varies. (3) Highly dependent on operating conditions and plasma position. 0-25 ILH04.0 TMXX 2. KXAMPV or MUU.TTC cotfCKNTiwrioN EQUIVAUHT* 1 • I Int«rf.r.«t Analyt* na Al Ca Cr . Cu r» Mq Mn Ml Tl V MtMMlfMMI 308.21% ~- 0.21 — . — . 1.4 Antimony 0.4—7 — . 2.9 0.08 — — -- .25 0.45 193.696 1.3 ~ 0.44 — "" ~" ~" ™~ ~~ 1.1 ^. BarltM 455.403 ~ — — -- — _~ B*rylllu« 313.042 0.04 O.OS 249.773 0.04 Boron 0.32 — — — — — CadMltM 226.502 ~. 0.03 — — 0.02 — ~- calclwa 317.933 — — 0.08 O.01 0.01 0.04 -- 0.03 0.03 7 Chro»i«* 267.716 0.003 — 0.04 — — - O.O4 to o* Cobalt 228.616 — — 0.03 O.OOS — — 0.03 0.15 — Coppar 324.754 ~— *"" "*"" "^ 0.003 — r- — 0.05 O.02 Iron 259.940 0.12 — — — L*ad 220.353 0.17 lfftQfMa*at iLlMI 279.079 — 0.02 0.11 0.13 — 0.25 — 0.0— 7 0.1—2 KAlHf AIW09 2S7.610 0.005 — 0.01 O.OOJ O.002 — — ~ — HolybdMiM 202.030 • O.OS 0.03 — ..«. — — NlelMl 231.604 _ — . — — — _ _«—.__ — f*l«nU* 196.026 0.2J — — 0.09 — .- — — ~ Silicon 28«. 151 _ .. 0.07 — i' 0.01 SOdiWM 588.995 _ ~. ~ 0.06 — ThallltM 190.864 0.30 — __ — — — «-. I VartadliM 292.402 ~ — 0.05 — O.OOS — — ~ 0.02 — 213.856 -- — 0.14 __ o,29 — — - 51ft- . txhibit D ICT-AIS TABLI 3. IKTtRTEWEHT AHO AKALYTX ELtMINTM. CONCSRISATIONS OStD TOR IHTtRTOMMCt XXXSUTtXMZNTS IM TABLt 2 An*lyt«« (ag/L) Int«rf«r«nt« Al 10 Al 1000 As 10 C* 1000 B 10 Cr 200 8*1 Cu 200 B« 1 F* 1000 C* 1 Kg 1000 Cd 10 Hn 200 Co 1 Hi 200 Cr 1 Ti 200 Cu 1 V 200 r« i Kg 1 Kn 1 Mo 10 Na 10 Hi 10 Pb 10 Sb 10 S* 10 Si 1 11 10 V 1 Zn 10 n D-27 ' ILM04.0 r-LJlTQMIC HBSOSITYON METHODS. FURNACE TTCHKIQgg Analvte/Method Pace No. Antimony - Method 204.2 CLP-M* D-29 Arsenic - Method 206.2 CLP-M 0-30 Beryllium - Method 210.2 CLP-M D-32 Cadmium - Method 213.2 CLP-M D-33 Chromium - Method 218.2 CLP-H D-34 Lead - Method 239.2 CLP-M D-3S Selenium - Method 270.2 CLP-H 0-37 Silver - Method 272.2 CLP-H D-39 Thallium - Method 279.2 CLP-H D-40 j *From "Methods for Chemical Analysis of Hater and Wastes" (EPA-600/4-79-020), Metals-' 4, as modified for use in the Contract Laboratory Program. CLP-M modified for the Contract Laboratory Program. D-28 IZJ404.0 ifl Exhibit O Kethod 206.2 ARSENIC Method 206.2 CLF-K** (Atonic Absorption, Furnace Technique) 1 Optimum Concentration Range» 5-100 ug/L Hi Approximate Detection Limit t 1 ug/L ) of Standard Solution 1. Stock solution: Dissolve 2.320 9 of arsenic trioxide, As2O3 {analytical reagent grade) in 100 mL of deionized distilled water containing 4 g HaOH. Acidify the eolation with 20 ml, cone. HNO3 and dilute to 1 liter. 1 mL - 1 «ng Ae (1000 2. Nickel Nitrate Solution, 5%: Dissolve 24.780 g of ACS reagent grade Ni(HO3)2'6H2O in deionized distilled water and make up to 100 mL. 3. Nickel Kitrate Solution, It: Dilute 20 mL of the 5% nickel nitrate to 100 mL with deionized distilled water. 4. Working Arsenic Solution: Prepare dilutions of the stock solution to be used as calibration standards at the tin* of analysis. Withdraw appropriate aliquot* of the stock solution, and add 1 mL of cone. RN03, 2 mL of 30% HjOj and 2 mL of the S% nickel nitrate solution. Dilute to 100 raL with deionized distilled water. Prearation 1. Add 100 uL of the 5% nickel nitrate solution to S mL of the digested sample. The sample is now ready for injection into the furnace. Note: Another matrix modifier may b« substituted for nickvl nitrat* if recommended by the instrument manufacturer. The matrix modifier used shall b* reported in the SDC Case Narrative. A Instrument Parameters fGeneral! 1. Drying Time and Temp: 30 sec 9 125°C. 2. Ashing Time and Temp: 30 sec 9 1100°C. 3. Atomizing Time and Teap: 10 sec 9 2700°C. 4. Purge Gas Atmosphere: Argon 5. Wavelength! 193.7 run 6. Operating parameters should be set as specified bv the particular instrument 1. The above concentration values and instrument conditions are for a Parkin-Elmer HCA-2100, based on the use of a 20 uL injection, purge gas interrupt and non- pyrolytic graphite. Smaller sire furnace devices or those employing faster rates of atomixation can be operated using lower atomization temperatures for shorter time periode than the above recommended settings. 2. Th« use of background correction is required. Background correction made by the deuterium arc method does not adequately compensate for high levels of certain interference (i.e., Al, Fe). Zf conditions occur where significant interference *CLP-M modified for the Contract Laboratory Program. -ft 0-30 ILM04.0 Exhibit D Method 206.2 is suspected, the l*b Bust switch to an alternate wavelength or take other appropriate actions to compensate for the interference effects. 3. For every cample analyzed, verification is necessary to determine that ee.thod of standard addition is not required (see Exhibit X). 4. If Mtbod of standard addition is required, follow the procedure given in Exhibit I. 5. The use of the Electrodeless Discharge Lamps (COL) for the light source is recommended. r ; 3'il I»Lr' Iv-'. 1< 1 &.:'!ii? D-31 ILK04.0 I t I i .1 :1 Exhibit O Hethod 239.2 LEAD Method 239.2 CtP-H* (Atomic Absorption, Furnace Technique) optimum Concentration Range: 5-100 ug/L Approximate Detection Limitt 1 ug/L preparation ef Standard Solution 1. Stock solution: Carefully weigh 1.599 g of lead nitrate, Pb(K03}2 (analytical reagent grade), and dissolve in deionixed distilled water. When solution is complete, acidify with 10 mL redistilled BRO3 and dilute to 1 Liter with deionixed distilled vater. 1 siL - 1 my Pb (lOOOng/L). 2. Lanthanum Nitrate solutions Dissolve 58.64 g of ACS reagent grade La2Oj in 100 «L cone. BNC-3 and dilute to 1000 mL with deionixed distilled water, a »L - SO tag La. 3. Working Lead solution: Prepare dilutions of stock lead solution to be used as calibration standard* at the time of analysis. The calibration standards must be prepared using the sane type of acid and at the same concentration as will result in the sample to be analyzed after sample preparation. To each 100 ml of diluted standard add 10 mL of the lanthanum nitrate solution. pimple Preparation 1. To each 100 mL of prepared sample solution add 10 mL of the lanthanum nitrate solution. • Mote: Another matrix modifier nay be substituted for lanthanum nitrate if recommended by the instrument manufacturer. The matrix modifier used shall be reported in the SDG Cats Narrative. Instrument Parameter* fGeneral) 1. Drying Time and Temp: 30 sec 9 125°C. 2. Ashing Time and Temp: 30 sec 9 SOO°C. 3. Atomizing Time and Temp: 10 sec € 2700°C. 4. Purge Gas Atmosphere: Argon 5. Wavelength: 283.3 run 6. Operating parameters should be set ac specified bv the particular instrument manufacturer. fotes 1. The above concentration values and instrument conditions are for a Parkin-liner HGA-2100, based on the use of a 20 uL injection, continuous flow purge gas and non-pyroly-tic graphite, and are to be used as guidelines only. Smaller size furnace devices or those employing faster rates of atomitation can be operated using lower atomization temperatures for shorter tine periods than the above recommended settings. 2. The use of background correction is required. 3. Greater sensitivity can be achieved using the 217.0 ran line, but the optimum concentration range is reduced. The use of a lead electrodeless discharge lamp at this lower wavelength has been found to be advantageous. Also a lower atomization temperature (2400°C) nay be preferred. "CLP-M modified for the Contract Laboratory Program. i -.1 D-35 ILK04.0 J exhibit D Method 239.2 4. To suppress sulfate interference (up to 1500 ppm), lanthanum Is added as the nitrate to both sample* and calibration standards. 5. Sine* glassware contamination i* a severe problen in lead analysis, all glassware should be cleaned immediately prior to use, and once cleaned, should not be open to the atmosphere except when necessary. 6. For every sample analyzed, verification is necessary to determine that method of standard addition is not required (see Exhibit E). 7. If method of standard addition is required, follow the procedure given in Exhibit X. 5-36 ILK04.0 exhibit D Kethod 270.2 SELENIUM Method 270.2 CLP-M* {Atomic Absorption, Furnace Technique) i Optimum Concentration Rangei 5-100 ug/L Approximate Detection Limits 2 ug/l preparation ef Standard Solution i 1. Stock Selenium eolation: Dissolve 0.3453 g of selenoue acid (actual aeeay 94.6% B2SeOa) in deionited dietilled water and make up to 200 oL. 2 ml. • 1 ag Se (1000 ag/L). i 2. Hickel Hitrate solution, 5%: Dissolve 24.760 g of ACS reagent grade Ri(H03)2.€H2O in deionized dietilled water and make up to 100 kL. 3. nickel Hitrate solution, 1%« Dilute 20 tut of the 5% nickel nitrate to 100 mL i with deionized distilled water. 4. Working Selenium solution: Prepare dilutions of the stock solution to be used as calibration standards at the time of analysis. The calibration standards must be prepared using the same type of acid and'at the same concentration as i will result in the sample to be analyzed after sample preparation. Withdraw appropriate aliquot* of the stock solution, and add 1 mL of cone. HNO^, 2 mL of 30% H2O2 and 2 ml. of the 5% r.ickcl nitrate solution. Dilute to 100 ml. with i deionized distilled water. Sample Preparation •» 1. Add 100 uL of the 5% nickel nitrate solution to 5 mL of the digested sample. i The sample i> now ready for injection into the furnace. Note: Another matrix modifier rosy be substituted for nickel nitrate if recommended by the instrument manufacturer. The matrix modifier used shall be i reported in the SDC Case Narrative. Instrument Parameters 1. Drying Time and Temp: 30 sec 0 125°C. i 2. Charring Time and Temp: 30 sec £ 1200°C. 3. Atomizing Time and Temp: 10 sec % 2700°C. 4. Purge Cas Atmosphere: Argon 5. Wavelength* 196.0 nm i 6. Operating parameters should be se,t a> specified bv the particular instrument manufacturer. Hotes i: 1. The above concentration values and instrument conditions are for a Parkin-Elmer HCA-2100, based on the use of a 20 ut injection, purge gas interrupt and non- pyrolytic graphite, and are to be used as guidelines only. Smaller site i furnace devices or those employing faster rates of atomization can be operated using lower atomization temperatures for shorter time periods than the above recommended settings. i 2. The use of background correction is required. Background correction made by the deuterium arc method does not adequately compensate for high levels of certain interferents (i.e., Al, Fe). If conditions occur where significant interference *CtP-M modified for the Contract Laboratory Program. D-37 ILK04.0 r *. _ Exhibit D Method 270.2 is suspected, the lab must switch to an alternate wavelength or take other appropriate actions to compensate for the interference effects. 3. Selenium analysis suffers interference from chlorides (>600 ng/L) and sulfate (>200 mg/L). For the analysis of industrial effluents and samples with concentrations of sulfate from 200 to 2000 mg/L, both samples and standards should be prepared to contain 1% nickel. 4. for every sample analyzed, verification is .necessary to determine that method at standard addition is not required (see Exhibit E). 5. If method of standard addition is required, follow the procedure given in Exhibit E. 6. The use of the Clectrodelesi Discharge Lamp (EOL) for the light source is recommended. f r 0-38 ILK04.0 exhibit P Method 245.1 HgRCCTY AHALY^IS II? WATER 8Y KAKITAL COLD V*POp KCfcCOWf Method 245.1 CLP-M* (Manual Cold Vapor Technique) 1. fteoce and Apolicatipn 1.1 In addition to inorganic forma of mercury, organic mercurials nay alco be present. Theee ergano-mercury compounds will not respond to the cold vapor atomic absorption technique unless they are first broken down and converted to mercuric ions. Potassium permanganate oxidizes many of these compounds, but recent studies have shown that a number, of organic mercurials, including phenyl mercuric acetate and methyl mercuric . chloride, are only partially oxidized by this reagent. Potassium persulfate has been found to give approximately 100% recovery when used as the oxidant with these compounds. Therefore, a persulfate oxidation step following the addition of the permanganate has been included to ensure that organo-mercury compounds, if present, will be oxidized to the mercuric ion before measurement. A heat step is required for methyl mercuric chloride when present in, or spiked to, a natural system. 1.2 The range of the method may be varied through instrument and/or recorder expansion. Using a 100 ml. sample, a detection limit of 0.2 ug Hg/L can be achieved (see 10.1). • 2. Summary of Method 2.1 The flatneless AA procedure is a physical method based on the absorption of radiation at 253. 7 rue by mercury vapor. Organic nercury compounds are oxidized and the mercury is reduced to the elemental state and aerated from solution in a closed system. The mercury vapor passes. through a cell positioned in the light path of an atomic absorption spectrophotometer. Absorbance (peak height) is measured as a function of mercury concentration and recorded in the usual manner. 3. Sample Handling and Preservation 3.1 Until more conclusive data are obtained, samples are preserved by acidification with nitric acid to a pH of 2 or lower immediately at the j; time of collection (Exhibit D, Section II). 4. Interference 4.1 Possible interference from sulfide is eliminated by the addition of potassium permanganate. Concentrations as high as 20 mg/L of sulfide as sodium sulfide do not interfere 'with the recovery of added inorganic j; mercury from distilled water (Exhibit 0, Section IX). 4.2 Copper has also been reported to interfere; however, copper ,4 concentrations as high as 10 mg/L had no effect on recovery of mercury from spiked samples. .1 *CLP-M modified for the contract Laboratory Program. D-47 ILM04.0 I T Exhibit 0 Method 245.1 4.3 Sea waters, brine* and industrial effluents high in chlorides require additional permanganate (as much as 25 mL). During the oxidation step, chlorides are converted to free chlorine which will also absorb radiation at 2S3 nre. Care must be taken to assure that free chlorine is absent before the mercury is reduced and swept into the cell. This may be accomplished by using an excess of hydroxylamine sulfate reagent (2S at). Both inorganic and organic nercury spikes have been quantitatively recovered from the sea water using this technique. 5. Apparatus 5.1 Atomic Absorption Spectrophotometen (See Note 1) Any atomic absorption unit having an open sample presentation area in which to mount the absorption cell is suitable. Instrument settings recommended by the particular manufacturer should be followed. NOTE Is Instruments designed specifically for the measurement of mercury using the cold vapor technique are commercially available and may be substituted for the atomic absorption spectrophotometer. 5.2 Mercury Hollow Cathode Lamp: Westinghouse WL-22847, argon filled, or equivalent. 5.3 Recorder: Any multi-range variable speed recorder that is compatible with the 0V detection system is suitable. 5.4 Absorption Cellt Standard spectrophotometer calls 10 cm long, having guartr end windows may be used. Suitable cells may be constructed front plexiglass tubing, 1* O.D. X 4*1/2". The ends are ground perpendicular to the longitudinal axis and quartz windows (I' diameter X 1/16" thickness) are cemented in place. The cell is strapped to a burner for support and aligned in the light beam by use of two 2" by 2" cards. One inch diameter holes are cut in the middle of each card; the cards are then placed over each end of th« cell. The cell is then positioned and adjusted vertically and horizontally to find the maximum transmittance. 5.5 Air Pump: Any peristaltic pump capable of delivering 1 liter of air per minute may be used. A Kasterflex pump with electronic speed control has been found to be satisfactory. 5.6 Flowmeterr. Capable of measuring an air flow of 1 liter per minute. 5.7 Aeration Tubing: A straight glass frit having a coarse porosity. Tygon tubing is used for passage of the mercury vapor from the sample bottle to the absorption cell and return. 5.8 Drying Tube: 6" X 3/4" diameter tube containing 20 g of magnesium perchlorate (see Rote 2). NOTE 2i In place of the magnesium perchlorate drying tube, a small reading lamp with 60W bulb may be used to prevent condensation of moisture inside the cell. The lamp is positioned to shine on the absorption cell maintaining the air temperature in the cell about 10°c above ambient. 0-48 ILM04.0 exhibit D Method 245.1 6. Reagents 6.1 Sulfuric Acid, Cone: Reagent grade. 6.1.1 Sulfuric acid, O.S Ki Dilute 14.0 aL of cone, sulfuric acid to 1.0 liter. 6.2 Kitric Acid, Concj Reagent grade of low mercury content (see Koto 3). KOTE 3: Zf a high reagent blank is obtained, it may be necessary to *, distill the nitric acid. |[ 6.3 Stannous Sulf ate i Add 25.g stannous sulfate to 250 aL of O.S. M sulfuric acid. This mixture is a suspension and should be stirred continuously during use. (Stannous chloride may be used in place of stannous sulfate.) 6.4 Sodium Chloride-Kyroxylamine Sulfate Solution: Dissolve 12 g of sodium chloride and 12 g of hydroxylamine sulfate in distilled water and dilute to 100 mL. (Hydroxylamine hydrochloride may be used in place of hydroxylamine sulfate.) 6.5 Potassium Permanganate (KHnO^): 5% solution, w/v. Dissolve 5 g of potassium permanganate in 100 mL of distilled water. 6.6 Potassium Persulfate: 5% solution, w/v. Dissolve 5 g of potassium persulfate in 100 mL of distilled water. 6.7 Stock Mercury Solution: Dissolve 0.1354 g of mercuric chloride in 75 mL of distilled water. Add 10 mL of cone, nitric acid and adjust the •• volume to 100.0 mL. 1-mL • 1 mg Hg. 6.6 Working Mercury .Solution: Make successive dilutions of the stock mercury solution to obtain a working standard containing 0.1 ug per mL. I This working standard and the dilutions of the stock mercury solution should be prepared fresh daily. Acidity of the working standard should be maintained at 0.15% nitric acid. This acid should be added to the flask as needed before the addition of the aliquot. 7. Calibration 7.1 Transfer 0, 0.2, O.S, 1.0, 5.0 and 10.0 mL aliquots of the working mercury solution containing 0 to 1.0 ug of mercury to a series of 300 mL BOO bottles. Add enough distilled water to each bottle to make a total volume of 100 mL. Mix thoroughly and add 5 mL of cone, sulfuric acid (6.1) and 2.5 mL of cone, nitric acid (6.2) to each bottle. Add 15 mL of XMn04 (6.5) solution to each bottle and allow to stand at least 15 minutes. Add 8 mL of potassium persulfate (6.6) to each bottle and heat for 2 hours in a water bath maintained at 9S°C. Alternatively, cover the BOD bottles with foil and heat in an autoclave for 15 alnutes at 120°C and 15 PSI. Cool and add 6 mL of sodium chloride-hydroxylamine sulfate solution (6.4) to reduce the excess permanganate. When the :; solution has been decolorized wait 30 seconds, add 5 mL of the stannous . ;: • sulfate solution (6.3) and immediately attach the bottle to the aeration ;';. I apparatus forming a closed system. At this point the sample is allowed I • to stand quietly without manual agitation. .[' ' •i) - , D-49 ILK04.0 Exhibit D Method 245.1 Th* circulating pump, which has previously been adjusted to a rat* of 1 liter p*r minute, I* allowed to run continuously (see Not* 4). Th* absorbence will increase and reach maximum within 30 seconds. Ac soon a« the recorder pen levels off, approximately 1 minute, open the bypass valv* and continue the aeration until the absorbanca returns to its minimum value (see Mote 3). Close the bypass valve, remove the. stopper and frit from the BOO bottle and continue the aeration. Proceed with the standards and construct a standard curve by plotting peak height versus microgran* of mercury. MOTE 4t An open system where the mercury vapor is passed through the absorption cell only once may be used instead of the closed system. MOTE Si Because of the toxic nature of mercury vapor precaution must be taken to avoid its inhalation. Therefore, a bypass has been included in th* system to either vent the mercury vapor into an exhaust hood or pass the vapor through some absorbing media, such as equal volumes of 0.1 H KMnO4, and 10% H2SO4 or 0.25% iodine in a 3% a KI solution. A specially treated charcoal that will adsorb mercury vapor is commercially available. 8. Procedure 8.1 Transfer 100 cnL, or an aliquot diluted to 100 mL, containing not aore than 1.0 u? of mercury, to a 300 mL BOO bottle. Add S mL of cone. sulfuric acid (6.1) and 2.5 mL of cone, nitric acid (£.2) .mixing after each addition. Add IS mi. of potassium permanganate solution (6.5) to each sample pottle (see Note 6). For sewage samples additional permanganate may be required. Shake and add additional portions of potassium permanganate solution, if necessary, until the purple color persists for at least 15 minutes. Add 8 mL of potassium persulfate (6.6) to each bottle and heat for 2 hours in a water bath at 9S°C. NOTE.- 6: The same amount of KMnO^ added to the samples should be present in standards and blanks. Cool and add 6 mL of sodium chloride-hydroxylamine sulfate (6.4} to reduce the excess permanganate (see Note 7). Purge the headspace in the BOO bottle for at least 1 minute and add 5 mL of stannous sulfate (6.3) and immediately attach the bottle to the aeration apparatus. Continue as described under Calibration. NOTE 7 1 -Add reductant in 6 mL increments until KMn04 is completely reduced. - •9. 9.1 Determine the peak height of the unknown from the chart and read the mercury value from the standard curve. 9.2 Calculate the mercury concentration in the sample by the formula: Hg, curve 1000 tat uy Hy/L volume. mL i L 0-50 ILM04.0 n Ixhibit O Kethod 245.1 n 10. 10.1 If additional sensitivity is required, a 200 mL sample with recorder expansion aay be used provided the instrument does not produce undue r noise. Using a Coleman M&S-50 with a drying tube of stagnesiua perchlorete and a variable recorder, 2 mv was set to read full scale. With these conditions, and distilled water solutions of mercuric chloride at concentrations of 0.15, 0.10, 0.05 and 0.025 ug/t, the standard deviations were ±0.027, ±0.0006, ±0.01 and ±0.004. Percent recoveries at thtse levels were 107, 83, 84 and 96%, respectively. 10.2 Directions for the disposal of mercury-containing wastes are given in ASTH Standards, Part 31, *Watsr, " p. 349, Method D3223 (1976)', 1 D-51 ILM04.0 n 1 fl -1'1 APPENDIX B USEPA T] REGION I H LOW STRESS (low flow) PURGING AND SAMPLING PROCEDURE FOR _'J THE COLLECTION OF GROUND WATER SAMPLES FROM -e MONITORING WELLS •0 July 30,1996 ^ Revision! 1 1 1 1 Ptuliddphia Nwil B«se: Gtnrd Po'tt Mmgonem Area LongTennOouod-WMcrManitDrinjPUn dM2VH29U8basU.3UtBpnS.doc ILS, ENVIRONMENTAL PROTECTION AGENCY REGION I LOW STRESS (low flow) PURGING AND SAMPLING PROCEDURE FOR THE COLLECTION OF GROUND WATER SAMPLES FROM MONITORING WELLS July 30,1996 Revision 2 SOP #: GW 0001 Region I Low Stress (Low Flow} 80P Revision Humbert 2 Date: July 30, 1996 Page 1 of 13 \ U.S. INVXROHMSNTAL PROTECTION AGENCY RIOION I LOW STRESS (low flow)" PUROIHO AMD MMPLXNQ 3KOMBURE TOR TBS COLLECTION CT GROtWD WATS* SAMPLES FROK KONITORINO WELLS I. SCOPE & APPLICATION This standard operating procedure (SOP) provides * general framework for collecting ground water sample* that are indicative of mobile organic and inorganic loads at ambient flow condition! (both the dissolved fraction and the fraction associated with mobile particulates). The SOP emphasizes the need to minimize stress by low water-level drawdowns, and low pumping rates (usually less than 1 liter/rain) in order to collect samples with minimal alterations to water chemistry. This SOP is aimed primarily at sampling monitoring wells that can accept a submersible pump and have a screen, or open interval length of 10 feet or less (this is the most common situation). However, this procedure is flexible and can be used in a variety of well construction and ground-water yield situations. Samples thus obtained are suitable for analyses of ground water contaminants (volatile and stmi-volatile organic analytes, pesticides, PCBs, metals and other inorganics), or other naturally occurring analytes. This procedure does not address the collection of samples from wells containing light or denae non-aqueous phase liquids (LNAPLs and DNAPLs). For this the reader may wish to check: Cohen, R.M. and J.w. Mercer, 1993, DNAPL Site Evaluation; C.K. Sraoley (CRC Press), Boca Raton, Florida and U.S. Environmental Protection Agency, 1992, RCRA Ground-Water Monitoringi Draft Technical Guidance; Washington, DC (2PA/530-R-93-001). The screen, or open interval of the monitoring well should be optimally located (both laterally and vertically) to intercept existing contaminant plume(s) or along flowpaths of potential contaminant releases. It is presumed that the analytes of interest move (or potentially move) primarily through the more permeable tones within the screen, or open interval. Use of trademark names does not imply"endorsement lay U.S. EPA but is intended only to assist in identification of a specific type of device. '_ :__. SOP #: GW 0001 Region Z Low Stress (Low Flow) sop Revision Number; 2 Datej July 30, 1996 Page 2 of J.3 Proper well construction and development cannot be overemphasized, ilnee the uee of installation techniques that are appropriate to the hydrogeologic setting often prevents "problem well" situations from occurring. It is also recommended that as part of development or redevelopment the well should be tested to determine the appropriate pumping rate to obtain stabilization of field indicator parameter a with minimal drawdown in shortest amount of time. With this information field crews can then conduce purging and sampling in a more expeditious manner. The mid-point of the saturated screen length (which should not exceed 10 feet) is used by convention as the location of the pump intake. However, significant chemical or permeability contrast(s) within the screen may require additional field work to determine the optimum vertical location(s) for the intake, and appropriate pumping rate(s) for purging and sampling more localized target zone(s). Primary flow zones (high(er) permealability and/or high (er) chemical concentrations) should be identified in wells with screen lengths longer than 10 feet, or in wells with open boreholes in bedrock. Targeting these tones for water sampling will help insure that the low stress procedure will not underestimate contaminant concentrations. The Sampling and Analysis Plan must provide clear instructions on how the pump intake depth (s) will be selected, and reason(s) for the depth(s) selected. Stabilization of indicator field parameters is used to indicate that conditions are suitable for sampling to begin. Achievement of turbidity levels of less than 5 NTU and stable drawdowns of less than 0.3 feet, while desirable, are cot mandatory. Sample collection may still take place provided the remaining criteria in this procedure are met. Zf after 4 hours of purging indicator field parameters have not stabilized, one of 3 optional courses of action may be taken: a) continue purging until stabilization is achieved, b) discontinue purging, do not collect any samples, and record in log book that stabilization could not be achieved (documentation must describe attempts to achieve stabilization) c} discontinue purging, collect samples and provide full explanation of attempts to achieve stabilization (notes there is a risk that the analytical data obtained, especially metals and strongly hydrophobic organic analyces, may not meet the sampling objectives). Changes to this SOP should be proposed and discussed when the site Sampling and Analysis Plan is submitted for approval. Subsequent requests for modifications of an approved plan must include adequate technical justification fot proposed changes. All changes and modifications must be approved before implementation in field. i < so? #? cw 0001 Rtgion I Low Street (Low Flow) SOP Revision Number; 2 Date: July 30, 1996 Page 3 of 13 II.IQUIPKEHT A. Extraction devict Adjustable rate,-submersible pumps are preferred (for example, centrifugal or bladder pump conitructed of stainless steel or Teflon). ' ; Adjustable rate, peristaltic pumps (suction) may be used with caution. Note that EPA guidance states: "Suction pumps are not , recommended because they may cause degassing,. pH modification, anil loss of volatile compounds* (EPA/540/P-67/001, 1987, page 8.5-11). The use of inertial pumps is discouraged. These devices frequently cause greater disturbance during purging and sampling and are leas easily controlled than the pumps listed above. This can lead to sampling results that are adversely affected by purging and sampling operations, and a higher degree of data variability. B. Tubing Teflon or Teflon lined polyethylene tubing are preferred when sampling is to include VOCs, SVOCs, pesticides, PCBs and inorganics. PVC, polypropylene or polyethylene tubing may be used when collecting samples for inorganics analyses. However, these materials should be used with caution .when sampling for organic*. If these materials are used, the equipment blank (which includes the tubing) data must show that these materials do not add contaminants to the sample, Stainless steel tubing may be used when sampling for VOCs, SVOCs, pesticides, and PCBs. However, it should be used with caution when ~ sampling for metals. The use of 1/4 inch or 3/8 inch (inner diameter) tubing is preferred. This will help ensure the tubing remains liquid filled when operating at very low pumping rates. Pharmaceutical grade (Pharmed) tubing should be used for the section around the rotor head of a peristaltic pump, to minimize gaseous diffusion. C. Water level measuring device(s), capable of measuring to -0.01 foot accuracy (electronic 'tape1, pressure transducer). Recording pressure transducers, mounted above the pump, are especially helpful in tracking water levels during pumping operations, but their use ' j SCP #: GW 0001 Region I Low Stress (Low Flow) SOP ~~ ; Revision Number: 2 Datei July 30, 1996 ., Page 4 of 13 - ./must include check measurements with a water level 'tape* at the 1' Bcart and end of each record. —' I'D. Flow measurement supplies (e.g., graduated cylinder and stop ' watch). _ [' E. Interface probe, if needed. I . F. Power source (generator, nitrogen tank, etc.). If a gasoline - • generator ie used, it must be located downwind and at least 30 feet ~ . from the well so that the exhaust fumes do not contaminate the samples. » • • „ - • 0. Indicator field parameter monitoring instruments - pR, Eh, " dissolved oxygen (DO), turbidity, specific conductance, and , , temperature. Use of a flow-through-cell is required when measuring - all listed parameters, except turbidity. Standards to perform field - • calibration of instruments. Analytical methods are listed in 40 CFR . 136, 40 CFR 141, and SW-846. For Eh measurements, follow __ . ' manufacturer's instructions. H. Decontamination supplies (for example, non-phosphate detergent, *' distilled/deionized water, icopropyl alcohol, etc.). j t I. Logbook(s), and other forms (for example, well purging forms}. — J. Sample Bottles. r . X. Sample preservation supplies (as required by the analytical __ / methods). * * ,. L. Sample tags or labels. ~ • M. Well construction data, location map, field data from last sampling event. - . . H. Hell keys. v 0. Site specific Sample and Analysis Plan/Quality Assurance Project - " , Plan. . - ?. PID or FID instrument (if appropriate) -co detect VOCs for health _ and safety purposes, and provide qualitative field evaluations. SOP *t Region I Low Stress (Low Flow) SOP Revision Number: 2 Date: July 30, 1996 Page 5 of 13 ZZZ.FRZLZMZHARY SITS ACKVZTZtt Check well for security damage or evidence of tampering, record pertinent observations. Lay out sheet of clean polyethylene for monitoring and campling equipment. Remove well cap and immediately measure VOCs at the rim of the well with a PID or FID instrument and record the reading in the field logbook. If the well casing does not have a reference point (usually & V-cut or indelible mark in the well casing), make one. Describe its location and record the date of the mark in the logbook. A synoptic water level measurement round should be performed (in the shortest possible time) before any purging and sampling activities begin. Zt is recommended that water level depth (to 0.01 ft.) and total well depth (to 0.1 ft.) be measured the day before, in order to allow for re-settlement of any particulates in the water column, if measurement of total well depth is not made the day before, it should not be measured until after sampling of the well is complete. All measurements must be taken from the established referenced point. ' Care should be taken to minimize water column disturbance. Check newly constructed wells for the presence of LNAPLs or DNAPLs before the initial sampling round. If none are encountered, subsequent check measurements with an interface probe are usually not needed unless analytical data or field head space information signal a worsening situation. Notet procedures for collection of LNAPL and D27APL samples are not addressed in this SOP. zv.proazxa AND SAKFLZKO PROCXDTCS Sampling wells in order of increasing chemical concentrations (known or anticipated) is preferred. 1. Install Pump .Lower pump, safety'cable, tubing and electrical lines slowly (to minimize disturbance) into the well to the midpoint of the zone to be sampled. The Sampling and Analysis Plan should specify the sampling depth, or provide criteria for selection of intake depth for each well (see Section I). If possible keep the pump intake at least two SOP ft: GW 0001 Region I Low Str««i (Low Flew) SOP Revision Dumber: 2 Datet July 30, 1996 Page 6 of 13 feet Above the bottom of the wtll, to minimize mobilization of particulars present in the bottom of the well. Collection of turbid • free water samples may be especially difficult if there is two feet or less of standing water in the well. • 2. Measure Water Level ' Before starting pump, measure water level. If recording pressure transducer is used-initializt starting condition. • 3, Purge Well 3a» Initial Low Stress Sampling Event Start the pump at its lowest speed setting and slowly increase the speed until discharge occurs. Check water level. Adjust pump speed until there is lictle or no water level drawdown (less than 0.3 feet). Ii the minimal drawdown that can be achieved exceeds 0.3 feet buz remains stable, continue purging until indicator field parameters stabilize. Monitor ar.d record water level and pumping rate every three to five minutes (cr as appropriate) during purging. Record any pumping rate adjustments (both time and flow rate). Pumping rates should, as needed, be reduced to the minimum capabilities of the pump (for example, 0.1 - 0.4 1/min) to ensure stabilization of indicator parameters. Adjustments are best made in the first fifteen minutes of pumping in order to help minimize purging time. During pump start-up,"drawdown may exceed the 0.3 feet target and then •recover" as pump flow adjustments are made. Purge volume calculations should utilize stabilized drawdown value, not the initial drawdown. Do not - allow the water level to fall to the intake level (if the static water level is above the well screen, avoid lowering the water level into the screen). The final purge volume must be greater than the stabilized drawdown volume plus the extraction tubing volume. Wells with low recharge rates may require the use of special pumps capable of attaining very low pumping rates (bladder, peristaltic), and/or the use of dedicated equipment. If the recharge rate of the well is lower than.extraction rat• capabilities of currently .manufactured pumps and the well is essentially dewatersd during purging, then the well should be sampled as soon as the water level has recovered sufficiently to collect the appropriate volume needed for all anticipated samples (ideally the intake should not be moved during this recovery period). Samples may then be collected even though the indicator field parameters have not stabilized. SOP #: OH 0001 Region I Low Serais (Low Flow) SOP Revision Number: 2 Datet July 30, 1996 Page 7 of 13 3b. Subsequent Low Stress Sampling Events After synoptic water level measurement round, check intake depth and drawdown information from previous'campling event(0) for each well. Duplicate, to the extent practicable, the intake depth and extraction rate (use final pump dial setting information) from previous event (s). Perform purging operations as above. 4. Monitor Indicator Field Parameters During well purging, monitor indicator field parameters (turbidity, temperature, specific conductance, pK, Eh, DO) every three to fiv* minutes (or less frequently, if appropriate). Note: during the early phase of purging emphasis ahould be put on minimizing and stabilising pumping stress, and recording those adjustments. Purging is considered complete and sampling may begin when all the above indicator field parameters have stabilized. Stabilization is considered to be achieved when three consecutive readings, taken at three (3) to five (5) minute intervals, are within the following limits: turbidity (10% for values greater than 1 NTU) , DO (10%), specific conductance (3V),' temperature (3%), pH (± 0,1 unit), ORP/Eh (± 10 millivolts) . All measurements, except turbidity, must be obtained using a flow- through-cell. Transparent flow-through-cells are preferred, because they allow field personnel to watch for particular build-up within the cell. This build-up may affect indicator field parameter values measured within the cell and may also cause an underestimation of turbidity values measured after the cell. Zf the call needs to be cleaned during purging operations, continue pumping and disconnect cell for cleaning, then reconnect after cleaning and continue monitoring activities. The flow-through-cell must be designed in a way that prevents air bubble entrapment in the cell. Whan the pump is turned off or cycling on/off (when using a bladder pump), water in the cell must not drain out. Monitoring probes must be submerged in water at all times. Zf two flow-through-eel Is are used in series, the one containing the dissolved oxygen probe should come first (this parameter is most susceptible to error if air leaks into the system). SOP #: GW 0001 Region I tow Stress {Low Flow) SOP Revision Humbari 2 Date: July 30, 1996 Page 8 of 13 5. Collect Water Samples Hater samples for laboratory analyses must be collected before water has passed through the flow-through-cell (use a by-pass assembly or disconnect cell to obtain sample). VOC samples should be collected first and directly into pre-preeerved sample containers. Fill all sample containers by allowing the pump discharge to flow gently down the inside of the container with minimal turbulence. During purging ar.d sampling, the tubing should remain filled with water so as to minimize possible changes in water chemistry upon contact with the atmosphere. It is recommended that 1/4 inch or 3/8 inch (inside diameter) tubing be used to help insure that the sample tubing remains water filled. If the'pump tubing is not completely filled to the sampling point, use.one of the following procedures to collect samples: "(1) add clamp, connector (Teflon or stainless steel) or valve .to constrict sampling end of tubing; (2) insert small diameter Teflon tubing ir.to water filled portion of pump tubing allowing the end to protrude beyond the end of the pump tubing, collect sample from email diameter tubing/ (3) collect non-VOC samples first, then increase flow rate slightly until the water completely fills the tubing, collect sample and record new drawdown, flow rate and new indicator field parameter values. Add preservative, as required by analytical methods, to samples immediately after they are collected if the sample containers are not pre-preserved. check analytical methods (e.g. EPA SW-846, water supply, etc.) for additional information on preservation. Check pH for all samples requiring pH adjustment to assure proper pH value. For VOC samples, this will require that a test sample be collected during purging to determine the amount of preservative that needs to be added to the sample containers prior to sampling. If determination of filtered metal concentrations is a sampling objective, collect filtered water samples using the same low flow procedures. The use of an in-line filter is required, and the filter size (0.45 urn is commonly used) should be based on the sampling objective. Pre-rinse the filter with approximately 25 • 50 ml of ground water prior to sample collection. Preserve filtered water •ample immediately. Note: filtered water samples are not an acceptable substitute for unfiltered samples when the monitoring objective is to obtain chemical concentrations of total mobile contaminants in ground water for human health risk calculations. SOP #: GW 0001 Region Z Low Stress (Low Flow) SOP Re via ion Number: 2 Date: July 30, 1996 Page $ of 13 Label each cample ae collected. Samples requiring cooling (volatile organic*, cyanide, etc.) will be placed into a cooler with ice or refrigerant for delivery to the laboratory. Metal camples after acidification to a pH less than 2 do not need to be cooled. 6. Pose Sampling Activities If recording pressure transducer is used, remeasure water level with tape. . i After collection of the samples, the pump tubing may either be dedicated to the well for resampling (by hanging the tubing inside the well), decontaminated, or properly discarded. . Sefore securing the well, measure and record the well depth (to 0.1 ft.), if not measured the day before purging began. Note: measurement of total well depth is optional after the initial low •tress sampling event. However, it is recommended if the well has ;; a •silting" problem or if confirmation of well identity is needed. Secure the well. V.DECONTAMINATION i Decontaminate campling equipment prior to use in the first well and following sampling of each subsequent well. Pumps will not be removed between purging and sampling operations. The pump and tubing (including support cable and electrical wires which are in contact with the well) will be decontaminated by one of the procedures listed below. Procedure 1 The decontaminating solutions can be pumped from either buckets or short PVC casing sections through the pump or the pump can be disassembled and flushed with the decontaminating solutions, it is recommended that detergent and isopropyl alcohol be used sparingly in the decontamination process and water flushing steps be extended to ensure that any sediment trapped in the pump is removed. The pump exterior and electrical wires must be rinsed with the • decontaminating solutions, as well. The procedure is as follows: Flush the equipment/pump with potable water. Flush with non-phosphate detergent solution. If the solution is BOP #.- GW oooi Region I Low Screes . (Low Flow) SOP Revision Number: 2 Datei July 3d 1996 page 10 Of 13 recycled, the solution must bt changed periodically. « • Flush with potable or distilled/deionizad water to remove all of the detergent solution. If the water is recycled, the water must be changed periodically. i • Flush with isopropyl alcohol (pesticide grade). If equipment 1 blank data from the previous campling event show that the level of ,. contaminants is insignificant, then this itep may be skipped. Flush with distilled/deionized water. The final water rinse trust not be recycled. • . pjrpeftdure 2 Steam clean the outside of the submersible pump. Pump hot potable water frsm the steam cleaner through the inside of the pump. This can be accomplished by placing the pump inside a three or four inch diamettr PVC pipe with end cap. Hot water from the steam cleaner jet will be directed inside the PVC pipe and the pump exterior will be cleaned. . The hot water from the steam cleaner will then be pumpad from the PVC pipe through the pump end • • collected into another container. Note: additives or solutions should not bt added to the steam cleaner. • • . Pump non-phoiphate detergtnt solution through the inside of the pump. If the solution is recycled, the solution must be changed periodically. • • Pump potable water through the inside of the pump to remove all of - ' ' • the detergent solution. If the solution is recycled, the solution must be changed periodically. Pump distillcd/deionized water through the pump. The final water rinse must not be recycled. VT.71ZLD QUALITY CONTROL . .Quality control samples are required to verify that the sample collection and handling process has not compromised the quality of the ground water samples. All field quality control sample* must be prepared the same as regular investigation samples with regard to sample volume, containers, and preservation. The following quality ; control samples shall be collected for each batch of samples (a batch SOP #J GW 0001 Region Z Low Serena (Low Flow) SOP Revision Number: 2 Date: July 30, 1956 Page 11 of 13 may not exceed 20 samples). Trip blanki are required for the voc camples at a frequency of one set per VOC sample cooler. Field duplicate. Matrix spike. Matrix spike duplicate. Equipment blank. Trip blank (VOCs). Temperature blank (one per cample cooler). Equipment blank shall include the pump and the pump's tubing. If tubing ie dedicated to the well, the equipment blank will only include the pump in subsequent sampling rounds. * * Collect samples in order from wells with lowest contaminant concentration to highest concentration. Collect equipment blanks after sampling from contaminated wells and not after background wells. Field duplicates are collected to determine precision of sampling procedure. For this procedure, collect duplicate for each analyte group in consecutive order (VOC original, VOC duplicate, SVOC original, flVOC duplicate, etc.). If split samples are to be collected, collect split for each analyte group in consecutive order (VOC original, VOC split, etc.). Split sample should be as identical as possible to original sample. All monitoring instrumentation shall be operated in accordance with EPA analytical methods and manufacturer's operating instructions. EPA analytical methods are listed in 40 CFR 136, 40 CFR 141, and SW- 846 with exception of Eh, for which the manufacturer's instructions are to be followed. Instruments shall be calibrated at the beginning of each day. Zf a measurement falls outside the calibration range, the instrument should be re-calibrated so that all measurement* rail within the calibration range. At the end of each day, check calibration to verify that instruments remained in calibration. Temperature measuring equipment, thermometers and thermistors, need not be calibrated to the above frequency. They should be checked for accuracy prior to field use according to EPA Methods and the manufacturer's instructions. SOP #: OW 0001 Region Z Low Stress (Low Flow) SOP Revision Number: 2 Date: July 30, 1996 Page 12 of 13 VZX.FXZLD LOGBOOK A field log ahall be kept to document all ground water field monitoring activititfi (see attached example matrix} , and record all of the following: Well identification. Well depth, and measurement technique. Static water level depth, date, time and measurement techniqut. Presence and thickness of immiscible liquid (KAPL) layers and detection method. Pumping rate, drawdown, indicator parameters values, and clock time, at the appropriate time intervals; calculated or measured total volume pumped. Well sampling sequence and time of each sample collection. Types of sample bottles used and sample identification numbers, Preservatives used. Parameters requested for analysis. Field observations during sampling event. Kama of sample collector(s). Weather conditions. QA/QC data for field instruments. Any problems encountered should be highlighted. Description of all sampling equipment used, including trade names, model number, diameters, material composition, etc. • "VTII. DATA REPORT Data reports are to include laboratory analytical results, QA/QC information, and whatever field logbook information is needed to allow for a full evaluation of data useability. EXAMPLE (Minimum Requirementa) ^ Page ot Hell PURQIHG-PIBLO HATER QUALITY MEASUREMENTS FORM Location (Site/Facility Name) Depth to / of screen Well Number Date_ (below MP) top bottom" Field Personnel ~" I'uwp Intake at (£L. below HP) Sampling Organization Purging Device; (pump type) ] Identify MP BJHffErTi**^ , , ,"' \ 1.! =J a '" SJT^^^^^B! Clock Mater Pump Purge Cum. Temp. Spec. pH ORP/ DO Turb- OooimentB Time Depth Dial1 Rate Volune Cond.2 Eh5 idity below Purged MP • 24 HR ft «l/odn liters *C ftS/cm «v «g/L RTO • * *• t- .'• 1. Pump dial setting (for example: hertz, cycles/min, etc) 2. jfSienens per cmt&ane an ftrnhoo/cni) at 25*0. 3. Oxidation reduction potential (ptand in for Eh). —I APPENDIX C GROUND-WATERSAMPLING CHECKLIST Ftiibdetpbit N«vil Base: SAMPLING PROCEDURE COMPLETED? Presampling Laboratory contacted 2 weeks prior to sampling. Laboratory sample supplies received. Equipment obtained. Keys to well locks and site access obtained. Sampling (each well) Headspace readings taken. Depth to ground water taken, (all wells measured same day). Well purged/Field measurements stabilized. Samples collected QA/QC samples collected. Labels completed. Chain of custody completed. Chain of custody seal placed on samples. Samples shipped within 24 hours. Information recorded in field log book. Equipment decontaminated. Data received from laboratory Report completed and delivered to client and regulators. FfaiteffeiphiaNml Bwe: Cinrd Point Mnagemef* Ana Long Tcnn Ground-Water Monitoring Pin 4W7Utt29nSUaxU.3Umiprv5.4ac APPENDIXD EXAMPLES OF GROUND-WATER FIELD ANALYSIS FORMS :: Girard Point Management Are* UmgTcnnGrouKf-WatcrMonhqringPbn — Table GROUND WATER FIELD ANALYSIS FORMS Date Site Location: Project No.: nitial Depth to Water Well ID: Well Location: Depth of Well Screen: ft (top) to ft (bottom) (bgs) Company: Depth of Well Well Diameter/Material of Construction: Pump intake set at ft (bgs) (bgs): Sampler Purging Device (pump type): Time Water Depth Pump Rate Cum Vol. Temp Specific Cond ORP/Eh Turbidity Dissolved pH (topofPVC) Purged Oxygen (24 hrs) (ft) (liters/min) (liters) (C) (mS/cm) (mv) (NTU) (mg/1) Comments >.-. ^".-- •• . •: ••* ;••:• ;•••;•{:.• ;^"fH^?-" T-ty*' ffi.^'. 1^;; ••••-.:• . -. '• •• ; ' • ' . . • '-,,' ••;;.V:-:r"v : .-'• • ^ '">•••.. . :•' •'. •'• • i~ •• " •':••• .• . •.;...... -.,•; •.''•..'•:.- ; : v :^ V \ : J -':•/;•. ' :V; '. .'"" • '•'. i:'i:'." ','.'•'. ••*.-•;':• '.;"'.'•' .' •. •' ' • . <",<;.. '..''': ' :'.• •.:/;•.. •.',•, v :•. '?••<•'•'•••''< >:'^ '';;- '": .'•." »;''!•: '••' ',•".-; VN**.;. ••''•' .V ;,'•''•'' '••.' ', : .'.• 1 1 '•.'•«•' ..••.'/./"/v':. ' .' • '.' r' ':; '/"^-'- * '.•'."' ' • ••..'. •••'. Notes: Philadelphia Naval Base: Girard Point Management Area Long Term Ground-Water Monitoring Plan dM2\(H29l I8\ttuk4.3\ltmpn5.doc TABLE SUMMARY OF GROUND-WATER SAMPLING INCLUDING QA/QC - MONTH/YEAR PHILADELPHIA NAVAL BASE - GIRARD POINT MANAGEMENT AREA Sample Sample Sample . Metals COC Number Shipment Seal Number Airbill Number Comments • Number Date Time Date Metals Arsenic Method 206.2 CLP-M Cadmium, Chromium, Copper, Nickel, Zinc Method 200.7 CLP-M Lead Method 239.2 CLP-M Selenium Method 270.2 CLP-M Philadelphia Naval Base: Glrard Point Management Area ';' i "'l "'I ''I -H APPENDIX E EXAMPLES OF EVALUATION TABLES Gnri Point M»*ement Aitt Long Tom Ground-W«cr Monitoring Pbn Table SUMMARY OF GROUND-WATER MONITORING WELLS - GPMA LTM PROGRAM Monitoring Well Old Identification Location Reason Sampled Number Number GPMA-LTM-1 GPMA-MW-1 Off-Site, North of GPMA Upgradient Well GPMA-LTM-2 GPMA-MW-2 Off-Site, North of GPMA Upgradient Well GPMA-LTM-3 NWPL-MW-1 Off-Site, North of GPMA Upgradient Well GPMA-LTM-4 NWPL-NW-4 NWPL Downgradient Well GPMA-LTM-5 4-MW-5 IR Site 4 Downgradient Well GPMA-LTM-6 4-MW-3 IRSite4 Downgradient Well GPMA-LTM-7 4-MW-4 IR Site 4 Downgradient Well GPMA-LTM-8 5-MW-3 IR Site 5 Downgradient Well GPMA-LTM-9 5-MW-8 IR Site 5 Downgradient Well GPMA-LTM-1 0 5-MW-2 IR Site 5 Downgradient Well Philadelphia N«vil Btse: Ginrt Point Maugonent Aret LTM Program Annual Report Table SUMMARY OF ANALYTICAL PARAMETERS Anatyte Analytical Method Method Number arsenic atomic absorption - furnace 206.2 CLP-M cadmium atomic emission - ICP 200.7 CLP-M chromium, total atomic emission - ICP 200.7 CLP-M copper atomic emission - ICP 200.7 CLP-M lead atomic absorption - furnace 239.2 CLP-M mercury atomic absorption - cold vapor 245.1 CLP-M nickel atomic emission - ICP 200.7 CLP-M selenium atomic absorption - furnace 270.2 CLP-M zinc atomic emission - ICP 200.7 CLP-M Notes ICP - Inductively Coupled Plasma M - Modified PhiladdpbU N«vil Base: Gmrd Point Mmwemeat Are« LTM Program Anm«l Report — TABLE Date GROUND-WATER FIELD SAMPLING LOG GIRARD POINT MANAGEMENT AREA MONITORING DOW DTW PURGE PURGE HEAD- TURBIDITY pH COND. DO TEMP. Eh COMMENTS WELL No. RATE SPACE (ft.) (ft.) VOL. (NTU) (mS/cm) (mg/1) CQ (mV) tnL/min READING (L) (ppm) GPMA-LTM-I GPMA-LTM-2 GPMA-LTM-3 GPMA-LTM-4 • GPMA-LTM-5 GPMA-LTM-6 GPMA-LTM-7 GPMA-LTM-8 GPMA-LTM-9 GPMA-LTM-10 DOW - Depth of Well DO - Dissolved Oxygen DTW -Depth to W*CT TEMP. - Temperature, degrees Cdim YOU -Volume Eh - Rcdox potential, millivolts (mV) COND. - Specific Conductance, millbiemera per centimeter (mS/cm) NTU - Nephelometric Turbidity Units Pump Type: Pump Manufacturer Philadelphia Naval Base: Girard Point Management Area LTM Program Annual Report TABLE_ Maximum EEQs for July 1996-May 1997 Ground-Water Baseline COPC Maximum AWQC Maximum EEQ Maximum Maximum Maximum Maximum Maximum Concentration (Mg/L) EEQ EEQ EEQ EEQ EEQ (Hg/L) 1OM 2OM 3OM 4OM 5OM Dilution Dilution Dilution Dilution Dilution Arsenic 252 190 1.3 0.13 Cadmium 24.6 1.1 22 2.2 0.22 Chromium 18.7 11 1.7 0.17 Copper 1,230 12 102 10.2 1.02 0.102 Lead 30.4 3.2 9.5 0.95 Mercury 1.6 0.012 133 1.33 0.133 Nickel 357 160 2.2 0.22 Selenium 20 5 4 0.4 Zinc 5,510 110 50 5.0 0.50 ug/L Micrograms per Liter Freshwater Chronic AWQC (EPA, 1993) OM Dilution Order(s) of Magnitude Dilution Maximum EEQ values less than unity arc in bold face Philadelphia Naval Base: Ginrd Point Management Area " 1 Pro-- ' mu»>-' f TABLE Maximum EEQs for Arsenic GPMALTM- 1996-2002 Year Maximum AWQC Maximum EEQ Maximum Maximum Maximum Maximum Maximum Arsenic fog/L) EEQ EEQ EEQ EEQ EEQ Concentration (W?/L) 1OM 20M 3OM 4OM 5OM Dilution Dilution Dilution Dilution Dilution 1996-1997 252 190 1.3 0.13 1998 • 1999 2000 2001 2002 ug/L Micrograms per Liter Freshwater Chronic AWQC (EPA, 1993) OM Dilution Ordcr(s) of Magnitude Dilution Maximum EEQ values less than unity are in bold face Philadelphia Naval Base: Glratd Point Management Area LTM Program Annual Report TABLE Maximum EEQs for July 1996-May 2002 Annual Ground-Water Sampling Rounds COPC Maximum AWQC 1996-1997 1998 1999 2000 2001 2002 Concentration (W?/L) Maximum EEQ Maximum Maximum Maximum Maximum Maximum (W5/L) EEQ EEQ EEQ EEQ EEQ (OM Dilution) (OM (OM (OM (OM (OM Dilution) Dilution) Dilution) Dilution) Dilution) Arsenic 252 190 0.13(1) Cadmium 24.6 1.1 0.22 (2) Chromium 18.7 11 0.17 (1) Copper 1,230 12 0.102 (3) Lead 30.4 3.2 0.95(1) Mercury 1.6 0.012 0.133 (2) Nickel 357 160 0.22(1) Selenium 20 5 0.4(1) Zinc 5,510 110 5.0 (2) Hg/L Micrograms per Liter Freshwater Chronic AWQC (EPA, 1993) OM Dilution Orders) of Magnitude Dilution Maximum EEQ values less than unity are in bold face Philadelphia Naval Base: Girard Point Management Area Project J.O. 04291.18.50 Appendix C Revision: Final APPENDIX C PHOTO LOG 2003 FIVE YEAR REVIEW Philadelphia Naval Business Center Guard Point Management Area Five Year Review div42\brac\0429II8SO\task6A_5YEAR\FINAL5YEARGPM4.doc PHOTO LOG Photo Number Description 1 Panoramic View (1) - Northwest Parking Lot 2 Panoramic View (2) - Northwest Parking Lot 3 Panoramic View (3) - Northwest Parking Lot and Vegetated Cover 4 Panoramic View (4) - Vegetated Soil Cover and Access Road 5 Panoramic View (5) - Vegetated Soil Cover and Building 825 6 Panoramic View (6) - Buildings 825, C-16, and 668(Incinerator) 7 Panoramic View (7) - Buildings 825, C-16, and 668; ER Site 5 8 Panoramic View (8) - Building 668 and IR Site 5 9 Panoramic View (9) - IR Site 5 and Tree Lined Bank 10 Panoramic View (10) - IR Site 5 and Tree Lined Bank 11 Panoramic View (1 1) - IR Site 5 and Bridge Street 12 Panoramic View (12) - IR Site 5 and Bridge Street 13 Panoramic View (13) - Access Road to GPMA 14 Monitoring Well NWPL-MW-03 (Damaged) 15 Monitoring Well GPMA-MW-01 (Damaged) 16 Monitoring Well GPMA-MW-02 (Damaged) 17 Monitoring Well GPMA-MW-02 (Damaged) 18 10 November 2003 Site Inspection - GPMA-MW-01 (Repaired) 19 10 November 2003 Site Inspection - GPMA-MW-02 (Repaired) 20 ER Site 5 Bank Stabilization (Looking East From Drain Pipe) 21 ER Site 5 Bank Stabilization (Looking West From Drain Pipe) 22 IR Site 5 Drain Pipe 23 ER Site 4 Bank Stabilization (Facing South) 24 ER Site 4 Tide Gate and Bank Stabilization 25 ER Site 4 Bank Stabilization (Facing North) 26 ER Site 4 Missing and Damaged Gabion Baskets 27 ER Site 4 Debris and Vegetation on Bank Stabilization 28 ER Site 5 Cable to Reserve Basin Inlet Trash Gate 29 ER Site 5 Kink in Cable to Trash Gate 30 10 November 2003 Site Inspection - Trash Gate Cable Repair 31 ER Site 4 Vegetated Drainage Swale 32 ER Site 4 Vegetated Drainage Swale 33 ER Site 4 Evergreens and Wildflowers 34 ER Sites 4 and 5 Deciduous Trees 35 ER Site 5 Dead Deciduous Tree 36 ER Site 5 Vegetation Obstructing Gas Line Sign 37 ER Site 4 Storm Drain Obstructed with Debris Photo 1 - Bituminous Concrete Pavement at Former Northwest Parking Lot Currently used for ship plating storage. (From Top of Building 993 - Facing Northeast) Photo 2 - Former Northwest Parking Lot and 1-95 Girard Point Bridge (From Top of Building 993 - Facing North) ^S&alMH*',* Photo 3 - Zone A (Vegetated Soil Cover) and Zone B (Bituminous Concrete Pavement) Western Boundary of Former Northwest Parking Lot (From Top of Building 993 - Facing North/Northwest) Photo 4 - Zone A (Vegetated Soil Cover) and Southwest Corner of Zone B Crane on GPMA access road. (From Top of Building 993 - Facing Northwest) Photo 5 - Girard Point Bridge, Building 825, Former IR Site 3 and Zone A Vegetated Soil Cover' (From Top of Building 993 -Facing West) "If Photo 6 - Girard Point Bridge, Building 825,'Building C-16, and Building 668 (Incinerator) Former IR Site 4 west of buildings and beneath Girard Point Bridge. (From Top of Building 993 -Facing West) Photo 7 - Girard Point Bridge, Building 825, Building C-16, Building 668, and Schuylkill River Former IR Site 5 east of buildings. Note that Building 668 (Incinerator) stack has been removed. (From Top of Building 993 - Facing West) Figure 8 - Building C-16, Building 668 (Incinerator), Former IR Site 5, and Confluence of Schuylkill and Delaware Rivers Note tree-lined bank and heavy vegetated soil cover throughout Zone A. (From Top of Building 993 -Facing West/Southwest) .•^crim^*!^**!-^*^^--*,* *-• <"•> * Photo 9 - Former IR Site 5, Reserve Basin Inlet, Schuylkill River, and Delaware River Note heavy vegetated soil cover and tree-lined bank along Reserve Basin Inlet. (From Top of Building 993 - Facing South) Photo 10 - Former IR Site 5, Reserve Basin Inlet, Schuylkill River, and Delaware River Note heavy vegetated soil cover and tree-lined bank along Reserve Basin Inlet (From Top of Building 993 -Facing South) Figure 11 - Former IR Site 5, Reserve Basin Inlet, and Bridge Street (bridge open) Kvaerner Shipyard in background. (From Top of Building 993 -Facing South/Southeast) Photo 12 - Former IR Site 5 and opened bridge at Bridge Street (From Top of Building 993 - Facing East/Southeast) Photo 13 - Fenced/gated GPMA access road. (From Top of Building 993 - Facing East) • V ;- " • ££^&^Ji%&i£iti&**iT£ijei££3!**4wv<*-r~ <;«-:^\:w Ji.-'.v.r.-y*-.1 * .-xA, V--. • t:!v'.- i>**^i^S,wW^i(-ij*tfc^w*»-^Si-.;;;---,..:.•«"! » ""•••"-'* '•''" -^:fe^..*r'"'';: '•*--t:-'*.-^y-': •.- ;:^---v-'>/^v**i'*: l rs^.^.Tf5»faS|!Sl i! ^ ^^y$f*^i5%i&^^[-!»•.••>•';-,1 •".•-•Viij- •,•..[».-,>'.• ;•-• -- :•• ^ ^•- -- --»«*>j^-~'9ft ^'S i': <• •' ,'• "'''*', " -"', ^^"'^^ ../.-..:,';..,^,,,-, ..,-.«•'-.,-; .^.',- ••:-5^^^aJ^\i«SU^m,a.A.;. p^^iir.^.i.-K^-Vi i. Photo 14 - Damaged well cover at Monitoring Well NWPL-MW-03 - i • >;'•/. ->®t r i' •»'•'''•'•••!•. •• •' " '''?\< ?'*'c"m>i•'' • ^'.•' "'"i -'^ '-^>i Photo 15 - Damaged protective well cover at Monitoring Well GPMA-MW Photo 16 - Damaged Monitoring Well GPMA-MW-2 **&!: '',-^3»k...... ;. .,; Photo 17 - Damaged Monitoring Well GPMA-MW-2 (Facing North) *'t %?~.>BWB^.tJLii»'fV«..«^ ,->"7-Xti.: ."Ji^iii Photo 18-10 November 2003 Site Inspection - GPMA-MW-01 (Repaired) (Facing North/Northeast) ^-^^^^^^••^s, m -pK-r-,o '^^^^^S^Sfm^^ Photo 19-10 November 2003 Site Inspection - (Facing North/Northeast) Photo 20 - Former IR Site 5 Bank Stabilization (Facing East Along Reserve Basin Inlet at Drainage Pipe Outlet) Photo 21 - Former IR Site 5, Bank Stabilization (Facing West Along Reserve Basin Inlet at Drainage Pipe Outlet) Photo 22- Former IR Site 5, Bank Stabilization and Drainage Pipe Outlet at Reserve Basin Inlet (Facing East/Southeast) i•s-r»***'3a: •* -~«H5j»• W-*t£^- 3a*;Sil«T: %Jf^fe-*»> £iS*|fe&i$*&N^ Photo 23 - Former FR Site 4, Bank Stabilization (Facing South/Southeast) Photo 24 - Former IR Site 4, Tide Gate and Bank Stabilization at Stormwater Outlet (Facing North/Northeast) Photo 25 - Former IR Site 4, Bank Stabilization at Northwest Corner of GPMA (Facing North) Photo 26 - Former IR Site 4, Missing and Damaged Gabion Baskets Near Girard Point Bridge (Facing North) ?9«>&&tf*'i Photo 27 - Former IR Site 4, Debris and Vegetation on Bank Stabilization Adjacent to Girard Point Bridge (Facing Northeast) Photo 28 - Former IR Site 5, Cable to Reserve Basin Inlet Trash Gate Over Bank Stabilization Note cable operates dkectly on gabions and rocks. (Facing West) Photo 29 - Former IR Site 5, Kink in Cable to Reserve Basin Inlet Trash Gate Photo 30 - 10 November 2003 Site Inspection - Trash Gate Cable Repair (Facing East) Photo 31 - Vegetated Drainage Swale at Former IR Site 4 No evidence of erosion in drainage swales. (Facing South) Photo 32 - Vegetated Drainage Swale at Former IR Site 4 No evidence of erosion in drainage swales adjacent to Girard Point Bridge Pier. (Facing North) _._ Photo 33 - Former IR Site 4, Evergreens and Wildflowers Adjacent to Bank Stabilization (Facing West) Photo 34 - Former IR Sites 4 and 5, Deciduous Trees Adjacent to Bank Stabilization (Facing East) Photo 35 - Former IR Site 5, Dead Deciduous Tree Adjacent to Bank Stabilization (Facing West) Photo 36 - Fonner IR Site 5, Vegetation Obtruding Gas Line Warning Sign (Facing Northeast at Cable Building) iS^P SS^v^^.^ i^*l^?^-*%•W*;&&&$. \*~i,r .-*-&&m£ >-.. Nii '. ..,. Photo 37 - Stonn Drain Outlet at Former IR Site 4 Note trash and debris in swale. (Facing South) Project: J.O. 04291.18.50 Appendix D Revision: Final APPENDIX GPMA LTM TREND LINES 2003 FIVE YEAR REVIEW Philadelphia Naval Business Center, Guard Point Management Area Five Year Review div42\brac\04291I850\task6A_5YEAR\FNAL5YEARGPM.doc GPMA LTM Trend Lines 1000 «• As • Cd Cr x Cu x Pb • Hg + Ni - Se a - Zn UJ R2 = 0.58 UJ Expon. (As ) 2 E R = 0.01 —Expon. (Cd) 2 R = 0.24 —Expon. (Cr) 2 R = 0.11 —Expon. (Cu) 2 R = 0.15 Expon. (Pb) 2 R = 0.08 Expon. (Hg) 2 R = 0.26 —Expon. (Ni) R2 = 0.13 Expon. (Zn) R2 = 0.47 ——Expon. (Se) 1996 1997 1998 1999 2000 2001 2002 2003 2004 LTM Sampling Rounds GPMA LTM Trend Line for Arsenic 10 a LaUi Arsenic I 1 Expon. (Arsenic) X TO R2 = 0.58 0.1 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds GPMA LTM Trend Line for Cadmium 100 10- aoi LU * Cadmium ——Expon. (Cadmium) R2 = 0.01 1 - 0.1 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds GPMA LTM Trend Line for Total Chromium 10 o 111 ui E Total Chromium i Expon. (Total Chromium) a R2 = 0.24 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds GPMA LTM Trend Line for Copper 1000 100 -• UJ I Copper i Expon. (Copper) 'x ra 2 5 R = 10 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds GPMA LTM Trend Line for Lead Lead Expon. (Lead) Rx = 0.15 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds GPMA LTM Trend Line for Mercury 1000 o UJ UJ E * Mercury 3 Expon. (Mercury) R2 = 0.08 10 - 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds GPMA LTM Trend Line for Nickel 10 o in 111 • Nickel Expon. (Nickel) x ra R2 = 0.26 0.1 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds f ! ! I I I I I I f I 1,1 GPMA LTM Trend Line for Selenium 10 a UJ UJ * Selenium I 1 —— Expon. (Selenium) X n R2 = 0.47 0.1 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds GPMA LTM Trend Line for Zinc 100 a aUiJ E Zinc 3 10 Expon. (Zinc) R2 = 0.13 1996 1997 1998 1999 2000 2001 2002 2003 2004 Annual Sampling Rounds