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HomeMy WebLinkAboutDSHW-2007-004871 - 0901a0688015765cLauncfi Systems Group P.O. Box 707 Brighiam City, UT 84302 www.atk.com 8 March 2007 8200-FY07-087 HAND DELIVERED MAR 0 9*07 UTAH DIVISION OF SOLID & HAZARDOUS WASTE Mr. Dennis R. Downs, Executive Secretary State of Utah Department of Environmental Quality Division of Solid and Hazardous Waste 288 N. 1460 W. P.O. Box 144880 Salt Lake City, Utah 84114-4880 Subject: Revised Groundwater Monitoring SAP and QAP for ATK Launch Systems, Promontory EPA ID # #UTD009081357 Dear Mr. Downs Attached, please find the revised groundwater Sampling and Analysis Plan and Quality Assurance Project Plan. These plans will be attachment 3 in the new Post-Closure Permit for this facility. If you have questions regarding these plans, please contact Dave Covington at (435) 863-3898. Sincerely, David P. Gosen, P.E., Director Environmental Services copy: D. Covington, ATK J. Vandell, DSHW ATK Launch Systems (ATK) Promontory Facility Post-Closure Permit 0 91007 UTAH DIVISION OF SOUD & HAZARDOUS WASTE QUALITY ASSURANCE PROJECT PLAN (QAPP) APPENDIX 4 Appendix 4 QAPP 1 ATK Launch Systems Promontory Facility June 2006 Post-Closure Pennit AI: APPROVAL SHEET Organization/Title Director, Utah Division of Solid and Hazardous Waste (Dated Approval Letter from the Division) ATK Project Manager (ATK PM) Paul V. Hancock Project Quality Assurance Manager (PQAM) Blair G. Palmer Field Operations Project Manager (OPM) David Covington Data Validation Support Manager (DVSM) Scott Fraser ATK Database Manager (DM) Kent Bates ATK Environmental Laboratory Manager (LM) Mike Killpack Signature Date Approval Letter WAkWyrftdm. ogoilo-7 ll/cj/fi? '± •yi.<^/n^yf^y^ 3/oi/jo7 Appendix 4 QAPP June 2006 ATK Launch Systems Proinontory Facility Post-Closure Permit A2: TABLE OF CONTENTS Page Al: APPROVAL SHEET 2 A2: TABLE OF CONTENTS 3 A3: DISTRIBUTION LISTS 6 A4: PROJECT ORGANIZATION 7 A5: PROBLEM DEFINITION 7 A6: PROJECT DESCRIPTION 8 A7: QUALITY OBJECTFVES AND CRITERIA 8 AS: SPECIAL TRAINING/CERTIFICATIONS 9 A9: DOCUMENTATION AND RECORDS 9 Bl: SAMPLING PROCESS DESIGN 11 B2: SAMPLING METHODS 13 B3: SAMPLING HANDLING AND CUSTODY 13 B4: ANALYTICAL METHODS 13 B5: QUALITY CONTROL 14 B5.1 Field Quality Control Checks 14 B5.1.I Field Duplicate Samples 15 B5.I.2 Trip Blanks 15 B5.I.3 Equipment Blanks 15 B5.1.4 Performance Evaluation (blind) Samples 16 B5.L5 Temperature Quality Control 16 B5.1.6 Field Blanks 16 B6: EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE 17 B7: EQUIPMENT C/VLIBRATION 17 B7.1 Field Equipment 17 B7.2 Laboratory Equipment 18 B8: INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES 18 B9: NON-DIRECT MEASUREMENTS 18 BIO: DATA MANAGEMENT 18 BlO.l Validation of Laboratory Data 19 B10.2 Validation of Field-Generated Data 19 B10.3 Use and Storage of Data 20 Cl: ASSESSMENT AND OVERSIGHT 21 Appendix 4 QAPP 3 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit C2: AUDITS AND REPORTS TO MANAGEMENT 21 C2.1 Performance Audit 22 C2.2 Data Quality Audit 22 C2.3 Technical Systems Audit 23 Dl: DATA REVIEW, VERIFICATION AND VALIDATION 24 Dl.l Laboratory Data Reduction and Review 24 D1.2 Laboratory Data Package Delivery Requirements 25 DI.3 Field Data Reduction and Review 26 D1.4 Data Validation 26 DI.4.I Laboratory Data Validation 26 Dl.4.2 Field Data Validation 28 D2: RECONCILIATION WITH USER REQUIREMENTS 29 Appendix 4 QAPP 4 ATK Launch Systems Promontory Facility June 2006 Post-Closure Pennit List of Tables Table B.l Checklist for Consideration in Developing Specific Sampling and Analysis Plans 19 List of Figures Figure 1 Work Plan Organizational Chart 10 Appendix 4 QAPP 5 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit A3: DISTRIBUTION LISTS Organization/Title Director, Utah Division of Solid and Hazardous Waste ATK Project Manager (PM) Project Quality Assurance Manager (PQAM) Field Operations Project Manager (OPM) Data Validation Support Manager (DVSM) ATK Environmental Laboratory Manager (LM) Appendix 4 QAPP 6 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit A4: PROJECT ORGANIZATION Director UDSHW ATK Thiokol Environmentai Laboratory Manager Contractor Laboratory Manager ATK Project Manager ATK Database Manager Project Quality Assurance Manager Field Operations Project Manager Data Validation Support Manager Field Operations Staff Line of Authority Line of Communication A5: PROBLEM DEFINITION This Quality Assurance Project Plan (QAPP) is a planning document that outlines the appropriate level of quality for production of data and appropriate data-management protocols for the RCRA Post-Closure permit conducted at the ATK Launch Systems Promontory Facility. The sampling and analysis plans (SAPs) for groundwater will contain data quality objectives (DQOs), analytical methods and their quality control requirements, and standard operating procedures (SOPs) for field activities, which are focused on specific characteristics of the groundwater undergoing investigation. The SAPs will utilize the QAPP to assure that execution of the SAPs is consistent with the QAPP. Groundwater sampling at the ATK facility in Promontory Utah plan satisfies the requirements for a ground water sampling and analysis plan as referenced in 264.97 of the Code of Federal Appendix 4 QAPP June 2006 ATK Launch Systems Promontory Facility Post-Closure Permit Regulations (CFR). The plan also addresses Section R315 7-13-4 of the Utah Administrative Code and 40 CFR 265.93 with respect to Assessment Monitoring. The Post Closure Permit for the M-136 Buming Area requires ATK to monitor groundwater in the uppermost aquifers as described in Attachment 4 of the Post Closure Permit in a manner that will monitor the release of hazardous constituents from the M-136 Buming Area, in compliance with R315-8-11.5(b)(2), R315-8-7, and R315-8-6 during the post-closure care period. Groundwater monitoring is also completed for the solid waste management units (SWMUs) at the facility. ATK maintains groundwater monitoring systems, which consist of monitoring wells located hydraulically upgradient and downgradient of the areas of contamination. Groundwater monitoring at the site has detected the following constituents: Acetone, Ammonia, Arsenic, Barium, Benzene, Bromomethane, Chloroethane, Chloroform, Chromium, 1,1-Dichloroethane, 1,1-Dichloroethene, 1,2-Dichloroethene, Manganese, Nitrate, Perchlorates, Sulfate, Tetrachloroethene, Tin, Total Dissolved Solids, 1,1,1-Trichloroethane, and Trichloroethene. Continued monitoring and data handling according to this QAP will ensure that groundwater concentrations and migration of contaminants is known. A6: PROJECT DESCRIPTION The groundwater sampling at the facility is conducted to determine whether former practices and activities at the site have contaminated groundwater under the site with VOCs, perchlorate, and metals and whether the contaminants have been or are cun-ently migrating. A secondary consideration is to determine sources for the contaminants found in groundwater. Groundwater samples will be collected from 41 monitoring wells at the site. These wells will be sampled for VOCs, perchlorate, and metals. A7: QUALITY OBJECTIVES AND CRITERIA The first step in SAP development will be the establishment of data DQOs. Specific DQOs will be listed in the SAP and will, at a minimum, comply with the requirements and guidance set forth in this QAPP. The DQO process is a systematic planning tool based on a logical method for establishing criteria for data quality. Establishing formal DQOs during the development of SAPs allows clear and unambiguous definitions of project objectives and decision criteria so that data of sufficient type, quality, and quantity are generated to meet project objectives. Details such as practical quantitation Limits (PQLs), method detection limits (MDLs), estimated quantitation limits (EQLs) used by the ATK Laboratory will be provided in the SAPs. In developing SAPs, the latest version of Guidelines for the Data Quality Objectives Process, US EPA, EPA QA/G-4, August 2000, or other appropriate guidelines will be followed. Appendix 4 QAPP 8 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit AS: SPECIAL TRAINING/CERTIFICATIONS The OPM and all field staff, including subcontractors that will be performing sampling work at the facility, shall have completed training that meets the requirements in OSHA 29 CFR 1910.120. Documentation and skills certification will be completed as described in OSHA 29 CFR 1910.120. No other certification or special training requirements are requisite for the completion of this project. A9: DOCUMENTATION AND RECORDS The document control system begins with approving and distributing pertinent project planning documents. These documents include initial and revised QAPPs, SAPs, SOWs, and SOPs. The PQAM has the responsibility for the controlled distribution of these documents. The ATK PM has approval authority. The PQAM is responsible for initiating any revisions to these planning documents and is responsible for assigning responsibility for making the needed revisions. The QAPP shall be approved first by the Director of the Division of Solid and Hazardous Waste by an official letter from the Division. All revisions or modifications related to this QAPP thereafter will be accomplished by specifying a revision or modification to the QAPP in a SAP. A sufficient number of modifications or a significant modification accepted by the Division in SAPs may justify a revision of the QAPP. All monitoring, testing and analytical data obtained pursuant to Condition V.E. in the ATK Operating Record will be entered in a database and reported. ATK will submit a report on the effectiveness of the corrective action program within six (6) months of CAP implementation as specified in Post Closure Permit. This report will include 1. Weekly measurements of volume and rate of groundwater fiow in the groundwater treatment system; 2. semi-annual results of sample analyses including; concentration of hazardous constituents, and a summary of the QA/QC data listed in Condition V.D.3. of the Post Closure Permit; 3. semi-annual measurements of static water levels and total well depths estimates; 4. semi-annual results of annual model recalibration and a summary analysis of annual model results; 5. annual contaminant concentration maps of the confined and unconfined aquifers; 6. annual potentiometric maps of the unconfined and confined aquifers. This map will indicate the rate and direction of flow, as indicated in V.D.4.b of the Post Closure Pennit; 7. annual submission to the Executive Secretary the analytical results required by Permit Conditions V.D., V.E., and the groundwater elevation data required by Condition V.D.4. These reports will be submitted no later than January 15 and July 15 of each year. The semi- annual reports will contain the infonnation and be submitted at the frequency as specified below: Appendix 4 QAPP 9 ATK Launch Systems Promontory Facility June 2006 Post-Closure Pennit Samples and data collected During the months of January-March April-June July-September October-November Semi-annual sampling events January-June June-December Results due to the Executive Secretary April 15 July 15 October 15 January 15 Appendix 4 QAPP June 2006 10 ATK Launch Systems Promontory Facility Post-Closure Permit Bl: SAMPLING PROCESS DESIGN The Sampling and Analysis Plan (SAPs) for groundwater sampling will be submitted under separate cover. The SAP will define the data quality objectives for groundwater sampling and will generally follow the procedures in Table B-l: Table B-1. CHECKLIST FOR DEVELOPING SAMPLING AND ANALYSIS PLANS ATK LAUNCH SYSTEMS SAP Component Specifications Sampling Sampling Plan Development of Data Quality Objectives Sample Design/Strategy List of Analytes List of Sampling Locations Analytical Methods Analytical Procedures Analytical Equipment Standard Operating Procedures (SOPs) For Field-Investigation Activities (such as sample collection, decon, shipping etc.) Field Equipment Selection of Sampling and Field Analysis Equipment Operation & Maintenance Procedures Calibration & Acceptance Criteria Calibration Frequencies, Decon Procedures Investigation Derived Waste (IDW) Disposal Field Data Sheets Field Activity Daily Log Field Instmmentation Log for Calibration and Maintenance Procedure Variance Log Sample-Handling and Shipping Procedures Containers & Volumes Holding Times & Preservation Requirements Sample Packaging & Shipping Sample Labels & Sample Identification Number Analytical Request and Chain of Custody Forms Appendix 4 QAPP June 2006 11 ATK Launch Systems Promontory Facility Post-Closure Permit Laboratory Analytical Procedures Quality Control Data Quality Measurement Sampling (continued) Transfer of Custody from Field to Laboratory Receipt and Acceptance of Samples Analytical Methods, Requirements, and Detection Limits Explosives: Procedure No. 25000DT05484 for NG, diNG, Butanetriol, and Bl IN and ATK SOP 424 for Nitroaromatics and nitroamines Volatile Organic Compounds (VOCs): USEPA Method 8260B- ATK SOP 401 Total Metals: USEPA Method 6010B-ATK SOP 364 Mercury: USEPA Method 7471A-ATK SOP 373, Cold Vapor Atomic Adsorption- Perchlorate: USEPA Method 314-ATK SOP 314 Anions: USEPA 9056-ATK SOP-341 Hydrogen ion (pH): USEPA 9040B (aqueous); USEPA 9045C (solids)-ATK SOP 333 Semivolatiles: USEPA 8270 C-ATK SOP 402 Other Analyses Obtain SOPs from the Laboratory for inclusion in the SAP Field Field Duplicates Trip Blanks Equipment Blanks Field Blanks (water) Laboratory See the laboratory-specific QAP on file with the laboratory. Precision Level (- 15%) Subject to adjustment if sample medium justifies change. Accuracy Value (- 20%) Subject to adjustment if sample medium justifies change. Representativeness - goal of representativeness will be specified in each SAP. Completeness Comparability Estimated Quantitation Limits Method Detection Limits Appendix 4 QAPP June 2006 12 ATK Launch Systems Promontory Facility Post-Closure Pennit B2: SAMPLING METHODS Specific groundwater sampling methods are addressed the groundwater SAP. These procedures have previously been established and utilized for groundwater sampling at the site. B3: SAMPLING HANDLING AND CUSTODY Written documentation of sample custody from the time of sample collection through the generation of data is recognized as a vital aspect of an environmental study. The Chain-of- Custody (COC) of the physical sample and its corresponding documentation will be maintained throughout the handling of the sample. All samples will be identified, labeled, and logged onto a COC and Request for Analysis form, as a part of the procedure designed to assure the integrity of the resulting data. The record of the physical sample, including the location and time of sampling, will be joined with the analytical results through accurate accounting of the sample custody. Sample custody applies to both field and laboratory operations. All laboratories completing chemical analyses will be required to maintain samples in a secure location with limited access from the time of sample receipt through sample disposal. Samples collected during this investigation will be either shipped to the laboratory via a commercial carrier or will be hand-delivered to the analytical laboratory when possible. All packaging materials and samples will be reviewed for compliance with changes in air shipment regulations when shipping by commercial carrier. Tf the samples are shipped via a commercial carrier, the following procedure will be used for packaging: • 1. Inert cushioning material will be utilized when needed; • 2. Sample containers will be placed upright in the cooler; • 3. Blue ice or wet ice and additional packaging materials will be placed around the containers; • 4. Pertinent paperwork such as the COC/Request for Analysis form will accompany shipping papers; • 5. The cooler will be sealed with packaging tape; and • 6. A shipping label will be affixed to the outside of the cooler. B4: ANALYTICAL METHODS Chemical analyses of samples will be completed by using specific laboratory methods in accordance with tum-around time for the completion of analyses and laboratory data reporting specified in SAPs. These methods may include analysis of explosives, volatile organic compounds (VOCs), semivolatile compounds, metals, and perchlorate. Samples will be Appendix 4 QAPP 13 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit collected and preserved as described in specific SAPs. Sample holding times shall be calculated from the date and the time of collection. Samples collected during this investigation will be analyzed by the ATK Environmental Laboratory or an ATK contractor laboratory. The laboratories chosen to complete the analyses during this investigation shall not subcontract any portion of the work without prior written approval from the ATK PM. The laboratory shall use analytical equipment and procedures to produce data that will meet the DQOs and requirements as specified in SAPs. If non-standard analytical methods are proposed, the method must be approved by the Division. Detailed descriptions of the analytical method shall be reviewed by the PQAM to ensure that data generated by the method will meet the minimum data quality objectives and requirements as specified in SAPs. The review will focus on the method as supplied by the analytical lab including scope, requirements, applicable documents, materials and equipment, operations, QC limits, QA/QC measures, safety, sample preparation and analysis. Upon completion and satisfactory review, the PQAM will recommend the ATK PM submit the method to the Division for approval. The data validation process for data generated by the method shall follow the protocol specified in this QAPP and in the pertinent SAP. B5: QUALITY CONTROL Quality Control checks of both the field sampling procedures and laboratory sample analyses will be used to assess and document data quality and to identify discrepancies in the measurement process that need correction. The checklist of the minimum analytical laboratory QC samples to be considered for inclusion in the SAPs is provided in Table 3.1. Quality control samples will be used to assess various data quality parameters such as representativeness of the environmental samples, the precision of sample collection and handling procedures, the thoroughness of the field equipment decontamination procedures, and the accuracy of laboratory analyses. In addition, all sample containers, preservation methods, and holding times will be in accordance with QC requirements, as specified in SAPs. The analytical laboratory will use a series of QC samples as identified in the laboratory QAP and specified in the standard analytical methods. The types of samples include method blanks, surrogate spikes, laboratory control samples, laboratory control sample duplicates, matrix spikes, and matrix spike duplicates. Analyses of QC samples will be performed for samples of similar matrix type and concentration and for each sample batch. B5.1 Field Quality Control Checks At a minimum, field equipment will be calibrated as frequently as recommended in the manufacturer's specifications. Each calibration including the results will be documented in the Appendix 4 QAPP 14 ATK Launch Systems Promontory Facility June 2006 Post-Closure Pennit field logbook or on a data sheet developed for calibration and signed by the OPM. Additionally, quality control samples will be collected during environmental sampling activities. Each type of field quality control sample is defined below. B5.1.I Field Duplicate Samples A field duplicate sample is a second sample collected at the same location as the sample designated for collection. Field duplicate sample results are used to assess precision, including variability, associated with both the laboratory analysis and the sample collection process. Field duplicate and regular samples will be collected simultaneously, from the same sample interval, providing sufficient material exists, and treated in an identical manner during storage, transportation, and analysis. When recovery of groundwater from sampling operations is sufficient, field duplicate samples will be collected at a frequency to be specified in specific SAPs. 85.1.2 Trip Blanks A trip blank is a sample of distilled and/or deionized, organic-free water preserved with HCl provided in three VOC bottles (and may vary in the specific SAPs). Trip blanks will be prepared only for the analysis of VOCs and will be subjected to the same handling as the other samples. The trip blanks will serve to identify contamination from sample containers or transportation and storage procedures. One trip blank will accompany each cooler of samples at a frequency specified in the SAP and will be sent to the laboratory for the analysis of VOCs. B5.I.3 Equipment Blanks Equipment blanks are collected and analyzed to determine any level of contamination potentially introduced into samples due to the equipment cleaning technique. Equipment blanks will be collected as determined by the ATK PM. General procedures for collecting equipment blanks are as follows: The sample collection device will be cleaned in the following sequence: (1) Wash - Scrub the sample device parts with a dedicated wash brush in a bucket of soap (Alconox®) mixed with tap water; (2) Initial Rinse - Scmb with dedicated rinse bmsh and rinse the sample device parts in a bucket of tap water; (3) Intermediate rinse - Repeat #2 in another rinse bucket of tap water. (4) Final Rinse - While holding the sample tube parts above the rinse bucket, rinse the parts again using clean distilled water from a pressurized container. For non-dedicated pumps the following procedure shall be followed: Appendix 4 QAPP 15 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit (1) Wash - Dip pump in a bucket of soap (Alconox®) mixed with tap water, and scrub with dedicated bmsh (2) Initial Rinse - Scrub with dedicated rinse bmsh and rinse the sample device parts in a bucket of tap water; (3) Intermediate rinse - Repeat #2 in another rinse bucket of tap water. (4) Final Rinse - While holding the sample tube parts above the rinse bucket, rinse the parts again using clean distilled water from a pressurized container. As detailed by specific SAPs, a sample of the equipment sample device rinse water will be collected using the following additional steps: (1) Collect a sample from the final rinse (step 4 above). Collect the water off the equipment being rinsed into the required sample bottie(s); (2) Submit the equipment blank for analysis of all waste constituents sampled groundwater. This equipment blank will be used to help quantify the potential for cross-contamination between samples due to improperly cleaned sampling devices; (3) Discharge wastewater to a sanitary sewer; and (4) Obtain fresh wash water and rinse water from the tap. B5.1.4 Performance Evaluation (blind) Samples If specified in the SAP, PE samples will be used to assess the accuracy of the analytical methods specified. These samples will be prepared by an independent laboratory or supplier with known composition and submitted to the analytical laboratory. The PE samples are analyzed in the same manner as all environmental samples. Acceptance criteria for PE samples will be specified by the PE sample supplier, or the PQAM. The data validation of the PE data will be conducted by the PQAM or a DVSM. B5.I.5 Temperature Quality Control All coolers storing samples and not immediately delivered to the laboratory, shall be maintained at a temperature between four to six degrees Celsius (4-6 ° C). B5.1.6 Field Blanks Field blanks consist of empty, clean sample containers filled with reagent grade water prior to collection of a primary sample. The field blank container is sealed and carried through the same handling, shipping, and analytical procedures as the primary sample. Since the frequency of field blanks is project-specific, field blanks will be specified in the SAP. Appendix 4 QAPP 16 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit B6: EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE To minimize downtime of measurement systems, all field sampling and laboratory equipment will be maintained in working condition. Also, backup equipment or common spare parts will be available so that if any piece of equipment fails during use, repairs or replacement can be made as quickly as possible and the measurement tasks resumed. All field equipment which have manufacturer-recommended schedules of maintenance will receive preventive maintenance according to that schedule. Other equipment used only occasionally will be inspected for availability of spare parts, cleanliness, battery strength, etc. at least quarterly and especially prior to being taken into the field. Electronic laboratory equipment usually has recommended maintenance prescribed by the manufacturer. These instmctions will be followed as a minimum requirement. Due to the cost of some laboratory equipment, back up capability may not be possible. But all commonly replaced parts will have spares available for rapid maintenance of failed equipment. Such parts include but are not limited to: batteries; tubes; light bulbs; tubing of all kinds; replacement specific ion electrodes; electrical conduits; glassware; pumps; etc. B7: EQUIPMENT CALIBRATION B7.1 Field Equipment Calibration of field equipment and instmmentation helps assure that accurate and reliable measurements are obtained. All measurement equipment used for groundwater sampling activities will be calibrated and adjusted to operate within manufacturer's specifications. Methods and intervals of calibration and maintenance will be based on the manufacturer's recommendations, the type of equipment, the analytical method, the instrument's stability characteristics, its required accuracy, intended use of the data, and environmental conditions under which the instrument is operated. Calibration standards, frequencies, equipment maintenance, and calibration acceptance criteria for field instmmentation will be provided in the SAPs. Information required for calibration will be maintained in the field logbooks. The OPM or designee shall assure that all applicable calibration procedures and frequency of calibration are met before and during sampling by recording applicable notes in the daily logs. The equipment necessary for the completion of groundwater sampling activities includes portable water quality meters that measure pH, specific conductance, and temperature. Additionally, portable sampling pumps, bailer, and generators will be used to collect groundwater samples. Appendix 4 QAPP 17 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit B7.2 Laboratory Equipment All instmments will be calibrated in accordance with the analytical method requirements and QC acceptance criteria. All analytes reported will be present in the initial and continuing calibrations and these calibrations, at a minimum, will meet the acceptance criteria specified in the method. Records of standards preparation and instrument calibration will be maintained and submitted upon request to the DVSM. Calibration standards will be traceable to standard materials or standard references. The initial calibration will be checked at the frequency specified in the method using standard materials. Mulfipoint calibrations will contain at least the minimum number of calibration points specified in the method. The calibration curve must meet the detection limits required by the DQOs as specified in SAPs. The laboratory instrumentation requirements and calibration requirements including frequency intervals and acceptance criteria are defined in specific SAPs under the analytical methods. BS: INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES Only sample containers approved for use with the analytical method will be acceptable for the project. The OPM will be responsible for distributing appropriate sample materials to the OS. All other consumables such as buffer solution and distilled water shall be checked by the OS prior to the sampling event for signs of tampering, expiration dates, and suitability for use. B9: NON-DIRECT MEASUREMENTS No non-direct data will be needed for the project. BIO: DATA MANAGEMENT All analytical data produced by ATK Environmental Laboratory, the contractor laboratory, and the field operations manager will be stored at each producer's location. A copy of all permanent data will be provided to Environmental Services Central File. Following implementation of an electronic database for Promontory, data will be electronically stored in the database. Data transfer and communications must ensure that only validated data (level 2) are stored in the project database. The transfer of data from generation, through validation, database entry and final delivery to the Division can be summarized as follows: Field personnel generate field data using appropriate field instmments under the direction of the OPM. Field personnel collect and send samples to the laboratory for analysis. The OPM supplies field data to the ATK PM for review. Appendix 4 QAPP 18 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit . The PQAM supplies validated field data to the ATK DM for entry into the project database. . The laboratory generates laboratory validated data and sends the data to the ATK PM. The ATK PM reviews laboratory validated data for representativeness. If required by the ATK PM, the laboratory sends laboratory validated data to the DVSM for review (rarely); otherwise, the laboratory will send laboratory validated data directly to the ATK DM (usually). If applicable, the DVSM performs a level 2 validation of a percentage of the laboratory- validated data. This percentage is determined by the judgment of the ATK PM. All laboratory validated data and if applicable, DVSM validated data are sent by the DVSM to the ATK DM for entry into the project database. The DVSM communicates with the LM and contract laboratory manager (CLM), the ATK PM, and ATK DM with respect to the validation process involving a laboratory. The PQAM, ATK PM, and OPM communicate with respect to the field data validation process. These communications occur throughout the data transfer process and provide the necessary feedback related to data validation. This communication constitutes the data validation communication loop for the respective types of data. . The ATK DM forwards electronic read only copies of validated data as part of reports to the Division, or upon request by the Division. Data-validation procedures apply to both field and laboratory data. All decisions and recommendations presented in communications between ATK and the Division will be based upon validated data. BlO.l Validation of Laboratory Data The ATK Environmental Laboratory and contractor laboratory will provide a QC review of their respective data in accordance with the relevant laboratory QAP. The laboratory will enter laboratory validated (level 2) data into the laboratory database. During the data validation process, the ATK Environmental Laboratory or a contractor laboratory will submit laboratory validated data to the ATK PM for review. B10.2 Validation of Field-Generated Data The ATK PM or the PQAM will conduct on-site data validation of field generated data and for audits of field procedures. All field generated data, will be reviewed by the OPM and validated by the ATK PM or the PQAM for completeness and legibility prior to incorporation into the project database by the DM (if available). The PQAM will validate data generated by the field instrumentation in accordance with instmctions supplied with the instmments. Appendix 4 QAPP 19 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit B10.3 Use and Storage of Data Data and documents shall be backed up daily to avoid loss. Retrieval of project documents is limited to project personnel who have been granted access to the appropriate electronic files. Sensitive or final electronic documents may be password protected to prevent unauthorized access or inadvertent changes. At project or contract closure, these electronic documents will be copied and electronically stored on a disc, CD, or DVD with an archived hardcopy in Environmental Services Central Files. Appendix 4 QAPP 20 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit Cl: ASSESSMENT AND OVERSIGHT ATK Environmental personnel will review this QAPP and the overall project design annually and may suggest procedural refinements or modifications. Any such changes will be subject to Division approval. C2: AUDITS AND REPORTS TO MANAGEMENT An official "hard copy" report shall be signed and transmitted by the LM to the OPM along with originals of the chain of custody records, field reports, and intemal QA/QC data. Additional reporting will be in accordance with module V.F. of the Post Closure Permit. Audits may be conducted as a principal means to determine compliance with this QAPP and the SAP. Audits are used to review the actual performance of the project during its course and throughout all levels of operations and management. Specifically, audits may be conducted for both field and laboratory operations to assess the accuracy of the measurement systems and to determine the effectiveness of QC procedures. Several factors will be taken into consideration for determining the scope and frequency for audits as follows: 1. Complexity of the activity; 2. Duration and scope of activity; 3. Degree of QC specified in the SAP; 4. Criteria to achieve quality assurance objectives; 5. Requirements for deliverables; 6. Criticality of data collection; and 7. Potential for or frequency of nonconformances. The PQAM has Primary Audit Responsibility: The PQAM will have primary responsibility for overseeing audits, and the authority to delegate certain audit functions, as necessary. For complex or highly specialized tasks, senior technical specialists may be assigned as audit team members and as such, assigned portions of an audit under the direction of the PQAM. Both the PQAM and technical specialists will be familiar with the technical and procedural requirements of the field and laboratory operations, the associated SAP, as well as this QAPP. The Auditing Process: The auditing process includes identifying an auditor, audit notification, audit report, identification of nonconformance, establishing corrective actions, and audit completion notification. Results of all audits performed, as well as associated recommendations for actions will be distributed to the Distribution List as given at the beginning of this QAPP. If there is any nonconfonnance identified during the audit, a follow-up audit after the report will be conducted to assure the nonconforming issue has been corrected. In circumstances where Appendix 4 QAPP 21 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit corrective actions have not been completed as planned or scheduled, the auditing process provides for management intervention to resolve problems. The various types of audits that may be conducted during the project are described in the following sections. These audits will be used to accomplish the following: 1. Verify that measurement systems are operating properly; 2. Assess whether data quality is adequately documented; 3. Confirm the adequacy of data collection systems; and 4. Evaluate management effectiveness to meet QA guidelines. Addressing Nonconformance: The PQAM and audit team members have the authority with the concurrence of the ATK PM to stop all or part of the project activities if a critical situation occurs. A critical situation is defined as a situation in which systematic nonconformances occur. In addition, the PQAM and audit team members have direct access to the ATK PM so that the required authority can be provided where necessary to assure appropriate development and implementation of the required corrective actions. Documentation: All auditing processes and results shall be documented by the PQAM, in an appendix attached to the Investigation Completion reports. C2.1 Performance Audit If deemed appropriate by the ATK PM, a performance audit may be performed during sampling. A performance audit is used to determine the status and effectiveness of both field and laboratory measurement systems. For laboratories, this may involve the use of PE samples. These samples have known concentrations of constituents that are analyzed as unknowns in the laboratory. Results of the laboratory analysis are calculated for accuracy against the known concentrations and acceptance limits provided by the supplier or manufacturer and evaluated by the PQAM or DVSM in relation to the project objectives. Field performance will be evaluated using field blanks, trip blanks, field duplicates, and equipment blanks as described in Section B5. C2.2 Data Quality Audit A data quality audit will be conducted following the procedures specified in Section C2 and the SAP to assess the effectiveness and documentation of the data collection and generation processes. Data-quality audits will be conducted by the DVSM at a frequency specified by the ATK PM. Appendix 4 QAPP 22 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit C2.3 Technical Systems Audit A technical systems audit is used to confirm the adequacy of the data collection (field operation) and data generation (laboratory operation) systems. This is an on-site audit that is conducted to determine whether the Work Plan, SAPs and SOPs are properly implemented. Technical systems audits of field activities may be conducted periodically during the field operations. Sample and field-data collection will be audited by the PQAM or designee while the laboratory data generation will be audited by a DVSM. The audit shall identify all instances of non- compliance and allow for recommendation of corrective actions. A systems audit of field procedures will be used to assess and document, at a minimum, sampling methods (including collection, containers, and preservation), equipment decontamination, chain of custody, sample tracking and shipment documentation, sample labeling, pre-field activities, equipment maintenance and calibration, field activity logs, and equipment check-in and re-calibration. An audit of sample specific requirements of the laboratory is included in Section D.l.4 Laboratory Data Validation. Appendix 4 QAPP 23 ATK Launch Systems Promontory Facility June 2006 Post-Closure Pennit Dl: DATA REVIEW, VERIFICATION AND VALIDATION This section outlines the methodology for assuring the correctness of the data-reduction process. The procedures describe steps for verifying the accuracy of data reduction. Data will be reduced either manually on calculation sheets or by computer on formatted printouts. The following responsibilities apply to all personnel who conduct activities in the data-reduction process: • Technical personnel will document and review their own work and are accountable for its correctness. • Major calculations, if applicable, will receive both a method and an arithmetic check by an independent checker. The checker will be accountable for the correctness of the checking process. • A technical review may be conducted by an independent reviewer to assure the consistency and defensibility of the concepts, methods, assumptions, calculations, etc., stated in reports. • The laboratory data reduction will be performed in a manner that produces quality data through review and approval of calculations. Dl.l Laboratory Data Reduction and Review Data reduction is the process of converting measurement-system outputs to an expression of the parameter that is consistent with the comparable objectives identified in SAPs. Reduction of laboratory analytical data will be completed in accordance with the laboratory QAP and SOPs. The laboratory will perfonn the in-house analytical data reduction and QA review under the direction of the laboratory manager or designee. The laboratory is responsible for assessing data quality and advising the ATK PM or DVSM of any data that were rated "preliminary" or "unacceptable," or other notations that would caution the data user of possible unreliability. Data reduction, QA review, and reporting by the laboratory may include, the following QC tasks: • The data reviewer will check that preliminary data produced by the analyst are processed and reviewed for attainment of quality control criteria as outiined in the laboratory QAP. • The data reviewer will check all manually entered sample data for entry errors and will check for transfer errors for all data electronically uploaded from the instmment output into the software packages used for calculations and generation of report forms and will decide whether any sample re-analysis is required. • The data reviewer will review initial and continuing calibration data, and calculation of response factors, surrogate recoveries, matrix spike/matrix spike duplicate recoveries, intemal standard recoveries, laboratory control sample recoveries, sample results, and other relevant QC measures. Appendix 4 QAPP 24 ATK Launch Systems Promontory Facility June 2006 Post-Closure Pennit • Upon acceptance of the preliminary reports by the laboratory data reviewer, the Laboratory QA Officer or certified technician will review and approve the data packages prior to report submittal to the DVSM and ATK PM. The signing of the Certified Analytical Data Report Submittal by the QA Officer indicates that the QC review tasks, as applicable, have been accomplished. D1.2 Laboratory Data Package Delivery Requirements The data reporting format shall meet the requirements of the method cited in the SAPs and this QAPP. The following forms and information (as pertinent to the method and analysis) will be delivered to a DVSM or ATK PM by analytical laboratories: Certified report listing all analytical methods used, sampling dates/times, EQLs, MDLs, dilutions, analysis dates/times, analyst, and results. A summary of any causes and reasons for variance from the original analytical request, corrective actions taken, factors affecting the analyses, other inconsistencies with paperwork, shipping, and packaging of samples. The report shall include any change or modifications to the sample, if done, and supporting reasons for the change or modifications. Analytical data results (listing both the laboratory ID and field sample ED) and detection limit summaries for all samples. Include results for method blanks, field blanks, MS/MSD, and QC samples as applicable. Blanks summary sheets (Initial, Continuing, Prep Blank). Calibration/Standardization plots and equations, as requested by the PM. Chain-of-Custody records. Copies of laboratory notebook pages showing data not otherwise recorded and calculations, as requested by the PM. Digestion and preparation logs, as requested by the PM. Enhanced or background subtracted spectra, as requested by the PM. ICP interference check sample summary form, ICP serial dilution, as requested by the PM. Initial and continuing calibration verification summary sheets with results of true values compared to found values, as requested by the PM. Intemal standard area (or recovery) and retention time summary infonnation, as requested by the PM. Laboratory control sample results information/summary. Appendix 4 QAPP June 2006 25 ATK Launch Systems Promontory Facility Post-Closure Permit (ftl • Laboratory generated library standard spectra. For tentatively identified compounds provide the reference mass spectrum or spectra from the software-spectra library, as requested by the PM. • Matrix spike/matrix spike duplicate recovery information. • Preparation and run logs and preliminary data (including printer tapes, strip charts, spectra, etc.) for analysis/reanalysis, calibrations, diluted/undiluted samples and QC samples, as requested by the PM. • Quantitation and integration reports, as requested by the PM. • Preliminary compound spectra, as requested by the PM. • Surrogate recovery information. • Standard addition results. • Sample extraction and analysis dates and times. D1.3 Field Data Reduction and Review The OPM is responsible for recording data generated by field instmments, possibly including but not limited to PIDs, thermometers, barometers, and field analytical test kits in accordance with SOPs provided by the manufacturer or in the SAPs. Data shall be reported in a format to be provided in SAPs and shall include, at a minimum the following QC checks: • The OPM will check that data produced by the instmment are within the calibration range of the instrumentation and other QC measures relevant to the field instmments. • The OPM will check field logs and cross check field sampling locations and procedures with the field data for representativeness. • The OPM will check all manually entered field data for entry errors and will check for transfer errors for all data electronically uploaded from an instmment output where appropriate. • Upon acceptance of the field data and field logs by the OPM, the data packages will be delivered, as requested by the PM, to the PQAM for review. D1.4 Data Validation Dl.4.1 Laboratory Data Validation The first level of review will be conducted by the ATK Environmental Laboratory or contractor laboratory. Laboratories have the initial responsibility for the correctness and completeness of the data they generate. The laboratory data reviewer will evaluate the quality of the analytical data based on an established set of laboratory guidelines (laboratory QAP and Appendix 4 QAPP 26 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit SOPs) and this QAPP. This person will review the data packages to confirm at a minimum, the following: • Sample preparation information is correct and complete; • Analysis information is correct and complete; • The appropriate SOPs have been followed; • Analytical results are correct and complete; • QC sample results are within established control limits; • Blank results are within appropriate QC limits; • Analytical results for QC sample spikes, sample duplicates, initial and continuing calibration verifications of standards and blanks, standard procedural blanks, and laboratory control samples are correct and complete; • Tabulation of reporting limits related to the sample is correct and complete; and • Documentation is complete (all anomalies in the preparation and analysis have been documented; holding times are documented). Another level of review beyond the laboratory validation of the laboratory generated analytical data is the data validation of a percentage of the data conducted by a DVSM upon request of the ATK PM. The DVSM will review sample-specific requirements as required under the DQOs. Data validation may be conducted from the results reported on the summary forms and certificates of analysis so that proper qualifiers are assigned to all results. The sample-specific requirement review conducted by a DVSM, at a minimum, may include the following: 1) Blanks Analyses 2) Organic Analyses a) Holding Times b) Surrogate Spike Results b) Matrix Spike/Matrix Spike Duplicate (MS/MSD) Sample Analysis c) Tentatively Identified Compound Identification d) Field Duplicate Agreement 3) Metals and Inorganic Analyses a) Holding Times b) Duplicate Sample Analysis c) Matrix Spike Sample Analysis d) Matrix spike duplicate or laboratory duplicate precision e) Post-digestion Spike Recovery 0 ICP Serial Dilution g) Field Duplicate Agreement Appendix 4 QAPP 27 ATK Launch Systems Promontory Facility June 2006 Post-Closure Pennit 4) Other Analyses The laboratory will be contacted by the DVSM with regard to any missing or incorrect deliverables in the data packages noted during the validation process. The DVSM will document all subsequent submittals and re-submittals from the laboratory, recalculations, and data reviewer corrections. The data package delivery requirements (D1.2) as specified in this QAPP and the SAP will be reviewed for completeness. Data determined to be outside acceptance criteria, using professional judgment, and any conclusions reached conceming usability of the suspect data will be described in the data validation reports submitted by the DVSM to the OPM with the laboratory results report. A data package shall consist of results associated with approximately 20 or fewer field sample numbers. Dl.4.2 Field Data Validation The purpose of the validation process is to evaluate the usability of field data that are collected or documented in accordance with specified protocols outlined in the SAPs. First, all field data will be reviewed by the OPM at the time of collection by following the QC checks outlined in the SAPs and this QAPP (5.1.3). Second, field data will be validated by the PQAM or designee, who will review the field data documentation to identify discrepancies or unclear entries. Field data documentation, at a minimum, may be validated against the following criteria, as appropriate: Sample location and adherence to the plan; Field instrumentation and calibration; Sample collection protocol; Sample volume; Sample preservation; Blanks prepared and submitted with each respective sample set for laboratory analysis; Duplicates collected and submitted with each respective sample set for laboratory analysis; Sample documentation protocols; Chain-of-custody protocols; and Sample shipment. Appendix 4 QAPP June 2006 28 ATK Launch Systems Promontory Facility Post-Closure Permit T--V- v D2: RECONCILIATION WITH USER REQUIREMENTS Once the data verification and validation procedures have been completed, the PQAM and DVSM will evaluate the results to determine if project DQOs have been met for field operations and laboratory analyses, respectively. The calculations specified in other sections of this QAPP and in SAPs will be used to determine if numeric acceptance criteria have been met. Data, which do not meet the requirements for their intended use, may be flagged accordingly and the fiags entered into the project database, so that all data reports used for decision making are clearly noted. Appendix 4 QAPP 29 ATK Launch Systems Promontory Facility June 2006 Post-Closure Permit HAND DELIVERED MAR 0 9 2007 UTAH DIVISION OF SOUD & HAZARDOUS WASTE ATK LAUNCH SYSTEMS PROMONTORY, UTAH GROUNDWATER SAMPLING AND ANALYSIS PLAN FOR POST-CLOSURE PERMIT JANUARY 2007 Groundwater SAP 1 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Pennit CONTENTS 1.0 PURPOSE AND SCOPE 4 2.0 QUALITY OBJECTIVES AND CRITERIA FOR MEASURMENT DATA 5 2.1 DATA QUALITY OBJECTIVES 5 2.1.1 Statement of Problem 5 2.1.2 Decision Statement 5 2.1.3 Decision Inputs 5 2.1.4 Study Boundaries 6 2.1.5 Decision Rule 6 2.1.6 Tolerable Limits on Decision Errors... 6 2.1.7 Selected Sampling Design 6 2.2 QUANTITATIVE OBJECTIVES 6 2.3 QUALITATIVE OBJECTIVES 7 2.4 AUDITS AND REPORTING 8 3.0 SAMPLE COLLECTION 9 3.1 WATER LEVEL MEASUREMENT 9 3.2 PURGING THE MONITORING WELLS 9 3.3.1 Purging High-Yield Formations 9 3.3.2 Purging Low Yield Formations 9 3.3.3 Purging and Sampling Equipment 10 3.3.4 Nested Multi-Screened Well 10 3.4 SAMPLING PROCEDURE FOR MONITORING WELLS 10 3.5 FIELD QUALITY ASSURANCE AND CONTROL PROGRAM 11 3.5.1 Trip Blanks, Field blanks and Field Duplicates 11 3.5.2 Blind Controls and Spiking Samples 12 3.5.3 Sample Handling 12 3.5.4 Labeling Samples 13 3.5.5 Field Book 13 3.5.6 Chain-of-Custody Control Procedures 13 3.5.7 Field Equipment Calibration Procedure 14 Groundwater SAP 2 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Pennit 3.6 SAMPLE COLLECTION SCHEDULE 14 4.0 ANALYSIS OF GROUND WATER SAMPLES 14 4.1 ANALYTICAL LABORATORY 14 5.0 REPORTS 14 5.1 PRESENTATION OF ANALYTICAL RESULTS 14 5.1.1 Listing of Data 15 FIGURES Figure I Example of Chain of Custody Form TABLES Table 1 Sampling and Analytical Methods Requirements Groundwater SAP 3 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Permit ATK LAUNCH SYSTEMS GROUND WATER SAMPLING AND ANALYSIS PLAN FOR POST-CLOSURE PERMIT MONITORING 1.0 PURPOSE AND SCOPE ATK Launch Systems (ATK) has developed this plan to satisfy the requirements for a ground water sampling and analysis plan as referenced in 264.97 of the Code of Federal Regulations (CFR). The plan also addresses Section R315 7-13-4 of the Utah Administrative Code and 40 CFR 265.93 with respect to Assessment Monitoring. The plan specifically addresses the sampling of ground water monitoring wells at ATK Launch systems Promontory, Utah-based Operations. The location, number, and description of each well have been submitted previously to the Utah DSHW. The plan addresses all procedures for taking ground water samples, shipping the samples for analysis, and methods for analyzing samples. The goal of this plan is to collect groundwater samples that are representative of in-situ groundwater conditions and to minimize changes in groundwater chemistry during sample collection and handling. DNAPL's are not known to be present in any screened interval of any well. If DNAPL's are discovered to be present in a well, this document is not sufficient, and protocol for sampling will be developed prior to sample collection. Groundwater SAP 4 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Permit 2.0 QUALITY OBJECTIVES AND CRITERIA FOR MEASURMENT DATA This section presents the DQOs for the project and the performance criteria necessary to meet these DQOs. Included are discussions of the project DQOs, quantitative DQOs (precision, accuracy, and completeness), and qualitative DQOs (comparability and representativeness). The overall QC objective is to generate data that are of known, documented, and defensible quality. 2.1 DATA QUALITY OBJECTIVES DQOs are statements that specify the quantity and quality of the data required to support project decisions. DQOs were developed for this project using the seven-step process listed in Data Quality Objectives Process for Hazardous Waste Site Investigations (U.S. EPA, 2000). The QC procedures as well as the associated sampling procedures for this project will be focused on achieving these DQOs in a timely, cost-effective, and safe manner. Deviations from the DQOs will require defining the cause or causes for noncompliance and will initiate the process of determining whether additional sampling and analyses will be required to attain project goals. 2.1.1 Statement of Problem Groundwater in many areas throughout the Promontory facility has historically contained elevated concentrations of various solvents and explosive constituents. The goal of this plan is to outiine the methodologies for collection of groundwater samples that are representative of in-situ groundwater conditions and to minimize changes in groundwater chemistry during sample collection and handling. 2.1.2 Decision Statement Decision statements identify the key questions that the study should address and altemative actions that may be taken, depending on the answer to the study questions. The key question associated with groundwater sampling at the Promontory facility is: Do contaminants of concem exist in groundwater at the site at concentrations that require future corrective action? Altemative actions associated with this key question include no action, continued monitoring, and remediation (either active or passive). The decision statement for this study is to determine whether or not contaminants in groundwater are increasing, decreasing, or staying the same by sampling and analyzing groundwater from the previously installed monitoring network. 2.1.3 Decision Inputs The most appropriate resolution of the decision statement will require the collection of groundwater samples on a regular schedule and analysis of these samples for appropriate constituents. These data will then be evaluated along with historic groundwater data from wells to determine the need for future action at the sites. Groundwater SAP 5 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Pennit 2.1.4 Study Boundaries The location, number, and description of each well have been submitted previously to the Utah DSHW. 2.1.5 Decision Rule The data collected from each groundwater sampling event will be initially screened using published MCLs or when not available, preliminary remediation goals ("PRGs") from EPA Region IX (Smucker, 2004) will be used to evaluate each sample. If the screening evaluation indicates that groundwater contaminant concentrations have not changed significantly from previous sampling efforts, then no corrective action will occur. Under this scenario, groundwater monitoring will continue. If a significant increase in contaminant concentration occurs, an evaluation will be undertaken to determine if the change is due to physical changes (i.e., spills or releases, seasonal variation, etc.) or potentially sampling error. 2.1.6 Tolerable Limits on Decision Errors Tolerable error limits assist in the development of sampling designs to ensure that the spatial variability and sampling frequency are within specified limits. However, the location, number, and frequency of sampling at the Promontory facility has been previously determined by the requirements of the Post Closure Permit and compliance monitoring downgradient of identified Solid Waste Management Units. The selection of the well locations was based on professional judgment rather than statistics. Therefore, error limits are not used to determine sampling locations or frequency. There is no need to define the "gray region" or the tolerable limits on the decision error, since these only apply to statistical designs. In general, the steps necessary to minimize errors and produce good quality data will be incorporated into quality assurance/quality control (QA/QC) protocols in this plan. 2.1.7 Selected Sampling Design The proposed sampling locations (monitoring wells) were drilled in areas based on best professional judgment, site history, aerial photos, and results of previous environmental investigations. Samples are collected based on the requirements of the Post Closure Permit. 2.2 QUANTITATIVE OBJECTIVES Precision quantifies the repeatability of a given measurement. Precision is estimated by calculating the relative percent difference (RPD) of field duplicates, as shown in the following equation: Groundwater SAP 6 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Permit (%)RPD= Result-DuplicateResult ^^^^ (Result + Duplicate Result)/2 The laboratory will review the QC samples to ensure that intemal QC data lies within the limits of acceptability. Any suspect trends will be investigated and corrective actions taken. The laboratory will document the calculation for %RPD or other statistical treatment used. The results will be compared to the acceptance criteria as published in the mandated test method. Where there are no established criteria, the laboratory will determine intemal criteria and document the method used to establish the limits Accuracy refers to the percentage of a known amount of analyte recovered from a given matrix. Percent recoveries are estimated using the following equation and can be calculated for the project-specific matrix (i.e., water). Recovery Laboratory Control Standard (LCS) and Surrogate Intemal Standard (SIS) (%) = (Amount Spike Recovered) ^^^^ Added Spike Amount Recovery Matrix Spike/Matrix Spike Duplicate (MS/MSD)(%)= ^^P'*^^^ ^^"^P'^ ^^^"'^^ - ^^^"^P'^ ^^^"'^^ xlOO Spike Added The recovery of most spiked organic compounds is expected to fall within a range of 70 to 130%. Completeness refers to the percentage of valid data received from actual testing done in the laboratory. Completeness is calculated as shown in the following equation. The target completeness goal for all compounds is 100%. However, where data are not complete, decisions regarding re-sampling and/or reanalysis will be made by a collaborative process involving ATK Environmental personnel, laboratory personnel, and regulatory personnel. The completeness goal for holding times will be 100%. Number of Measurements Judged Valid ..^^ Completeness % = — xlOO Total Number of Measurements 2.3 QUALITATIVE OBJECTIVES Comparability is the degree to which one data set can be compared to another. To ensure comparability, samples will be collected at specified intervals and in a similar manner, and will be analyzed within the required holding times by accepted and comparable methods. Comparability will be obtained through the use of standard sampling procedures and trained personnel, and through standard analytical methods used by the laboratory. Additionally, Groundwater SAP 7 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Pennit adherence to the procedures and QC approach contained in the QAPP will provide for comparable data throughout the sampling events. All data and units used in reporting for this project will be consistent with accepted conventions for environmental matrix analyses. This approach will ensure direct comparability between the results from one sampling event to the next sampling event using the methods presented in this SAP. Representativeness is the degree to which a sample or group of samples is indicative of the population being studied. Over the course of a project, samples will be collected in a manner such that they are representative of both the chemical composition and the physical state of the sample at the time of sampling. 2.4 AUDITS AND REPORTING A Performance Audit will be conducted during a sampling round at least once in a five year period. The performance audit will be used to determine the status and effectiveness of field and laboratory measurement systems. For the laboratory, this will involve the use of PE samples with known concentrations of constituents that will be analyzed as unknowns in the laboratory. Results of the laboratory analysis will be calculated for accuracy against the known concentration and acceptance limits provided by the supplier or manufacturer. Field performance will be evaluated using field blanks, trip blanks, field duplicates, and equipment blanks as described in Section B5 of the QAPP. A Data Quality Audit will be conducted following the procedures specified in Section C2 of the QAPP to assess the effectiveness and documentation of the data collection and generation processes. Data-quality audits will be conducted by the DVSM at least once during a five year period. A Technical System Audit (TSA) will be perfonned once each five years. A TSA is a thorough and systematic qualitative onsite audit where equipment, personnel, training, procedures, and record keeping are examined for conformance with requirements of the QAPP. The TSA will encompass field sampling activities, data validation, and data management. All findings will be documented in writing to the OPM and communicated to the PM when the assessment is complete. A copy of the TSA report will be provided to the Division for review, together with a discussion of all proposed corrective actions and corrective actions taken as a result of the audit. The TSA will include a field audit to check on sample collection and sample handling procedures. The field audit will include: • A review of compliance with requirements of the QAPP and Sampling Plans • On-site visits, which will include observation of field personnel as they perfonn all aspects of the sampling programs: field equipment calibration, equipment decontamination, sample collection, sample packaging, and documentation. The on-site visits will also include a review of data collection forms, COC forms. Groundwater SAP 8 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Permit calibration procedures, etc. The auditor will also talk individually with field personnel to determine consistency of sampling procedures and adherence to the approved sampling plan. 3.0 SAMPLE COLLECTION 3.1 WATER LEVEL MEASUREMENT Before sampling any ground water monitoring wells, a water level measurement will be recorded using an electronic water level indicator to the nearest 0.01 feet. The water level will be recorded in the field book before each monitoring well is sampled. The total depth of the monitoring wells that are sampled and that are completed in unconsolidated sediments and do not contain dedicated pumping systems will be recorded to the nearest 0.1 feet in the field book. The northem edge of the (inner) PVC casing shall be used as the reference point. A List of all wells that were completed in unconsolidated material is in TABLE 2. 3.2 PURGING THE MONITORING WELLS The ground water monitoring well will be purged before sampling begins. Monitoring wells shall be purged so that stagnant waters, which are not representative of the waters in the aquifer, can be removed before sampling. The amount of water to be removed from the well will be dependant upon the ground water yield for the formation in which the well in located. Although specific purge and sample systems are described below, other methods may be employed if they meet guidelines approved by the USEPA and Utah DSHW. 3.3.1 Purging High-Yield Formations For high-yield formations (which produce greater than 1 gpm), three casing volumes of water will be removed from the well or until the pH, temperature, and conductance has stabilized within approximately 10% over at least two measurements. A casing volume is defined as the volume of water between the water level measured and the total depth of the monitoring well. The casing volume will be calculated during each sampling period, so that a consistent volume of standing water can be removed prior to each sampling. 3.3.2 Purging Low Yield Formations For low-yield formations (which produce less than approximately 1 gpm), wells should be purged at or below their recovery rate so that migration of water in the formation above the well screen does not occur. A low purge rate also will reduce the possibility of stripping VOCs from the water, and will reduce the likelihood of mobilizing colloids in the subsurface that are immobile under natural flow conditions. Make sure that purging does not cause formation water to cascade down the sides of the well screen. At no time should a well be purged to dryness if recharge caused the formation water to cascade down the sides of the screen, as this will cause an accelerated loss of volatiles. Water should be purged from the well at a rate that does not cause Groundwater SAP 9 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Permit recharge water to be excessively agitated until the pH, temperature and conductance has stabilized within approximately 10% over at least two measurements. 3.3.3 Purging and Sampling Equipment Wells less than 250 feet deep may be purged and sampled with a variable frequency pump. Wells greater than 250 feet deep, may be purged and sampled using a pneumatic-operated tubing-vented piston pump. Wells greater than 250 feet with a dedicated system may use a submersible pump for purging and a bladder pump for collection of volatile organic samples or a variable frequency 4" diameter Pump. Variable speed low rate centrifugal pumps may also be used for both purging and sampling. When dedicated equipment is not used for sampling it should be cleaned in the following manner: Wash the equipment with a nonphosphate detergent. Rinse the equipment with tap water. Rinse the equipment with reagent water. Decontamination fluids should be put in the waste water collection tank and disposed of with the collected well water. Equipment blanks will be taken on approximately 10% of all wells sampled not using dedicated equipment. 3.3.4 Nested Multi-Screened Well Wells B-2 and F-2 consist of three two inch inside-diameter well casings nested within an eight- inch diameter borehole. Each casing is screened at a different depth in the aquifer. Purging and sampling is accomplished by using a pneumatic-operated tubing-vented piston pump or a centrifugal, variable speed, low-rate pump. Each casing shall be purged of three casing volumes prior to sampling, or until parameters stabilize. 3.4 SAMPLING PROCEDURE FOR MONITORING WELLS Each well will be sampled using the following procedure. These procedures will describe specifically the following steps for sampling the wells. (1) Each well will be purged before removing a sample (2) The sampling pump will be operated to produce a stream of ground water. Before taking a sample, the pH, specific conductance, and temperature will be measured using portable meters. Samples will be taken when the pH, conductance, and temperature have stabilized to within approximately 10% over at least two readings, or after three casing volumes of water have been purged. A sample from the pump will be put into an appropriate container. (3) For the Volatiles the flow rate will be restricted to less than lOOml/minute while taking the samples. Groundwater SAP 10 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Pennit (4) Metal samples will be collected using direct inline filters with a .045 micron pore size filter membrane. Allow approximately 150 mis of sample to pass through the filtering device before filling sample containers. (5) The samples will be taken in the following guide: 1) 2) 3) 4) 5) Volatiles Anions TDS Metals Other Constituents (6) If samples are being split, the samples will be taken directly from the ground water monitoring well. This process will be done in order to minimize volatilization of sensitive organics. 3.5 FIELD QUALITY ASSURANCE AND CONTROL PROGRAM The field QA/QC program is described in the Post-Closure Permit Quality Assurance Project Plan. A general description is given below. A QA/QC officer has been appointed to oversee the Ground Water QA/QC Plan, implement all phases of the Field Quality Assurance and Control Program, and to periodically audit the laboratory's QA/QC Program. The QA/QC officer will work with the sampling staff and the laboratory's QA/QC officer to assure that the data collected from the ground water is accurate. The QA/QC officer duties include: 1. Making sure that the Ground Water Sampling Plan is followed. 2. Making sure the laboratory follows their QA/QC plan. 3 Send spiked samples periodically to the laboratory to audit the QA/QC program. 3.5.1 Trip Blanks, Field Blanks and Field Duplicates Trip blanks, when collecting VOC's, will consist of not less than ten percent of the total of samples, and will be made of deionized water, prepared at the laboratory immediately before leaving on a sampling run. The trip blanks are then placed in a cooler which will be filled by other samples: the trip blanks are handled in the same manner as other samples. Holding times for a trip blank begins when groundwater samples are being collected. Groundwater SAP 11 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Pennit Field Blanks (field rinsate blank, decontamination blank, equipment blank) Collect one field blank for every 10 samples collected. Decontaminate the sampling equipment for the field blank the same way you do when collecting other samples. After decontaminating the sampling device (e.g., bailer or pump), fill it with laboratory reagent grade water, then collect a sample of the reagent grade water, this is your field blank. The field blank should be analyzed for the same parameters as the samples. Field blanks are not required if you used dedicated sampling equipment (permanently left in the well) or disposable sampling equipment. Field duplicates, consisting of not less than ten percent of the total samples, will be collected and stored with the water samples. The field duplicates are collected and handled at the same time and in the same manner as a regular sample. The results of these samples are compared against those of the appropriate regular sample. 3.5.2 Blind Controls and Spiking Samples Annually, the QA/QC officers will send a spiked sample or a blind control to the laboratory to audit the laboratory's Q/VQC program. A blind control and a spiked sample both are samples with a known amount of solute in a solvent. The difference between a blind control and a spiked sample is the following: 6) Blind Control - An unannounced spiked sample sent to the laboratory. 7) Spiked Sample - An announced spiked sample sent to the laboratory. The level of contamination in either case is not divulged to the laboratory. The QA/QC officer will review the spike or blind control recovery. If the spike or blind control recovery is out of line with the laboratory's surrogate spike and matrix spike recoveries, the laboratory's QA/QC officer will be contacted to resolve the problem. 3.5.3 Sample Handling Sampling equipment and techniques have been designed so that the ground water sample is not contaminated or altered. A critical part of obtaining samples is proper sample handling. All of these procedures will be followed for handling ground water samples. All samples requiring refrigeration will be stored in a secured refrigerator or ice chest with ice. All samples will be labeled and accompanied by a laboratory request and chain of custody sheets. Groundwater SAP 12 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Permit 3.5.4 Labeling Samples All sample containers will be labeled with the following information: 1) Sampling date and time 2) Sample number 3) Name of person taking samples 4) Parameters to be analyzed in sample 5) Location of sampling point 6) Preservative added (if applicable) 3.5.5 Field Book During each sampling period, the person sampling the ground water wells will keep a field book into which all relevant infonnation regarding sampling will be recorded. The data must be entered in the book using permanent ink. The following informafion will be entered into the field book: 1) Signature and date of person(s) conducting the sampling. 2) General weather conditions. 3) Date and time each well is sampled. 4) Sample number and location of sample (i.e., well number). 5) Static water level in well. 6) Volume of a casing of well (if applicable). 7) Flow rate, and purge start and stop times. 8) PH, specific conductance, and temperature measured during stabilization of well. 9) Conductance and pH meter calibration date. 10) Any irregularities in the sampling procedures or in the conditions of the wells. 11) Any other information the sampler deems necessary or important during sampling. 3.5.6 Chain-of-Custody Control Procedures All samples will be controlled by chain-of-custody procedures. All samples shall be accompanied by a chain-of-custody form. This form must be completely filled out, signed, and dated by the sampler. An example of the form is found on Figure 1. Groundwater SAP 13 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Pennit The containers will be placed in a lockable cold storage box, or refrigerator. This box will be in the possession of the person charged with the custody of the samples or the box will be locked and placed in a secure place. Under no circumstances will the box with the samples be left unlocked or unattended. A copy of all the Chain-of-Custody forms will be reviewed for accuracy and filed by the Q/VQC officer. 3.5.7 Field Equipment Calibration Procedure Each sampling day, the pH and conductivity meters will be calibrated with a standardized solution in accordance with the manufacturer's specification. Record of these calibrations will be kept in the Field Log Book. 3.6 SAMPLE COLLECTION SCHEDULE The ground water monitoring wells will be sampled semiannually. 4.0 ANALYSIS OF GROUND WATER SAMPLES Wells will be sampled for constituents specified in the post-closure permit. Samples will also be analyzed for the field water quality parameters pH, temperature, and conductance. 4.1 ANALYTICAL LABORATORY All samples will be analyzed by a state certified laboratory using EPA or State approved analytical methods. If there is not an established EPA or State approved analytical method, the Utah DSHW will be notified of the proposed analytical method. If the laboratory is not State certified to do a specific analysis, the laboratory will subcontract a qualified laboratory to do the analysis. Table 1, contains a listing of analytes, methods, containers, and holding times. 5.0 REPORTS Reports submitted semiannually to the Utah DEQ will include raw analytical data and analysis of data as described previously in Sections A-9 of the QAPP. 5.1 PRESENTATION OF ANALYTICAL RESULTS The analytical results received from the laboratory will be placed on a computer for easy data manipulation and presented in the following manner: Groundwater SAP 14 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Permit 5.1.1 Listing of Data All the collected monitoring data will be presented in a list. This list will be presented according to monitoring well and will include all of the data produced from sampling the monitoring well. The list will include the following data: Ground water contaminant constituents Monitoring well number Date sample was taken Concentration of constituents Units Laboratory detection limits Groundwater SAP 15 ATK Launch Systems, Promontory Facility Jan. 2007 Post-Closure Pennit Turn Around Time: FIGURE 1 CHAIN OF CUSTODY ATK Launch Systems, Promontory Utah Page of. Collected by: Contact: Telephone: Project: Collection Location: Work Order: SAMPLE NUMBER *H-LAB DATE SAMPLED TIME SAMPLED , NUMBEI^ OF ^BOTTLES ANALYSIS FtEQUESTED ., y'^' ..••. ,,;,.-.i..:. • .. • . ..t .. •-•.^- •• '"••••••'• ":•• ..... ...••; '••: -X-- _.. .::•, _ ^ ....•:,-,•••,,:•-,--.^K--'"- •" ;.;>: •...:-,; ..•• "••••". •-- :;..-.;;; . .'^': ,:;•.;•* ' .'-'lj :.: '•^.%:'i-y;^.y:^: .V '• • ""••"• '.%'•' k. . •^ y'-y •• . . "^.•4:'.. -.r^.=:'".::..".•.• . . •' yy^;: y--c •' '.y.y^y i^ Relinquished by: Received by: Dale/Time TABLE 1. SAMPLING AND ANALYTICAL METHODS REQUIREMENTS Parameter Volatile Organic Compounds Perchlorate Metals: Ag, Cd, Cr, Pb Matrix Water Water Water Analytical Method USEPA Method 8260B - Thiokol SOP 401 USEPA Method 314- ThiokolSOP314 USEPA Method 60lOB- Thiokol SOP 364 USEPA Method 747 lA-Thiokol SOP 373 Containers per sample (number, size, and type) 3-40 ml glassTeflon cap 250 ml nalgene 500 ml nalgene Preservation Requirements (temperature, chemical) Cool 4° C HCl to pH<2 Cool 4° C Cool 4° C HNO3 to pH<2 Maximum Holding Time (to extraction) 14 Days 28 days 28 days (Hg); 6 months (other) Lab Holding Time (after extraction) 40 days 28 days 40 days CONSTITUENTS AND GROUNDWATER DETECTION LEVELS Constituent 1,1-Dichloroethene 1,1-Dichloroethane 1,2-Dichloroethane 1,4-Dioxane 1,1,1- Trichloroetiiane 1,1,2- Trichloroethane 4-Methyl-2- pentanone Acetone Acrolein Benzene Bromomethane Carbon Tetrachloride Chlorobenzene Chloroform Cis-1,2- Dichloroethene Methyl Ethyl Ketone (2-Butanone) Methylene Chloride Tetrachloroethene Toluene Trans-1,2- dichloroethene MDL* (ug/L) 0.2 0.5 0.3 100 0.2 0.3 0.6 30 20 0.3 0.6 0.3 0.2 0.3 0.2 1.2 0.8 0.3 0.3 0.4 EQL (ug/L) 10 10 10 500 10 10 10 100 200 10 10 10 10 10 10 10 10 10 10 10 Constituent Trichloroethene Trichlorofluoromethane Vinyl Chloride Xylene Antimony Arsenic Barium Beryllium Chromium (total) Cobalt Manganese Molybdenum Nickel Perchlorate Ammonia Nitrate 1,3-Dinitroglycerin Nitroglycerin ^ RDX HMX MDL* (ug/L) 0.8 0.3 0.3 2 20 20 2 0.5 10 1 1 1 5 1 30 10 0.3 0.6 0.4 0.3 EQL (ug/L) 10 10 10 10 100 100 10 2.5 50 5 5 5 25 4 150 100 1 1 1 1 * Note: MDLs are approximate values and are subject to change.