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

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Cmt.# Page # Line # New Page or Sheet Comment Shaw Environmental, Inc. 7 of 39 Recommendation Response 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 Laboratory Protocol (CLP) and Department of Defense Quality System Management Plan (DOD QSM). (g) Metals: There is no qualification needed as far as LCG is concerned. TestAmerica assigned “J” (only in case of metals “J” qualifier is applied for blank contamination) for blank contamination in metal samples. However, in all those cases the metal concentrations in the blank were below one half of the reporting limit. Thus, no qualification or correction is required. (h) SVOCs: LCG does not address sample qualification criteria when associated method blank and LCS yields out of range recoveries. Although recoveries of 2,4,6tribromophenol (a surrogate) was below LCG allowable limit 50-150% in the method
Cmt.# A-7 A-8 A-9 A-10 Page # Line # Appendix C and F, Pg 1-3 Appendix C and F, Pg 1-6 Appendix C and F, General Appendix C and F, New Page or Sheet App C, Section Comment “Adherence to the LCG QC/MRL requirements was not required for this project……therefore; corrective action was not required for QC/MRL results outside the LCG control limits. The last sentence should probably say “…each test panel in each sample delivery group or data package” rather than “in each sample”. Apparently, data qualifications were not performed in accordance with the LCG. Tables 1 through 10 in the LCG provide explicit instruction on how the data should be qualified based upon QC outliers. Please also include the sample preparation methods, where Shaw Environmental, Inc. 8 of 39 Recommendation MRLs would be required if the work was contracted to follow the LCG unless specifically stated otherwise. Response blank and in LCS, no qualification was assigned. (i) PCBs: As shown in Table 2- 2 recoveries of decafluorobiphenyl were outside the allowable limits of 50-150% for samples LL2ss-062, LL3ss-085, LL3ss-092, LL1ss-017, and LL3ss-073. Thus, the results will be qualified “J” for these samples. (j) Explosives: Samples LL3ss- 088 and LL3ss-098 were extracted outside the holding time. The results of these samples will be qualified “J”. This sentence was introduced unintentionally. The statement will be removed. Correct if applicable. For both Appendix C and F, this sentence in Section 1.3 has been revised to state: “..each test panel in each sample delivery group or data Review the LCG guidelines for the qualification of analytical data. package..” The LCG guidelines for data qualification will be reviewed and a section summarizing data qualifications will be included in Appendix C and F. For text to be included in these appendices, please see response to Comment A-6. Include. The report will be revised to include sample preparation method when
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