FINAL SAMPLING AND ANALYSIS PLAN - Documents for Moffett Field

FINAL 

SAMPLING AND ANALYSIS PLAN 

(FIELD SAMPLING AND QUALITY ASSURANCE PROJECT PLAN) FOR 

NON-TIME-CRITICAL REMOVAL ACTION FOR PCB CONTAMINATION 

AT INSTALLATION RESTORATION SITE 29, HANGAR 1 

Former Naval Air Station Moffett Field, 

Moffett Field, California 

PERMAC Contract Number N62473-08-D-8816 

Contract Task Order 0005 

Document Control Number AMEC-8816-0005-0039 

April 2010 

Submitted to: 

U.S. Department of the Navy 

Base Realignment and Closure 

Program Management Office West 

1455 Frazee Road, Suite 900 

San Diego, California 92108-4310 

Submitted by: 

AMEC Earth & Environmental, Inc. 

9210 Sky Park Court, Suite 200 

San Diego, California 92123 

(858) 300-4300

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EXECUTIVE SUMMARY 

AMEC Earth & Environmental, Inc., (AMEC) has been contracted by Naval Facilities 

Engineering Command Southwest (NAVFAC SW) under Contract Task Order (CTO) 0005 

to manage and perform the removal action for Hangar 1 at Former Naval Air Station Moffett 

Field (Moffett Field), located in Moffett Field, California. This document presents the 

Sampling and Analysis Plan (Field Sampling Plan and Quality Assurance Project Plan; 

hereafter referred to as the SAP) for the Hangar 1 removal action and was prepared in 

concurrence with the Draft Non-Time-Critical Removal Action Work Plan (Work Plan). 

This SAP meets the updated Uniform Federal Policy for Quality Assurance Project Plans 

(UFP-QAPP) (U.S. Environmental Protection Agency [EPA] 2005) and EPA Guidance for 

Quality Assurance Project Plans, EPA Quality Assurance (QA)/G-5, Quality Assurance 

Manual (QAM) (U.S. EPA 2002) requirements. 

Moffett Hangar 1 was constructed in 1932 to house airships as part of the Navy’s Lighterthan-Air 

program. Construction materials used included Robertson Protected Metal siding, 

now known to contain polychlorinated biphenyls (PCBs) and asbestos. Hangar 1 was coated 

with a lead-based paint that contains PCBs. PCBs are a probable human carcinogen and 

ecological contaminant that bioaccumulates in the environment. Hangar 1 was also used for 

aircraft maintenance, training facilities, and office space. Control of property management 

of Hangar 1 was transferred to National Aeronautics and Space Administration (NASA) 

under the Base Realignment and Closure (BRAC) program in 1994. During this time, the 

facility was used for air shows, open houses, a field museum, and various other public and 

commercial activities. In 1997, routine cleaning and sampling activities of a settling basin 

located approximately 2,000 feet northwest of Hangar 1 indicated the presence of a 

relatively uncommon PCB, Aroclor 1268. Hangar 1 was suspected as the source of the PCBs 

in the sediment samples. Subsequent investigations included sampling of the Hangar 1 

exterior construction materials, the interior paint, and ambient air outside and inside Hangar 

1, as well as stormwater and stormwater sediment. Data gathered from the investigations 

confirmed Hangar 1 as the PCB source. 

In July 2003, the Regional Water Quality Control Board (Water Board) was notified by 

NASA of the presence of Aroclor 1260 and Aroclor 1268 in the stormwater collection 

trench. Due to health and safety concerns, Hangar 1 was closed in 2003 to all access except 

for essential maintenance, abatement, or environmental cleanup. In September of 2003 

NASA conducted a Time-Critical Removal Action (TCRA) which involved cleaning out and 

characterizing sediment residue in the stormwater collection trench surrounding Hangar 1. 

In October of 2003 the Navy conducted a TCRA which involved pressure washing the 

exterior surface and the surrounding area of the hangar, coating the corrugated siding with 

an asphalt emulsion, and installing a security fence. 

Final Sampling and Analysis Plan 

Installation Restoration Site 29, Hangar 1 

Former Naval Air Station, Moffett Field, Moffett Field, California 

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The Engineering Evaluation/Cost Analysis (EE/CA), finalized in July 2008, identified PCBs 

as the chemicals of concern and stated that the release of the PCBs needed to be controlled. 

In December 2008, the Action Memorandum for the Non-Time-Critical Removal Action 

(NTCRA) for the PCB Contamination at Hangar 1 was completed. The Action 

Memorandum selected Alternative 10, the removal of the Hangar 1 siding and application of 

a coating to the exposed surfaces, as the preferred removal action. Although PCBs are the 

regulatory driver for this NTCRA, the presence of lead and asbestos in the exterior and 

interior building materials of Hangar 1 will require abatement and disposal compliance, as 

well as additional health and safety precautions. 

To verify that the removal is executed without the release of PCBs into the environment as a 

result of the removal action, soil and sediment samples will be collected to establish baseline 

concentrations of PCBs, lead, and asbestos. Baseline/pre-construction samples will be 

collected from the soil areas immediately adjacent to Hangar 1 and from any sediment that 

may be present in the stormwater trench/conveyance system. The baseline/pre-construction 

soil samples will also indicate if soil excavation will be necessary to remove soil where the 

PCB concentrations exceed project action limits of 1000 micrograms per kilogram (µg/kg). 

Following the removal activities, samples will be collected from the previously sampled soil 

areas adjacent to Hangar 1 and from locations on the interior concrete floor of Hangar 1. 

Soil samples will be analyzed for PCBs, lead, and asbestos. Post-construction confirmation 

soil sample concentrations will be compared with the baseline/pre-construction soil sample 

concentrations to verify that contaminants were not released into the environment as a result 

of the removal action, and to ensure PCBs are below 1000 µg/kg. Concrete wipe samples 

will be collected from the interior concrete floor and analyzed for PCBs and lead to confirm 

that concentrations are below the regulatory limits. Sediment will be removed (washed) 

from the stormwater trench/conveyance system as part of the removal action, therefore; it is 

anticipated that there will not be sediment to sample during the confirmation sampling 

event. 

Waste streams generated during the removal action will be characterized and sent to the 

proper disposal facility. Spent water generated and collected during the removal action will 

be treated on site. Pending analytical results and verification that analytical results are below 

discharge criteria, the treated spent wash water will be discharged to the Sunnyvale Publicly 

Owned Treatment Works (POTW) via the NASA/Ames Sanitary Sewer system. 




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All laboratories will be evaluated by the Naval Facilities Engineering Services Center 

(NFESC) or will hold the Department of Defense (DoD) Environmental Laboratory 

Accreditation Program (ELAP) certification, and the California Department of Public Health 

ELAP certification (for methods certified by California). For removal actions at installation 

restoration (IR) sites, data will be validated at 80 percent (%) Level III and 20% Level IV as 

described in the NAVFAC SW Environmental Work Instruction #1 (SWDIV 2001) by a 

third party for all samples except Investigation-Derived (IDW), air quality monitoring, and 

process sampling. AMEC chemists will evaluate the data against Data Quality Objectives 

(DQOs) specified in this SAP. 

This SAP consists of 37 worksheets organized according to the Uniform Federal Policy for 

Quality Assurance Project Plans (UFP-QAPP) (EPA 2005). The UFP-QAPP is the resulting 

product of the Intergovernmental Data Quality Task Force (IDQTF). It is the companion to 

the Uniform Federal Policy for Implementing Environmental Quality Systems (UFP-QS). 

The UFP-QS was developed to consistently implement the quality system requirements of 

(American National Standards Institute/American Society for Quality) ANSI/ASQ E4-2004 

Quality Systems for Environmental Data and Technology Programs (ANSI 2004). A list of 

the worksheets is provided in the Table of Contents. 




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TABLE OF CONTENTS 

Page 

WORKSHEET #1: TITLE AND APPROVAL PAGE ............................................................. 1 

WORKSHEET #2: SAP IDENTIFYING INFORMATION ................................................ 2-1 

WORKSHEET #3: DISTRIBUTION LIST ........................................................................... 3-1 

WORKSHEET #4: PROJECT PERSONNEL SIGN-OFF SHEET .................................... 4-1 

WORKSHEET #5: PROJECT ORGANIZATIONAL CHART .......................................... 5-1 

WORKSHEET #6: COMMUNICATION PATHWAYS ..................................................... 6-1 

WORKSHEET #7: PERSONNEL RESPONSIBILITIES AND QUALIFICATIONS .... 7-1 

WORKSHEET #8: SPECIAL PERSONNEL TRAINING REQUIREMENTS ............... 8-1 

WORKSHEET #9: PROJECT SCOPING SESSION PARTICIPANTS SHEET ............. 9-1 

WORKSHEET #10: PROBLEM DEFINITION .................................................................... 10-1 

WORKSHEET #11: PROJECT QUALITY OBJECTIVES/SYSTEMATIC PLANNING 

PROCESS STATEMENTS .................................................................. 11-1 

11.1 Introduction and Problem Statements ................................. 11-1 

11.2 DQOs for Removal Action for Hangar 1 ............................ 11-1 

WORKSHEET #12: MEASUREMENT PERFORMANCE CRITERIA TABLES ......... 12-1 

WORKSHEET #13: SECONDARY DATA CRITERIA AND LIMITATIONS .............. 13-1 

WORKSHEET #14: SUMMARY OF PROJECT TASKS ................................................... 14-1 

14.1 Site Preparation, Sampling, and Analysis Tasks .................. 14-1 

14.2 Sampling Procedures ................................................................ 14-3 

14.2.1 Pre-construction/Baseline Soil Sampling 

Procedure ................................................................... 14-3 

14.2.2 Pre-construction/Baseline Sediment Sampling 

Procedure ................................................................... 14-4 

14.2.3 Confirmation Soil Sampling Procedure ..................... 14-4 

14.2.4 Wipe Sampling Procedure.......................................... 14-5 

14.2.5 Import Soil Sampling Procedure ................................ 14-6 

14.3 Analytical Tasks ........................................................................ 14-6 

14.4 Quality Control Tasks .............................................................. 14-6 

14.5 Field Documentation and Data Correcting Tasks ................. 14-7 

14.6 Computerized and Manual Data Management Tasks for 

Analysis, Reporting, Storage and Archiving ......................... 14-7 

14.7 Data Tracking, Storage, Archiving, Retrieval, and 

Security ....................................................................................... 14-8 

14.7.1 Electronic Data: ........................................................ 14-8 

14.7.2 Documentation and Records: .................................. 14-8 

14.7.3 Assessment/Audit Tasks: ......................................... 14-8 

14.7.4 Laboratory Analytical Data Review Tasks: .......... 14-9 

14.7.5 Laboratory Analytical Data: .................................. 14-10 

14.7.6 Independent Data Validation: ............................... 14-13 

14.7.7 Data Usability Assessment: ................................... 14-14 




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TABLE OF CONTENTS (Cont.) 

Page 

WORKSHEET #15: REFERENCE LIMITS AND EVALUATION TABLE ................... 15-1 

WORKSHEET #16: PROJECT SCHEDULE ........................................................................ 16-1 

WORKSHEET #17: SAMPLING DESIGN AND RATIONALE ...................................... 17-1 

WORKSHEET #18: SAMPLING LOCATIONS AND METHODS/SOP 

REQUIREMENTS TABLE ................................................................. 18-1 

WORKSHEET #19: ANALYTICAL SOP REQUIREMENTS TABLE ........................... 19-1 

WORKSHEET #20: FIELD QUALITY CONTROL SAMPLE SUMMARY .................. 20-1 

WORKSHEET #21: PROJECT SAMPLING SOP REFERENCES TABLE .................... 21-1 

WORKSHEET #22: FIELD EQUIPMENT CALIBRATION, MAINTENANCE, 

TESTING, AND INSPECTION TABLE ........................................... 22-1 

WORKSHEET #23: ANALYTICAL SOP REFERENCES TABLE .................................. 23-1 

WORKSHEET #24: ANALYTICAL INSTRUMENT CALIBRATION TABLE ........... 24-1 

WORKSHEET #25: ANALYTICAL INSTRUMENT AND EQUIPMENT 

MAINTENANCE, TESTING, AND INSPECTION TABLE ......... 25-1 

WORKSHEET #26: SAMPLE HANDLING SYSTEM ....................................................... 26-1 

WORKSHEET #27: SAMPLE CUSTODY REQUIREMENTS ......................................... 27-1 

27.1 Sample Name Assignment ....................................................... 27-1 

27.2 Field Sample Collection ........................................................... 27-1 

27.3 Field Sample Container Custody ............................................ 27-1 

27.4 Field Sample Identification Procedures ................................. 27-1 

27.5 Chain-of-Custody Forms ......................................................... 27-2 

27.6 Field Sample Packaging ........................................................... 27-2 

27.7 Laboratory Sample Custody Procedures ................................ 27-2 

27.8 Field Sample Custody, Shipment, and Laboratory 

Receipt ........................................................................................ 27-3 

WORKSHEET #28: LABORATORY QC SAMPLES TABLE.......................................... 28-1 

WORKSHEET #29: PROJECT DOCUMENTS AND RECORDS TABLE ..................... 29-1 

WORKSHEET #30: ANALYTICAL SERVICES TABLE ................................................. 30-1 

WORKSHEET #31: PLANNED PROJECT ASSESSMENTS TABLE ............................ 31-1 

WORKSHEET #32: ASSESSMENT FINDINGS AND CORRECTIVE ACTION 

RESPONSES .......................................................................................... 32-1 

WORKSHEET #33: QUALITY ASSURANCE MANAGEMENT REPORTS ............... 33-1 

WORKSHEET #34: VERIFICATION (STEP 1) PROCESS TABLE ............................... 34-1 

WORKSHEET #35: VALIDATION (STEPS IIA AND IIB) PROCESS TABLE ........... 35-1 

WORKSHEET #36: ANALYTICAL DATA VALIDATION (STEPS IIA AND IIB) 

SUMMARY TABLE............................................................................. 36-1 

WORKSHEET #37: USABILITY ASSESSMENT ......................................................... 37-1 




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Page 

LIST OF TABLES 

Table 3-1. Document Distribution List ..................................................................................... 3-1 

Table 4-1. Project Personnel Sign-off Sheet ............................................................................. 4-1 

Table 6-1. Communication Matrix ............................................................................................ 6-1 

Table 7-1. Key Personnel Project Responsibilities ................................................................... 7-1 

Table 11-1. Data Quality Objectives Summary Pre-Construction and Confirmation 

Sampling ................................................................................................................ 11-1 

Table 11-2. Data Quality Objectives Summary Treated Water Sampling ................................ 11-4 

Table 12-1. Concrete Wipe ....................................................................................................... 12-1 

Table 12-2. Soil ......................................................................................................................... 12-1 

Table 12-3. Sediment ................................................................................................................ 12-2 

Table 15-1. Reference Limits and Evaluation for PCBs in Pre-construction Samples ............. 15-1 

Table 15-2. Reference Limits and Evaluation for PCB in Wipe Samples ................................ 15-2 

Table 15-3. Reference Limits and Evaluation for PCBs in Treated Water Samples ................ 15-3 

Table 15-4. Reference Limits and Evaluation for Metals in Import Soil .................................. 15-4 

Table 15-5. Reference Limits and Evaluation for PAHs in Import Soil ................................... 15-6 

Table 15-6. Reference Limits and Evaluation for Semi-volatile Organics in Import 

Soil ......................................................................................................................... 15-7 

Table 15-7. Reference Limits and Evaluation for TPHs in Import Soil ................................... 15-9 

Table 15-8. Reference Limits and Evaluation for Lead in Wipe Samples ................................ 15-9 

Table 15-9. Reference Limits and Evaluation for pH in Treated Water ................................. 15-10 

Table 15-10. Reference Limits and Evaluation for Asbestos in Soil/Sediment Samples ......... 15-10 

Table 15-11. Reference Limits and Evaluation for Metals in Treated Water Samples ............. 15-10 

Table 19-1. Analytical SOP Requirements ............................................................................... 19-1 

Table 20-1. Field Quality Control Sample Summary ............................................................... 20-1 

Table 21-1. Project Sampling SOP References ......................................................................... 21-1 

Table 22-1. Field Equipment Calibration, Maintenance, Testing, and Inspection .................... 22-1 

Table 23-1. Analytical SOP Reference Table ........................................................................... 23-1 

Table 24-1. Analytical Instrument Calibration ......................................................................... 24-1 

Table 25-1. Analytical Instrument and Equipment Maintenance, Testing, and 

Inspection............................................................................................................... 25-1 

Table 28-1. Laboratory Quality Control Samples – Soil/EPA Method 8082 ........................... 28-1 

Table 28-2. Laboratory Quality Control Samples – Wipe/EPA Method 8082 ......................... 28-2 

Table 28-3. Laboratory Quality Control Samples – Water/EPA Method 6010B ..................... 28-3 

Table 28-4. Laboratory Quality Control Samples – Wipe/Soil/ EPA Method 6010B .............. 28-4 

Table 29-1. Project Documents and Records ............................................................................ 29-1 

Table 30-1. Analytical Services Matrix .................................................................................... 30-1 

Table 31-1. Planned Project Assessments Matrix ..................................................................... 31-1 

Table 32-1. Assessment Findings and Corrective Action Response ......................................... 32-1 




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Page 

LIST OF TABLES (Cont.) 

Table 33-1. Quality Assurance Management Reports .............................................................. 33-1 

Table 34-1. Verification Process ............................................................................................... 34-1 

Table 35-1. Validation Process ................................................................................................. 35-1 

Table 36-1. Analytical Data Validation Summary .................................................................... 36-2 

Table 37-1. Usability Assessment Activities ............................................................................ 37-2 

LIST OF FIGURES 

Figure 11-1. Soil Sample Location Map .................................................................................... 11-5 

Figure 11-2. Wipe Sample Location Map .................................................................................. 11-7 

Figure 17-1. Decision Tree for Soil Samples ............................................................................. 17-4 

Figure 17-2. Decision Tree for Sediment Samples .................................................................... 17-5 

LIST OF APPENDICES 

APPENDIX A 

APPENDIX B 

APPENDIX C 

AMEC STANDARD OPERATING PROCEDURES 

FIELD FORMS 

RESPONSES TO COMMENTS 




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ACRONYMS AND ABBREVIATIONS 

% percent 

µg/ft 2 

micrograms per square foot 

µg/kg 

micrograms per kilogram 

AMEC 

APP 

BC Labs 

BHAP 

BMP 

BRAC 

California EPA 

CARB 

CAS 

CCAL 

CCB 

CCR 

CCV 

CERCLA 

CFR 

CLP 

cm 2 

COD 

CTO 

DCC 

DoD 

DoN 

DQI 

DQO 

DTSC 

EDD 

EE/CA 

ELAP 

EPA 

EWI 

ft 2 

FAA 


Accident Prevention Plan 

BC Laboratories, Inc. 

Biological Hazards Abatement Plan 

Best Management Practice 

Base Realignment and Closure 

California Environmental Protection Agency 

California Air Resource Board 

Chemical Abstract Service 

continuing calibration 

continuing calibration blank 

California Code of Regulations 

continuing calibration verification 

Comprehensive Environmental Response, Compensation, and Liability Act 

Code of Federal Regulations 

Contract Laboratory Program 

square centimeter 

coefficient of determination 

Contract Task Order 

daily calibration check 

Department of Defense 

Department of Navy 

data quality indicator 

data quality objective 

Department of Toxic Substances Control 

electronic data deliverable 

Engineering Evaluation/Cost Analysis 

Environmental Laboratory Accreditation Program 

United States Environmental Protection Agency 

Environmental Work Instruction 

Square feet 

Federal Aviation Administration 




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ACRONYMS AND ABBREVIATIONS (Cont.) 

GC 

GPS 

ICAL 

ICB 

ICP 

ICS 

ICV 

ID 

IDL 

IDW 

IR 

LCS 

LIMS 

mg/kg 

Moffett 

MPC 

MS/MSD 

NA 

NAS 

NASA 

NAVFAC SW 

Navy 

NCR 

NEDD 

NFESC 

NIRIS 

NTCRA 

PAH 

PAL 

PCB 

PERMAC 

POTW 

PQO 

PT 

QA 

QAO 

QC 

gas chromatography 

global positioning system 

initial calibration 

initial calibration blank 

Inductively Coupled Plasma 

interference check solution 

initial calibration verification 

identification 

instrument detection limit 

investigation-derived wastes 

Installation Restoration 

laboratory control sample 

laboratory information management system 

milligrams per kilogram 

Former Naval Air Station Moffett Field 

measurement performance criteria 

matrix spike/matrix spike duplicate 

not applicable 

Naval Air Station 

National Aeronautics and Space Administration 

Naval Facilities Engineering Command Southwest (formerly SWDIV) 

U.S. Department of the Navy 

non-conformance report 

Naval Electronic Data Deliverable 

Naval Facilities Engineering Services Center 

Naval Installation Restoration Information Solution 

Non-Time-Critical Removal Action 

polyaromatic hydrocarbon 

project action limit 

Polychlorinated Biphenyl 

Performance-Based Environmental Multiple Award Contract 

Publicly Owned Treatment Works 

project quality objective 

proficiency testing 

quality assurance 

Quality Assurance Officer 

quality control 




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ACRONYMS AND ABBREVIATIONS (Cont.) 

QCM 

QL 

QSM 

ROICC 

RPD 

RPM 

RSD 

RSL 

RT 

Water Board 

SAP 

SDG 

SHSP 

SOP 

SQL 

SVOC 

SWPPP 

TBD 

TCRA 

TPH 

TSA 

TSCA 

UFP-QAPP 

Work Plan 

yd 3 

Quality Control Manager 

quantitation limit 

Quality System Manual 

Resident Officer in Charge of Construction 

relative percent difference 

Remedial Project Manager 

relative standard deviation 

Regional Screening Levels 

retention time 

San Francisco Bay Regional Water Quality Control Board 

Sampling and Analysis Plan 

sample delivery group 

Site Health and Safety Plan 

standard operating procedure 

structured query language 

semi-volatile organic compound 

Storm Water Pollution Prevention Plan 

to be determined 

Time-Critical Removal Action 

total petroleum hydrocarbon 

technical systems audit 

Toxic Substance Control Act 

Uniform Federal Policies for Quality Assurance Project Plan 

Non-Time-Critical Removal Action Work Plan 

cubic yards 




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WORKSHEET #2: 

SAP IDENTIFYING INFORMATION 

Site Name: Installation Restoration (IR) Site 29, Hangar 1 

Operable Unit: 

Not Applicable (NA) 

Contractor Name: 

AMEC Earth & Environmental, Inc. (AMEC) 

Contract Number: 

N62473-08-D-8816 

Contract Title: 

Performance-Based Environmental Multiple Award 

Contract (PERMAC) 

Work Assignment Number (optional): Contract Task Order (CTO) 0005 

1. This Sampling and Analysis Plan (SAP) was prepared in accordance with the 

requirements of the Uniform Federal Policy for Quality Assurance Project Plans 

(UFP-QAPP) (Intergovernmental Data Quality Task Force [IDQTF] 2005a,b) and 

United States Environmental Protection Agency (EPA) Guidance for Quality 

Assurance Project Plans, EPA Quality Assurance (QA)/G-5, Quality Assurance 

Manual (EPA 2002), and supplemental Naval Facilities Engineering Command 

Southwest (NAVFAC SW) guidance documents. 

2. Identify regulatory program: Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) 

3. This SAP is a project-specific sampling and analysis plan. 

4. List dates of scoping sessions that were held: 

Project kick-off meeting with the Remedial Project Manager (RPM), stakeholders, 

and Resident Officer in Charge of Construction (ROICC) on 27 October, 2009. 

5. List dates and titles of any SAP documents written for previous site work that are 

relevant to the current investigation: 

• Benchmark Environmental Engineering. Polychlorinated Biphenyl, Lead, and 

Asbestos Sampling Report. Hangar 1, Moffett Field, Mountain View, 

California. January 2003. 

• Harding Environmental Science and Engineering. Ambient Air Sampling and 

Analysis Report, Moffett Field, Hangar 1. Moffett Field, California. December 

2002. 

• Professional Analysis, Incorporated. Report of Investigation for Source of 

Aroclor1268 in Soil and Stormwater, National Aeronautics and Space 

Administration (NASA) Ames Research Center. October 2002. 




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6. List organizational partners (stakeholders) and connection with lead organization: 

• San Francisco Bay Regional Water Quality Board (Water Board) 

• EPA Region IX. 

7. The NAFVAC SW is the lead organization. 

8. All required SAP elements and information are included and applicable to this 

project except as noted below: 

Worksheet 13 – Secondary data criteria and limitations is not applicable to this 

project because secondary data was not evaluated for the decision making process. 




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WORKSHEET #3: 

DISTRIBUTION LIST 

This worksheet identifies all personnel/entities who receive copies of the SAP, subsequent 

SAP revisions, addenda, and amendments. All submittals will be electronic except to Base 

Realignment and Closure (BRAC), NAVFAC SW and regulatory agencies. 

Name of SAP 

Recipients 

Narciso Ancog 

Title/Role 

Quality Assurance 

Officer (QAO) 

Table 3-1. Document Distribution List 

Organization 

Telephone 

Number 

(Optional) 

NAVFAC SW 619-532-3046 

Angela Lind RPM BRAC 619-532-0922 

Gary Munekawa ROICC NAVFAC SW 650-603-9834 

David Smith ROICC NAVFAC SW 650-603-9836 

Sarah Kloss EPA RPM EPA Region IX 415-972-3156 

Kathryn Stewart 

Elizabeth Wells 

BRAC 

Environmental 

Coordinator 

Water Board 

Project Manager 

BRAC 415-743-4715 

Water Board 510-622-2440 

E-mail Address or Mailing Address 

narciso.ancog@navy.mil 

1220 Pacific Hwy. 

San Diego, CA 92132 

angela.lind@navy.mil 

1455 Frazee Rd, Ste 900 

San Diego, CA 92108-4310 

gary.munekawa@navy.mil 

ROICC SFBA (Moffett Field Site Office) 

Bldg 107 (Corner of Wescoat Rd & 

McCord Ave) 

Moffett Field, CA 94035-0068 

david.r.smith2@navy.mil 

ROICC SFBA (Moffett Field Site Office) 

Bldg 107 (Corner of Wescoat Rd & 

McCord Ave) 

Moffett Field, CA 94035-0068 

kloss.sarah@epa.gov 

U.S. EPA Region 9 

75 Hawthorne Street 

San Francisco, CA, 94105 

Kathryn.Stewart@navy.mil 

1 Avenue of the Palms, Suite 161 

Treasure Island 

San Francisco, CA 94130-1807 

ewells@waterboards.ca.gov 

1515 Clay St, Suite 1400 

Oakland, CA 94612 

Mike Schulz Project Manager AMEC 505-796-7290 mike.schulz@amec.com 

Ann Bernhardt 

Program 

Quality Control AMEC 503-639-3400 ann.bernhardt@amec.com 

Manager (QCM) 

Mark Maniaci 

Construction 

Manager 

AMEC 618-401-3758 mark.maniaci@amec.com 

Mary Schneider 

Project 

QCM 

AMEC 909-569-7805 mary.schneider@amec.com 

Danille Jorgensen Project Chemist AMEC 503-639-3400 danille.jorgensen@amec.com 

Dan Higgins Data Manager AMEC 503-639-3400 dan.higgins@amec.com 

Jeanne Peterson Project Manager 

Analytical 

Quality 

Associates, Inc. 

702-3683513 jpeterson@aqainc.net 

(AQA) 

Tina Green Project Manager 

BC 

Laboratories, 

Inc. (BC Labs) 

661-327-4911 tina@bclabs.com 




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WORKSHEET #4: 

PROJECT PERSONNEL SIGN-OFF SHEET 

The Final version of this SAP will be delivered to all project personnel involved with implementing any portion of the SAP. 

They will all be given sufficient time to read and ask questions about the content before the field activities commences. 

I have had the opportunity to read and ask questions about this SAP. My signature certifies that I understand the procedures, 

equipment, and restrictions of this plan and agree to abide by them. 

Table 4-1. Project Personnel Sign-off Sheet 

Name 

Organization/Title/Role 

Telephone Number 

Signature/ 

(optional) 

E-mail receipt 

Mike Schulz AMEC/Project Manager 505-796-7290 

Mark Maniaci AMEC/Construction Manager 618-401-3758 

Mary Schneider AMEC/Project QCM 909-569-7805 

Danille Jorgensen AMEC/Project Chemist 503-639-3400 

Dan Higgins AMEC/Data Manager 503-639-3400 

To be determined (TBD) AMEC/Field Staff 

Jeanne Peterson AQA/ Project Manager 702-368-3513 

Tina Green BC Labs/Project Manager 661-327-4911 

Notes: 

TBD - Specific field staff will be designated based on staff experience and availability before field work commences. 

SAP Section 

Reviewed 

Date SAP Read 




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WORKSHEET #5: 

PROJECT ORGANIZATIONAL CHART 



Former Naval Air Station, Moffett Field, Moffett Field, 

California 

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WORKSHEET #6: 

COMMUNICATION PATHWAYS 

This worksheet describes the communication pathways and modes of communication that 

will be used during the project. This worksheet is intended to promote an understanding of 

which project team members including the Department of the Navy (Navy) personnel are 

exchanging key information, and describes the procedures for soliciting and/or obtaining 

approval between project personnel, between different contractors, and between samplers 

and laboratory staff. Also described in this worksheet are the procedures that will be 

followed when any project activity requires real-time modification to achieve project goals, 

or when a SAP amendment is required. Procedures and personnel responsible for stopping 

work are also defined herein. 

Communication 

Drivers 

Point of Contact 

with Regulators 

Navy Quality 

Assurance 

Manage All 

Project Phases 

Manage All Field 

Tasks 

Field Quality 

Assurance 

Daily Field 

Progress Reports 

Responsible 

Affiliation 

Navy RPM 

Navy QAO 

AMEC 

Project 

Manager 

AMEC 

Construction 

Manager 

Navy ROICC 

AMEC 

Construction 

Manager 

Table 6-1. Communication Matrix 

Name 

Angela Lind 

Narciso 

Ancog 

Mike Schulz 

Mark Maniaci 

Gary 

Munekawa 

David Smith 

Mark Maniaci 

Phone Number 

and/or e-mail 

619-532-0922 

angela.lind@navy.mil 

619-532-3046 

narciso.ancog@navy.mil 

505-821-1801 

mike.schulz@amec.com 

618-401-3758 (mobile) 

mark.maniaci@amec.com 

650-603-9834 

gary.munekawa@navy.mil 

650-603-9836 

david.r.smith2@navy.mil 

618-401-3758 (mobile) 


Procedure 

(timing, pathway to 

& from, etc.) 

All project documentation will be 

forwarded by the Navy RPM to 

the regulators. 

RPM will notify BRAC Cleanup 

Team members including the 

EPA within 7 days of significant 

changes to the SAP. 

The QAO will coordinate with the 

Navy RPM and AMEC Program 

QCM. 

The AMEC Project Manager will 

direct and approve of all 

communication to the Navy 

RPM. The AMEC Project 

Manager will notify the Navy 

RPM of field changes or 

modifications by email within 24 

hours of first occurrence. 

Acts as alternate point of contact 

at AMEC in the absence of the 

Project Manager. Responsible 

for direct oversight of field 

sampling activities and 

enforcement of SAP Accident 

Prevention Plan (APP) and Site 

Health and Safety Plan (SHSP). 

Perform QA that all field work is 

completed in accordance with 

contract and project 

requirements. 

The AMEC Construction 

Manager will send field progress 

reports to the AMEC Project 

Manager daily via email. 





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Table 6-1. Communication Matrix 

Communication 

Drivers 

SAP Review 

SAP Changes in 

the Field 

Field and 

Analytical 

Corrective 

Actions 

Release of 

Analytical Data 

Reporting Lab 

Data Quality 

Issues 

Responsible 

Affiliation 

AMEC 

Program QCM 

AMEC 

Construction 

Manager 

AMEC Project 

QCM 

AMEC Data 

Manager 

Laboratory 

Project 

Manager 

Name 

Ann Bernhardt 

Mark Maniaci 

Mary 

Schneider 

Dan Higgins 

Tina Green 

Phone Number 

and/or e-mail 

503-639-3400 

ann.bernhardt@amec.com 

618-401-3758 (mobile) 


909-569-7805 

mary.schneider@amec.com 

503-639-3400 

dan.higgins@amec.com 

661-327-4911 

tina@bclabs.com 

Procedure 

(timing, pathway to 

& from, etc.) 

The Program QCM assures the 

SAP is compliant with Navy 

requirements and applicable 

regulatory requirements. 

The AMEC Construction 

Manager or designee will notify 

the AMEC Project Manager, the 

Project QCM, and the Program 

QCM of proposed changes to the 

SAP and justifications by phone 

within 24 hours of first 

occurrence. The Navy QAO will 

be contacted for approval of any 

revisions or amendments of this 

SAP. SAP changes requiring 

Navy QAO approval include 

changes in: analytical methods, 

sampling methods, contaminants 

of concern, sampling locations, 

investigation scope changes, 

organizational changes, or any 

change in site characterization 

that alters the DQOs (see 

Environmental Work Instruction 

[EWI] #2). 

The need for corrective action for 

field and analytical issues will be 

determined by the AMEC Project 

QCM. 

No analytical data can be 

released until validation is 

completed and AMEC’s Data 

Manager has approved the 

release. 

All QA/QC issues with project 

field samples will be reported by 

the subcontract laboratory 

Project Manager to the AMEC 

Project Chemist or Project QCM 

within two business days. 





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WORKSHEET #7: 

PERSONNEL RESPONSIBILITIES AND 

QUALIFICATIONS 

This worksheet identifies key project personnel associated with each organization, 

contractor, and subcontractor participating in responsible roles. Specific personnel roles 

and responsibilities are described in this worksheet. 

Name 

Table 7-1. Key Personnel Project Responsibilities 

Title/Role 

Organizational 

Affiliation 

Angela Lind Navy RPM Navy, BRAC 

Narciso Ancog 

Gary Munekawa 

David Smith 

Sarah Kloss 


Mike Schulz 

Ann Bernhardt 

Navy QAO 

Navy ROICC 

Navy ROICC 

EPA RPM 

Water Board 

Project 

Manager 

Project 

Manager 

Program 

QCM 

Navy, 

NAVFAC SW 

Navy, NAVFAC 

SW 

Navy, NAVFAC 

SW 

EPA, 

Region IX 

San Francisco 

Water Board 

AMEC 

AMEC 

Mary Schneider Project QCM AMEC 

Mark Maniaci 

Chris Miele 

Construction 

Manager 

Site Safety & 

Health 

Supervisor 

AMEC 

AMEC 

Responsibilities 

RPM is the Navy manager directly responsible for 

project execution and coordination with base 

representatives, regulatory agencies and the 

NAVFAC SW management team. 

Provides government oversight of the QA program, 

including review and sign-off on SAPs. The QAO has 

the authority to suspend affected projects activities if 

NAVFAC SW-approved quality requirements are not 

maintained. 

Provides site access and enforcement of SAP, APP 

and SHSP. 

Provides site access and enforcement of SAP, APP 

and SHSP. 

Manages the oversight of the project for EPA, 

Region IX. 

Manages the oversight of the project for the San 

Francisco Water Board. 

Supervises and coordinates all work performed on 

the project. These responsibilities include project 

planning and execution, scheduling, staffing, data 

evaluation, report preparation, subcontracts, and 

managing deliverables. 

Assures the SAP is compliant with Navy and 

applicable regulatory requirements. 

Oversees and directs QA reviews for this project, 

including periodic reports, analytical program 

requirements, and schedules before submittal to the 

Navy for review and comment. 

Manages all field tasks. 

Responsible for development and implementation of 

the APP and SHSP. 





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Name 

Dan Higgins 

Danille 

Jorgensen 

Table 7-1. Key Personnel Project Responsibilities 

Title/Role 

Data 

Manager 

Project 

Chemist 


Affiliation 

AMEC 

AMEC 

Responsibilities 

Responsible for inputting all the field data and the 

maintenance of the database. Submitting Naval 

Electronic Data Deliverable (NEDD) to the Navy in 

accordance with the requirements set forth in 

Environmental Work Instruction (EWI) EVR.6, 

Environmental Data Management and Required 

Electronic Delivery Standards (Naval Facilities 

Engineering Command-Southwest, 2005.) 

Oversees and reviews all laboratory procedures and 

actions. Reviews data and coordinates data 

validation. Has oversight responsibility for 

management and integrity of the data. 





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WORKSHEET #8: 

SPECIAL PERSONNEL TRAINING REQUIREMENTS 

Project 

Function 

Wipe Sampling 

Specialized Training 

By Title or Description 

of Course 

Wipe sampling 

procedure 

Training 

Provider 

Project Chemist 

Training 

Date 

Prior to 

sample 

collection 

Personnel/Groups 

Receiving 

Training 

Personnel 

Titles/ 


Affiliation 

Location of Training 

Records / Certificates 

Field sampler AMEC Project field office 




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WORKSHEET #9: 

PROJECT SCOPING SESSION PARTICIPANTS SHEET 

Project Name: Non-Time Critical Removal Action (NCTRA) 

for Polychlorinated Biphenyl (PCB) 

Contamination 

Projected Date(s) of Sampling: April 2010 through April 

2011 

Site Name: IR Site 29 

Site Location: Former Naval Air Station (NAS) 

Moffett Field 

Project Manager: Mike Schulz 

Date of Session: 10/27/2009 

Scoping Session Purpose: Project Kickoff Meeting 

Name Title Affiliation 

Phone 

Number 

E-Mail Address 

Project 

Role 

Angela Lind RPM BRAC 619-532-0922 angela.lind@navy.mil RPM 

Kathy Stewart 

Gary 

Munekawa 

BRAC 

Environmental 

Coordinator 

BRAC 415-743-4715 Kathryn.stewart@navy.mil 

BRAC 

Environmental 

Coordinator 

ROICC NAVFAC SW 650-603-9834 Gary.munekawa@navy.mil ROICC 

David Smith ROICC NAVFAC SW 650-603-9836 David.r.smith2@navy.mil ROICC 

Mike Schulz 

Project 

Manager 

AMEC 505-796-7290 mike.schulz@amec.com 

Ann Bernhardt QCM AMEC 503-639-3400 Ann.bernhardt@amec.com 


Water Board 


Water Board 510-622-2440 ewells@waterboards.ca.gov 

Project 

Manager 

Program 

QCM 

Project 

Manager 

Sarah Kloss RPM EPA 415-972-3156 Kloss.sarah@epa.gov RPM 

Comments/Decisions: Present remedial action approach including sampling strategy 

consistent with technical proposal submitted to the Navy. 

Action Items: Prepare and submit Work Plan, SAP and other appendices. 

Consensus Decisions: Project team to coordinate in advance on approach to minimize 

rounds of edits and comments and expedite plan approval. 





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WORKSHEET #10: PROBLEM DEFINITION 

Hangar 1 is located at Moffett Field, a joint civil-military airport located near the south end 

of San Francisco Bay, in Sunnyvale, California. The facility is located 30 miles southeast 

of San Francisco and 10 northwest of San Jose. Moffett Field, which was formerly a 

United States Naval Air Station, is owned and operated by the NASA Ames Research 

Center. NASA operates several aircraft from Moffett Field. 

IR Site 29 (Hangar 1) is located west of the flight line between Sayre Avenue and 

Cummins Avenue at the Former NAS Moffett Field. Hangar 1 was built in 1932 to house 

U.S.S. Macon and other Navy Lighter-than-Air program airships. The building is 

constructed of a structural steel frame with corrugated siding and measure 1,133 feet long, 

308 feet wide, and 198 feet high. The interior floor of the hangar is of concrete 

construction. Hangar 1 is primarily surrounded by pavement, with several small grassy 

areas adjacent to the building. Water run-off from the building and surrounding areas is 

collected in a storm water conveyance system around the perimeter of the building. The 

corrugated siding panels of the hangar are constructed of a composite material known as 

Robertson Protected Metals, which contains PCBs and asbestos. Lead-paint is also present 

on the hangar. 

Hangar 1 is located within an industrial land use area adjacent to an active air field. Hangar 

1 and the surrounding area is part of an ecological community known as the Upland Areas. 

The Upland Areas include disturbed complexes that are characterized by human activity 

and corresponding physical disturbance resulting in the introduction of exotic plant 

species. Upland Areas surrounding Hangar 1 are paved or minimally landscaped and do 

not provide valuable habitat for wildlife species (Navy, 2001). 

During routine storm water management system cleanout and sampling activities 

conducted in 1997, PCBs were detected in sediment samples collected from a storm water 

settling basin located approximately 2,000 feet northwest of Hangar 1. In 1999, PCBs were 

detected in a storm water sample collected from a manhole “downstream” of Hangar 1. 

Based on the detection of PCBs in rainwater running off the hangar siding and out of the 

hangar downspout, an investigation was undertaken in 2002 to test the building materials 

in Hangar 1 for PCBs and other potential contaminants, specifically lead and asbestos. 

Samples were collected from siding panels, window putty, and roofing material. The 

analytical results of samples collected from siding material indicate that Aroclor-1268 is 

present in paint on the siding panels at concentrations that exceed 6,000 mg/kg. 

Concentrations Aroclor-1268 is present in the interior layers of the siding panels at 

concentrations up to 188,000 milligrams per kilogram (mg/kg) (18.8 percent by weight). 

Aroclor-1260 is present in interior layers of the siding up to a maximum concentration of 

5,500 mg/kg. PCBs were also detected in lead-based paint used to coat the steel support 





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structure. Aroclor-1260 was detected in the structural steel paint coating at concentrations 

up to 120 mg/kg, and Aroclor-1268 was detected at concentrations up to 94 mg/kg. Total 

PCBs were detected in the paint at concentrations ranging from 65 to 214 mg/kg. Paint 

coatings of similar appearance that appear to be present on redwood ceiling and catwalk 

planks were not analyzed but are assumed to contain similar concentrations of PCBs. 

In addition to PCBs, lead was detected in paint that currently covers the hangar siding, 

doors and steel support structure, at maximum detected concentrations of 200,000 mg/kg 

(20%). Asbestos was also detected in building materials, including siding panels, roofing, 

and other surface materials. The PCB-containing building materials are considered the 

most likely source of the PCBs reported in sediment in the storm water collection trench 

around the perimeter of Hangar 1. 

NASA and the Navy completed Time-Critical Removal Actions (TCRAs) at Hangar 1 as 

interim measures to address potential threats to human health and the environment 

associated with elevated concentrations of PCBs in Hangar 1 building materials and the 

adjacent storm water management system. 

In 2008, an Engineering Evaluation/Cost Analysis (EE/CA) was prepared to evaluate PCB 

removal alternatives. Alternative 10, removal siding and coating of exposed surfaces, was 

selected as the preferred approach as documented in the Action Memorandum (Navy 

2008). 

This removal action will be conducted to address human health and environmental 

concerns associated with potential exposure pathways, including the surface water runoff 

pathway to storm water management system, through controlling the migration of PCBs 

from Hangar 1 to the environment. The Removal Action Objective is to control the release 

of contaminants at Hangar 1, thereby reducing the potential risks to human health and the 

environment while minimizing future operation and maintenance activities at the site. 

It should also be noted that this removal action is not addressing 1) potential releases to 

groundwater, because data previously collected indicates there have been no impacts to 

groundwater from PCBs, lead or asbestos; 2) contamination in or below the concrete 

foundation, because the foundation will be left in place and there are no indications that it 

is contaminated; or 3) institutional controls, because they are outside the scope of this 

NTCRA. 

To verify that the removal is executed without the release of PCBs into the environment as 

a result of the removal action, soil samples from areas adjacent to Hangar 1, sediment 

samples from storm drain system, and wipe sample from the concrete floor inside the 

hangar will be collected as pre- and post-removal samples. 





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WORKSHEET #11: PROJECT QUALITY OBJECTIVES/SYSTEMATIC 

PLANNING PROCESS STATEMENTS 

11.1 Introduction and Problem Statements 

The DQO problem statements are presented in Table 11-1. DQOs for the removal action 

for Hangar 1 are presented in Section 11.2. 

11.2 DQOs for Removal Action for Hangar 1 

The DQO process consists of seven steps that are presented in the Tables 11-1 and 11-2. 

Process 

Step 1 

State the 

problem. 

Step 2 

Identify the goals 

of the study 

Table 11-1. Data Quality Objectives Summary 

Pre-Construction and Confirmation Sampling 

Response 

The results of the various sampling and analysis investigations conducted at and 

adjacent to Hangar 1 confirmed that building materials used in the original construction 

were the source of the PCBs that were originally detected in the settling basin in 1997. 

PCBs. Specifically Aroclor-1260 and Aroclor-1268, were found in the building materials, 

with the highest concentrations detected in paint and interior layers of the siding panels. 

PCBs were also detected in window putty, roofing material and roof sealant, paint coating 

of the steel support structure and floor wipe samples. In addition, lead and asbestos 

detected in various building material. 

The PCB-containing building materials are considered the most likely source of the PCBs 

reported in sediment in the storm water collection trench around the perimeter of 

Hangar 1. 

The removal action will be conducted to address human health and environmental 

concerns associated with potential exposure pathways, including the surface water runoff 

pathway to storm water management system, through controlling the migration of PCBs 

from Hangar 1 to the environment. Asbestos and lead data will be collected to support 

the removal action health and safety program, and to verify that lead and asbestos were 

not released as a result of the removal action. 

After the removal action is completed, soil areas adjacent to Hangar 1, storm drain 

system, and interior concrete floor will be tested to verify that PCBs are not present 

above the established cleanup levels and that PCBs, lead and asbestos were not 

released into the environment as a result of the removal action. 

Data collected during the baseline/pre-construction and confirmation sampling events will 

be used for the following: 

1. Does the concentration of PCBs in baseline/pre-construction samples exceed 

regulatory limit listed in Worksheet 15 and require excavation or removal? 

2. Do the concentrations of PCBs,lead and asbestos in post-construction 

confirmation samples indicate that contaminants were released to the 

environment from the removal action of Hangar 1? 

3. Do the concentrations of PCBs and lead in the wipe samples collected from the 

floor of Hangar 1 demonstrate successful decontamination of the floor? 

4. Are concentrations of PCBs, lead and asbestos in storm drain sediment (if 

present after pressure washing) less than concentrations from baseline/pre- 





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Process 

Step 3 

Identify 

information 

inputs 

Step 4 

Define the study 

boundaries 



Response 

construction samples to verify that contaminants were not released to the 

environment? 

5. Are the results of PCBs, metals, semi-volatile organic compounds (SVOCs), 

polyaromatic hydrocarbons (PAHs), total petroleum hydrocarbons (TPHs), 

asbestos and pH in imported soil (clean fill) samples within the regulatory limits 

listed in Worksheet 15? 

Baseline/pre-construction concentrations of PCBs, lead, and asbestos will be established 

from pre-construction samples collected from the soil areas adjacent to Hangar 1 and the 

sediment in the stormwater trench/conveyance system surrounding the building. 

Samples will be collected from the soil after the removal action and analyzed for PCBs, 

lead, and asbestos. If sediment is present in the stormwater trench/conveyance system, 

post-removal samples will be collected and analyzed for PCBs, lead, and asbestos. 

Concrete wipe samples will be collected from the floor of Hangar 1 and analyzed for 

PCBs and lead. Soil to be imported to use as backfill, if excavation is necessary, will be 

sampled and analyzed for TPHs, PAHs, SVOCs, PCBs, asbestos, metals and pH. 

The proposed soil sample locations are presented in Figure 11-1 and the interior 

concrete floor samples are presented in Figure 11-2. Soil samples will be collected from 

the soil areas immediately adjacent to Hangar 1. Concrete wipe samples will be collected 

from the floor of Hangar 1, within its interior boundaries. 

Sediment samples will be collected from the sediment inside the stormwater 

trench/conveyance system. Sample locations will be determined based on where there is 

a sufficient amount of sediment present for sample collection. 

Field activities are anticipated to begin in June 2010 and end in August 2011. Preconstruction 

samples will be collected before removal activities begin. Confirmation 

samples will be collected after removal and decontamination activities have been 

completed. 

1. If the concentrations of PCBs in baseline/pre-construction soil sample exceeds 

the regulatory limit listed in Worksheet 15, then the surrounding contaminated 

soil will be removed half way to the next clean sample location, and confirmation 

samples will be collected from the bottom center and on all four sides of the 

excavation until the result of the confirmation sample indicates that the 

concentration of total PCB in soil is below 1000 µg/kg. The Navy will consult 

with the EPA and Water Board for concurrence on areas requiring soil removal.. 

Step 5 

Develop the 

analytic approach 

If the concentration of PCBs in baseline/pre-construction or confirmation 

samples are below the regulatory limit listed in Worksheet 15, then soil removal 

will not be required. 

2. If the concentrations of lead and asbestos in post-construction confirmation soil 

samples are at or below the levels reported in baseline/pre-construction sample, 

then contaminants were not released to the environment from the removal 

action of Hangar 1 and no soil removal is required. 

If concentrations of lead and asbestos in post-construction confirmation samples 

are greater than baseline samples, results will be provided to EPA and Water 

Board for consultation to determine the appropriate response action. 





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Process 



Response 

3. If the PCBs and lead concentrations in the post-construction confirmation 

concrete wipe samples exceed the regulatory limits listed in Worksheet 15, then 

the concrete floor will be decontaminated and re-sampled. 

If the PCB and lead concentrations in the post-construction confirmation 

concrete wipe samples are within the regulatory limits listed in Worksheet 15, 

then no further action is required. 

4. If the concentrations of PCBs, lead and asbestos in post-construction 

confirmation sediment samples (if sediment is present after pressure washing) 

are above the concentrations found in baseline/pre-construction samples, 

sediment will be removed and the stormwater trench will be rewashed. 

If the concentrations of PCBs, lead and asbestos in post-construction 

confirmation sediment samples (if sediment is present after pressure washing) 

are within the concentrations found in baseline/pre-construction samples, no 

further action is required. 

5. If the results of PCBs, TPHs, SVOCs, PAHs, asbestos, metals and pH in import 

soil samples are within the regulatory limits listed in Worksheet 15, then the soil 

is considered clean and will be imported to the site. 

If the results of PCBs, TPHs, SVOCs, PAHs, asbestos, metals or pH in import 

soil samples are above the regulatory limits listed in WS 15, then another import 

soil source will be identified and soil samples will be collected and analyzed. 

Regulatory limits for PCB, lead, and asbestos concentrations are presented in 

Worksheet 15. 

Step 6 

Specify 

performance or 

acceptance 

criteria 

Step 7 

Develop the plan 

for obtaining the 

data 

Laboratory data will be developed using EPA protocols, and the reported data will be 

evaluated using AMEC QA and quality control (QC) procedures. 

To minimize error samplers will be trained and samples will be collected in accordance 

with procedures described in this SAP. 

The laboratories will be evaluated by the Naval Facilities Engineering Services Center 

(NFESC) or will hold the Department of Defense (DoD) Environmental Laboratory 

Accreditation Program (ELAP) certification, and the California Department of Public 

Health ELAP certification (for methods certified by California). Laboratory standard 

operating procedures (SOPs) will comply with DoD Quality System Manual (QSM) 

version 4.1. 

The sampling design is presented in Worksheet 17. 





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Treated Water Sampling 

Process 

Step 1 

State the 

problem. 

Step 2 

Identify the goals 

of the study 

Step 3 

Identify 

information 

inputs 

Step 4 

Define the study 

boundaries 

Response 

Spent wash water generated from the washing activities will be treated and then 

discharged if treated water meets the Sunnyvale Publicly Owned Treatment Works 

(POTW) discharge requirement. 

Are the treated spent wash water concentrations less than or equal to the Sunnyvale 

POTW limits (see Worksheet 15)? 

Water samples will be collected and analyzed in accordance with the Sunnyvale POTW 

discharge requirements. 

This project is anticipated to begin field work in June 2010 and the estimated date of 

completion is August 2011. 

Step 5 

Develop the 

analytic approach 

If treated spent wash water is above the Sunnyvale POTW limits, then it will be retreated 

until it meets the discharge limits. 

If treated spent wash water is below the Sunnyvale POTW limits, then it will be 

discharged to the Sunnyvale treatment plant. 

Step 6 

Specify 


acceptance 

criteria 

Step 7 

Develop the plan 

for obtaining the 

data 

Sunnyvale POTW limits are presented in Worksheet 15. Limits for additional disposal 

facilities will be included upon procurement. 

Laboratory data will be developed using EPA protocols, and the reported data will be 

evaluated. 

To minimize error, samplers will be trained and samples will be collected in accordance 

with field sampling procedures describes in this SAP. 

The laboratories will be evaluated by the NFESC or will hold the DoD ELAP certification, 

and the California Department of Public Health ELAP certification (for methods certified 

by California). Laboratory SOPs will comply with the DoD QSM version 4.1. 

A waste water sample will be collected per every 120,000 gallons of treated spent wash 

water. 





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WORKSHEET #12: MEASUREMENT PERFORMANCE CRITERIA TABLES 

The following table identifies the data quality indicators (DQIs), measurement 

performance criteria (MPC), and QC sample and/or activity used to assess the 

measurement performance for both the sampling and analytical measurement systems. 

QC Sample 

Analytical 

Groups 

Table 12-1. Concrete Wipe 

Frequency 

Data Quality 

Indicators 

(DQIs) 

Measurement 

Performance Criteria 

QC Sample 

Assesses Error 

for Sampling (S), 

Analytical (A) or 

both (S&A) 

Field Duplicate NA 1 NA NA NA NA 

Equipment Blank NA 2 NA NA NA NA 

Source Blank NA 2 NA NA NA NA 

Field Blank PCBs, Lead 5% Accuracy 

No Analyte > 

Quantitation Limit 

S 

(QL) 

Trip Blank NA 3 NA NA NA NA 

Matrix Spike 

(MS)/Matrix 

Spike Duplicate 

NA NA NA NA NA 

(MSD) 

Notes: 

1 Field duplicates will not be collected for wipe sample because it is impractical to collect a duplicate from a 

wipe location. 

2 Decontamination of equipment will not be necessary. Therefore, equipment blank will be not collected. 

3 Trip blank samples are not applicable for wipe samples since samples will not be analyzed for volatile organic 

compounds. 

QC Sample 

Analytical 

Groups 

Frequency 

Table 12-2. Soil 

Data Quality 

Indicators 

(DQIs) 

Measurement 


QC Sample 




both (S&A) 

Field Duplicate 

PCBs, Lead, 

Asbestos 

10% Precision RPD < 30% S 




MS/MSD PCBs, Lead 5% 

Precision and Criteria Listed in 

Accuracy Worksheet 28 

A 

Notes: 

1 Equipment blanks and source blanks are not applicable because soil samples will be collected using a 

disposable scoop and decontamination of equipment will not be necessary. 

2 Trip blank samples are not applicable since samples will not be analyzed for volatile organic compounds. 





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QC Sample 

Analytical 

Groups 

Table 12-3. Sediment 

Frequency 

Data Quality 

Indicators 

(DQIs) 

Measurement 


QC Sample 




both (S&A) 

Field Duplicate 

PCBs, Lead, 

Asbestos 

10% Precision RPD < 30% S 




MS/MSD PCBs, Lead 5% 

Precision and Criteria Listed in 

Accuracy Worksheet 28 

A 

Notes: 

2 

Equipment rinsates and sources blanks are not applicable because sediment samples will be collected 

using a disposable scoop and decontamination of equipment will not be necessary. 

3 

Trip blank samples are not applicable since samples will not be analyzed for volatile organic compounds. 





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WORKSHEET #13: SECONDARY DATA CRITERIA AND LIMITATIONS 

This worksheet identifies the source of secondary data and information pertinent to this 

investigation. Secondary data is not applicable to this project. 





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WORKSHEET #14: SUMMARY OF PROJECT TASKS 

This worksheet summarizes the major tasks for this project. 

14.1 Site Preparation, Sampling, and Analysis Tasks 

• Coordinate site access through the ROICC and NASA to minimize disruption to 

ongoing activities. 

• Mobilization, Utility Clearance, and Implementation of Stormwater Best 

Management Practices (BMP), and Storm Water Pollution Prevention Plan 

(SWPPP). 

• Biological Survey: Prior to beginning site activities, AMEC will conduct a 

biological survey to check for the presence of bird and mammals residing in 

Hangar 1. AMEC will work with a biologist from NASA to mitigate biological 

hazards in the hangar. 

• Dust/Air Emission Control: A perimeter air monitoring program will be 

implemented so that workers, NASA tenants, and the public are protected against 

dust emissions that could be generated during demolition. Baseline sampling will 

be conducted prior to the start of work and continuous, real-time perimeter dust 

monitoring will be provided during working hours. Air monitoring is discussed in 

detail in the Air Emission Control and Monitoring Plan, which is included in the 

Work Plan. 

• Asbestos Abatement: Asbestos abatement will comply with the California Code of 

Regulations (CCR), Title 8, and section 1529. Asbestos abatement is discussed in 

detail in the Work Plan. 

• Baseline/Pre-Construction Sampling: Samples will be collected from the soil area 

immediately adjacent to Hangar 1 and from the sediment in the stormwater 

trench/conveyance system around the perimeter of Hangar 1. Sampling strategy for 

soil and sediments are discussed in Worksheet 17. 

• Removal of Equipment and Furniture, Capping Utilities, and Demolition of Interior 

Buildings: The utilities in Hagar 1 will be capped in accordance with national and 

local codes, and Navy/NASA requirements prior to interior demolition. Greater 

detail is provided in the Work Plan. 





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• Removal of Lighting, Power, and Communication Systems: All lighting, power, 

distribution, and communication systems will be removed from the interior of the 

hangar with the exception of power to the North Clamshell doors, the Federal 

Aviation Administration (FAA) Obstruction Lights and Airfield Beacon, the sump 

pump, and star, and surrounding buildings that receive their power from Hangar 1 

electric vault. Greater detail is provided in the Work Plan. 

• Pressure Washing and Removal of Siding: Once interior demolition is complete, 

AMEC will pressure wash and coat all accessible steel in the hangar while the 

exterior siding is still in place. AMEC will then remove the siding systematically 

from south to north, dividing the area into zones. Greater detail is provided in the 

Work Plan. 

• Replacement of Structural Steel Members: An AMEC structural engineer licensed 

in California will perform an inspection of the structure after interior demolition is 

complete. At that time, specifications and drawings will be prepared to define the 

location and type of repairs needed. Repairs will be made by a qualified steel 

erector and inspected by an AMEC engineer. 

• Segregation, Classification, and Disposal of Waste: Waste streams generated 

during the demolition activities will be characterized and disposed at the selected 

disposal facility. Spent wash water generated during the wash-down of the hangar 

interior, hangar concrete floor, and stormwater trench/conveyance system will be 

treated onsite and discharged to the Sunnyvale POTW. All waste will be handled 

per the Waste Transportation and Disposal Plan included in the Work Plan. 

• Coating Remaining Structure: The remaining structure will be coated with an 

epoxy coating system. Greater detail is provided in the Work Plan. 

• Implementation of Measures to Abate Bird Strike and Animal Hazards: AMEC will 

implement the recommended abatement measures during construction and will 

make recommendations for changes to Moffett Field’s Biological Hazards 

Abatement Plan (BHAP) plan based upon the final configuration of Hangar 1. 

Greater detail will be provided in the Biological Hazard Abatement Plan. 

• Post-construction confirmation samples will be collected after the removal 

activities are complete: Soil samples will be collected from the same sample 

locations as the baseline/pre-construction samples and analyzed for PCBs, lead, and 

asbestos at areas where PCB contaminated soil (above 1000 µg/kg) removal is not 

required. Results will be compared to the baseline/pre-construction soil samples or 

regulatory limit of 1,000 µg/kg for PCBs to verify that contaminants were not 

released into the environment as a result of the removal action. If the results of 

PCBs exceed the criteria the Navy will verify exact areas for excavation with the 

EPA and Water Board prior to removal of contaminated soil. 





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• Excavation and Disposal of Contaminated Soil: Upon Navy approval, the PCB 

contaminated soil will be removed with a loader and place it in roll-off bins for 

transportation to the selected disposal facility. Confirmation samples will be 

collected after the excavation until the concentrations for total PCB in soil is below 

1000 µg/kg. For areas where concentrations of total PCB in baseline/preconstruction 

samples exceed 1000 µg/kg, post-construction confirmation samples 

for asbestos and lead will be collected after PCB contaminated soil has been 

removed. The excavation will be backfilled with imported clean fill and compacted. 

The clean fill will be analyzed for PCBs, SVOCs, TPHs, PAHs, metals, asbestos, 

and pH. 

• The stormwater trench/conveyance system will be cleaned out and pressure washed 

as part of the scope of work, therefore; it is unlikely that sediment will be present to 

sample for comparison purposes with pre-construction samples. Thirty-seven wipe 

samples will be collected from the concrete floor of Hangar 1 and analyzed for 

PCBs and lead. If the PCB and lead concentrations are within the regulatory limits 

of 10 µg/100 square centimeter (cm 2 ), and 40 micrograms per square foot (µg/ft 2 ), 

respectively, then cleanup will be deemed complete in this area. If either PCB or 

lead concentrations are not within the regulatory limits then additional pressure 

washing will be conducted, followed by additional wipe sampling until complete 

cleanup is demonstrated. 

• Airfield Beacon and Obstruction Lights, Decontamination, Site Cleanup, and 

Demobilization: AMEC will comply with FAA requirements for maintenance and 

final placement of the beacon and obstruction lights on top of the hangar. 

• Waste water generated during the NTCRA will be stored and treated on site prior to 

disposal or re-use. Treated water will be sampled every 120,000 gallons analyzed 

for PCBs, chromium, zinc, lead, asbestos, and pH, as required by the Sunnyvale 

POTW discharge permit. Treated water will be re-used for construction purposes 

when analyses indicate that water does not contain contaminants above federal, 

state and local concentration limits. 

14.2 Sampling Procedures 

14.2.1 Pre-construction/Baseline Soil Sampling Procedure 

The following is the soil sampling procedure for pre-construction samples: 

1. Don a new pair of nitrile gloves. 





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2. Place the auger bit in the selected location and turn the auger until the 0.5 foot (6- 

inch) depth is obtained. Remove auger and collect sample from bit into a clean 8- 

ounce glass sample jar. Close the jar, label and place in cooler. 

2. Replace the auger bit into the original hole and continue augering until the 1 foot 

depth is reached. Remove auger and collect sample as above. Place excess soil back 

to the hole. Label a wooden stake with the sample number to mark the location for 

confirmation sampling. 

3. Complete chain-of-custody record before taking the next sample. 

4. Place sample containers in an insulated cooler with ice. 

5. Samples will be packaged and shipped in accordance with SOP FP-F-7, Sample 

Handling, Storage, and Shipping (Appendix A). 

14.2.2 Pre-construction/Baseline Sediment Sampling Procedure 

Sediment samples will be collected from a shallow trench with disposable scoops. A new 

pair of nitrile gloves will be worn prior to sample collection. Nitrile gloves will be 

disposed of after each sample is collected, and a new pair will be worn before the next 

sample is collected to avoid possible cross-contamination. 

Using a new, individually packaged, disposable plastic scoop or equivalent, place sediment 

into an 8-ounce glass jar. Affix a completed sample label to the sample container. Wrap 

glass jar in bubble-wrap packaging material, place into resealable bags, and place sample 

containers into a cooler containing ice. Record sample number, time and date, and 

requested analysis on chain-of-custody form. Samples will be packaged and shipped in 

accordance with SOP FP-F-7, Sample Handling, Storage, and Shipping procedure 

provided in Appendix A. 

14.2.3 Post-Construction Confirmation Soil Sampling Procedure 

The following is the soil sampling procedure for post-construction confirmation 

samples: 

1. Don a new pair of nitrile gloves. 

2. Place the auger bit in the selected location and turn the auger until 6-inch depth 

below surface is obtained. Remove auger and place soil in a stainless steel mixing 

bowl and homogenized. Then, place mixed soil into a clean 8-ounce glass sample 

jar. Close the jar, label and place in cooler. 

3. Label a wooden stake with the sample number to mark the location for 

confirmation sampling. 





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4. Complete chain-of-custody record before taking the next sample. 

5. Place sample containers in an insulated cooler with ice. 

6. Samples will be packaged and shipped in accordance with SOP FP-F-7, Sample 


14.2.4 Wipe Sampling Procedure 

Wipe samples will be collected from the floor of Hangar 1 following the procedure below: 

• Prepare a 100 cm 2 template by cutting 10 cm x 10 cm square area (for PCBs) or a 1 

ft 2 template by cutting 1 foot x 1 foot square area (for lead) from plastic sheet or 

cardboard. 

• Place the 100 cm 2 template over the area to be sampled for PCBs, and secure it so 

that the template will not move during sampling. 

• Don a new pair of disposable nitrile gloves. 

• Remove pre-moistened gauze soaked with appropriate solvent for PCB from the 

container provided by the laboratory. Avoid excess solvent on the gauze as it may 

cause drips and running on the surface thus diluting the sample. 

• Wipe the surface with firm pressure, using S-strokes (edge to edge direction, 

covering the entire surface. Fold the exposed side of the gauze inward (i.e. fold in 

half), and wipe the same area with S-strokes at right angles to the first wipe. Fold 

the exposed side of the gauze in (twice-folded), and wipe with S-strokes in the 

original direction. Then, fold the exposed side of the gauze in, and place it back in 

the container. 

• Cap the sample container, place in a double plastic bag and attach the label and 

custody seal. Record all pertinent data in the field logbook. 

• Place the 1 ft 2 template near where 100 cm 2 template was placed. 

• Remove pre-weighed ashless quantitative gauze paper soaked with appropriate 

solvent for lead from the container provided by the laboratory. Repeat step 5 and 

step 6. 

• Complete chain-of-custody record before taking the next sample. 

• Place sample containers in an insulated cooler with ice. 

• Samples will be packaged and shipped in accordance with SOP FP-F-7, Sample 

Handling, Storage, and Shipping procedure provided in Appendix A. 





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14.2.5 Import Soil Sampling Procedure 

Soil to be used for import soil will be collected and analyzed for PCBs, metals, asbestos 

and pH prior to transporting to the site. It is anticipated that the material to be used will be 

from land near rock quarry. Based on the Information Advisory Clean Imported Fill 

Material fact sheet developed by the Department of Toxic Substance Control (DTSC) 

(DTSC 2001), five soil samples will be collected using following procedure: 

• The soil area will be divided into the number of sections equivalent to 500 cubic 

yards per sample. 

• The sample locations will be determined by generating random numbers. 

• Sampling personnel will don a new pair of disposable nitrile gloves immediately 

before collecting samples at each location. 

• A hand auger, or similar device, will be used to access each x, y, and z coordinate. 

Due to limitations in accessing deep depths in a large soil area, z-coordinates may be 

limited to 10 feet. 

• Once the sample location has been accessed, grab samples will be collected by 

inverting the hand auger with the material and dislodging the material into an 8- 

ounce glass jar. 

• Place sample containers in an insulated cooler with ice. 

• Samples will be packaged and shipped in accordance with SOP FP-F-7, Sample 


14.3 Analytical Tasks 

Baseline/pre-construction and confirmation soil and sediment samples will be analyzed for 

PCBs, lead and asbestos. If import soil is required, soil samples will be tested for PCBs, 

asbestos, metals and pH. Wipe samples from concrete floor of Hangar 1 will be analyzed 

for PCBs, and lead. Samples will be analyzed for PCBs including Aroclor-1268 by EPA 

method 8082, lead and metals by EPA method 6010B, pH by EPA method 150.1, and 

asbestos by California Air Resource Board (CARB) 435 method. Samples will be sent to 

an off-site laboratory evaluated by NFESC or will hold the DoD ELAP certification, and 

the California Department of Public Health ELAP certification (for methods certified by 

California). 

14.4 Quality Control Tasks 

Soil samples will be collected using procedures presented above. Field QC samples to be 

collected are presented in WS #12. Sample collection activities will be documented in 





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accordance with procedures described in WS #27. In addition, sample handling, packaging 

and shipping procedure is described in SOP FP-F-7, Sample Handling, Storage, and 

Shipping (Appendix A). 

14.5 Field Documentation and Data Correcting Tasks 

Field measurements will be made by qualified field geologists, engineers, environmental 

scientists, and/or technicians. All field data will be recorded in ink on the forms listed 

below. Review of field data and records will be performed by the Project QCM or 

designee. All instrument selections and use, including calibration and standardization, field 

deviations, and sampling limitations, will be recorded on the daily field log. Field records 

will be initialed by the reviewer prior to their incorporation into reports or use in program 

decisions. Any changes or corrections to field form entries will be completed by striking 

out the incorrect entry with a single line and inserting the correct entry next to the stricken 

entry. The corrector’s initials will be placed next to the correction. 

Examples of the field forms listed below are provided in Appendix B: 

• Daily Field Log 

• Daily Report Form 

• Sample Collection Log 

• Chain-of-Custody 

14.6 Computerized and Manual Data Management Tasks for Analysis, 

Reporting, Storage and Archiving 

During sample collection, field-collected data including field observations and field 

screening data measurements will be hand-entered by field staff onto the appropriate field 

data recording forms (See Appendix B). These data will be transcribed by data specialists 

to electronic data deliverables (EDDs) and loaded into an EQuIS 5 database. In addition, 

the data specialists will load: (1) field sample data (sample dates and time, sample depth, 

etc.); (2) requested analytical methods; and (3) electronic laboratory sample receipt data 

and planned test tables within the EQuIS database. Then the sample names and laboratorylogged 

analytical methods will be compared against the records in the sample and planned 

test tables in the database to make sure the laboratory logged in the correct sample names 

and requested analytical methods. 

Following laboratory analysis of the project samples, their analytical results will be 

supplied to AMEC by the laboratory in the standard EQuIS four-file format using Naval 

Installation Restoration Information Solution (NIRIS) valid-values and loaded into the project 

EQuIS database. These records will be flagged as unvalidated pending validation by a third-party 





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firm. These draft records will be compared to the planned test and sample receipt records to insure 

completeness of the data deliverables. Data will be reported with 80 percent (%) Level III and 20% 

Level IV data package. AMEC will supply the data validator with a data validation EDD to 

populate with data qualifiers and reason codes. Following validation, AMEC will load this 

validation EDD into the project database, update the records with any applied qualifiers and reason 

codes, and flag all validated results as validated. 

Once the data validation records are updated in the database, AMEC will perform a 20% check of 

analytical records from the database to hard copy analytical reports, and a 100% check of handentered 

field data, by comparing the field data sheets to field data in the database. If any systemic 

errors are identified in the analytical records, then a full 100% check will be performed on the 

relevant data deliverables. 

Finally, the Data Manager will export validated and quality checked data from the database as 

EDDs conforming to the Naval Electronic Data Deliverable (NEDD) format, checked with the 

NIRIS data checker, and loaded into the NIRIS database. 

14.7 Data Tracking, Storage, Archiving, Retrieval, and Security 

14.7.1 Electronic Data: 

The data tracking process is described above. The electronic data will be stored on a 

structure query language (SQL)-Server database using the Earthsoft EQuIS 5 data 

management system. Daily backups will be performed by the SQL-Server system and 

archived on a separate file server. In addition, AMEC’s information technology staff will 

perform daily backups of both servers to a tape drive. 

Only a limited subset of AMEC database users is allowed access to the physical server. In 

addition, this project’s database will further limit access only to users who work directly on 

the project. Individual user rights will vary depending on their project role. 

14.7.2 Documentation and Records: 

Field logs, field forms, chains-of-custody, correspondence, and project reports will be 

maintained in electronic format at the AMEC San Diego office at completion of the 

project. Hard copies of field forms and chains-of-custody will be retained on-site in the 

project files until demobilization of the project. 

14.7.3 Assessment/Audit Tasks: 

Audits of field staff compliance with project SOPs will be performed on a periodic basis as 

determined by the Project QCM, consistent with AMEC SOP FP-F-5. At least one audit 

will be performed during each sampling task, as defined in this Worksheet. Audits of 





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laboratory compliance will be handled by the Navy or AMEC if requested by the Navy. 

AMEC will use laboratories previously audited by the Navy or through the DoD ELAP. 

14.7.4 Laboratory Analytical Data Review Tasks: 

Prior to submitting analytical data to AMEC, the laboratory must verify compliance with 

the method requirements. The laboratory will follow their QA manual, SOPs, and this SAP 

for all sample analyses. The laboratory will also be responsible for the oversight of the data 

quality for all analyses. Any sample integrity issues, discrepancies with the chain-ofcustody, 

or concerns with the analysis will be addressed and resolved through the 

laboratory QA Manager. 

All analytical data shall be reviewed by the laboratory and shall include a minimum of 

three levels of documented review. An additional level of review shall be performed by the 

laboratory on 5% of data to ensure system compliance. For each level, the review process 

shall be documented, signed, and dated by the reviewer. Each step of this review process 

shall include the evaluation of data quality based on both the results of the QC data and the 

professional judgment of those conducting the review. 

The first level of review, by the analyst, shall include QC review, method compliance, and 

documentation accuracy. For data that are manually processed, all steps in the computation 

shall be provided, including equations used and the source of input parameters such as 

response factors, dilution factors, and calibration constants, and shall be initialed and dated 

by the analyst and attached to the data sheets. For data entered into the computer, the 

analyst shall verify the sample-specific and project-specific information (i.e. project 

numbers, sample numbers, units, and dilution factors). 

The second level of review shall be performed by a supervisor, another analyst, or data 

review specialist. The function of this review is to provide an independent, complete peer 

review of the analytical data. This review shall include the review of QC performance, 

method compliance, documentation, calibrations, and identifications (IDs). 

A third level of review is performed by the laboratory Program Manager, Quality 

Assurance Officer (QAO), or designee. This review shall provide a total overview of the 

data package to ensure its compliance with project requirements. 

Non-conformance reports (NCRs) will be required for any errors noted. In all cases, an 

NCR shall be issued with the name of the individual reporting the issue, a description of 

the noncompliance issue, the corrective action taken, the date the issue was discovered, and 

the affected project samples. All employees are responsible for reporting the 





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nonconformance. The appropriate supervisor is responsible for assuring that the corrective 

actions are taken. 

14.7.5 Laboratory Analytical Data: 

The laboratory will prepare summary data packages and provide them to AMEC. The 

summary data package will consist of a case narrative, copies of all associated 

Contaminant of Concern (COC) forms, sample results, and QA/QC summaries. The case 

narrative will identify the following information: 

• Subcontractor name, project name, contract task order (CTO) number, sample 

delivery group (SDG) number, and a table that cross-reference client and laboratory 

sample ID numbers. 

• Detailed documentation of all sample shipping and receiving, preparation, 

analytical, and quality deficiencies. 

• Thorough explanation of all instances and manual integration. 

• Copies of all associated nonconformance and corrective action forms that will 

describe the nature of the deficiency and the corrective action taken. 

• Copies of all associated sample receipt notices. 

When a full data package is required, the laboratory will prepare data package that will 

contain all of the information from the summary data package and all associated raw data. 

The laboratory will provide two copies of the summary package within 15 days after they 

receive the last sample in the SDG. 

Summary Data package requirements (Level III packages) are as follows: 

Organic Analysis 

• Cover page (with laboratory name, address, phone number, contact person, and 

SDG number) 

• Case narrative 

• Copies of nonconformance and corrective action forms 

• COC forms 

• Copies of sample receipts notices 

• Analytical results including dilutions, re-analysis and confirmation of positive 

results for PCBs 

• System monitoring compound and surrogate recoveries 





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• Matrix spike (MS) and matrix spike duplicate (MSD) recoveries and relative 

percent differences (RPDs) 

• Blank spike or laboratory control sample (LCS) recoveries 

• Method Blanks 

• Performance check 

• Initial calibration (ICAL) with retention time information (When manual 

integration is performed, raw data records shall include a complete audit trail for 

those manipulations, raw data output showing the results of the manual integration, 

and notation of rationale, date and initials of person performing manual integration) 

• Continuing calibration (CCAL) with retention time information 

• Internal standard areas and retention times 

• Analytical sequence 

Inorganic Analysis 


SDG number) 





• Analytical results, including dilutions and re-analysis 

• Initial and continuing calibration verification (CCV) 

• Detection limit standard 

• Method blanks, CCAL blanks, and preparation blanks 

• Inductively coupled plasma (ICP) interference-check samples 

• MS and post-digestion spikes 

• Sample duplicates 

• LCSs 

• Method of standard additions 

• ICP serial dilution 

• Instrument detection limit 





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• ICP interelement correction factors 

• ICP linear working range 

Full data package requirements (Level IV) are as follows: 

Organic Analysis 


SDG number) 





• Analytical results (including dilutions, re-analysis and confirmation of positive 

results for PCBs) plus raw data 

• System monitoring compound and surrogate recoveries 

• MS and MSD recoveries and RPDs form plus raw data 

• Blank spike or LCS recoveries form plus raw data 

• Method Blanks form plus raw data 

• Performance check 

• ICAL with retention time form plus raw data (When manual integration is 

performed, raw data records shall include a complete audit trail for those 

manipulations, raw data output showing the results of the manual integration, and 

notation of rationale, date and initials of person performing manual integration) 

• CCAL with retention time form plus raw data 

• Internal standard areas and retention times plus raw data 

• Analytical sequence 

• Instrument analysis log 

Inorganic Analysis 


SDG number) 






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• Analytical results, including dilutions and re-analysis 

• Initial and CCV 

• Detection limit standard 

• Method blanks, CCAL blanks, and preparation blanks 

• ICP interference-check samples 

• MS and post-digestion spikes 

• Sample duplicates 

• LCSs 

• Method of standard additions 

• ICP serial dilution 

• Instrument detection limit 

• ICP interelement correction factors 

• ICP linear working range 

• % moisture for soil samples 

• Sample digestion, distillation, and preparation logs, as necessary 

• Instrument analysis log for each instrument used 

• Standard preparation logs, including initial and final concentrations for each 

standard used. 

• Formula and a sample calculation for the ICAL 

• Formula and a sample calculation for soil sample results 

14.7.6 Independent Data Validation: 

All analytical data will be independently validated by a subcontract validation. For 

investigation on IR projects for National Priorities List (NPL) sites, data will be randomly 

selected and validated at 80 percent level III and 20 percent level IV as described in 

NAVFAC SW Environmental Work Instruction #1 (SWDIV 2001). In this process, 





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laboratory data are subjected to a comprehensive technically oriented evaluation by 

personnel experienced in the analysis and review of data from environmental matrices. 

For a Level III data validation effort, the data values for routine and QC samples are 

generally assumed to be correctly reported by the laboratory. Data quality is assessed by 

comparing QC parameters to the appropriate limits. In addition to performing data quality 

assessment for Level III, calculations of analytical values for routine and QC data are 

verified for Level IV data validation. 

14.7.7 Data Usability Assessment: 

Data will be evaluated by the AMEC Project Chemist for its use based on review of the 

data validation report, qualifications to the data, performance criteria, and any deviations 

from planned activities. 





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WORKSHEET #15: REFERENCE LIMITS AND EVALUATION TABLE 

This worksheet identifies the project-required action limits and quantitation goals. Project 

Action Limits (PALs) are defined below in Tables 15-1 through 15-4. 

Table 15-1. Reference Limits and Evaluation for PCBs in Pre-construction 

Samples 

Matrix: Soil 

Analytical Group: PAHs 

Analyte 

Chemical 

Abstract 

Service 

(CAS) 

Number 

Project 

Action Limit 

(µg/kg) 

Project Action 

Limit 

Reference 

Project 

Quantitation 

Limit Goal 1 

(µg/kg) 

Laboratory-specific 

(ug/kg) 

QLs 1 

(µg/kg) 

Method 

Detection 

Limit 1 

(MDLs) 

(µg/kg) 

Aroclor 1016 12674-11-2 NE 40 CFR 761.61 2 50 10 2.7 

Aroclor 1221 11104-28-2 NE 40 CFR 761.61 2 50 10 5 

Aroclor 1232 11141-16-5 NE 40 CFR 761.61 2 50 10 1.2 

Aroclor 1242 53469-21-9 NE 40 CFR 761.61 2 50 10 1.6 

Aroclor 1248 12672-29-6 NE 40 CFR 761.61 2 50 10 1.2 

Aroclor 1254 11097-69-1 NE 40 CFR 761.61 2 50 10 0.78 

Aroclor 1260 11096-82-5 NE 40 CFR 761.61 2 50 10 2.2 

Aroclor 1268 11100-14-4 NE 40 CFR 761.61 2 50 10 5 

Total Aroclor -65 3 1,000 4 40 CFR 761.61 2 350 10 5 

Notes: 

1 Limits based on dry weight. 

2 

CFR 761.61 – self-implementing cleanup of PCB contaminated waste for high-occupancy area. 

3 

Total PCB is not registered in the CAS system. Therefore, the Department of Navy assigned a number with the “-” 

prefix to be used for the NEDD. 

4 Total Arocolor will be determined by adding individual Aroclor concentrations. The laboratory will report detected 

concentration between MDL and QL as estimated. If an Aroclor is not detected, the MDL value will be used to 

determine total Arocolor concentration. 





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Table 15-2. Reference Limits and Evaluation for PCB in Wipe Samples 

Matrix: Wipe 

Analytical Group: PCBs 

Analyte 

CAS 

Number 


Limit 

(µg/100cm 2 ) 


Limit 

Reference 

Project 

Quantitation 

Limit Goal 

(µg/100cm 2 ) 


(ug/kg) 

QLs 

(µg/100cm 2 ) 

MDLs 

(µg/100cm 2 ) 

Aroclor 1016 12674-11-2 NE 40 CFR 761.30 0.5 0.3 0.09 

Aroclor 1221 11104-28-2 NE 40 CFR 761.30 0.5 0.3 0.17 

Aroclor 1232 11141-16-5 NE 40 CFR 761.30 0.5 0.3 0.04 

Aroclor 1242 53469-21-9 NE 40 CFR 761.30 0.5 0.3 0.053 

Aroclor 1248 12672-29-6 NE 40 CFR 761.30 0.5 0.3 0.04 

Aroclor 1254 11097-69-1 NE 40 CFR 761.30 0.5 0.3 0.026 

Aroclor 1260 11096-82-5 NE 40 CFR 761.30 0.5 0.3 0.073 

Aroclor 1268 11100-14-4 NE 40 CFR 761.30 0.5 0.3 0.17 

Total Aroclor -65 1 10 2 40 CFR 761.30 3.5 0.3 0.17 

Notes: 

1 

Total PCB is not registered in the CAS system. Therefore, the Navy assigned a number with the 

“- prefix to be used for the NEDD. 








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Table 15-3. Reference Limits and Evaluation for PCBs in Treated Water 

Samples 

Matrix: Water 

Analytical Group: PCBs 

Analyte 

CAS 

Number 

Project 

Action Limit 

(mg/L) 


Limit Reference 

Project 

Quantitation 

Limit Goal 

(mg/L) 


(ug/kg) 

QLs 

(mg/L) 

MDLs 

(mg/L) 

Aroclor 1016 12674-11-2 NE Sunnyvale POTW 0.04 

0.0004 0.0001 


0.0004 0.0001 


0.0004 0.0001 


0.0004 0.0001 


0.0004 0.0001 


0.0004 0.0001 


0.0004 0.0001 


0.0004 0.0001 

Total Aroclor -65 1 1.0 2 Sunnyvale POTW 0.3 

0.0004 0.0001 

Notes: 

1 

Total PCB is not registered in the CAS system. Therefore, the Navy assigned a number with the 

“-” prefix to be used for the NEDD. 








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Table 15-4. Reference Limits and Evaluation for Metals in Import Soil 

Matrix: Soil 

Analytical Group: Metals 

Analyte 

CAS 

Number 

Project 

Action 

Limit 

(mg/kg) 

Antimony 7440.36-0 380 



Industrial 

California Human 

Health Screening 

Levels (CHHSLs) 

Project 

Quantitation 

Limit Goal 1 

(mg/kg) 


(ug/kg) 

QLs 1 

(mg/kg) 

MDLs 1 

(mg/kg) 

140 0.5 0.033 

Arsenic 7440-38-2 0.24 2 Industrial CHHSL 0.5 0.5 0.12 

Barium 7440-39-3 190000 

Industrial Regional 

Screening Level 

(RSL) 

64000 0.25 0.095 

Beryllium 7440-41-7 1700 Industrial CHHSL 650 0.25 0.064 

Cadmium 7440-43-9 7.5 Industrial CHHSL 250 0.25 0.033 

Chromium 7440-47-3 1400 Industrial RSL 450 0.75 0.21 

Cobalt 7440-48-4 300 Industrial RSL 100 0.25 0.016 

Copper 7440-50-8 38000 Industrial CHHSL 13500 0.5 0.17 

Lead 7439-92-1 320 Industrial CHHSL 100 0.25 0.038 

Mercury 7439-97-6 180 Industrial CHHSL 1700 0.48 0.014 

Molybdenum 7439-98-7 310 Industrial RSL 100 0.25 0.033 

Nickel 7440-02-0 16000 Industrial CHHSL 6500 0.5 0.037 





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Analyte 

CAS 

Number 

Project 

Action 

Limit 

(mg/kg) 



Project 

Quantitation 

Limit Goal 1 

(mg/kg) 


(ug/kg) 

QLs 1 

(mg/kg) 

MDLs 1 

(mg/kg) 

Selenium 7782-49-2 4800 Industrial CHHSL 1700 0.5 0.065 

Silver 7440-22-4 4800 Industrial CHHSL 1700 0.25 0.032 

Thallium 7440-28-0 63 Industrial CHHSL 35 0.25 0.037 

Vanadium 7440-62-2 6700 Industrial CHHSL 2400 0.75 0.28 

Zinc 7440-66-6 100000 Industrial CHHSL 103000 1.3 0.46 

Notes: 

1 

Limits based on dry weight. 

2 

The laboratory will report detected concentration above the MDL with a qualifier. 





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Table 15-5. Reference Limits and Evaluation for PAHs in Import Soil 

Matrix: Soil 

Analytical Group: PAHs 

Analyte 

CAS 

Number 

Project 

Action Limit 

(ug/kg) 



Project 

Quantitation 

Limit Goal 

(ug/kg) 


(ug/kg) 

QLs 1 MDLs 1 

Acenaphthene 83-32-9 33,000,000 Industrial RSL 10,000,000 200 60 

Anthracene 120-12-7 170,000,000 Industrial RSL 60,000,000 200 60 

Benz(a)anthracene 56-55-3 2,100 Industrial RSL 700 200 60 

Benzo(a)pyrene 50-32-8 130 2 CHHSL 130 200 60 

Benzo(b)fluoranthene 205-99-2 2,100 Industrial RSL 700 200 60 

Benzo(k)fluoranthene 207-08-9 21,000 Industrial RSL 7000 200 60 

Chrysene 218-01-9 210,000 Industrial RSL 70,000 200 60 

Dibenz(a,h)anthracene 53-70-3 210 Industrial RSL 150 200 60 

Fluoranthene 206-44-0 22,000,000 Industrial RSL 7,000,000 200 60 

Fluorene 86-73-7 22,000,000 Industrial RSL 7,000,000 200 60 

Indeno(1,2,3-cd)pyrene 193-39-5 2,100 Industrial RSL 700 200 60 

Naphthalene 91-20-3 18,000 Industrial RSL 6,000 200 60 

Pyrene 129-00-0 17,000,000 Industrial RSL 5,000,000 200 60 

Notes: 


2 The aboratory will report detected concentration above the MDL with a qualifier. 





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Table 15-6. Reference Limits and Evaluation for Semi-volatile Organics in 

Import Soil 

Matrix: Soil 

Analytical Group: SVOCs 

Analyte 

CAS 

Number 


Limit 

(mg/kg) 


Limit 

Reference1 

Project 

Quantitation 

Limit Goal 

(mg/kg) 

Laboratoryspecific 

QLs 1 

(mg/kg) 

MDLs 1 

(mg/kg) 

1,2,4-Trichlorobenzene 120-82-1 99 Industrial PRG 33 0.20 0.060 

1,2-Dichlorobenzene 95-50-1 9,800 Industrial PRG 330 0.20 0.060 

1,4-Dichlorobenzene 106-46-7 12 Industrial PRG 4.0 0.20 0.060 

2,4,5-Trichlorophenol 95-95-4 62,000 Industrial PRG 20,000 0.40 0.10 

2,4,6-Trichlorophenol 88-06-2 160 Industrial PRG 50 0.40 0.020 

2,4-Dichlorophenol 120-83-2 1,800 Industrial PRG 600 0.20 0.060 

2,4-Dimethylphenol 105-67-9 12,000 Industrial PRG 4,000 0.20 0.060 

2,4-Dinitrophenol 51-28-5 1,200 Industrial PRG 400 1.0 0.30 

2,4-Dinitrotoluene 121-14-2 5.5 Industrial PRG 1.8 0.20 0.060 

2,6-Dinitrotoluene 606-20-2 620 Industrial PRG 200 0.20 0.060 

2-Chloronaphthalene 91-58-7 82,000 Industrial PRG 27,000 0.20 0.060 

2-Chlorophenol 95-57-8 5,100 Industrial PRG 1,700 0.20 0.060 

2-Methylphenol 95-48-7 31,000 Industrial PRG 10,000 0.20 0.060 

2-Nitroaniline 88-74-4 6,000 Industrial PRG 2000 0.20 0.060 

3,3’-Dichlorobenzidine 91-94-1 3.8 Industrial PRG 1.0 0.40 0.10 

4,6-Dinitro-2-methylphenol 534-52-1 62 Industrial PRG 20 1.0 0.30 

4-Chloroaniline 106-47-8 8.6 Industrial PRG 3.0 0.40 0.10 

3-&4-Methylphenol 

108-39-4 

/106-44-5 

3,100 Industrial PRG 1,000 0.40 0.10 

4-Nitroaniline 100-01-6 86 Industrial PRG 28 0.40 0.10 

bis(2-Chloroethyl)Ether 111-44-4 1 Industrial PRG 0.5 0.20 0.060 





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Analyte 

CAS 

Number 


Limit 

(mg/kg) 


Limit 

Reference1 

Project 

Quantitation 

Limit Goal 

(mg/kg) 

Laboratoryspecific 

QLs 1 

(mg/kg) 

MDLs 1 

(mg/kg) 

bis(2-Ethylhexyl) phthalate 117-81-7 120 Industrial PRG 40 0.40 0.10 

Butylbenzylphthalate 85-68-7 910 Industrial PRG 300 0.20 0.060 

Diethylphthalate 84-66-2 490,000 Industrial PRG 163,000 0.20 0.060 

Di-n-butylphthalate 84-74-2 62,000 Industrial PRG 20,000 0.20 0.060 

Hexachlorobenzene 118-74-1 1.1 Industrial PRG 1.0 0.20 0.060 

Hexachlorobutadiene 87-68-3 22 Industrial PRG 7 0.20 0.060 

Hexachlorocyclopentadiene 77-47-4 3,700 Industrial PRG 1200 0.20 0.060 

Hexachloroethane 67-72-1 120 Industrial PRG 40 0.20 0.060 

Isophorone 78-59-1 1,800 Industrial PRG 600 0.20 0.060 

Nitrobenzene 98-95-3 24 Industrial PRG 8.0 0.20 0.060 

N-nitrosodi-N-propylamine 621-64-7 0.25 Industrial PRG 0.2 0.20 0.060 

N-nitrosodiphenylamine 86-30-6 350 Industrial PRG 110 0.20 0.060 

Pentachlorophenol 87-86-5 9 Industrial PRG 3 0.40 0.020 

Phenol 108-95-2 180,000 Industrial PRG 60,000 0.20 0.060 

Notes: 

1 

Limits based on dry weight. 





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Table 15-7. Reference Limits and Evaluation for TPHs in Import Soil 

Matrix: Soil 

Analytical Group: TPHs 

Analyte 

CAS 

Number 

Project 

Action 

Limit 

(mg/kg) 



Project 

Quantitation 

Limit Goal 1 

(mg/kg) 


QLs 1 

(mg/kg) 

MDLs 1 

(mg/kg) 

Gasoline -3534 2 180 ESL 3 2 20 5.0 

Diesel 

(C 10 to C 24 ) 

-3527 2 180 ESL 3 15 10 1.2 

Notes: 


2 

TPH is a multi-component chemical substance and not registered in the Chemical Abstract Service system. Therefore, 

the Navy assigned a number with the “-“ prefix to be used for the NEDD. 

3 

Environmental Screening Levels for Shallow Soils where Groundwater is Not a Current or Potential Source of 

Drinking Water (RWQCB 2008) 

Table 15-8. Reference Limits and Evaluation for Lead in Wipe Samples 

Matrix: Wipe 

Analytical Group: Lead 

Analyte 

CAS 

Number 


Limit 

(µg/ft 2 ) 


Limit 

Reference 

Project 

Quantitation Limit 

Goal 

(µg/ft 2 ) 


QLs 

(µg/ft 2 ) 

MDLs 

(µg/ft 2 ) 

Lead 7439-92-1 40 TSCA 403 13 0.75 0.114 





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Table 15-9. Reference Limits and Evaluation for pH in Treated Water 

Matrix: Water 

Analytical Group: pH 

Analyte 

CAS 

Number 


Limit 

(pH units) 


Limit 

Reference 

Project 

Quantitation 

Limit Goal 

(pH units) 


QLs 

(pH units) 

MDLs 

(pH units) 

pH -9 6.0-10.5 

Sunnyvale 

POTW 

2.0-13.0 NA NA 

Table 15-10. Reference Limits and Evaluation for Asbestos in Soil/Sediment 

Samples 

Matrix: Soil/Sediment 

Analytical Group: Asbestos 

Analyte 

CAS 

Number 


Limit 

(percent) 


Limit 

Reference 

Project 

Quantitation 

Limit Goal 

(percent) 


QLs 

(percent) 

MDLs 

(percent) 

Asbestos 1332-21-4 0.25 

Recommended 

by EPA 

NA 0.25 NA 

Table 15-11. Reference Limits and Evaluation for Metals in Treated Water 

Samples 

Matrix: Water 

Analytical Group: Metals 

Analyte 

CAS 

Number 


Limit 

(mg/L) 


Limit 

Reference 

Project 

Quantitation 

Limit Goal 

(mg/L) 


QLs 

(mg/L) 

MDLs 

(mg/L) 

Lead 7439-92-1 0.5 

Chromium 7440-47-3 1.7 

Zinc 7440-66-6 1.48 

Sunnyvale 

POTW 

Sunnyvale 

POTW 

Sunnyvale 

POTW 

0.15 0.001 0.00019 

0.5 0.003 0.00064 

0.5 0.01 0.0032 





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WORKSHEET #16: PROJECT SCHEDULE 

Project schedule for Moffett Hangar 1 demolition activities has been developed and is presented 

as Figure 3. 





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WORKSHEET #17: SAMPLING DESIGN AND RATIONALE 

Samples collected during this project will include baseline soil/sediment samples collected 

prior to construction and confirmation soil, wipe, and sediment samples collected once the 

removal action is completed. Details on the sampling design and rationale are presented 

below. 

Baseline/Pre-Construction Samples: 

Pre-construction samples will be collected from soil areas immediately adjacent to Hangar 

1 and from the sediment in the stormwater trench/conveyance system around the perimeter 

of Hangar 1. The purpose of the pre-construction soil and sediment samples is to establish 

baseline concentrations of PCBs, lead, and asbestos. Baseline/pre-construction 

concentrations will be compared to confirmation soil samples to verify that contaminants 

were not released into the environment as the result of the removal action. 

The scope of the soil sampling effort is restricted to the area of the soil immediately 

adjacent to (east of) Hangar 1. This area is approximately 21,000 ft 2 . The rationale for 

limiting the soil sampling effort to this area is based on the following: 

• This is the only unpaved area within the project site. 

• Hangar 1 is surrounded by a perimeter storm water collection trench which 

prevents surface water from leaving the project site. 

• The nearest unpaved area is 300 feet North of Hangar 1. 

• Hangar 1 is in an industrial land use area and there are no sensitive habitats nearby 

(see Worksheet 10). 

Soil samples will be collected from 51 locations from soil areas on the east side of the 

Hangar. Sample locations are shown in Figure 11-1. At each location, soil samples will be 

collected from 0-6 inches (surface) and 6-12 inches below ground surface (bgs). Surface 

samples will be analyzed for PCBs, lead, and asbestos. If the concentration of PCBs in the 

surface sample is above 1000 ug/kg, then the 6-12 inch sample will be analyzed for PCBs 

to determine the vertical extent of the PCB contamination. Additional samples will be 

collected at 6-inch intervals to determine the depth of PCB contamination. Results of 

baseline/pre-construction samples will be provided to EPA and Water Board for 

consultation and concurrence on areas requiring soil removal if PCB concentrations exceed 

1000 ug/kg. 

Four baseline/pre-construction sediment samples will also be collected from the 

stormwater trench/conveyance system. Locations will be selected based on where there is a 

sufficient amount of sediment present for sample collection. Soil and sediment samples 

will be collected using the procedure described in Worsheet 14. 





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The action level for baseline/pre-construction sampling is PCB concentrations above 1000 

ug/kg, which is selected based on the EPA self-implementing, on-site, cleanup requirement 

for high occupancy areas. Soil that exceeds the PCB action level will be removed and 

disposed off site. For each sample location that exceeds the PCB action level, the 

surrounding soil will be removed half way to the next clean location, in each direction. 

Excavation depth will be determined based on baseline/pre-construction sampling results. 

Laterally, soil will be removed half way to the next clean location. Following soil removal, 

confirmation samples will be collected from the bottom of the excavation, at the center and 

on all four sides of the excavation. If the concentration of PCBs in a confirmation sample 

is above 1000 ug/kg, then an additional 6-inches of soil will be removed from the bottom 

of the excavation. This step will be repeated until the result of the confirmation sample 

indicates that the concentration of PCBs in soil is below 1000 ug/kg. Soil samples will be 

collected using the procedure described in Worksheet 14. 

Post-Construction Confirmation Samples: 

Upon completion of the Hangar 1 removal action, post-construction confirmation samples 

will be collected from the soil areas to demonstrate that the removal action has not released 

contaminants at the site. 

For soil areas that do not require removal of PCB contaminated soil based on 

baseline/preconstruction sample results, post-construction confirmation samples will be 

collected where baseline/preconstruction samples were taken previously, and analyzed for 

PCBs, lead and asbestos. 

For areas where PCB contaminated soil were removed, one sample from the bottom of the 

excavation will be collected and analyzed for lead and asbestos. If results indicate that 

post-construction confirmation results exceed pre-construction (in addition to the PCB 

confirmation samples analyzed during the soil removal) concentrations, the Navy will 

consult with EPA and the Water Board to determine the appropriate response action (see 

Figure 4, Decision Tree for Soil Sample). 

The scope of work for the Hangar 1 removal action includes the removal of sediment from 

the stormwater trench/conveyance system and the subsequent pressure washing of the 

trenches, therefore; it is highly unlikely that sediment will be present for post-construction 

confirmation sampling (See Figure 5, Decision Tree for Sediment Samples). 

Post-construction/confirmation samples will also be collected from the floor of Hangar 1 

once the removal action has been completed. Thirty-seven concrete wipe samples will be 

collected from the floor of Hangar 1. The purpose of the concrete wipe samples is to 

confirm that the PCB and lead concentrations of the floor are within the regulatory limits 

of 10 µg/100cm 2 for PCBs and 40 µg/ft 2 for lead. If the concrete wipe samples exceed the 





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Page 17-2

PCBs and/or lead regulatory limits, the concrete floor will be re-washed and resampled 

(See Figure 6, Decision Tree for Wipe Samples). Concrete wipe samples will be collected 

using the procedure described in Worksheet 14. Figure 11-2 presents the Concrete Wipe 

Sample Locations. 

Treated Water Samples: 

Waste water generated by the Hangar 1 removal action will be treated onsite. Waste water 

will be sampled every 120,000 gallons, which is estimated to take 4 to 6 weeks to generate. 

The sample will be analyzed for PCBs, chromium, zinc, lead, asbestos, and pH, as required 

by the Sunnyvale POTW discharge permit. Once the waste water has been treated to 

Sunnyvale limits, it will be discharged to the POTW. 

Import Soil: 

After contaminated soil has been removed, the excavation will be backfilled with clean soil 

obtained from a suitable source. Prior to being used as backfill, the clean soil will be 

sampled and analyzed for PCBs, metals, total petroleum hydrocarbons, semi-volatile 

organic compounds, and polyaromatic hydrocarbons, asbestos, and pH. One sample will be 

collected from the clean soil per 250 yd 3 , as recommended by the DTSC Information 

Advisory Clean Imported Fill Material. It is anticipated that approximately 400 cubic yards 

(yd 3 ) of clean soil would be used as backfill if the entire volume of soil were removed. 





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Figure 17-1. Decision Tree for Soil Samples 





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Figure 17-2. Decision Tree for Sediment Samples 





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Figure 17-3. Decision Tree for Wipe Samples 





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Page 17-6

WORKSHEET #18: SAMPLING LOCATIONS AND METHODS/SOP 

REQUIREMENTS TABLE 

This worksheet provides a list of all anticipated sample locations and corresponding 

analyses and a reference to the applicable collection SOP(s) provided in Appendix A. 

Sampling 

Location/ID 

Number 1 

PC-SO-001 

through PC-SO- 

101 

Matrix 

Soil 

Sampling 

Interval 

Analytical 

Group(s) 

Pre-Construction Samples 

Pre-Construction 

PCB, Lead, 

Asbestos 

Sampling 

Frequency 

Anticipated 

Number of 

Samples 

1 102 

Sampling 

SOP 

Reference 

Worksheet 

14 

PC-SD-001 

through 004 

CO-SO-200 

through 250 

CO-W-500 

through 540 

Sediment 

Soil 

Surface 

Wipe 

PCB, Lead, 

Pre-Construction 

Asbestos 

Confirmation Soil Samples 

PCB, Lead, 

Confirmation 

Asbestos 

Confirmation Wipe Samples 

1 4 

1 51 

Confirmation PCB, Lead 1 41 

Import Soil Samples 

PCBs, 

A-clean-ddmmyy Soil Import soil 

Metals, 

Asbestos, 

pH 

NA 2 

Treated Water Samples 

PCBs, 

Chromium, One every 

A-TW-ddmmyy Water Treated water Zinc, lead, 120,000 13 

asbestos, gallons 

and pH 

Notes: 

1 Please refer to Worksheet 27 for a detailed description of the project sample naming scheme 

Worksheet 

14 

Worksheet 

14 

Worksheet 

14 

Worksheet 

14 

Worksheet 

14 





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WORKSHEET #19: ANALYTICAL SOP REQUIREMENTS TABLE 

This worksheet presents the analytical and preparation method/SOP and associated 

container specifications, preservation requirements, and maximum holding time for each 

matrix and analytical group. 

Matrix 

Wipe 

Wipe 

Soil 

Soil 

Soil 

Soil 

Analytical 

Group 

PCBs 

Lead 

PCBs 

Lead 

SVOCs 

PAHs 

TPHs 

Table 19-1. Analytical SOP Requirements 

Preparation and 

Analytical Method/ 

SOP Reference 

EPA Method 

3550B/8082 

BCPREP0002/ 

BCORG019 

EPA Method 

3050B/6010B 

BCPREP015/ 

BCMET013 

EPA Method 

3550B/8082 

BCPREP0002/ 

BCORG019 

EPA Method 

3050B/6020,6010B 

BCPREP015/ 

BCMET013 

EPA Method 

3550B/8270C 

BCPREP0002/BCO 

RG020 

EPA Method 

3550B/8015B 

BCPREP0002/BCO 

RG005 

Soil Asbestos CARB 435 /TBD 

Sediment 

Sediment 

PCBs 

Lead 

EPA Method 

3550B/8082 

BCPREP0002/ 

BCORG019 

EPA Method 

3050B/6010B 

BCPREP015/ 

BCMET013 

Sediment Asbestos CARB 435 /TBD 

Water 

PCBs 

EPA Method 

3520C/8082 

BCPREP001/ 

BCORG019 

Containers 

8 oz glass 

jar 

8 oz glass 

jar 

8 oz glass 

jar 

4 oz glass 

gar 

8 oz glass 

jar 

8 oz glass 

jar 

4 oz glass 

gar 

1 L amber 

bottle 

Minimum 

Sample 

Volume 2 

10 X 10 

cm 

Preservation 

Requirements 

Matrix 

Water 

Water 

Analytical 

Group 

Chromium 

,Zinc, 

Lead 

pH 

Preparation and 

Analytical Method/ 

SOP Reference 

EPA Method 

3010A/ 6010B 

BCPREP0006/ 

BCMET013 

EPA Method 150.1 

/BCGEN065 

Containers 

250 ml Poly 

bottle 

250 ml Poly 

bottle 

Minimum 

Sample 

Volume 2 

100 ml 

Preservation 

Requirements 

pH < 2 with 

HNO 3 

WORKSHEET #20: FIELD QUALITY CONTROL SAMPLE SUMMARY 

Field QC samples serve as a check on the precision and accuracy of analytical methods and instrumentation, and potential 

contamination that may occur during laboratory sample preparation and analyses. 

Matrix 

Analytical 

Group 

No. of 

Sampling 

Events 

Table 20-1. Field Quality Control Sample Summary 

No. of Field 

Duplicates 

No. of 

MS/MSDs 

No. of 

Field 

Blanks 

No. of Equip. 

Blanks 

No. of VOA 

Trip Blanks 

No. of PT 

Samples 

Anticipated 

No. of 

Samples to 

Lab 

Soil PCBs 155 1 16 8 0 0 0 0 179 

Soil Lead 104 1 11 6 0 0 0 0 121 

Soil Asbestos 104 1 11 0 0 0 0 0 121 

Soil SVOCs 2 0 1 0 0 0 0 3 

Soil PAHs 2 0 1 0 0 0 0 3 

Soil TPHs 2 0 1 0 0 0 0 3 

Sediment PCBs 8 1 1 0 0 0 0 10 

Sediment Lead 8 1 1 0 0 0 0 10 

Sediment Asbestos 8 1 0 0 0 0 0 10 

Wipe PCBs 41 2 0 0 2 0 0 0 43 

Wipe Lead 41 2 0 0 2 0 0 0 43 

Notes: 

1 

Total number of soil sample will increase if excavation is necessary. 

2 

Additional wipe samples will be collected if decontamination of the Hangar floor is warranted. 




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WORKSHEET #21: PROJECT SAMPLING SOP REFERENCES TABLE 

This worksheet presents a list of relevant SOPs and sampling methodology. Copies of the 

SOPs listed in this worksheet are included in Appendix A of this SAP. 

Reference 

Number 

FP-F-7 

Table 21-1. Project Sampling SOP References 

Title 

Sample Handling, 

Storage, and Shipping 

Originating 

Organization 

of Sampling 

SOP 

Equipment 

Type 

Modified 

for 

Project 

Work? 

(Y/N) 

Comments 

AMEC NA No None 





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WORKSHEET #22: FIELD EQUIPMENT CALIBRATION, MAINTENANCE, 

TESTING, AND INSPECTION TABLE 

Table 22-1. Field Equipment Calibration, Maintenance, Testing, and 

Inspection 


Acceptance Corrective Resp. 

Activity Frequency 

Equipment 

Criteria Action Person 

All field testing equipments to be used on site is for health and safety purposes. 

SOP 

Reference 

Comments 





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WORKSHEET #23: ANALYTICAL SOP REFERENCES TABLE 

This worksheet identifies all analytical procedures that will be implemented during this 

project. This worksheet will be completed upon laboratory procurement. Laboratoryspecific 

SOPs will be listed for all off-site analyses and copies of the SOPs will be 

included in Appendix C of this SAP upon laboratory procurement. The laboratory SOP 

reference numbers will be referenced throughout the SAP to refer to a specific SOP. 

Lab SOP 

Number 

BCORG019 

Title, Revision 

Date, and/or 

Number 

Gas 

Chromatorgraphy 

for PCBs EPA 

8082 Rev.8 

BCMET013 Determination of 

Metals and Trace 

Elements in 

Water and Waste 

Water by ICP- 

AES 200.7/6010 

Rev.15 

1265 CARB 435 and 

EPA Screening 

Protocol Modified 

(Qualitative and 

Semi- 

Quantitative) 

using PLM, Rev. 

0 

BCORG019 Gas 

Chromatorgraphy 

for PCBs EPA 

8082 Rev.8 

Table 23-1. Analytical SOP Reference Table 

Definitive 

or 

Screening 

Data 

Definitive 

Definitive 

Definitive 

Matrix and 

Analytical 

Group 

Soil/Sediment, 

PCBs 


Lead 


Asbestos 

Instrument 

Organization 

Performing 

Analysis 

Modified 

for Project 

Work? 

(Y/N) 

GC BC Labs N 

ICP BC Labs N 

Microscope EM Lab N 

Definitive Wipe, PCBs GC BC Labs N 





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Lab SOP 

Number 

BCMET013 

BCGEN065 

BCORG020 

BCORG005 

Title, Revision 

Date, and/or 

Number 

Determination of 

Metals and Trace 

Elements in 

Water and Waste 

Water by ICP- 

AES 200.7/6010 

Rev.15 

Electrical 

Conductivity, pH, 

Alkalinity Rev. 1 

GC/MS for Semivolatiles, 

Rev. 12 

TPH (Fuels), 

Rev. 10 

Table 23-1. Analytical SOP Reference Table 

Definitive 

or 

Screening 

Data 

Matrix and 

Analytical 

Group 

Instrument 

Organization 


Analysis 

Modified 

for Project 

Work? 

(Y/N) 

Definitive Wipe, Lead ICP BC Labs N 

Definitive Soil pH meter BC Labs N 

Definitive Soil GC/MS BC Labs N 

Definitive Soil GC BC Labs N 





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Instrument 

WORKSHEET #24: ANALYTICAL INSTRUMENT CALIBRATION TABLE 

This worksheet provides a list of analytical instrumentation required to perform the laboratory analyses and the associated 

calibration procedures. In addition, documentation of the frequency, acceptance criteria, and corrective action requirements are 

also provided. All instruments will be calibrated according to the schedule specified by the method and instrument manual or 

applicable SOPs. This worksheet will be completed upon laboratory procurement. 

Calibration 

Procedure 

GC ICAL Initially, prior to sample 

analysis 

GC Second source 

initial calibration 

verification (ICV) 

GC CCV Daily before sample 

analysis, every 10 

samples, and at the end of 

the analysis sequence 

GC/MS 

ICAL 

Table 24-1. Analytical Instrument Calibration 

Frequency of Calibration Acceptance Criteria Corrective Action 

One of the options below: 

Option 1: relative standard 

deviation (RSD) for each 

analyte ≤ 20% 

Option 2: linear least 

squares regression: 

r≥0.995 

Option 3: non-linear 

regression: coefficient of 

determination (COD) r 2 ≥ 

0.99. 

After every ICAL All analytes within ± 20% 

of expected value from the 

ICAL. 

Method inception, CCAL 

fails 

All analytes within ± 20% 

of expected value from the 

ICAL. 

Locate the source of the problem. If 

expected RSD is not met, then check 

for standard degradation or perform 

instrument adjustment and/or 

maintenance to correct the problem and 

repeat ICAL. 

Prepare fresh standard and re-analyze 

ICV to rule out standard degradation or 

inaccurate injection. If problem persists, 

then perform instrument adjustment 

and/or maintenance to correct the 

problem and repeat ICAL. 


CCV to rule out standard degradation 

or inaccurate injection. If problem 

persists, then perform instrument 

adjustment and/or maintenance to 

correct the problem and repeat ICAL. 

Person 

Responsible for 

Corrective Action 

Laboratory Analyst 



SOP 

Reference 

BCORG019 

BCORG005 

BCORG019 

BCORG005 

BCORG019 

BCORG005 

RRF ≥ 0.05, %RSD

Instrument 

Calibration 

Procedure 

GC/MS 

GC/MS DFTPP 

Tune 

Prior to start of analysis 

GC/MS CCAL 

and every 12 hours 

thereafter 

ICP ICAL Daily and prior to sample 

analysis 

ICP ICV After ICAL, prior to 

beginning a sample run 

ICP CCV Daily before sample 

analysis, every 10 

samples, and at the end of 

the analysis sequence 

Polarized Light 

Microscopy 

(PLM) 

Blank 

Table 24-1. Analytical Instrument Calibration 

Frequency of Calibration Acceptance Criteria Corrective Action 

Person 



SOP 

Reference 

Beginning of 12-hour shift Method-specified Repeat until criteria are met Laboratory Analyst BCORG020 

Friable – one blank side 

daily or every 50 samples, 

whichever is less. 

Non-friable – one 

asbestos containing 

material (ACM) or nonfriable 

material every 20 

samples. 

RRF ≥ 0.05, %D±25% 

All analytes within ±10% 

of expected value. r ≥ 

0.995. 

All analytes within + 10% 

of expected value 

RSD of replicate 

integrations: < 5% 

All analytes within + 10% 

of expected value 

RSD of replicate 

integrations < 5% 

Repeat CCAL once; repeat ICAL if 

second CCAL fails 


ICV to rule out standard degradation or 

inaccurate injection. If problem persists, 

then perform instrument adjustment 

and/or maintenance to correct the 


If RSDs 5%, then perform 

instrument maintenance to correct the 


If RSDs 5%, then perform 

instrument maintenance to correct the 

problem. Recalibrate and reanalyze all 

samples since last successful CCV. 





Negative Prepare and analyze another blank. Laboratory Analyst 1265 

BCORG020 

BCMET013 

BCMET013 

BCMET013 




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April 2010 

Page 24-2

WORKSHEET #25: ANALYTICAL INSTRUMENT AND EQUIPMENT MAINTENANCE, TESTING, AND INSPECTION 

TABLE 

This worksheet identifies all analytical instrumentation that requires maintenance, testing, or inspection and provides the laboratory 

SOP reference number for each. In addition, documentation of the frequency, acceptance criteria, and corrective action requirements 

are also provided on this worksheet. This worksheet will be completed upon laboratory procurement. 

Instrument/ 

Equipment 

Table 25-1. Analytical Instrument and Equipment Maintenance, Testing, and Inspection 

Maintenance 

Activity 

Testing 

Activity 

Inspection 

Activity 

GC Parameter Setup Physical check Physical 

check 

GC Retention time 

(RT) window 

width calculated 

for each analyte 

and surrogate 

GC RT window 

position for each 

analyte check 

Instrument 

Performance 

Instrument 


Instrument 

performance 

check 

Instrument 

performance 

check 

Frequency 

Initially; prior 

to daily 

calibration 

check 

At method setup 

and after 

major 

maintenance 

(e.g. column 

change) 

Once per ICAL 

and at the 

beginning of 

the analytical 

shift 

Acceptance Criteria 

Autosampler must 

move to the expected 

position when 

activated. 

Refer to instrument 

optimize temperature 

program setup. 

RT width is ± 3 times 

standard deviation for 

each analyte RT from 

a 72-hour study. 

Position shall be set 

using the midpoint 

standard of the ICAL 

curve when ICAL is 

performed. On days 

when ICAL is not 

performed, the initial 

CCV is used. 

Corrective 

Action 

Reset if 

incorrect 

Locate 

source of 

the problem. 

Repeat if 

incorrect. 

Locate 

source of 

the problem. 

Repeat if 

incorrect. 

Responsible 

Person 

Laboratory 

Analyst 

Laboratory 

Analyst 

Laboratory 

Analyst 

SOP 

Reference 

BCORG019 

BCORG005 

BCORG019 

BCORG005 

BCORG019 

BCORG005 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 25-1

Instrument/ 

Equipment 

Mass 

Spectrometer 

Mass 

Spectrometer 

Mass 

Spectrometer 

Mass 

Spectrometer 

Maintenance 

Activity 

Pump Oil Level 

Detector 

Bakeout 

Clean source, 

replace filament 

Detector Precalibration 

Testing 

Activity 

NA 

Observation of 

deteriorating 

chromatograp 

hy 

Observation of 

deteriorating 

chromatograp 

hy 

Resolution 

adjustment 

Inspection 

Activity 

Visual 

inspection of 

oil gauge 

and color of 

oil 

NA 

Visual 

inspection of 

filaments 

Observation 

of tuning 

spectrum 

ICP Parameter Setup Physical check Physical 

check 

Frequency 

Check 

Monthly; 

Change 

Annually 

As needed 

As needed 

Every 12 

hours 

Initially; prior 

to DCC 


Adequate oil 

level 

No interference/ 

carryover peaks 

No interference; 

adequate 

spectral 

resolution 

Per method 

tuning 

requirements 

Predetermined 

optimum parameter 

settings 

Corrective 

Action 

Add oil 

Clean 

detector 

Clean 

source; 

replace 

filament 

Adjust 

optics 

Reset if 

incorrect 

Responsible 

Person 

Laboratory 

Analyst 

Laboratory 

Analyst 

Laboratory 

Analyst 

Laboratory 

Analyst 

Laboratory 

Analyst 

SOP 

Reference 

BCORG020 

BCORG020 

BCORG020 

BCORG020 

BCMET013 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 25-2

Instrument/ 

Equipment 

ICP 

ICP 

Maintenance 

Activity 

Interference 

check 

solutions/interfer 

ence check 

solution – A 

(ICS/ICS-A) 

ICAL 

blank/CCAL 

blank (ICB/CCB) 

Testing 

Activity 

Instrument 


Instrument 


Inspection 

Activity 

Conformanc 

e to 

interference 

check 

Instrument 

contaminati 

on check 

Frequency 

Prior to 

sample 

analysis 

After every 

calibration 

verification 


Within + 20% of 

expected value 

No analytes detected 

greater than (>) three 

times instrument 

detection limit (IDL) 

Corrective 

Action 

Terminate 

analysis, 

reanalyze 

ICS to rule 

out standard 

degradation 

or 

inaccurate 

injection. If 

problem 

persist, then 

perform 

instrument 

maintenanc 

e, repeat 

calibrations, 

and 

reanalyze all 

associated 

samples. 

Determine 

possible 

source of 

contaminati 

on and 

apply 

appropriate 

measure to 

correct the 

problem. 

Reanalyze 

calibration 

blank and all 

associated 

samples. 

Responsible 

Person 

Laboratory 

Analyst 

Laboratory 

Analyst 

SOP 

Reference 

BCMET013 

BCMET013 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 25-3

Instrument/ 

Equipment 

Maintenance 

Activity 

Testing 

Activity 

Inspection 

Activity 

Frequency 

PLM PLM alignment Prior to each 

use. 

PLM Refractive 

Initially and 

Index liquid 

semiannually, 

calibration 

or next use 

whichever is 

less frequent 


Accuracy of 0.004 

with temperature 

accuracy of 2 o C 

Corrective 

Action 

Repeat 

refractive 

index liquid 

calibration. 

If problem 

persists, 

then 

perform 

maintenanc 

e and repeat 

calibration. 

Responsible 

Person 

Laboratory 

Analyst 1 

Laboratory 

Analyst 1 

SOP 

Reference 

EM Lab 

EM Lab 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 25-4

WORKSHEET #26: SAMPLE HANDLING SYSTEM 

This worksheet identifies components of the project-specific sample handling system. Key 

personnel (and their organizational affiliations) who are primarily responsible for ensuring 

proper handling, custody, and storage of field samples are identified in the table below. 

The table also identifies the number of days that field samples and their extracts/digestates 

will be archived prior to disposal. 

SAMPLE COLLECTION, PACKAGING, AND SHIPMENT 

Sample Collection (Personnel/Organization): AMEC field personnel 

Sample Packaging (Personnel/Organization): AMEC field personnel 

Coordination of Shipment (Personnel/Organization): AMEC field personnel 

Type of Shipment/Carrier: FedEx or equivalent overnight delivery service or contract courier 

SAMPLE RECEIPT AND ANALYSIS 

Sample Receipt (Personnel/Organization): BC Labs Sample Control personnel 

Sample Custody and Storage (Personnel/Organization): BC Labs Sample Control personnel 

Sample Preparation (Personnel/Organization): BC Labs Organic Prep and Inorganic Prep personnel 

Sample Determinative Analysis (Personnel/Organization): BC Labs Organic and Inorganic analyst 

SAMPLE ARCHIVING 

Field Sample Storage (No. of days from report delivery): 60 days 

Sample Extract/Digestate Storage (No. of days from report delivery): 60 days 

Biological Sample Storage (No. of days from sample collection): Not Applicable 

SAMPLE DISPOSAL 

Personnel/Organization: BC Labs Personnel 

Number of Days from Report Delivery: 90 days 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 26-1





DCN: AMEC-8816-0005-0039 

April 2010 

Page 26-2

WORKSHEET #27: SAMPLE CUSTODY REQUIREMENTS 

The integrity of data obtained for samples collected in the field and those created in the lab 

for the bench test depends on adherence to proper procedures for sample management 

involving both proper labeling and handling of samples. 

27.1 Sample Name Assignment 

Sample names will be unique alpha numeric codes assigned by AMEC, with a maximum 

length of 40 characters. The following designations will be used for samples associated 

with this project: 

• Event-matrix-XXXX 

“Event” refers to either the baseline/pre-construction (PC) or post-construction 

confirmation (CO) stage of work; “matrix” refers to the matrix of the sample; and 

“XXXX” refers to three-digit sequential integer number assignment for this project. For integers 

less than ten, the first two characters will be “00”, and for less than one hundred, the first 

character will be”0”. For example, the first soil sample collected from the pre-construction 

event would be assigned the sample name “PC- SO-001.” 

All coded sample names, will be recorded in the field on the “Sample Record Form” 

(Appendix B). 

27.2 Field Sample Collection 

To limit sample contamination during sample collection and handling, field staff will wear 

a clean new pair of disposable nitrile gloves each time a different sample is collected. Field 

staff will not touch the inside of the sample container or lid during sample collection. 

27.3 Field Sample Container Custody 

All sample collection containers will be laboratory-supplied and pre-preserved (if required 

by method). The sample jars will be delivered in sealed containers to the AMEC Project 

Field Office at Moffett Field by laboratory personnel or by a common carrier (e.g. FedEx). 

The laboratory will include a list of the containers shipped and the purpose of each 

container. 

27.4 Field Sample Identification Procedures 

Samples will be identified with water-proof labels pre-printed with analytical methods, 

project name, and project number. Field staff will add the sample name, sample date, and 

sample time to the label in ink at the time the sample is collected. All coded sample names 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 27-1

and field quality control sample associations will be recorded in the field on the “Sample 

Record Form” (see Appendix B). 

27.5 Chain-of-Custody Forms 

Samples will be accompanied by a completed chain-of-custody form (see Appendix B) 

containing the following information: sample name, sample date and time, sample matrix, 

total number of bottles for each sample and requested analyses, special instructions for the 

laboratory, as well as the signature of the person collecting the samples. 

27.6 Field Sample Packaging 

Field samples will be packaged and shipped in accordance with SOP FP-F-7, Sample 

Handling, Storage, and Shipping Procedure provided in Appendix A. 

27.7 Laboratory Sample Custody Procedures 

The chain-of-custody form will be signed on receipt by the laboratory to complete the 

custody chain. The condition of the samples upon receipt by the laboratory will be 

documented on a cooler receipt log or sample condition upon receipt form. This form will 

note sample integrity, preservation, temperature, custody seal condition, and will note any 

discrepancies between information on the sample labels and that on the chain-of-custody 

form. 

Each sample will be logged into the laboratory information management system (LIMS) 

by assigning it a unique sample number. This number and the field sample ID number will 

be recorded on the laboratory report. Samples will be stored and analyzed according to 

specified methods. The original chain-of-custody form will be returned to the AMEC Data 

Manager for permanent storage. 

Once the laboratory has logged in the samples, their progress through preparation and 

analysis will be tracked and monitored through the LIMS. The analysts will be required to 

sign out samples from the sample storage area or refrigerator by entering their initials, date 

and time of sample removal. The samples will be taken to the appropriate analytical 

section for preparation and analysis, where all procedures will be documented in laboratory 

notebooks or forms and on run logs. Dates of preparation and analysis will be entered into 

the LIMS. Sample results will be entered into the LIMS either through direct download 

from the instrument or manually. Unused sample portions and extracts will be returned to 

the sample storage area and signed back in. The sample or extract will remain in storage at 

the laboratory until the disposal time period is reached. Disposal information will be 

entered into the laboratory information system. Sample disposal will not occur until 

AMEC confirms that all data have been fully validated and have provided written approval 

to permit sample disposal. 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 27-2

27.8 Field Sample Custody, Shipment, and Laboratory Receipt 

Samples are considered “in custody” if the following conditions are true: 

• The responsible person (either the person collecting the sample or the person 

designated on the chain-of-custody form as having custody) maintains possession 

of the samples. 

• After the samples are collected by or relinquished to a responsible person they must 

remain in view of, or in the physical possession of, the responsible person. 

• Samples are sealed so that no one can tamper with them. 

• Samples are maintained in an area restricted to authorized personnel. 

Samples will be maintained in the custody of the sampling personnel during daily sample 

activities. As each sample is collected, field personnel will complete a chain-of-custody 

form (see Appendix B for that sample that includes sample name, sample date and time, 

sample matrix, total number of bottles for each sample, and requested analyses, as well as 

the signature of the person collecting the samples. 

Before leaving the field, sampling personnel will verify that the information on the chainof-custody 

form matches the information on each sample’s scheduled analyses, and will 

make sure that each cooler contains the correct bottle count for each sample. On transfer of 

custody to a new responsible person, the sampling personnel will sign and date the 

relinquishment of custody, and the recipient of custody will sign and date 

acknowledgement of receipt. If samples are shipped by a common carrier then the 

receiving agent will not sign the chain-of-custody form, and instead the signed 

relinquishment will be sealed in the cooler. 

On receipt by the laboratory the receiving agent (custodian) will document the condition of 

the cooler, the integrity of the custody seal, the internal temperature of the cooler and the 

condition of the sample containers. After the samples are logged in, the laboratory 

custodian will sign and date the chain-of-custody form. The original form will be retained 

by the laboratory and a copy of the form will be provided to AMEC to be included in the 

project files. In addition, the laboratory will provide AMEC with a copy of the sample 

receiving documentation, including the sample receipt date, the number of samples and 

containers received, a summary of the analyses to be performed, expected results reporting 

date, and a laboratory-issued sample delivery group number. 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 27-3





DCN: AMEC-8816-0005-0039 

April 2010 

Page 27-4

WORKSHEET #28: LABORATORY QC SAMPLES TABLE 

This worksheet identifies all laboratory QC samples anticipated to be completed for this 

investigation. A separate table is provided for each analytical method, matrix, and 

analytical group. Laboratory QC samples are analyzed as part of standard laboratory 

practice. The laboratory monitors the precision and accuracy of the results of its analytical 

procedures through analysis of QC samples. 

At a minimum, one laboratory QC sample is required per 20 samples (including blanks and 

duplicates). If method/SOP QC acceptance limits exceed the measurement performance 

criteria identified in the tables below, the data may be qualified in the data validation 

process and be unusable for making project decisions if rejected. 

Table 28-1. Laboratory Quality Control Samples – Soil/EPA Method 8082 

Matrix Soil 

Analytical 

Group 

PCBs 

Method/SOP EPA Method 

References 3550B/8082 

QC Sample 

Method 

Blank 

LCS 

Surrogate 

MS/MSD 

Frequency/ 

Number 1 

1/batch 

1/batch 

All 

environmental 

and laboratory 

samples 

1/batch 

Method/SOP 

QC 

Acceptance 

Limits 

No detects ≥ ½ 

QL 

PCB-1016: 

25-145% 

PCB-1260: 

30-145% 

Corrective 

Action 

Reanalyze with 

all associated 

samples 



samples 

Person(s) 

Responsible 

for Corrective 

Action 

Analyst 

Analyst 

Data 

Quality 

Indicator 

(DQI) 

Accuracy 

Accuracy 

Measurement 


Criteria 


QL 

PCB-1016: 

25-145% 

PCB-1260: 

30-145% 

Decachlorbiph 

enyl: 30-150% Reanalyze once Analyst Accuracy Decachlorbipheny 

l: 30-150% 

PCB-1016: 

25-145% 

PCB-1260: 

30-145% 

RPD < 30% 

None 

Analyst 

Accuracy, 

Precision 

Notes: 

1 

Batch is equivalent to 20 or fewer samples prepared and analyzed together with common QC samples. 

PCB-1016: 

25-145% 

PCB-1260: 

30-145% 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 28-1

Table 28-2. Laboratory Quality Control Samples – Wipe/EPA Method 8082 

Matrix Wipe 

Analytical 

Group 

PCBs 

Method/SOP EPA Method 

References 3550B/8082 

QC Sample 

Method 

Blank 

LCS 

Surrogate 

Frequency/ 

Number 1 

1/batch 

1/batch 

All 

environmental 


samples 

Method/SOP QC 

Acceptance 

Limits 

No detects ≥ ½ QL 

PCB-1016: 

25-145% 

PCB-1260: 

30-145% 

Decachlorbiphenyl 

30-150% 

Corrective 

Action 



samples 



samples 

Reanalyze 

once 

Person(s) 

Responsible 


Action 

Data 

Quality 

Indicator 

(DQI) 

Measurement 


Criteria 

Analyst Accuracy No detects ≥ ½ QL 

Analyst 

Analyst 

Accuracy 

Accuracy 

PCB-1016: 

25-145% 

PCB-1260: 

30-145% 

Decachlorbiphenyl 

30-150% 

MS/MSD NA 2 NA None Analyst NA NA 

Notes: 

1 


2 

MS/MSD will not be collected for wipe sample because it is not practical to collect the number of samples needed. 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 28-2

Table 28-3. Laboratory Quality Control Samples – Water/EPA Method 6010B 

Matrix Water 

Analytical 

Group 

Metals 

Method/SOP 

EPA 6010B 

Reference 

QC Sample 

Method 

Blank 

Frequency/ 

Number 1 

1/batch 

Method/SOP 

QC Acceptance 

Limits 


QL 

LCS 1/batch 80%-120% 

Postdigestion 

Spike 

Serial 

Dilution 

When dilution 

fails 

1/batch 

75%-125% 

≤10% for 

analytes with 

concentration 

>50x QL 

MS/MSD 1/batch 80%-120% 

Method of 

Standard 

Addition 

When matrix 

interference is 

suspected 

Corrective 

Action 



samples 

Reprep and 

reanalyze the 

LCS and all 

samples 

Analyze 

samples by 

method of 

standard of 

addition 

Perform post 

digestion spike 

If the result is 

indicative of 

matrix 

interference, 

discuss in the 

case narrative. 

Otherwise, 

check for a 

possible source 

of error, and 

extract/reanalyz 

e the sample. 

Person(s) 

Responsible 


Action 

Analyst 

Data Quality 

Indicator 

(DQI) 

Accuracy 

Measurement 


Criteria 


QL 

Analyst Accuracy 80%-120% 


Analyst 

Analyst 

Accuracy 

Interferences - 

Accuracy/Bias 

- Precision 


analytes with 

concentration 

>50x QL 

80%-120% 

NA NA NA Interferences NA 

Notes: 

1 





DCN: AMEC-8816-0005-0039 

April 2010 

Page 28-3

Matrix 

Analytical 

Group 

Method/SOP 

Reference 

QC Sample 

Method Blank 

Table 28-4. Laboratory Quality Control Samples – Wipe/Soil/ EPA Method 

6010B 

Wipe/Soil 

Metals 

EPA 6010B 

Frequency/ 

Number 1 

1/batch 

Method/SOP QC 

Acceptance 

Limits 


QL 

LCS 1/batch 80%-120% 

Post-digestion 

Spike 

Serial Dilution 

MS/MSD 

(soil only) 

Method of 

Standard 

Addition 

When dilution 

fails 

1/batch 

75%-125% 


analytes with 

concentration 

>50x QL 

1/batch 80%-120% 

When matrix 

interference is 

suspected 


Reanalyze with all 

associated samples 

Reprep and 

reanalyze the LCS 

and all samples 

Analyze samples by 

method of standard 

of addition 

Perform post 

digestion spike 

If the result is 

indicative of matrix 

interference, discuss 

in the case narrative. 

Otherwise, check for 

a possible source of 

error, and 

extract/reanalyze the 

sample. 

Person(s) 

Responsible 


Action 

Analyst 

Data Quality 

Indicator 

(DQI) 

Accuracy 

Measurement 


Criteria 


QL 



Analyst 

Analyst 

Accuracy 

Interferences - 

Accuracy/Bias 

- Precision 


analytes with 

concentration 

>50x QL 

80%-120% 

NA NA NA Interferences NA 

Notes: 

1 





DCN: AMEC-8816-0005-0039 

April 2010 

Page 28-4

Table 28-5. Laboratory Quality Control Samples – Soil/ EPA Method 8270B 

Matrix 

Analytical 

Group 

Method/SOP 

Reference 

QC Sample 

Soil 

SVOCs 

EPA 8270C 

Frequency/ 

Number 1 

Method/SOP 

QC 

Acceptance 

Limits 2 

Method Blank 1/batch No detects ≥QL 

LCS 

1/batch 

Laboratory 

Limits 

(Appendix C) 

Lab Duplicate 1/batch ≤20% RPD 

Surrogate 

Internal 

Standard 

All 

environmental 


samples 

All 

environmental 


samples 

Laboratory 

Limits 

(Appendix C) 

50%-100% 



associated samples if 

there are suspect 

instrument performance 

or loading issues. 

If instrument is ok then 

re-prep and reanalyze 

samples. 

See note 3 


associated samples if 

there are suspect 

instrument performance 

or loading issues. 

If instrument is ok the 

re-prep and reanalyze 

samples 

See note 3 

Evaluate in 

consideration of other 

batch QC parameters 

and sample 

homogeneity. Re-prep 

and reanalyze if no 

extenuating 

circumstances are 

found. High RPD for 

non-detects are not 

reanalyzed 

Reanalyze once to 

confirm matrix 

interference 

Reanalyze once to 

confirm matrix 

interference 

Person(s) 

Responsib 

le for 

Corrective 

Action 

Analyst or 

QA 

Manager 

Analyst or 

QA 

Manager 

Analyst or 

QA 

Manager 

Analyst or 

QA 

Manager 

Analyst or 

QA 

Manager 

Data 

Quality 

Indicator 

(DQI) 

Accuracy 

Accuracy 

Precision 

Accuracy 

Measurement 


Criteria 

No detects ≥QL 

Laboratory Limits 

(Appendix C) 

≤20% RPD 

Laboratory Limits 

(Appendix C) 

Accuracy 50%-100% 

Notes: 

1 





DCN: AMEC-8816-0005-0039 

April 2010 

Page 28-5

Table 28-6. Laboratory Quality Control Samples – Soil/ EPA Method 8015B 

QC Sample 

Frequency/ 

Number 1 

Method/SOP 

QC 

Acceptance 

Limits 2 

Method Blank 1/batch No detects ≥QL 

LCS 

Surrogate 

1/batch 

All 

environmental 


samples 

Diesel: 50- 

136% 

Tetracosane: 

34-136% 

MS/MSD 1/batch 40-137% 

Corrective 

Action 


associated 

samples if there 

are suspect 

instrument 


loading issues. 

If instrument is ok 

then re-prep and 

reanalyze 

samples. 


associated 

samples if there 

are suspect 

instrument 


loading issues. 

If instrument is ok 

the re-prep and 

reanalyze 

samples 

Reanalyze once 

to confirm matrix 

interference 

Evaluate in 

consideration of 

LCS results. If 

LCS is acceptable 

then narrate 

indication of 

matrix effects in 

MS/MSD present. 

Person(s) 

Responsible 


Action 

Analyst or QA 

Manager 

Analyst or QA 

Manager 

Analyst or QA 

Manager 

Analyst or QA 

Manager 

Data Quality 

Indicator 

(DQI) 

Accuracy 

Measurement 


Criteria 

No detects ≥QL 

Accuracy Diesel: 50-136% 

Accuracy 

Accuracy, 

Precision 

Notes: 

1 

Batch is equivalent to 20 or fewer samples prepared and analyzed together with common QC samples 

Tetracosane: 34- 

136 

40-137% 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 28-6

WORKSHEET #29: PROJECT DOCUMENTS AND RECORDS TABLE 

This worksheet identifies the documents and records that will be generated for all aspects 

of the project including, but not limited to, sample collection and field measurement, offsite 

analysis, and data assessment. All project data and information will be documented in 

a format that is usable by project personnel. This worksheet also describes how project 

data and information will be documented, tracked, and managed, from generation in the 

field to final use and storage in a manner that ensures data integrity, defensibility and 

retrieval. All project documents and records that will be generated for every aspect of the 

project are identified in the table below. The second column in the table below is used to 

note where the project documents will be maintained to facilitate future retrieval of this 

information. Long-term storage/location is also provided for archiving of data after the 

project is complete. 

Table 29-1. Project Documents and Records 

Document 

Sample Collection and Field Measurement 

Records 

Field logbook 

Chain-of-custody records 

Corrective action reports 

Documentation of corrective action results 

Documentation of deviation from methods 

Documentation of internal QA review 

ID of QC samples 

Meteorological data from field (e.g. wind, 

temperature) 

Sample locations (global positioning system 

[GPS] or survey coordinates) 

Photographs and/or digital videos 

Analytical Records (hard copy) 

Chain-of-custody records 

Sample receipt forms and sample tracking forms 

Preparation and analysis forms and/or logbooks 

Case narrative 

Sample chronology (time of receipt, extraction, 

and analysis) 

Raw data 

ID of QC samples 

Communication logs 


Definitions of laboratory qualifiers 

Documentation of corrective action results 

Documentation of laboratory method deviations 

Instrument calibration reports 

Laboratory name 

Laboratory sample ID numbers 

Reporting forms, completed with actual results 

Signatures for laboratory sign-off (e.g. lab QA 

manager) 

EDD (NEDD format) 

Where Maintained 

All records generated in the field will be stored in a field 

binder and kept in the custody of the field crew. These 

records will be periodically delivered to the AMEC Project 

Manager. Once in the possession of the project manager, 

the records will be stored in the project file in a secured 

file cabinet. After project close-out, the project files will be 

archived at a commercial document storage facility in San 

Diego, CA for the contract required period of time. 

All analytical records generated by the laboratory will be 

delivered to the AMEC Project Chemist within the 

specified turn-around time. Once in the possession of the 

Project Chemist, the analytical records will be stored in 

the project file in a secured file cabinet. Analytical records 

will be submitted to the Navy Administrative Record office 

after the report is prepared. 




DCN: AMEC-8816-0005-0039 

April 2010 

Page 29-1

Table 29-1. Project Documents and Records 

Document 

Project Data Assessment Records 

Field sampling audit checklists 

Data validation reports 

Telephone logs 


Laboratory QA plans 

Laboratory accreditation certificates 

Where Maintained 

All data assessment records will be compiled and stored 

in the project file in a secured file cabinet. After project 

close-out, the project files will be archived at a commercial 

document storage facility in San Diego, CA for the 

contract required period of time. Data Validation reports 

will be transferred to NAVFAC SW Administrative Record 

office. 




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Page 29-2

WORKSHEET #30: ANALYTICAL SERVICES TABLE 

This worksheet identifies all laboratories that will provide analytical services for the 

project grouped by matrix and analytical group. This worksheet will be completed upon 

laboratory procurement. Backup laboratories will also be identified in the event that the 

primary laboratory cannot be used. The desired data package turnaround time will be 

identified in this worksheet. 

Matrix 

Soil 

Soil 

Sediment 

Sediment 

Wipe 

Analytical 

Group 

PCBs, Lead 

Asbestos 

PCBs, Lead, 

Asbestos 

PCBs, Lead 

Table 30-1. Analytical Services Matrix 

Sample 

Locations/ID 

Number 

PC-SO-001 through 

101 

CO-SO-200 

through 250 

PC-SO-001 through 

101 

CO-SO-200 

through 250 

PC-SD-01 through 

PC-SD-04 

PC-SD-01 through 

PC-SD-04 

CO-W-500 through 

540 

Analytical 

Method 

EPA 

8082, 

6020, 

CARB 435 

EPA 

8082, 

6020, 

CARB 435 

EPA 

8082, 

6020 

Data 

Package 

Turnaround 

Time 

15 days 

15 days 

15 days 

15 days 

15 days 

Laboratory/ 

Organization 

(name and 

address, 

contact 

person and 

telephone 

number) 

Tina Green 

BC Labs 

4100 Atlas 

Court 

Bakersfield, 

CA. 93308 

Simone Singh 

EM Lab 

1150 Bayhill 

Drive, Suite 

100 

San Bruno, 

CA 94066 

Tina Green 

BC Labs 

4100 Atlas 

Court 

Bakersfield, 

CA. 93308 

Simone Singh 

EM Lab 

1150 Bayhill 

Drive, Suite 

100 

San Bruno, 

CA 94066 

Tina Green 

BC Labs 

4100 Atlas 

Court 

Bakersfield, 

CA. 93308 

Backup 

Laboratory/ 

Organization 

(name and 

address, 

contact 

person and 

telephone 

number) 

NA 

NA 

NA 

NA 

NA 




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April 2010 

Page 30-1

Matrix 

Water 

Analytical 

Group 

PCBs, 

Chromium, 

Zinc, Lead, 

pH 

Sample 

Locations/ID 

Number 

A-TW-ddmmyy 

Analytical 

Method 

EPA 

8082, 

6020, 

150.1 

Data 

Package 

Turnaround 

Time 

15 days 

Laboratory/ 

Organization 

(name and 

address, 

contact 

person and 

telephone 

number) 

Tina Green 

BC Labs 

4100 Atlas 

Court 

Bakersfield, 

CA. 93308 

Backup 

Laboratory/ 

Organization 

(name and 

address, 

contact 

person and 

telephone 

number) 

NA 




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April 2010 

Page 30-2

WORKSHEET #31: PLANNED PROJECT ASSESSMENTS TABLE 

This worksheet identifies the different types of assessments for evaluating the project activities. The table below identifies the 

type, frequency, and responsible parties of planned assessment activities that will be performed for the project. Laboratory 

assessments are not anticipated for this investigation, because only laboratories that have passed the evaluation of Naval 

Facilities Engineering Services Center (NFESC) or DoD ELAP will be utilized. 

Assessment 

Type 

Project 

Document 

Assessment 

Frequency 

Once for 

each draft 

version of all 

planning 

documents 

Internal or 

External 

Internal 

Table 31-1. Planned Project Assessments Matrix 

Organization 


Assessment 

AMEC 

Person(s) 



Assessment 

(title and 

organizational 

affiliation) 

Ann Bernhardt 

AMEC Program QCM 

Person(s) 


Responding to 

Assessment 

Findings 

(title and 


affiliation) 

Various report 

authors at AMEC 

Person(s) Responsible 

for Identifying and 

Implementing 

Corrective Actions 

(CA) 

(title and 


affiliation) 


AMEC Project QCM 

Person(s) 


Monitoring 

Effectiveness of CA 

(title and 


affiliation) 

Ann Bernhardt 


Field Sampling 

Technical 

Systems Audit 

Once during 

first week of 

field effort 

Internal 

AMEC 

Ann Bernhardt (or 

designee) 


Mark Maniaci 

AMEC Construction 

Manager 








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Page 31-2

WORKSHEET #32: ASSESSMENT FINDINGS AND CORRECTIVE ACTION RESPONSES 

This worksheet describes the activities for identifying and correcting any problems encountered during the project that have the 

potential to impact data quality (e.g. sampling error). 

Assessment 

Type 

Project 

Document 

Assessment 


Sampling 

Technical 

Systems 

Audit (TSA) 

Nature of 

Deficiencies 

Documentation 

Written 

comments (or 

embedded track 

changes) and 

signed peer 

review form 

Memo or email 

Table 32-1. Assessment Findings and Corrective Action Response 

Individual(s) 

Notified of 

Findings (name, 

title, organization) 

Various report 

authors at AMEC 

Mark Maniaci 

AMEC 

Construction 

Manager, 

Ann Bernhardt 

AMEC Program 

QCM, 

Mike Schulz 

AMEC Project 

Manager, 

Angela Lind 

BRAC RPM, 

Narciso Ancog 

Navy QAO, 

Sarah Kloss 

EPA RPM, 


Water Board 


Timeframe of 

Notification 

Written comments 

(or embedded 

track changes) 

within 24 hours of 

document review 

Verbal notification 

within 24 hours 

and written within 

1 week 

Nature of 


Response 

Documentation 

Revised reports 


Report 

Notes: 

1 Corrective action response(s) for any significant event will be forwarded to the EPA by the RPM 

Individual(s) Receiving 


Response 1 (name, title, 

organization) 

Ann Bernhardt 


Mark Maniaci 


Manager, 

Ann Bernhardt 

AMEC Program QCM, 

Mike Schulz 

AMEC Project Manager, 

Angela Lind 

BRAC RPM, 

Narciso Ancog 

Navy QAO, 

Sarah Kloss 

EPA RPM, 


Water Board Project 

Manager 

Timeframe for 

Response 

As soon as possible, 

but not later than 5 

working days 

following receipt of 

comments 

As soon as possible, 

but not later than 3 

working days 

following deficiency 

notification 




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WORKSHEET #33: QUALITY ASSURANCE MANAGEMENT REPORTS 

This worksheet describes the type and frequency of each QA management report that will be 

generated for the project. The personnel responsible for generating the reports and the personnel 

receiving the reports are also identified in this worksheet. 

Type of Report 

Contractor 

Quality Control 

Report 

Contractor 

Production 

Report 

Field Sampling 

TSA 


Report 

Monthly Rework 

Items List 

Table 33-1. Quality Assurance Management Reports 

Frequency 

(daily, weekly 

monthly, quarterly, 

annually, etc.) 

Projected 

Delivery Date(s) 

Person(s) 


Report Preparation 

(title and 


affiliation) 

Daily Daily Mary Schneider 


Daily Daily Mark Maniaci 


Manager 

Once during first 

week of field effort 

Once following any 

non-conformance 

issue identified 

Monthly 

Verbal 

notification within 

24 hours and 

written audit 

report within 1 

week 

Verbal 

notification within 

24 hours and 

written report 

within 1 week 

Last working day 

of each month 

containing an 

open nonconforming 

issue 

Mary Schneider (or 

designee) 






Report Recipient(s) 

(title and organizational 

affiliation) 

ROICC 

Angela Lind 

ROICC 

Angela Lind 

Mark Maniaci 


Manager, 

Ann Bernhardt 


Mike Schulz AMEC 

Project Manager, 

Angela Lind 

BRAC RPM, and 

Narciso Ancog 

Navy QAO - Navy 

Mark Maniaci 


Manager, 

Ann Bernhardt 




Angela Lind 

BRAC RPM, and 

Narciso Ancog 

Navy QAO 

Mark Maniaci 


Manager, 

Ann Bernhardt 




Angela Lind 

BRAC RPM, and 

Narciso Ancog 

Navy QAO 




DCN: AMEC-8816-0005-0039 

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WORKSHEET #34: VERIFICATION (STEP 1) PROCESS TABLE 

This worksheet describes the processes that will be followed to verify project data quality. 

The table below describes how each item will be verified, when the activity will occur, 

what documentation is necessary, and who the responsible person is. 

Verification 

Input 

Chain-of- 

Custody 

Audit 

Reports 

Field Notes 

Analytical 

Data 

Packages 

Table 34-1. Verification Process 

Description 

Chain-of-custody forms will be reviewed by the project team in the 

field upon completion and verified against the packed sample 

coolers they represent. The shipper’s signature on the chain-ofcustody 

will be initialed by the reviewer, a copy of the chain-ofcustody 

retained in the project file, and the original and remaining 

copies taped inside the cooler for shipment. 

A copy of all audit reports will be placed in the project file upon 

completion. If corrective actions are required, a copy of the 

documented corrective action taken will be attached to the 

appropriate audit report in the project file. At the beginning of each 

week and at the completion of the site work, project file audit reports 

will be reviewed internally to ensure that all appropriate corrective 

actions have been taken and that corrective action reports have 

been attached. If corrective actions have not been taken, the project 

manager will be notified to ensure action is taken. 

Field notes will be reviewed internally and placed in the project file. 

A copy of the field notes will be attached to the final report. 

All laboratory data packages will be verified internally by the 

laboratory performing the work for completeness and technical 

accuracy prior to submittal. 

All data packages will be verified externally by data validator who is 

not associated with the collection and analysis of samples, 

interpretation of sample data, or with any decision-making process 

within the scope of this investigation. The EWI #1 3EN2.1-specified 

data validation strategy for this project is 20% Level IV data 

validation and 80% Level III data validation for all laboratory data. In 

Level III data validation, data quality is assessed evaluating 

parameters by the appropriate criteria (or limits) specified in 

Worksheets 12, 19, and 28 of the project SAP, Contract Laboratory 

Program (CLP) requirements, EWI 3EN2.1 requirements, or the 

analytical methods. If calculations for quantitation are verified, it is 

done on a limited basis and may require raw data in addition to the 

standard data forms normally present in a data package. 

Level IV data validation follows the EPA protocols and CLP criteria 

set forth in the functional guidelines for evaluating organic and 

inorganic analyses (EPA 1999, 2004). Level IV data validation 

consists of Level III data validation as well as checking calculations 

of quantified analytical data, including routine field samples and field 

and laboratory QC samples. Additionally, instrument performance, 

calibration, and calibration standard data are evaluated to ensure 

that detection limits and data values are appropriate. 

Internal/External 

Internal 

Internal 

Internal 

Internal and 

External 

Responsible 

for 

Verification 

(name, 

organization) 


Personnel 

Ann 

Bernhardt, 

AMEC 

Program 

QCM 


Personnel 

Internal: 

Tina Green/ 

BC Labs 

External: 

Jeanne 

Peterson/ 

AQA 




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WORKSHEET #35: VALIDATION (STEPS IIA AND IIB) PROCESS TABLE 

This worksheet describes the process for documenting and establishing the validation 

procedures and criteria for the project. Validation procedures and criteria are documented 

in the SAP to ensure that data are evaluated properly, completely, and consistently for use 

in meeting DQOs. 

Table 35-1. Validation Process 

Step 

IIa/IIb 1 Validation Input Description 

IIa 

IIa 

IIa 

IIa 

IIa 

IIa 

IIa 

IIa 

IIa 

IIa 

IIa 

Data Deliverables 

and SAP 

Analytes 

Chain-of-Custody 

Holding Times 

Sample Handling 

Sampling 

Methods and 

Procedures 


Transcription 

Analytical 

Methods and 

Procedures 

Data Qualifiers 

Laboratory 

Transcription 

Standards 

Ensure that all required information on sampling and 

analysis from Step I was provided (including planning 

documents). 

Ensure that required lists of analytes were reported as 

specified in governing documents (i.e. method, 

procedure, or contract). 

Examine the traceability of the data from time of 

sample collection until reporting of data. Examine 

chain-of-custody records against contract, method, or 

procedural requirements. 

Ensure that samples were analyzed within holding 

times specified in method, procedure, or contract 

requirements (Worksheet #19). If holding times were 

not met, confirm that deviations were documented, 

that appropriate notifications were made (consistent 

with procedural requirements), and that approval to 

proceed was received prior to analysis. 

Ensure that required sample handling, receipt, and 

storage procedures were followed, and that any 

deviations were documented. Verify summa canister 

vacuum present after sample collection and prior to 

analysis. 

Establish that required sampling methods were used 

and that any deviations were noted. Ensure that the 

sampling procedures and field measurements met 

performance criteria and that any deviations were 

documented. 

Authenticate transcription accuracy of sampling data 

(i.e. from field notebook to reports). 

Establish that required analytical methods were used 

and that any deviations were noted. Ensure that the 

QC samples met performance criteria and that any 

deviations were documented. 

Determine that the laboratory data qualifiers were 

defined and applied as specified in methods, 

procedures, or contracts. 

Authenticate accuracy of the transcription of analytical 

data (i.e. laboratory notebook to reporting form, or 

instrument to LIMS). 

Determine that standards are traceable and meet 

contract, method, or procedural requirements. 


Validation 

(name, organization) 

Jeanne Peterson/ AQA 






Danille 

Jorgensen/AMEC 








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April 2010 

Page 35-1

Table 35-1. Validation Process 

Step 

IIa/IIb 1 Validation Input Description 

IIa 

IIa 

IIa 

IIb 

IIb 

IIb 

IIb 

IIb 

IIb 

IIb 

IIb 

IIb 

IIb 

Communication 

Audits 

Step IIa 

Validation Report 

Data Deliverables 

and SAP 

Deviations 

Sampling Plan 

Sampling 

Procedures 

Field Duplicates 

Project 

Quantitation 

Limits 

Confirmatory 

Analysis 


Criteria 

Data Qualifiers 

Step IIb 

Validation Report 

Establish that required communication procedures 

were followed by field or laboratory personnel. 

Review laboratory audit reports, accreditation, and 

certification records for the laboratory’s performance 

on specific methods. Conduct field audit to verify 

compliance with planned procedures. 

Summarize deviations from methods, procedures, or 

contracts. Include qualified data and explanation of all 

data qualifiers. 

Ensure that the data report from Step IIa was 

provided. 

Determine the impacts of any deviations from 

sampling or analytical methods and SOPs. For 

example, confirm that the methods given in the SAP 

were used and, if they were not, determine if data still 

meet MPCs. Consider the effectiveness and 

appropriateness of any corrective action. 

Determine whether the sampling plan was executed 

as specified (i.e. the number, location, and type of 

field samples were collected and analyzed as 

specified in the SAP). 

Evaluate whether sampling procedures were followed 

with respect to equipment and proper sampling 

support (e.g. techniques, equipment, 

decontamination, volume, temperature, preservatives, 

etc.). 

Compare results of collocated field duplicates with 

criteria established in the SAP. 

Determine that quantitation limits were achieved, as 

outlined in the SAP, and that the laboratory 

successfully analyzed a standard at the QL. 

Evaluate agreement of laboratory results. 

Evaluate QC data against project-specific 

performance criteria in the SAP (i.e. evaluate quality 

parameters beyond those outlined in the methods). 

Determine that the data qualifiers applied in step IIa 

were those specified in the SAP and that any 

deviations from specifications were justified. 

Summarize outcome of comparison of data to MPC in 

the SAP. Include qualified data and explanation of all 

data qualifiers. 


Validation 

(name, organization) 

Danille 


Danille 


Mary Schneider/AMEC 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Note: 

1 

IIa-compliance with methods, procedures, and contracts [see Table 10, page 117, UFP-QAPP manual, V.1, March 

2005.] 

IIb-comparison with measurement performance criteria in the SAP [see Table 11, page 118, UFP-QAPP manual, V.1, 

March 2005] 




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WORKSHEET #36: ANALYTICAL DATA VALIDATION (STEPS IIA AND IIB) 

SUMMARY TABLE 

Following data verification, data validation will be performed in accordance with 

NAVFAC SW EWI#1 (SWDIV 2001a). Following the NAVFAC SW policy, an 

independent party with experience performing data validation for Navy projects will 

perform the validation. With the exception of waste characterization samples, data will be 

validated at 80% EPA Level III and 20% EPA Level IV. Data validation will be performed 

in accordance with the Navy Installation Restoration Chemical Data Quality Manual 

(NFESC, 1999), and patterned after the EPA CLP National Functional Guidelines for 

Superfund Organic Methods Data Review and Inorganic Data Review (EPA 2008, 2004), 

and QC criteria specified in this document. Validation of data generated from previous 

investigations will generally conform to Level III guidelines, except that evaluation of QC 

sample results will be limited to the information provided in the available laboratory 

reports. 

For Level III data validation, data quality will be assessed by comparing the QC 

parameters to the appropriate criteria (or limits) as specified in this SAP. Verification of 

quantitation calculations may be performed on a limited basis and may require raw data in 

addition to the standard data forms. 

Level IV (full) data validation follows the EPA protocols and CLP criteria as set forth in 

the functional guidelines for evaluating organic (EPA 2008) and inorganic (EPA 2004) 

analyses. These guidelines apply to full data packages that include raw data (e.g. 

instrument spectra and chromatograms), backup documentation for calibration standards, 

analysis run logs, dilution factors, and additional information necessary to check 

calculations for quantified analytical data. Calculations are checked for QC samples (e.g. 

MS/MSD and LCS data) and routine field samples (including field duplicates, field blanks, 

equipment blanks, and volatile organic compounds, trip blanks). To assure that detection 

limits and data values are appropriate, an instrument performance, method of calibration, 

and calibration standards are evaluated. 

Analytical data may be qualified based on data validation reviews. Qualifiers will be 

consistent with the applicable EPA national functional guidelines and will be used to 

provide data users with an estimate of the level of uncertainty associated with the qualified 

result. 

Data validation results will be evaluated with respect to the attached qualifiers to determine 

data usability issues, if any. The following qualifiers may be assigned during the validation 

process. 




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J - estimated concentration 

R - rejected value (unusable) 

N - presumed identity 

U - not detected (e.g. not present based on blank contamination) 

UJ - sample detection limit is estimated. 

Data validation will be patterned after CLP NFG. The objectives, evaluations, and actions 

employed during the data validation process will follow those outlined in the NFG. 

Differences between NFG and project validation procedures will include; review items and 

data validation criteria. The laboratory will be permitted to provide CLP-like forms in lieu 

of true CLP forms. The data validation criteria will not adhere to NFG but will be based on 

method criteria for preservation, holding times, instrument tuning, calibration, instrument 

performance checks, internal standard responses, serial dilutions, and target compound ID; 

laboratory-specified criteria for surrogate, laboratory control samples, laboratory 

duplicates, and matrix spikes; and the validator’s professional judgment. 

Step 

IIa/ IIb 

Matrix 

IIa/IIb Wipe Lead 

IIa/IIb Wipe PCBs 

IIa/IIb Soil Lead 

IIa/IIb Soil PCBs 

Table 36-1. Analytical Data Validation Summary 

Analytical 

Group 

Validation Criteria 

EPA Method 6010B; EWI #1, 

DoD QSM 

EPA Method 8082, EWI #1, 

DoD QSM 

EPA Method 6010B; EWI #1, 

DoD QSM 

EPA Method 8082, EWI #1, 

DoD QSM 

Data Validator 

(title and organizational 

affiliation) 

IIa: Jeanne Peterson/ AQA 

IIb: Danille Jorgensen, AMEC 










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WORKSHEET #37: USABILITY ASSESSMENT 

A data usability report will be prepared by AMEC incorporating the findings of the data 

validation effort, evaluation of the data against the DQOs specified in this SAP, and other 

supporting information. This assessment will evaluate data on a matrix-specific, analytespecific 

and location-specific basis. The potential impact of any sampling discrepancies or 

data qualifications (rejected, nondetected, estimated) on the removal actions will be 

discussed with the remedial program manager (RPM) and QAO. Recommendations for 

further actions will be provided, if necessary and appropriate. 

Elements that will be addressed in the usability report include, but are not limited to: 

• Compliance of sampling methods with the SAP 

• Completeness of sampling effort 

• Potential sampling error 

• Compliance of analyses with SAP methods and QC requirements 

• Completeness of laboratory analyses 

• Potential analytical error 

• Corrective actions and resolutions 

• Validation findings 

• Measurement performance criteria 

• Remedial options 

Completeness of sampling will be determined by the number of samples collected divided 

by the number of samples to be collected as specified in the SAP, expressed as a 

percentage. The requirement of completeness is 95% for sampling. 

Completeness for laboratory analyses will be determined by the number of valid results 

(results not qualified with a rejected (R) flag) divided by the number of possible individual 

analyte results, expressed as a percentage. The requirement for analytical completeness is 

95%. 

Assessment activities are presented below. 




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Item 

Data 

Deliverables 

and SAP 

Deviations 

Sampling 

Locations 

Chain-of- 

Custody 

Holding Times 

Damaged 

Samples 

SOPs and 

Methods 

QC Samples 

Matrix 

Meteorological 

Data and Site 

Conditions 

Comparability 

Completeness 

Critical 

Samples 

Data 

Restrictions 

Usability 

Decision 

Usability 

Report 

Table 37-1. Usability Assessment Activities 

Assessment 

Activity 

Ensure that all necessary information was provided, including but not 

limited to validation results. 

Determine the impact of deviations on the usability of data. 

Determine if alterations to sample locations continue to satisfy the project 

objectives. 

Establish that any problems with documentation or custody procedures do 

not prevent the data from being used for the intended purpose. 

Determine the acceptability of data where holding times were exceeded. 

Determine whether the data from damaged samples are usable. If the data 

cannot be used, determine whether resampling is necessary. 

Evaluate the impact of deviations from SOPs and specified methods on 

data quality. 

Evaluate the implications of unacceptable QC sample results on the data 

usability for the associated samples. For example, consider the effects of 

observed blank contamination. 

Evaluate matrix effects (interference or bias). 

Evaluate matrix effects (interference or bias). 

Evaluate the possible effects of meteorological (e.g. wind, rain, 

temperature) and site conditions on sample results. Review field reports to 

identify whether any unusual conditions were present and how the 

sampling plan was executed. 

Evaluate the impact of missing information. Ensure that enough information 

was obtained for the data to be usable (completeness as defined in PQOs 

documented in the SAP). 

Establish that critical samples and critical target analytes, as defined in the 

SAP, were collected and analyzed. Determine if the results meet criteria 

specified in the SAP. 

Describe the exact process for handling data that do not meet PQOs (i.e. 

when measurement performance criteria are not met). Depending on how 

those data will be used, specify the restrictions on use of those data for 

environmental decision-making. 

Determine if the data can be used to make a specific decision considering 

the implications of all deviations and corrective actions. 

Discuss and compare overall precision, accuracy/bias, representativeness, 

comparability, completeness, and sensitivity for each matrix, analytical 

group, and concentration level. Describe limitations on the use of project 

data if criteria for data quality indicators are not met. 

Person Responsible for 

Activity 

Danille 


Danille 


Mike Schulz/AMEC 

Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 


Danille 





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Page 37-2

REFERENCES 

Navy, 2001. Draft Proposed Plan for Stationwide No Action Sites, Moffett Federal Air 

Field, California. 

Navy (Department of Navy), 2008. Action Memorandum for the Non-Time-Critical 

Removal Action for the PCB Contamination at Installation Restoration Site 29, Hangar 

1, Former Naval Air Station Moffett Field, Moffett Field, California. December. 

Intergovernmental Data Quality Task Force (IDQTF). 2005a. Uniform Federal Policy for 

Quality Assurance Project Plans – Evaluating, Assessing, and Documenting 

Environmental Data Collection and Use Programs, Part 1: UFP-QAPP Manual. Final. 

Version 1. March. 

IDQTF. 2005b. Workbook for Uniform Federal Policy for Quality Assurance Project Plans 

– Evaluating, Assessing, and Documenting Environmental Data Collection and Use 

Programs, Part 2A: UFP-QAPP Workbook, Final, Version 1, March. 

Naval Facilities Engineering Command, Southwest Division (SWDIV). 2001a. 

Environmental Work Instruction (EWI) #1: Chemical Data Validation. November. 

EPA. 2002. USEPA Guidance for Quality Assurance Project Plans, EPA QA/G-5, QAMS 

EPA. 2004. USEPA Contract Laboratory Program National Functional Guidelines for 

Inorganic Data Review. October. 

EPA. 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process, 

EPA QA/G-4 

EPA. 2007. Test Methods for Evaluating Solid Wastes (SW-846). 3 rd Edition. Revision 6. 

February. 




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References Page 1





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References Page 2

APPENDIX A 

STANDARD OPERATING PROCEDURES 




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DCN: AMEC-8816-0005-0039 

April 2010

AMEC 

Standard Operating Procedures 

Procedure No.: 

FP-F-7 

Revision No.: 0 

Revision Date: 

Page: 1 of 1 

Approved by: 

SAMPLE HANDLING, STORAGE, 

AND SHIPPING 

Ann Bernhardt 

PERMAC QC Manager 

1.0 PURPOSE 

The objective of this procedure is to provide standard methods for handling, storing, and 

transporting of environmental samples following their collection. 

2.0 SCOPE 

This procedure will be used during the collection of all types of environmental media that 

include, but are not limited to, groundwater, surface water, soil, and sediment. 

This procedure has been developed to serve as AMEC Earth and Environmental 

(AMEC)-approved professional guidance for the AMEC Program. As professional 

guidance for specific activities, this procedure is not intended to obviate the need for 

professional judgment to accommodate unforeseen circumstances. Deviation from this 

procedure in the execution of planned activities must be documented in the field logbook. 

3.0 DEFINITIONS 

Temperature Blank – A vial filled with tap water and stored in the cooler during sample 

collection and transportation. The temperature of the cooler will be recorded by the 

laboratory on the chain-of-custody record immediately upon receipt of the samples. 

4.0 RESPONSIBILITIES 

The Project Manager or designee will have the responsibility to oversee and ensure that 

the handling of samples is in accordance with this standard operating procedure (SOP) 

and project specific Sampling and Analysis Plan (SAP). 

The field sampling personnel will be responsible for the understanding and 

implementation of this SOP during all sampling activities, as well as, obtaining the 

FP-F-7-1

AMEC 



FP-F-7 



Page: 2 of 2 

appropriate field logbooks, forms, and records necessary to complete the sampling 

activities. 

The Quality Control (QC) Manager is responsible for ensuring that sample handling, 

storage, and transport activities conducted during all projects are in compliance with this 

SOP. 

5.0 

PROCEDURES 

The following method outlines general considerations for sample handlings in the field 

and maintaining sample custody after collection. 

Immediately following collection, all samples will be labeled in accordance with 

procedure FP-F-6 Record Keeping, Sample Labeling, and Chain-of-Custody. Sample 

labels are required on all sample containers for the purpose of sample identification. A 

chain-of-custody form must be initiated at the time that the sample containers are filled. 

Immediately after sample labeling, custody seals will be affixed to each sample 

container.The lids of the containers shall not be sealed with duct tape. For vials, the 

custody seal will be placed on the outside of the first resealable bag; then the container 

will be placed in a second resealable bag. This will prevent any contact with the 

adhesive from the custody seal and the sample. Other sample containers will be placed in 

double-resealable plastic bags to protect the sample from moisture, and to prevent 

breakage and potential cross-contamination during transportation to the laboratory. All 

glass sample containers will be protected with bubble wrap first, if transported by a 

commercial carrier. Vials should be wrapped with bubble wrap, then placed in a 

resealable bag, a custody seal placed over the bag, and then placed in another resealable 

bag. Samples must be placed in an insulated cooler with ice to preserve at 6 o C during 

field work. 

Samples shall be shipped as soon as possible to allow the laboratory to meet holding 

times for analysis. Environmental samples, including groundwater samples, are currently 

exempt from Hazardous Goods regulation. 40 Code of Federal Regulations 261.40(d) 

states, “A sample of solid waste or a sample of water, soil or air which is collected fro the 

sole purpose of testing to determine its characteristics or composition is not subject to 

this Part or Parts 262 through 267 or Part 124 of this chapter or to notification 

requirements of Section 3010 of RCRA.” Therefore, no special regulations are required 

to be followed for the shipment of environmental samples from the field. However, 

sample containers should be properly packed such that inadvertent spillage does not 

occur during shipment (e.g., any discharge spouts should be taped closed). 

FP-F-7-2

AMEC 



FP-F-7 



Page: 3 of 3 

The sample containers will be placed in an insulated cooler with ice in double-resealable 

bags or with pre-frozen “blue ice”. Ice will be placed at the bottom of the 

cooler; one 

layer of sample containers will be placed on the ice, and more double-bagged ice will be 

placed on top of the containers. This will be repeated until the cooler is filled with ice as 

the top layer in the cooler. Each cooler will be shipped with a temperature blank. 

The field personnel collecting the samples will be responsible for the custody of the 

samples until transport to the laboratory by either transferring to a laboratory 

representative or shipping by common carriers (i.e., Federal Express). If samples are to 

be transferred to a laboratory representative, signature of individuals relinquishing and 

receiving the samples, and date and time of transfer must be completed on the chain-ofcustody 

form. A copy of the chain-of-custody record will be maintained by the field 

personnel. Common carriers are not expected to sign the chain-of-custody form. 

However, the bill of lading or airbill becomes part of the chain-of-custody record. 

If samples are to be shipped by common carriers, the top two copies of the chain-of-form 

will be placed in a double-resealable bag and then taped to the inside of the sample cooler 

lid. The cooler will be taped shut with strapping tape. Two custody seals will be taped 

across the cooler lid: one seal in the front and one seal in the back. Clear tape will be 

applied to the custody seals to prevent accidental breakage during shipment. The pouch 

for the airbill will be placed on the cooler and secured with clear tape. The airbill will be 

completed for priority overnight delivery and placed in the pouch. If multiple coolers are 

being shipped, the original airbill will be placed on the cooler with the chain-of-custody 

record, and copies of the airbill will be placed on the other coolers. The number of 

packages should be included on each airbill (e.g., 1 of 2, 2 of 2). Saturday deliveries 

should be coordinated with the laboratory in advance, and field sampling personnel, or 

their designees, must ensure that Saturday delivery stickers are placed on each cooler by 

the commercial courier. A letter stating the names and telephone numbers of AMEC and 

laboratory personnel at various locations who can be contacted in the event of problems 

with the sample shipment should also be taped to the outside of the cooler. 

6.0 RECORDS 

Field personnel are responsible for assuring that the original documentation is maintained 

in the project file. 

FP-F-7-3

AMEC 



FP-F-7 



Page: 4 of 4 

7.0 REFERENCES 

None. 

8.0 ATTACHMENTS 

Example chain-of-custody 

Example Sample Label 

Example custody seal 

FP-F-7-4

AMEC 



FP-F-7 



Page: 5 of 5 

ATTACHMENT 

FP-F-7-5

AMEC 



FP-F-7 



Page: 6 of 6 

SAMPLE LABEL (EXAMPLE) 

AMEC 

7376 SW Durham Road 

Portland, Oregon 97224 

PH: 503-639-3400 

FX: 503-620-7892 

Job Name: 

Job Number: 

Sample I.D.: 

Date: 

Sampler: 

Time: 

Comments: 

CUSTODY SEAL (EXAMPLE) 

CUSTODY SEAL 

Person Collecting Sample: ____________________________ Sample No.:______ 

(Signature) 

Date Collected:______________ Time___________ 

__________________________________________________________ 

FP-F-7-6

Procedure No.: FP-F-7 

AMEC Earth & Environmental 


Standard Operating Procedures Revision Date: 

Page: 7 of 7 

Project Name: 

Project Number: 

Project Manager: 

SHIP TO: 

DATE: 

AMEC 

7376 SW Durham Road 

Portland, OR 97224 

C HAIN OF CUSTODY COC #: 

(503) 639-3400 PAGE: 

Project Contact: Bill To: AMEC Disposal Instructions: 

Phone Number: 

Shipment Method: 

Project Phase: 

Waybill Number: 

OF 

LAB 

COURIER/FedEx 

N/A 

Sample Information Methods for Analysis RUSH 

No. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

Sample ID 

Date 

Sampled Time Sampled Matrix 

Sam pler's Signature: Date: 

Tim e: 

For Lab Use 

For Lab Use 

Does COC match samples: Y or N Comments: H=Hold Analysis Request X=Analyze 

Relinquished By/Affiliation: 

Date : 

Time: Broken Container: 

COC seal intact: 

Y or N 

Received By: 


Date : 

Date : 

Time: Other problems: 

AMEC contacted: 

Time: Date contacted: 

Y or N 

Y or N 

Y or N 

Received By: Date : 

Time: Cooler Temperature at receipt: C 


Date : 

Time: 

NUMBER OF COOLERS SENT: 

Received By (LAB): Date : 

Tim e: 

FP-F-7-7

APPENDIX B 

FIELD FORMS 




DCN: AMEC-8816-0005-0039 

April 2010





DCN: AMEC-8816-0005-0039 

April 2010





DCN: AMEC-8816-0005-0039 

April 2010





DCN: AMEC-8816-0005-0039 

April 2010





DCN: AMEC-8816-0005-0039 

April 2010

Sample Collection Log 

Sample name Sample ID Parent Sample 

Trip Blank 

Association 

Equipment/Rinse 

Blank Association 

Field Blank 

Association 

Source Blank 

Sample 

Type 

Sample er Initials 

Spike Collected? (Y?N) 

Matrix 

Matrix 

Sample 

Start Depth (feet) 

Sample 

End Depth (feet) 

Sample 

Date 

Sample 

Time 

PCBs 8082 

Lead 6010 

Asbes stos 

Notes 

C:\Documents and Settings\gerrie.gomez\Desktop\Gerrie Gomez\00 PERMAC\moffett for size\Appendix B\Sample Collection Log.xls Page 1 8:58 AM4/12/2010

APPENDIX C 

RESPONSES TO COMMENTS 




DCN: AMEC-8816-0005-0039 

April 2010





DCN: AMEC-8816-0005-0039 

April 2010

RESPONSE TO COMMENTS ON 

Draft Sampling and Analysis Plan for Non-Time Critical Removal Action 

for Polychlorinated Biphenyl Contamination at Installation Restoration Site 

29 Hangar 1 



Comments by: 

Sarah Kloss 

Remedial Project Manager 

US EPA Region 9 

DCN: AMEC‐ 8816‐0005‐0040 

Responses by: 


Line Number 

Section/Figure/ 

Table/Appendix 

Comments 

1 Worksheet 10 Scope of Soil Sampling: Worksheet 

#10 of the Draft Sampling and 

Analysis Plan (SAP) states that one 

of the objectives of the soil 

sampling is to "verify that the 

removal is executed without the 

release of PCBs into the 

environment as a result of the 

removal action." However, it is not 

clear how the area of potential 

impact due to the removal action 

was determined. The soil sampling 

design proposed assumes that 

possible PCB releases during the 

removal action will deposit on the 

soil within 35 ft of the Hangar 

footprint. Please revise the report to 

include justification why the 35 ft 

radius is considered appropriate or 

Responses (Contractor) 

The soil sampling strategy will be 

revised. A grid approach will be 

utilized to collect soil samples 

from soil areas on the east side of 

the Hangar. The grid will cover the 

entire soil area. Language 

regarding a lateral step-out 

approach will be eliminated. 

Response to Comments on Draft Sampling and Analysis Plan 


DCN: AMEC-8816-0005-0040 

April 2010 

Page 1 of 10

expand the radius as necessary. 

2 SAP Ecological Receptors: Please 

include justification for why the soil 

areas adjacent to Hangar 1 are not 

considered ecologically important. 

Likewise, if the radius of potential 

impact expands in the next revision 

of this SAP, the Navy should 

evaluate potential ecological 

impacts in other nearby unpaved 

areas that may be considered 

habitat. An alternative to expanding 

the baseline soil sampling radius 

due to ecological concerns would be 

to expand air monitoring to include 

potential habitat areas that could be 

impacted by the removal action. 

3 Worksheets 11, 14, 15, 17 The rationale for the where the 

samples are located and the number 

of samples for each area (concrete 

pad, soil, etc.) is not provided. Also, 

the soil areas should be fully 

characterized. Due to the large 

height of Hangar 1, PCBs could be 

found at 35 ft from the edge of the 

pavement even if they are not found 

at 20 ft; thus, the Navy should 

sample at 35 ft from the pavement 

edge regardless of the 20 ft results. 

Revise the SAP to provide the 

rationale for the selected sampling 

locations, indicate if the sample 

The Pre-Final Draft will provide 

references to substantiate that the 

soil areas adjacent to the hangar 

are not ecologically sensitive. 

Additional site description 

information will be provided that 

defines the distance of other 

potential nearby habitats from the 

hangar. 

See response to general comment 

1. 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 2 of 10

Worksheets 11, 14, 15, 17 

Worksheets 11, 14, 15, 17 

locations were selected randomly 

and edit the sampling approach to 

include analyzing all samples at 

once instead of a step-out approach. 

The soil decision units is (are) not 

clearly defined. Step 5 of Table 11- 

1 states that the contaminated soil at 

the area where exceedance was 

detected will be removed. However, 

the boundaries of the area that 

would be removed are not indicated 

in the SAP. Revise the SAP to 

define the decision units for the 

potential soil excavation areas. 

Please eliminate the references to 

the 95% confidence levels for 

confirming the removal action has 

not impacted soil. The comparison 

between baseline and post- removal 

levels should be conducted on a 

point by point basis with regulatory 

consultation. The 95% confidence 

interval approach may average over 

too large of an area to be able to 

The Pre-Final Draft will define the 

soil decision units and boundaries 

of excavation areas. A grid 

approach will be adopted for 

baseline and confirmation 

sampling. In general, if an 

exceedance occurs at any sample 

location, the soil will be excavated 

half way to the next clean location, 

in each direction. Confirmation 

samples will then be collected 

from the bottom of the excavation, 

at the center and on all four sides 

of the excavation. Sample results 

will be provided to both EPA and 

Water Board for consultation on 

the specific soil removal approach. 

Text references to the 95% will be 

removed. The comparison between 

baseline and post- removal levels 

will be conducted on a point by 

point basis in consultation with 

EPA and the Water Board. 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 3 of 10

Worksheets 11, 14, 15, 17 

spot smaller impacted areas. 

The timing and depth of the 

excavation described in Worksheet 

#17 is unclear. Worksheet #17 

states that if the PCB results for 

baseline/pre-construction samples 

are greater than 1,000 micrograms 

per kilogram (ug/kg), the 12-inch 

depth samples "may" be analyzed to 

determine vertical extent and the 

soil down to 6 inches will be 

removed. The plan should clearly 

state that the Navy will analyze the 

12-inch samples if the 6-inch 

samples show PCBs are above the 

action level. Also, please specify if 

the 12-inch samples will be 

analyzed before or after excavation 

of the top six inches of soil (if any 

excavation is needed). Finally, it is 

unclear if additional action would 

be performed as a part of this 

removal action should the 12-inch 

samples exceed the action limits. 

Revise the SAP to clarify the 

decision criteria and timing of each 

step. 

The Pre-Final Draft plan will state 

that the Navy will analyze the 12- 

inch samples if the 6-inch samples 

show PCBs are above the action 

level. The 12-inch samples will be 

analyzed before excavation of the 

top 6 inches. If the 12 inch 

samples exceed the action limit, 

then additional excavation will 

occur until the action levels are 

met. The SAP will be revised to 

clarify the decision criteria and 

timing of each step. 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 4 of 10

Worksheets 11, 14, 15, 17 

The description of the procedure for 

collecting the excavation 

confirmation samples presented in 

Worksheet #14 is insufficiently 

detailed. For example, it is not clear 

what depth will be targeted for 

these samples and why the top two 

inches of top soil will be removed 

prior to collection of the 

confirmation samples. Revise 

Worksheet # 14 to provide 

additional details and justification 

for how excavation confirmation 

samples will be collected. 

Revise the information presented in 

Worksheets #11, #14, #15, and #17 

to be consistent and clearly describe 

the timing and decision criteria for 

all steps of the removal action. It 

may be useful to include a decision 

tree for this purpose. 

The sampling procedure for 

confirmation samples will be 

revised to provide the requested 

detail. Confirmation samples will 

be collected from the bottom of 

the excavation, at the center and 

on all four sides. 

The information in Worksheets 11, 

14, 15, and 17 will be revised to 

describe the new sampling 

approach (see response to 

comment 1 above). A new figure 

(decision tree) will be added in 

Worksheet 17 to illustrate the 

sequence and timing of data 

collection steps, decision points, 

and removal actions. 

4 Laboratory Information. The SAP 

does not provide the laboratoryspecific 

standard operating 

procedures (SOPs). Further, please 

specify if the quantitation limits 

(QLs) and method detection limits 

(MDLs) presented in Worksheet 

#15 are laboratory-specific limits or 

Laboratory-specific SOPs are not 

provided in the SAP because they 

are proprietary documents. They 

will be available for review, if 

requested. 

Per the NAVFAC SAP template 

requirements, MDLs and QLs 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 5 of 10

limits established by the analytical 

method or some other document. 

Also, discuss why the Project 

Quantitation Limit Goal for arsenic 

is less than the QL. Revise the SAP 

to include all relevant laboratoryspecific 

SOPs as discussed the 

Uniform Federal Policy for Quality 

Assurance Project Plans Manual 

dated March 2005 (UFP QAPP 

Manual) or provide a summary of 

all laboratory procedures in the 

SAP. Also, revise the SAP to 

reference a source for the QLs and 

MDLs presented in Worksheet #15. 

Finally, assess the QL for arsenic to 

ensure that it meets the PAL. 

5 Field Duplicates. This SAP states 

that field duplicate samples will not 

be collected due to the nonhomogenous 

nature of soils and 

sediments; however, it is unclear 

how reliable decisions can be made 

if sample heterogeneity is a 

concern. Collection of duplicates is 

recommended and procedures 

should be included to assess sample 

heterogeneity. Revise the SAP to 

include field duplicates for soil and 

sediment samples. Additionally, 

indicate what measures will be 

taken to reduce sample 

heterogeneity. 

listed are specific to BC Labs as 

identified in Worksheet 30. 

The Project Quantitation Limit 

Goal for arsenic will be changed to 

0.5 mg/kg. 

Field duplicate samples for soil 

and sediment will be collected at 

10% frequency. 

The sampling procedure will be 

revised to include homogenization 

process. 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 6 of 10

6 Worksheets #6 and #32 Notification to EPA of Corrective 

Action. The corrective action 

presented in the SAP is 

insufficiently detailed. For example, 

the SAP does not indicate that EPA 

will be notified of any significant 

changes to the SAP by corrective 

action. Revise worksheets #6 and 

#32 to indicate that EPA will be 

notified of any significant 

corrective action and the time frame 

of notification. 

7 Data Validation. The SAP states 

that 20% of the data will be 

validated at Level IV and 80% will 

be validated at Level III. However, 

it is unclear how data will be 

selected for each level (e.g., 

randomly). Revise the SAP to 

clarify this issue. 

8 Reporting Requirements. The SAP 

does not discuss manual 

integrations for chromatographic 

analyses or second column 

confirmation for PCB identification. 

Revise the SAP to indicate that if 

manual integration is required, 

supporting information for manual 

integrations (i.e., chromatograms 

before and after manual integration 

as well as a brief explanation for the 

manual integration) will be included 

SAP will be revised accordingly. 

Samples for Level IV validation 

will be selected randomly. 

Reporting requirements for manual 

integrations and second column 

confirmation will be included in 

Section 14.7.5. 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 7 of 10

in the data package deliverables and 

evaluated during data validation. 

Further, revise the SAP to ensure 

that second column confirmation 

information is provided for PCB 

analysis. 

9 Checklists The SAP does not contain data 

verification and quality control 

(QC) checklists. Revise the SAP to 

provide all data verifications and 

QC checklists as discussed in 

Section 5 of the UFP QAPP Manual 

(Data Review Elements). 

Specific Comments 

1 Page 10-2 Worksheet 10 Problem 

Definition 

2 Page 11-1 Worksheet #11 - Table 11-1, 

Data Quality Objectives 

Summary Pre-Construction and 

Confirmation Sampling 

3 Page 12-1 through 12-2 Worksheet #12 - 

Measurement Performance 

Criteria Table 

In the first sentence of the fourth 

paragraph please change 

"eliminate" to "address" or some 

other word that indicates that the 

risk will be greatly reduced, but not 

completely eliminated. Also, in the 

fifth paragraph please clarify that 

there have been no impacts to 

groundwater from PCBs, lead, or 

asbestos. There is evidence to 

suggest that the regional plume 

extends under the footprint of the 

Hangar. 

Please change "eliminate" to 

"address" or similar language for 

Step 1 as noted in Specific 

Comment 1. 

This worksheet does not include 

any QC samples for asbestos. 

Revise the table to include QC 

samples for the asbestos analysis 

(e.g., confirmation of the 

Data verification information as 

described in Section 5 of the UFP- 

QAPP manual is presented in 

Worksheet 34. 

Comment noted. The word 

“eliminate” will be replaced with 

“address” in the first sentence of 

the fourth paragraph. 

The first sentence of the fifth 

paragraph will be revised as “It 

should be noted … there have been 

no impacts on groundwater from 

PCBs, lead, or asbestos; …”. 

Comment noted. The word 

“eliminate” will be replaced with 

“address”. 

Comment noted. Worksheet 12 

will be revised. 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 8 of 10

4 Worksheet #15 - Reference 

Limits and Evaluation Table, 

Tables 15-1 and 15-4, Pages 

15-1 and 15-4 



Table 15-4, Page 15-4 



Table 15-7, Page 15-6 



Pages 15-1 through 15-3 

quantitation result by a second 

analysis of 10% of the analyzed 

samples). 

It is unclear if the PALs, QLs, and 

MDLs presented on this table are 

given on a dry weight or wet weight 

basis. Revise the SAP to clarify this 

information. 

The acronym RSL stands for 

"Regional" Screening Level. 

It is unclear if total Aroclors will be 

determined by adding individual 

Aroclor concentrations or if the area 

under the entire chromatogram will 

be quantified. If total Aroclor 

concentrations will be determined 

additively, it is unclear if and how 

non-detected results will be 

incorporated into the calculation 

(e.g., non-detects will be set at zero, 

the QL, or one half the QL, etc.). 

Revise this worksheet to describe 

how total Aroclor concentrations 

will be determined and how nondetected 

results will be 

incorporated. 

The project action limit listed for 

asbestos, 1 %, is not considered 

health protective. In the event that 

fill will be imported, the Navy will 

have to work with the EPA to 

develop a more health protective 

process for screening asbestos in 

fill. 

Soil and sediment samples for this 

project will be reported on a dry 

weight basis. A footnote will be 

added to Table 15-1 and 15-4 to 

clarify this information. 

Comment noted. The acronym will 

be revised. 

Total Aroclors will be determined 

by adding individual Aroclor 

concentrations. For this project, 

the laboratory will report detected 

concentration between method 

detection limit (MDL) and 

quantitation limit (QL) as 

estimated. If an Aroclor is not 

detected, the MDL value will be 

used to determine total Aroclor 

concentration. 

The project action limit for 

asbestos will be revised to 0.25 

percent, as recommended by EPA. 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 9 of 10

8 Worksheet #19 - Analytical 

SOP Requirements Table, 

Page 19-1 


SOP Requirements Table, 

Page 19-1 

10 Worksheet #28 - Laboratory 

QC Samples Table, 

Page 28-3 through 28-4 


Services Table, Page 30-1 

The extraction methods listed for 

the water and wipe matrices are not 

the methods recommended by EPA 

methods. For example, the SAP 

lists EPA Method 3050 and 3550B 

for extraction of water samples, but 

these methods are intended for solid 

matrices, not water. The PCB 

extraction method listed for the 

wipe samples (EPA Method 3580) 

is applicable to waste dilutions, not 

wipe samples. Revise this 

worksheet to present applicable 

methods for each analyte group and 

matrix. 

The Navy should discuss further 

with the EPA modifications to the 

CARB 435 method that may be 

needed to increase sensitivity once 

laboratory services for asbestos are 

procured. 

The table for Method 6010B states 

that post-digest spikes are analyzed 

when the dilution fails. However, 

post digest spikes should be 

analyzed when the matrix 

spike/matrix spike duplicate fails. 

Further, the QC limits for the post 

digest spike should reflect the limits 

established in the most recent 

version of EPA Method 6010C (i.e., 

80-120%). Revise the table to 

correct 

these discrepancies. 

The table does not list a laboratory 

for asbestos analysis. Revise the 

table to include this information. 

EPA method 3580 is not the 

extraction method of wipe 

matrices. Worksheet 19 will be 

revised with the appropriate 

extraction method for wipe 

samples. 

Comment noted. EPA will be 

contacted to discuss CARB 435 

method modifications if the 

subcontract laboratory is not able 

to meet reporting limit of 0.25 

percent. 

Laboratory performing samples for 

DoD Installation Restoration 

project must meet DoD Quality 

System Manual (QSM) 

requirements. The acceptance 

limits and frequency of postdigestion 

spike presented in the 

SAP are in accordance with the 

QSM. 

The asbestos laboratory name will 

be included in the Pre-Final 

Sampling and Analysis Plan. 



DCN: AMEC-8816-0005-0040 

April 2010 

Page 10 of 10

RESPONSE TO COMMENTS ON 

Draft Sampling and Analysis Plan for Non‐Time Critical Removal Action for 

Polychlorinated Biphenyl Contamination at Installation Restoration Site 29 Hangar 1 



Comments by: 

Alec Naugle 

Sr. Engineering Geologist 

California Regional Water Quality Control Board, 

San Francisco Bay Region 

DCN: AMEC‐8816‐0005‐0041 

Responses by: 


Line Number 

Section/Figure/ 

Table/Appendix 

Comments 

1 SAP The acronym “RWQCB” for the San 

Francisco Regional Water Quality 

Control Board should be changed to 

“Water Board” throughout the document. 

2 SAP Import soil samples should be tested for 

other chemicals, including petroleum 

hydrocarbons, semivolatile organic 

compounds, and polynuclear aromatic 

hydrocarbons, in addition to the 

chemicals of concern (PCBs, lead, and 

asbestos) to document that it is “clean” 

fill. The Navy should document that 

import soil is clean and contains neither 

the chemicals of concern nor other 

chemicals that could pose a risk to 

human health and the environment. 

Responses (Contractor) 

Comment noted. “RWQCB” will be 

replaced with “Water Board” 

throughout the document. 

Comment noted. Soil samples for 

import soil will also be tested for total 

petroleum hydrocarbon, semi-volatile 

organic compounds, and polynuclear 

aromatic hydrocarbons. 



DCN: AMEC-8816-0005-0041 

April 2010 

Page 1 of 4

3 SAP The areas of soil in question are small 

and disconnected. Water Board staff 

suggest soil data from each sampling 

location and be compared the project 

action limit sample by sample to 

determine what action is required, if any. 

4 Worksheets #3, #7, and #9 Correct Elizabeth Wells’ title to be 

“Water Board PM.” 

5 Page 10-2 Worksheet #10 Revise the text to read “…1) potential 

releases to groundwater, because data 

previously collected indicates there have 

been no PCB-impacts on groundwater 

…” The statement as presented is 

incorrect; groundwater beneath Hangar 1 

is impacted by volatile organic 

compounds. 

6 Worksheet #11, Section Revise the schedule to show the correct 

11.1 

7 Worksheet #14, Section 

14.2.1 

date(s) for distribution of the Work Plan. 

Clarify if gloves will be worn for soil 

sampling activities. Sampling without 

gloves is a health and safety concern, and 

could result in cross contamination of 

soil samples. The text states that gloves 

will be worn for all other sampling 

activities. 



utilized to collect soil samples from 

soil areas on the east side of the 

Hangar. The grid will cover the entire 

soil area. Sample results will be 

provided to both EPA and Water 

Board for consultation on the specific 

soil removal approach. 

Comment noted. Elizabeth Wells’ 

title will be changed to “Water Board 

PM”. 

The first sentence of the fifth 

paragraph will be revised as “It 

should be noted … there have been no 

impacts on groundwater from PCBs, 

lead, or asbestos; …”. 

Comment noted. Project schedule will 

be updated. 

Section 14.2.1 will be revised to 

include wearing a new pair of gloves 

for each sample collection. 



DCN: AMEC-8816-0005-0041 

April 2010 

Page 2 of 4

8 Worksheet #15, Table 15-4 Change the project action limit for lead 

to the September 2009 California Human 

Health Screening Level (CHHSL). The 

California Office of Environmental 

Health Hazard Assessment recalculated 

the cleanup number based on a level of 

lead in soil that could result in up to a 1 

microgram per deciliter (µg/dL) increase 

in blood lead level.. The re-calculation 

reduced the CHHSL for lead to 320 

milligrams per kilogram for 

commercial/industrial exposure. If the 

Navy elects not to make this 

recommended change, provide 

justification for the decision. 

9 Worksheet #16 Revise the schedule to show the correct 

date(s) for distribution of the Work Plan. 

10 Worksheet #17 Describe the steps that will be taken if 

the soil samples from 12 inches below 

ground surface contain chemicals of 

concern at concentrations greater than the 

screening criteria. The Navy has not 

included a sampling contingency for this 

scenario. 

11 Worksheet #17 Revise the soil sampling locations to 

collect representative soil samples from 

each soil area. Soil contamination, if 

present, likely is the result of deposition 

of contaminated particles that slough off 

the hangar. Because these particles could 

be transported via wind prior to 

deposition on the soil surface, there is no 

basis for sampling solely at the locations 

closest to the hangar. 

The project action limit for lead for 

import soil will be changed to 320 

milligrams per kilogram. 

Comment noted. Project schedule will 

be updated. 

If the 12 inch samples exceed the 

action limit, then additional 

excavation will occur until the action 

levels are met. The Pre-Final Draft of 

the SAP will be revised accordingly. 



utilized to collect soil samples from 

soil areas on the east side of the 

Hangar. The grid will cover the entire 

soil area. Sample results will be 

provided to both EPA and Water 

Board for consultation on the specific 

soil removal approach. 



DCN: AMEC-8816-0005-0041 

April 2010 

Page 3 of 4

12 Worksheet #17 Provide the basis for the sampling 

frequency of one sample per 120,000 

gallons of treated water. 

13 Worksheet #17 Describe how wastewater will be treated 

and how any by-product (such as 

sediment from settling tanks), if 

generated, will be tested and disposed. 

The City of Sunnyvale Incidental 

Sewer Discharge (ISD) Permit 

requires demonstrating compliance 

with the permit discharge limits, 

however the sampling frequency is 

not specified. An initial sample of the 

treated wastewater will be collected 

as part of the ISD permit application. 

AMEC anticipates that 500,000 

gallons of waste water will be 

discharged during the project. Since 

the wastewater will be generated by a 

consistent pressure washing 

operation, the effluent concentrations 

are not expected to change. Therefore 

one sample per 120,000 gallons is 

considered appropriate. 

Detailed information on the 

wastewater treatment system design 

and process is contained in the Work 

Plan for this removal action. Waste 

characterization and disposal 

requirements for tank sediment are 

also discussed in the Work Plan. A 

summary of the pertinent information 

will be added to the SAP 



DCN: AMEC-8816-0005-0041 

April 2010 

Page 4 of 4

FINAL SAMPLING AND ANALYSIS PLAN - Documents for Moffett Field

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