Final Remedial Action Completion Report for the ... - Rvaap.org

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Cmt.# A-4 Page # Line # Section 3.6.2, Pg 3-13 New Page or Sheet Pg 3-17, Section 3.6.2, Line 30- 32 Comment Please indicate the analyses each laboratory was responsible for. A-5 Tables B-1 Screening criteria should be included on the sample results tables for groundwater. A-6 Appendix C and F, Section 1.2 App C, Added Section 2.8 Am puzzled by the statement “data qualifiers were not assigned based on data verification findings”. Shaw Environmental, Inc. 3 of 39 Recommendation Response 3.6.1 that states “It should be noted that the reduction of the sample volume prior to shipment deviated from the methodology outlined in the RAWP but was approved by USACE and the OhioEPA prior to implementation in the field.” Add a table or some text. The following will be added to this section after the first sentence: “Shaw contracted both laboratories to ensure adequate turn-aroundtimes were achieved in conjunction with Shaw’s aggressive excavation schedule. Both laboratories performed analyses for benzo(a)pyrene, 2,4,6-TNT and metals. In addition to these analyses, Test America analyzed solely for propellants and PCBs and RDX samples were analyzed only by Include a column(s) for the appropriate screening criteria and bold anything that exceeds criteria. Clarify if based upon the data evaluation no data qualifiers were required or if this is to be interpreted that the data verification process did not include data qualification. Note the latter statement is not correct. See comment 9. Kemron.” Shaw will include the screening criteria used in the FWGWMP into the sample results table for groundwater. Section 2.8 – Data Qualifications will be added to the Groundwater Data Verification Report in Appendix C. The text will go as follows: “Data qualifications have been performed in accordance to LCG. The qualification “UJ” is defined as the estimates (J) to non-detects (U) for non metals. It is to be noted that LCG has a much stringent (or difficult) QA/QC criteria (except for VOC) than SW-846, Contract
Cmt.# Page # Line # New Page or Sheet Comment Shaw Environmental, Inc. 4 of 39 Recommendation Response Laboratory Protocol (CLP) and Department of Defense Quality System Manual (DOD QSM). (a) Metals: QC/MRL standards (opening and closing) were outside the allowable range on a number of occasions. However, an MDL check was analyzed at the end subsequently, no corrective action was required (no qualifier was assigned) (b) SVOCs: LCG does not address sample qualification criteria (or the corrective action) on the samples, when associated method blank and LCS yields out of range recoveries (as long as the recovery is over 10%). Although a number of surrogate recoveries were outside the allowable range (as shown in Table 2-1) for method blanks and LCSs, no qualification was assigned. The following sample results will be assigned UJ based on surrogate recovery (one or more outside the allowable range of 50- 150%). (c) Pesticides: LCG does not address sample qualification criteria (or the corrective action) on the samples, when associated method blank and LCS yields out of
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