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3 SANTA SUSANA FIELD LABORATORY (SSFL) RCRA FACILITY INVESTIGATION March 2009, Revision 4 Prepared for: THE BOEING COMPANY, NATIONAL AERONAUTICS and SPACE ADMINISTRATION (NASA), and U.S. DEPARTMENT OF ENERGY (DOE) Prepared by: MEC X, LP East Vassar Drive Aurora, CO w w w. m e c x. n e t

4 SANTA SUSANA FIELD LABORATORY (SSFL) RCRA FACILITY INVESTIGATION March 2009, Revision 4

5 TABLE OF CONTENTS NOTE TO REVIEWERS: THIS DOCUMENT COMPILES AND UPDATES PREVIOUSLY PUBLISHED QUALITY ASSURANCE INFORMATION IN VARIOUS PROJECT WORK PLANS AND REPORTS. PLEASE SEE SECTION 1.1 FOR ADDITIONAL INFORMATION. Section Page 1.0 INTRODUCTION Background and Purpose PROJECT ORGANIZATION Quality Assurance Responsibilities Field Quality Assurance Responsibilities Laboratory Responsibilities Special Training/Certification Requirements PROJECT OBJECTIVES PROBLEM DEFINITION DATA QUALITY OBJECTIVES (DQO) SURFICIAL MEDIA SAMPLING FIELD MEASUREMENTS LABORATORY ANALYSES DATA MANAGEMENT QUALITY CONTROL PROCEDURES FIELD MEASUREMENT AND SAMPLE COLLECTION Calibration Procedures and Frequency Preventative Maintenance Laboratory Equipment QC Procedures for Field Measurements Volatile Compounds in Soil Screening Field Test Kits Screening Water Level Measurements Water Quality Parameters Discharge Measurements Quality Control Procedures for Sample Collection Sample Custody Sample Naming Laboratory Procedures SSFL Site Specific Modifications to Analytical Procedures QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT DATA ASSESSMENTS AND OVERSIGHT DATA REDUCTION, VALIDATION AND REPORTING Field Measurement Data 88 i

6 TABLE OF CONTENTS NOTE TO REVIEWERS: THIS DOCUMENT COMPILES AND UPDATES PREVIOUSLY PUBLISHED QUALITY ASSURANCE INFORMATION IN VARIOUS PROJECT WORK PLANS AND REPORTS. PLEASE SEE SECTION 1.1 FOR ADDITIONAL INFORMATION. Section Page Laboratory Analytical Data INTERNAL QUALITY CONTROL (QC) PERFORMANCE AND SYSTEM AUDITS SPECIFIC ROUTINE PROCEDURES TO ASSESS DATA CORRECTIVE ACTIONS QUALITY ASSURANCE REPORTS DATA QUALITY ASSESSMENT REPORTS REFERENCES 97 ii

7 TABLE OF CONTENTS (Continued) LIST OF TABLES Table Surficial Media Work Plans and Reports with Laboratory or QA Requirements Table 4-1 Summary of Field Standard Operating Procedures (SOPs) Table 4-2 Laboratory Analytical Methods and Detection Limits Table 5-1 Preservation, Container and Holding Time Requirements Table 5-2 Sample Naming Site Identification Codes Table 5-3 Sample Naming Sample Matrix Codes Table 6-1 Precision and Accuracy Requirements Table Reviewer Qualifiers Table Reason Codes iii

8 1.0 INTRODUCTION This Quality Assurance Project Plan (QAPP) has been prepared to accompany the Work Plans and Sampling and Analysis Plans being used in the data collection programs required in the Resource Conservation and Recovery Act (RCRA) Facility Investigation RFI program for the Surficial Media Operable Unit at Santa Susana Field Laboratory (SSFL). These data are to essential to characterize the nature and extent of chemical contamination in the surficial media at SSFL, evaluate human and ecological risk, and gather data for the subsequent step of the RCRA Corrective Action Program; a Corrective Measures Study (CMS). The RCRA Corrective Action Program is under the regulatory oversight of the California Environmental Protection Agency (Cal-EPA) Department of Toxic Substance Control (DTSC). This QAPP includes the quality assurance/quality control (QA/QC) procedures to ensure that field and laboratory data quality and project work meet the data quality objectives (DQOs) for the intended data use of the surficial media sampling program at SSFL. Additionally, the objectives of this QAPP are to ensure the project work performed is in accordance with professional standards and regulatory guidelines as specified within project work plans submitted to DTSC for the Surficial Media Program. This document has been prepared with guidance from: U.S. Environmental Protection Agency, Region IX, Guidance for Preparing Quality Assurance Project Plans for Superfund Remedial Projects, U.S. Environmental Protection Agency, EPA Region 9, Requirements for Quality Assurance Program Plan Guidance, Draft. R9QA/03.1, August U.S. Environmental Protection Agency, Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G-4, U.S. Environmental Protection Agency, EPA Guidance for Quality Assurance Project Plans, EPA/240/R-02/009, December U.S. Environmental Protection Agency, EPA Requirements for Quality Assurance Project Plans, QA/R-5, EPA/240/B-01/003, March U.S. Environmental Protection Agency, Data Quality Objective Process for Hazardous Waste Site Investigations, EPA QA/G-4, February 2006 U.S. Environmental Protection Agency, Systematic Planning: A Case Study for Hazardous Waste Site Investigations, EPA QA/CS-1,

9 Background and Purpose This QAPP incorporates the ever-green updates which have been made to the QA Program since the publication of the SSFL Quality Assurance Project Plan Addendum in (AMEC 2000). The 2000 QAPP Addendum was approved by DTSC and is the primary sampling and analysis guidance document for the RFI. However, additional laboratory analytical requirements have been published for the RFI in various work plans and reports submitted to DTSC for review and approval. DTSC has reviewed and approved some of these documents, while others are still within the DTSC review process. The purpose of this 2008 Surficial Media QAPP is to compile all QA requirements for the surficial media sampling program into a single document for ease of use by multiple contractors supporting the field and laboratory program at the SSFL. Thus, this document serves as a reference for previously published project QA requirements and provides an update to address additional requirements due to an expanded field program (i.e., naming conventions and data management). This QAPP is intended to give comprehensive QA/QC guidance for all methods and all associated analytes utilized for the surficial media RFI, and includes laboratory requirements published in project work plans and reports. The following table provides a list of project work plans and reports prepared and submitted to DTSC that describe laboratory and QA programs for various tasks for investigation of surficial media during the RFI, and that formed the basis of this document. A brief description of purpose and content is also provided, as well as review status by DTSC. These documents are not included herein, and the reader is referred to these specific documents for any site-specific application or implementation details. This 2008 Surficial Media QAPP will be updated as additional requirements are identified or specified by DTSC. 2

10 Table 1-1 Surficial Media Work Plans and Reports with Laboratory or QA Requirements Document Author, Date Purpose/Content DTSC Review Status (as of June 15, 2008) RCRA Facility Investigation Work Plan Addendum Amendment Ogden, 2000 RFI QAPP, Appendix A DTSC Approved Perchlorate Characterization Work Plan (Revision 1) MWH, 2003 Contains Perchlorate QAPP, Appendix I In DTSC Review LOX Soil Sampling Work Plan MWH, 2004 Soil Vapor Sampling DTSC Approved RCRA Facility Investigation Program Report, Surficial Media Operable Unit MWH, 2004 Overall Laboratory and QA Program Description In DTSC Review Vapor Migration Modeling Validation Study Work Plan MWH, 2005 Surficial Vapor Flux and Ambient Air Monitoring DTSC Approved Vapor Migration Modeling Validation Study Work Plan Addendum MWH, 2005 Surficial Vapor Flux Monitoring DTSC approved Area I Burn Pit (AIBP) Sampling Work Plan Haley & Aldrich, 2006 Contains AIBP QAPP, Appendix A, Sitespecific Requirements In DTSC Review Radioactive Materials Handling Facility (RMHF) Work Plan MWH, 2008 Contains QAPP Supplement, Appendix C, Site-specific Requirements In DTSC Review In addition to the surficial media specific work plans and reports listed above, overall RCRA RFI project descriptions and DQOs have also been recently published in the Site-wide Groundwater Monitoring Sampling and Analysis Plan QAPP (Haley & Aldrich, 2007). 3

11 2.0 PROJECT ORGANIZATION 2.1 Quality Assurance Responsibilities The project team consists of a Project Coordinator, Project Manager, Program Quality Assurance Officer (QAO), Project Quality Assurance Officer (QAO), Laboratory QAO, Data Validation Staff, Site Health and Safety Officer (SSO), Regulatory Quality Assurance Reviewer (QAR), and various task leaders and field personnel. A description of the project organization and responsibilities of key personnel is presented in the respective media based Field Sampling Plans (FSP). Personnel responsibilities specifically related to quality assurance activities are as follows: Project Coordinator The Project Coordinator will be responsible for administration of the Respondent s actions required by the Consent Order for Corrective Action. The Project Coordinator is responsible for project implementation and has the authority to commit the resources necessary to meet project objectives and requirements. The Project Coordinator s primary function is to ensure that technical, financial and scheduling objectives are achieved successfully. The Project Coordinator will provide the major point of contact and control matters concerning the project. The Project Coordinator will also establish project policy and procedures to address the specific needs of the project as a whole. Project Manager The Project Manager will assist the Project Coordinator in day-to-day project management. The Project Manager will be responsible for coordinating all field activities and the procurement of project subcontractors. Additional responsibilities include assisting in monitoring the progress and quality of investigative collection, preparing and reviewing interim monitoring reports, and providing technical support of project activities. Quality Assurance Officers (QAO) The Program and Project Quality Assurance Officers (QAO) will be responsible for overseeing the review of field and laboratory produced data for: Assuring the application and effectiveness of the QAPP by the analytical laboratory and the project staff; Serve as a resource to the project manager in quality matters; Aid in the selection of analytical methodology; Conducting internal quality checks of the investigation activities; and 4

12 Providing input to the Project Manager as to corrective actions required resulting from the abovementioned evaluations. Data Validation Staff The QAO will be assisted by the Data Validation Staff in the evaluation and validation of field and laboratory generated data. The QAO and Data Validation Staff will monitor the activities of the contract laboratories to ensure that the Data Quality Objectives (DQOs) for the project are met. The data validator will have sole responsibility for review and validation of the analytical laboratory data generated. The data validator will be a professional independent of the laboratory and familiar with the analytical procedures performed. The data validation services will utilize the EPA's "National Functional Guidelines for Organic Data Review", EPA 2/99, and the "National Functional Guidelines for Inorganic Data Review", 10/04. The validation will include a review of each validation criterion as prescribed by the guidelines and be presented in a Data Validation Report (DVR) for each analytical data package. State of California Environmental Protection Agency (CalEPA) Remedial Program Manager The CalEPA Remedial Project Manager is responsible for overview of this project. The CalEPA PM is responsible for review and approval of the QAPP or submitting this QAPP and any subsequent revisions or amendments to the appropriate CalEPA personnel for review and approval. CalEPA Quality Assurance Reviewer (QAR) The CalEPA QAR responsibilities include: Ensuring that all environmental information collection activities are managed by appropriate quality system documentation; Ensuring that sampling and analytical methods for routine operations are well-documented through Standard Operating Procedures (SOP); Assists in determining the need for, type, and frequency of performance evaluation (PE) and standard reference material (SRM) samples; and Assists in solving QA-related problems Field Quality Assurance Responsibilities The Project Manager or designee is responsible for field quality assurance. Depending on the task, appropriately experienced personnel will be assigned as Field Team Leaders. The Field Team Leader is responsible for the overall operation of the field team. The Field Team Leader works with the Site Safety Officer (SSO) to conduct operations in compliance with the Site Health & Safety Plan. The Field Team Leader will facilitate communication and coordinating efforts between the site manager and the field team members. 5

13 Field Team Personnel involved in investigations and operations are responsible for: Performance of field activities as detailed in the media specific Field Sampling Plan and in compliance with the DQO outlined in this document; and Taking all reasonable precautions to prevent injury to themselves and to their fellow employees and immediately reporting any accidents and/or unsafe conditions to the SSO. 2.3 Laboratory Responsibilities The specific responsibilities of laboratory personnel involved in the project are as follows: Laboratory Project Manager The Laboratory Project Manager will report directly to the Project Manager and/or QAO and will be responsible for ensuring all resources of the laboratory are available on an as-required basis. The Laboratory Project Manager will also sign all final laboratory data reports provided from the analysis of the project samples and will provide Case Narrative descriptions of any data quality issues encountered during the analyses conducted by the laboratory. Laboratory Quality Assurance Officer The Laboratory Quality Assurance Officer is responsible for the quality of the analytical data produced by the analytical chemistry and/or radiochemistry laboratory. The laboratory QAO will monitor the QA processes to ensure the generation of data of a known quality and must perform and document audits and data reviews to ensure this quality. The laboratory QAO and staff must maintain independence in laboratory organization. The laboratory QAO is also responsible for the quality of any subcontracted analytical work. The laboratory QAO will provide written communications to the Project Manager and/or QAO for any anomalies or corrective actions implemented that affect the reported results for the project samples. Sample Custodian The sample custodian will receive and inspect the incoming sample containers, record the condition of the incoming sample containers and sign chain of custody (COC) documentation. The custodian will notify the Project Manager and/or QAO of any non-conformances identified during sample receipt and inspection and assign a unique identification number to each sample. After log-in, the sample custodian will initiate transfer of the samples to appropriate laboratory sections and monitor access/storage of samples and extracts. 6

14 2.4 Special Training/Certification Requirements Field sampling team members have received the 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER) safety training and annual 8-hour refresher courses required by 29CFR Parts 1910 and On-Site subcontractor personnel involved in invasive activities (e.g., drilling) have received equivalent training. Each subcontractor will be responsible for compliance of their personnel with the applicable training requirements. The laboratory performing sample analyses will be accredited by the State of California Department of Heath Services (CalDHS) under the Environmental Laboratory Accreditation Program (ELAP) or National Environmental Laboratory Accreditation Program (NELAP). The laboratory must be approved under ELAP for each analytical method or approved for each parameter of analysis under NELAP. If there is no California accreditation of an analytical parameter, accreditation through another NELAP accreditation body or by a Department of Defense (DoD) quality assurance program will be considered with approval from the CalEPA QAR. Additional consideration will be given to emerging technology utilized to meet a specific site characterization or remediation need. 7

15 3.0 PROJECT OBJECTIVES The purpose of the RFI is to assess the nature and extent of chemical contamination in the surficial media at SSFL, to evaluate the risks to human and ecological receptors and to gather data to support the CMS. The surficial media operable unit is composed of soil, soil vapor, sediment, surface water, near-surface groundwater, air, biota, and weathered bedrock. 3.1 Problem Definition This plan has been prepared to prescribe sampling procedures, sample custody, analytical procedures, data reduction, validation and reporting, and personnel requirements to ensure that the data are of sufficient quality and quantity to adequately characterize the chemical impacts at SSFL and enable the assessment of risk to human health and the environment. A detailed description of each of the investigational activities is described in site- and task-specific RFI Work Plans and Sampling and Analysis Plans (SAPs). Primary objectives of the RFI Work Plans and SAPs include: Provide sufficient data to support ongoing surficial media assessment activities; Provide quality representation of the medium evaluated according to accuracy, precision, and completeness for both the field and analytical laboratory programs; Produce technical products of consistent quality through the formal standardization and documentation of field and laboratory techniques and activities. 8

16 4.0 DATA QUALITY OBJECTIVES (DQO) Data Quality Objectives (DQOs) prescribe the goals that ensure the data collected during surficial media sampling tasks are of adequate quality to comply with regulatory requirements by characterizing the nature and extent of contamination in the surficial media. DQOs are qualitative and quantitative statements derived from the outputs of each step of the investigative process. The DQO process is a series of planning steps based on the scientific method that is designed to ensure that the type, quantity and quality of environmental data used in decision making are appropriate for the intended application. The seven (7) steps of the DQO process include: 1. the statement of the problem; 2. the identification of the decision; 3. the identification of the inputs to the decision; 4. the definition of the boundaries of the study; 5. the development of the decision rule; 6. the specification of the limits on decision errors; and 7. the optimization of the design for obtaining data. The decision rules for the major RFI investigation activities are provided below. In general, chemical analyses to be completed, as a part of these investigation activities, will include target analyte list (TAL) parameter analyses, as listed in Table Surficial Media Sampling The problem statement for the RFI Surficial Media Operable Unit sampling program is: Comply with regulatory requirements by characterizing the nature and extent of contamination in surficial media (soil matrix, soil vapor, sediment, surface water, near-surface groundwater, air, biota, and weathered bedrock). Five decision questions were identified during the DQO process and are used to guide data collection and evaluation for the Surficial Media Operable Unit RFI. These five questions are: 1. Has historical information on chemical use areas and chemical releases been used to identify potential source areas? 2. Have source area sampling and analysis plans been developed to characterize the nature and extent of contamination? 3. Is the nature and extent of contamination at potential source areas within RFI sites characterized sufficiently for risk assessment? 4. Have potential human health and ecological impacts been assessed? 5. Have characterization and risk assessment results been used to make site action recommendations for the corrective measures study (CMS)? 9

17 The inputs to the decision for the soil investigation are data from previous and proposed investigations and the published Standardized Risk Assessment Methodology (SRAM) Work Plan, Santa Susana Field Laboratory, Venture County California, Revision 2 (MWH, 2005). The spatial boundaries for the soil investigation are the regulated unit boundaries, administrative areas at SSFL, RFI sites and adjacent drainages, adjacent open spaces and drainages, potential source areas within RFI sites and associated drainages for soil samples, near-surface groundwater, surface water, and sediment. The decision rules for the SSFL surficial media investigation include the following rules which are pertinent to the analytical program. 1. If chemical use in a potential source area is well defined, then targeted analytical suites will be used. 2. If chemical use in potential source areas is not well defined, then broader analytical suites will be based upon potential chemical releases. The full list of decision rules for the surficial media investigation can be found in the RFI Program Report, (MWH, 2004). The limits on decision errors for the surficial media investigation include the following: Type I decision error (false rejection error): Conclusion that soils are unimpacted, when in fact they are impacted. Decision is to limit further sampling and analysis based upon this information. Consequences involve possible underestimation of site risk and under-determination of extent of contamination. Type II decision error (false acceptance error): Conclude that soils are impacted, when in fact they are un-impacted. Decision is to complete additional sampling and analysis to define the extent of impact. Consequences involve the unnecessary expenditure of additional resources to conduct additional sampling and analyses. Optimization of the design for obtaining data include additional review of historical data sources, the ability to modify plans as new information becomes available and the ability to conduct additional sampling and analysis as the new information is evaluated to reduce overall uncertainties. Task-specific DQOs have also been prepared for specific areas, phases and actions of the investigation. Task-specific DQOs can be found in the RFI Program Report, (MWH 2004). Group-specific DQOs may be included in specific work plans. The QA objective for the surficial media sampling programs is that the resulting analytical data meet the criteria for precision, accuracy, representativeness, completeness and comparability established in this QAPP. The QA objectives will be met by following the standard operating procedures (SOP) included in the site-wide work plans [Work Plan Addendum (WPA) and Work Plan Addendum Amendment (WPAA) (Ogden 1996, 2000)] and site-specific work plans and field sampling plans and implementing the procedures outlined 10

18 in this QAPP. A summary of the SOPs to be used in the performance of the Surficial Media Sampling Program are provided in Table 4-1. TABLE 4-1 SUMMARY OF FIELD STANDARD OPERATING PROCEDURES (SOPs) SANTA SUSANA FIELD LABORATORY, VENTURA COUNTY, CALIFORNIA Title Use Source Utility Clearance Surface Geophysics Soil Gas Survey Soil and Rock Classification Soil Sampling Surface Water Sampling Groundwater Sampling Equipment Decontamination Investigation-Derived Waste Management Field Logbooks Record Keeping, Sample Labeling and Chain of Custody Field QC Samples Data Management Chain-of-Custody Logbook Sample Handling, Storage and Shipping Piezometer Installation Piezometer Sampling Piezometer Development Perchlorate Sampling Perchlorate Quality Assurance Pre/Post-Sampling Sampling Post-Sampling Pre-sampling Sampling Pre-sampling Sampling Pre and Post Sampling Work Plan Addendum, Ogden 1996 SSFL Field Sampling Plan, Haley & Aldrich, Work Plan Addendum, Ogden 1996 Near-Surface Groundwater, Ogden 2000 Perchlorate Characterization Work Plan, Revision 1 MWH 2003 Appendix I, Perchlorate Characterization Work Plan, Revision 1 MWH 2003 Note: Site and Task Specific Work Plans and Field Sampling Plans must be consulted as needed for site-specific and/or additional field SOPs. 11

19 4.2 Field Measurements Field activities outlined in the work plans include screening measurement soil volatile organic compound content, field test kits to provide screening level measurements of organic and inorganic constituents, field water quality parameters (i.e., electrical conductivity (EC), ph, dissolved oxygen (DO), oxidation and reduction potential (ORP), temperature, turbidity), well discharge rates and static groundwater elevations. Field personnel will perform validation of all data obtained from field measurements by checking calibration procedures utilized in the field. Section 5 addresses QC measures that will be implemented for data validation and inspection of field measurement and analytical data. 4.3 Laboratory Analyses Surficial media samples will be collected and submitted for off-site laboratory analysis as part of the Surficial Media RFI Program. The DQO for analytical data provided by the laboratory will be expressed in terms of precision, accuracy, representativeness, completeness and comparability criteria presented in this QAPP. These DQOs will be achieved by a comparison of EPA method acceptance criteria and laboratory QC procedures. Laboratory analyses should meet the reporting limits (RL) as presented in Table

20 TABLE 4-2 LABORATORY ANALYTICAL METHODS AND REPORTING LIMITS SANTA SUSANA FIELD LABORATORY VENTURA COUNTY, CALIFORNIA SOIL REPORTING LIMITS Laboratory RL Volatile Organics by EPA 8260B ug/kg 1,3-Dichlorobenzene 2 1,3-Dichloropropane 2 1,4-Dichlorobenzene 2 2-Chloroethyl vinyl ether 5 2-Chloro-1,1,1-trifluoroethane 5 2-Chlorotoluene 5 2-Butanone (MEK) 10 2-Hexanone 10 2,2-Dichloropropane 1 4-Chlorotoluene 5 4-Methyl-2-pentanone (MIBK) 5 Acetone 10 Benzene 2 Bromobenzene 5 Bromochloromethane 5 Bromodichloromethane 2 Bromoform 5 Bromomethane 5 n-propylbenzene 2 p-isopropyltoluene 2 sec-butylbenzene 5 tert Butylbenzene 5 Styrene 2 Tetrachloroethene 2 Toluene 2 trans-1,2-dichloroethene 2 trans-1,3-dichloropropene 2 Trichloroethene 2 Trichlorofluoromethane 5 o-xylene 2 m, p-xylene 5 Vinyl chloride 2 1,1,2-Trichloro-1,2,2-trifluoroethane 5 1,1,1-Trichloroethane 2 1,1,1,2-Tetrachloroethane 1 1,1,2,2-Tetrachloroethane 2 13

21 SOIL REPORTING LIMITS Laboratory RL ug/kg 1,1,2-Trichloroethane 2 1,1-Dichloroethane 2 1,1-Dichloroethene 5 1,1-Dichloropropene 2 1,2,3-Trichlorobenzene 5 1,2,3-Trichloropropane 1 1,2,4-Trichlorobenzene 5 1,2,4-Trimethylbenzene 2 1,2-Dibromo-3-chloropropane 5 1,2-Dibromoethane (EDB) 2 1,2-Dichlorobenzene 2 1,2-Dichloroethane 1 1,2-Dichloropropane 2 1,3,5-Trimethylbenzene 2 Carbon tetrachloride 1 Chlorobenzene 2 Chloroethane 5 Chloroform 2 Chloromethane 5 Chlorotrifluoroethylene 5 cis-1,2-dichloroethene 2 cis-1,3-dichloropropene 2 Dibromochloromethane 2 Dibromomethane 1 Dichlorodifluoromethane 5 Ethylbenzene 2 Hexachlorobutadiene 5 Isopropylbenzene 2 Methyl-tert-butyl- Ether (MTBE) 5 Methylene chloride 5 n-butylbenzene 5 1,4-Dioxane by EPA 8260B SIM ug/kg 1,4-Dioxane 5 Semivolatiles by EPA 8270C ug/kg 1-Methylnaphthalene 330 1,2-Dichlorobenzene 330 1,2-Diphenylhydrazine/Azobenzene 330 1,3-Dichlorobenzene 330 1,4-Dichlorobenzene 330 1,2,4-Trichlorobenzene

22 SOIL REPORTING LIMITS Laboratory RL ug/kg 2,4,5-Trichlorophenol 330 2,4,6-Trichlorophenol 330 2,4-Dichlorophenol 330 2,4-Dimethylphenol 330 2,4-Dinitrophenol 660 2,4-Dinitrotoluene 330 2,6-Dinitrotoluene 330 3,3-Dichlorobenzidine Chloronaphthalene Chlorophenol Methylnaphthalene Methylphenol Nitroaniline Nitrophenol Nitroaniline 330 3,5-Dimethylphenol 330 4,6-Dinitro-2-methylphenol Bromophenyl-phenylether Chloroaniline Chloro-3-methylphenol Chlorophenyl-phenylether Methylphenol Nitroaniline Nitrophenol 830 Acenaphthene 330 Acenaphthylene 330 Aniline 420 Anthracene 330 Benzidine 1600 Benzoic acid 830 Benzo(a)anthracene 330 Benzo(a)pyrene 330 Benzo(b)fluoranthene 330 Benzo(g,h,i)perylene 330 Benzo(k)fluoranthene 330 Benzyl alcohol 330 bis(2-chloroethoxy)methane 330 Bis(2-chloroethyl)ether 330 Bis(2-chloroisopropyl)ether 330 Bis(2-ethylhexyl)phthalate 330 Butylbenzylphthalate 330 Carbazole

23 SOIL REPORTING LIMITS Laboratory RL ug/kg Chrysene 330 Dibenzo(a,h)anthracene 330 Dibenzofuran 330 Diethylphthalate 330 Dimethylphthalate 330 Di-n-butylphthalate 330 Di-n-octyl-phthalate 330 Fluoranthene 330 Fluorene 330 Hexachlorobenzene 330 Hexachlorobutadiene 330 Hexachlorocyclopentadiene 830 Hexachloroethane 330 Indeno(1,2,3-cd)pyrene 330 Isophorone 330 Naphthalene 330 Nitrobenzene 330 n-nitroso-di-n-propylamine 330 n-nitrosodimethylamine 330 n-nitrosodiphenylamine 330 Phenanthrene 330 Pentachlorophenol 830 Phenol 330 Pyrene 330 Semivolatiles EPA 8270C (SIM*) PAHs ug/kg 1-Methylnaphthalene 20 2-Methylnaphthalene 20 Acenaphthene 20 Acenaphthylene 20 Anthracene 20 Benzo(a)anthracene 20 Benzo(a)pyrene 20 Benzo(b)fluoranthene 20 Benzo(g,h,i)perylene 20 Benzo(k)fluoranthene 20 Bis(2-ethylhexyl)phthalate 20 Butyl benzyl phthalate 20 Chrysene 20 Di-n-butyl phthalate 20 Di-n-octyl phthalate 20 Dibenz(a,h)anthracene 20 16

24 SOIL REPORTING LIMITS Laboratory RL ug/kg Diethyl phthalate 20 Dimethyl phthalate 20 Fluoranthene 20 Fluorene 20 Indeno(1,2,3-cd)pyrene 20 n-nitrosodimethylamine 20 Naphthalene 20 Phenanthrene 20 Pyrene 20 TOC By SW mg/kg Total Organic Carbon 100 TOC By Walkley-Black Percent Total Organic Carbon 0.01 Dioxin/Furans By EPA 8290/1613 pg/g 2,3,7,8-TCDD 1 1,2,3,7,8-PeCDD 5 1,2,3,4,7,8-HxCDD 5 1,2,3,6,7,8-HxCDD 5 1,2,3,7,8,9-HxCDD 5 1,2,3,4,6,7,8-HpCDD 5 OCDD 10 2,3,7,8-TCDF 1 1,2,3,7,8-PeCDF 5 2,3,4,7,8-PeCDF 5 1,2,3,4,7,8-HxCDF 5 1,2,3,6,7,8-HxCDF 5 2,3,4,6,7,8-HxCDF 5 1,2,3,7,8,9-HxCDF 5 1,2,3,4,6,7,8-HpCDF 5 1,2,3,4,7,8,9-HpCDF 5 OCDF 10 Total TCDD 1 Total PeCDD 5 Total HxCDD 5 Total HpCDD 5 Total TCDF 1 Total PeCDF 5 Total HxCDF 5 Total HpCDF 5 17

Certifications: New York (EPA: NY00906, ELAP: 11078), New Jersey (NY026), Connecticut (PH-0337), Massachusetts (M-NY906), Virginia (1884)

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