United States Environmental Protection Agency, Region 4
Quality Assurance Project Plan
Katrina Response
Environmental Soil and Sediment Sampling
Gulf Coast of Mississippi
September, 2005
Science and Ecosystem Support Division
980 College Station Road
Athens, GA 30605
Mississippi Department of Environmental Quality
2380 Highway 80 West
Jackson, Mississippi 39204
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Title and Approval Sheet
Title: Quality Assurance Project Plan, Katrina Response Environmental
Soil and Sediment Sampling, Gulf Coast of Mississippi
This quality assurance project plan (QAPP) has been prepared according to:
EPA Requkements for Quality Assurance Project Plans (EPA QA/R5 EPA/240/B-01/003, U.S.
Environmental Protection Agency, Office of Environmental Information, Washington, DC, March 2001
(USEPA, 2001).
This document will be used to ensure that environmental and related data collected, compiled, and/or
generated for this project are of the type, quantity, and quality required for their intended purposes
within the limitations of available resources.
Management Approvals:
Fred Sloan.
Project Leader
Environmental Investigations Branch
Date
Antonio Quinones, Chief
Environmental Investigations Branch
Date
Marilyn Thornton, Chief
Quality Assurance Section
Management & Technical Services Branch
Date
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Distribution List
Phil Bass - MDEQ
Richard Harrell - MDEQ
Ben Franco - EPA
Mike Norman - EPA
Lael Butler - EPA
Terry Stilman - EPA
Trent Rainey - EPA
Don Rigger-EPA
Barbara Scott - EPA
Scott Sudweeks - EPA
Beverly Banister - EPA
Franklin Hill - EPA
Alan Farmer - EPA
Gary Bennett - EPA
David Langston - EPA
Dana Tulis-EPA
Vanessa Vu - EPA
Tom Armitage - EPA
Science Advisory Board
phil_bass@deq. state, ms. us
richard_harrell@deq.state. ms. us
franco.benjamin@epa.gov
norman.michael@epa.gov
butler.lael@epa.gov
stilman.terry@epa.gov
rainey.trent@epa.gov
rigger.don@epagov
scott.barbara@epa.gov
sudweeks.scott@epa.gov
banister, beverly@epa.gov
hill.franklin@epa.gov
farmer, alan@epa.gov
bennett.gary@epa.gov
langston.david@epa.gov
tulis.dana@epa.gov
vu.vanessa@epa,gov
armitage.thomas@epa.gov
601-961-5100
601-961-5343
404-562-8758
404-562-8792
404-562-8453
404-562-8748
703-355-8576
404-562-8744
404-562-8773
404-562-8834
404-562-9326
404-562-8846
404-562-8313
706-355-8551
404-562-8478
202-564-7938
202-343-9874
202-343-9995
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Table of Contents
1.0 INTRODUCTION 5
1.1 Background/Site Location 5
1.2 Site Histories\Status Post Katrina 5
2.0 SAMPLING/DATA QUALITY OBJECTIVES 9
2.1 Data Quality Objectives 9
2.1.1 Problem Statement 9
2.1.2 Identify the Decision 9
2.1.3 Decision Inputs 10
2.1.4 Study Boundaries 10
2.1.5 Decision Rule 11
2.1.6 Error Limits 11
2.1.7 Optimize Sampling Design 11
3.0 INVESTIGATION MANAGEMENT PLAN 11
3.1 Field Project Responsibilities 11
3.2 Site Control and Access 11
3.3 Sample Collection and Handling Procedures 12
3.4 Sample Analysis and Validation 13
3.5 Chain of Custody 13
3.5.1 Sample Labels 13
3.5.2 Sample Custody Seals 14
3.5.3 Chain-of-Custody Record 14
3.6 Station and Sample Identification 14
3.7 Site Mapping 14
3.8 Investigation Derived Waste (IDW) 15
3.9 Sample Containers 15
3.10 Investigation Schedule 15
4.0 SAMPLING DESIGN AND RATIONALE 16
4.1 Sampling Design 16
42 Data Validation/Usability 16
43 Data Management/Document Control 17
5.0 QUALITY ASSURANCE 18
5.1 Organization and Responsibilities 18
5.2 Field QA/QC Samples 18
5.2.1 Matrix Spike/Matrix Spike Duplicate 18
5.2.2 Population Variability - Duplicate Samples 18
5.2.3 Sample Handling - On-Site Splits 18
5.3 Audits '. 19
5.4 Reconciliation With User Requirements 19
6.1 Facility Addresses 20
7.0 REFERENCES 21
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1.0 INTRODUCTION
On August 31, 2005, Hurricane Katrina made landfall along the Gulf coast of the
southeastern United States, causing unprecedented damage from eastern Louisiana to near
Mobile, Alabama, due to the high winds and storm surge. During the week of October 3,2005,
the USEPA Region 4, Science and Ecosystem Support Division (SESD) will collect soil and
sediment samples near impacted facilities in the affected areas in Mississippi to determine if
flooding from the storm surge released hazardous constituents and materials. The facilities being
investigated are located in the storm surge impacted portions of Hancock, Harrison and Jackson
Counties in Mississippi. This investigation was requested by the Mississippi Department of
Environmental Quality (MDEQ) and the USEPA, Region 4, Waste Management Division.
This Quality Assurance Project Plan (QAPP) for the collection of environmental samples
in the three county Gulf coastal area of Mississippi was developed by the United States
Environmental Protection Agency (EPA), Region 4, in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by
the Superfund Amendments and Reauthorization Act (SARA), of 1986 (EPA 1986). The EPA
Guidance for Quality Assurance Project Plans (EPA QA/G-5,1998) was followed during the
development of this QAPP.
Soil and sediment samples will be collected from impacted RMP (Risk Management
Plan), Tier 2, and TRI (Toxic Release Inventory) facilities in the three counties. In addition, one
facility, NCBC Gulfport, was selected because the recent flooding may have recontaminated a
partially cleaned up site. All samples will be analyzed for metals (including mercury), volatile
organic compounds and extractable organic compounds, including pesticides/PCBs, with the
exception of one site (NCBC Gulfport) where samples will be analyzed for dioxins only. At the
DuPont DeLisle facility, samples will also be analyzed for dioxin, in addition the parameters
listed above. Samples from the Chevron Refinery - Pascagoula, First Chemical, and MS
Phosphates complex will also be analyzed using gamma spectroscopy in addition to the
parameters listed above. Split samples will be offered to each facility.
Where knowledge of site specific analytes is available (such as the NCBC and DuPont
Delisle), the analyte list has been tailored for that situation. The analytical results will be
evaluated to determine if these constituents are present in soils and sediments adjacent to the
facilities, indicating a possible release to the environment, which may in turn lead to a more
thorough assessment.
1.1 Background/Site Location
Maps have been prepared showing the locations of the facilities and the proposed
sampling locations. See Figures 1- 6 in Appendix A.
1.2 Site Histories\Starus Post Katrina
These facilities were selected because they are located in areas of significant widespread
damage, and are RMP, Tier II, or TRI facilities. All have reported damage from the effects of
5
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Katrina. One additional facility (Naval Construction Battalion Center, Gulfport) was included
because the possibility of re-contamination of a wetland due to the flooding exists. It should be
noted that these facilities may be covered by more than one of these definitions.
Risk Management Plan (RMP) Facilities:
Initial reports from these facilities indicate no visible releases of hazardous constituents
beyond their perimeters. However, due to the large amounts of chemicals used and/or
manufactured by these facilities, an off-site examination has been deemed necessary. The
following information was obtained from the South Programs Section, RCRA Programs Branch.
DuPont DeLisle - Pass Christian
Operational titanium dioxide refinery facility; MDEQ visited the site (2) days after the
Hurricane along with Florida Emergency Responders. The storm surged over the site's levy (~
20 feet) and the site was under 7-9 feet of water. There is significant mud and sediment from
Bay St. Louis spread across the site; DuPont reports that they do not believe there is any process
material in the sediments. All plant process ditches, sumps and trenches were cleaned prior to
the storm and all containment and structures faired well. DuPont has been in contact with Mark
Williams of MDEQ Solid Waste issues. There was nearly 100% retention in the Waste
Management area; one small breech at WMU #11 of mostly stormwater occurred; this was
repaired. There have been no known leaks/releases to the air or water. There was a minor
chlorine leads on piping (barely noticeable by odor, much less that 1 Ib released); repairs
completed. Several railcars were blown off the rail: (13) chlorine tanks were on their sides.
These have been righted and are being placed back on the rail. No spill or release of chlorine
occurred from any railcars. Rainwater that contacts the coke and ore solid waste management
unit is contained and pumped down the deepwell when the plant is operational. FeCL2
wastewater generated from the process is necessary to mix with solid waste management area
stormwater for deepwell injection. DuPont is looking into a variety of concepts to manage the
waste water since the FeCL2 wastes will not be generated and deepwell injection will not occur
until the facility is 100%. Due to housing needs for employees and contractors, DuPont has
brought (2) package sewer treatment facilities on site and contacted MDEQ concerning permit
requirements for these units.
Aerial imagery indicates a small area of housing immediately north of the facility. This
facility is located in Figure 1.
Chevron Refinery - Pascagouta
Operating refinery at 45% of capacity today. From the Chevron webpage...Press Release
on 9/06: "Initial assessments of Chevron's Pascagoula Refinery show that a dike built following
Hurricane Georges in 1998 was successful in preventing catastrophic damage. The breached
section of the dike is expected to be repaired this week, but it will be days before a full estimate
of damage is known or when operations can be safely brought back online."
No nearby housing areas were located on the aerial imagery. This facility is located in
Figure 2.
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First Chemical Corp. - Pascagoula
Initial contact was made with Mr. Al Biehle of DuPont Corporate Remedial Group on
September 7. Most recent update came from Mr. Stephen Weishar, contractor for DuPont on
September 14. The FCC facility is currently a major producer of aniline and nitrotoluene
intermediates and derivatives, primarily nitrogen group substituted benzenes and toluenes. The
site primarily produces aniline, nitrotoluene, and nitrobenzene. Other products are
orthotoluidine, n-ethyl aniline (NBA) and n-ethylmorpholine (NEM), o-nitrotoluene (ONT), p-
nitrotoluene (PNT), m-nitrotoluene (MNT), para-toluidine (PTOL), m-toluidine (MTOL),
hydrogen, nitric acid, and various specialty products. No detailed assessment yet; however there
was no heavy damage and no releases reported. The facility has 72 SWMUs and six AOCs.
Initial contact was made with Mr. Al Biehle of DuPont Corporate Remedial Group on September
7. Two (removed hazardous waste) storage tanks were damaged, but the contents were
transferred to temporary storage tanks. The facility will be out of operations for several weeks,
but FCC hopes to be back in operation some time in October. A POTW to which the facility
pipes its partially treated effluent was damaged; however, it may be out of commission for
"months". The facility is looking for an alternate means to dispose of its wastewater.
No nearby housing areas were located on the aerial imagery. This facility is located in
Figure 2.
Toxic Release Inventory (TRD Facilities:
From the TRI website (http://www.epa.gov/tri/): The Toxics Release Inventory (TRI) is
a publicly available EPA database that contains information on toxic chemical releases and other
waste management activities reported annually by certain covered industry groups as well as
federal facilities. This inventory was established under the Emergency Planning and Community
Right-to-Know Act of 1986 (EPCRA) and expanded by the Pollution Prevention Act of 1990.
Information about these facilities is limited, but releases are known to have occurred due
to the effects of Hurricane Katrina. Region 4 On-Scene Coordinators (OSCs) have responded to
releases at the following facilities:
Omega Protein - Moss Point
No nearby housing areas were located on the aerial imagery. This facility is located in
Figure 3.
Polychemie, Inc. - Pearlington
No nearby housing areas were located on the aerial imagery. This facility is located in
Figure 4.
Ershigs Fiberglass - Biloxi
Housing was noted to the northwest, west and south in the aerial imagery. This facility is
located in Figure 5.
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Tier II Facility;
The Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) has a
requirement for facilities exceeding the EPCPvA Chemicals and Reporting Thresholds specified in
Sections 311/312 of the Act to submit a Tier II form.
Mississippi Phosphates - Pascagoula
No nearby housing areas were located on the aerial imagery. This facility is located in
Figure 2.
Data from Region 4 OSCs indicates a leak of anhydrous ammonia from an above ground
storage tank. This is a large facility that had the potential to release hazardous constituents
beyond its' operational perimeter.
Potential Release From Superfund Site:
Naval Construction Battalion Center - Gulfport NCBC Gulfport is located in the
western part of the City of Gulfport, in Harrison County, Mississippi, approximately two miles
north of the Gulf of Mexico. The off-base Area of Concern (AOC) is located immediately
downgradient (north) of Outfall 3.
The source area of dioxin contamination for the off-base AOC is the Herbicide Orange
Storage Area, designated as Site 8, at NCBC Gulfport. Between 1968 and 1977, Site 8 was used
by the USAF as a storage area for drums containing the herbicide Agent Orange, also known as
Herbicide Orange, prior to being shipped to Vietnam. Occasional spills and drum ruptures
occurred during storage and handling of the Herbicide Orange. Dioxin migration has occurred
primarily through erosion of dioxin-contaminated soil and sediment from Site 8 and its transport
downstream via ditches and canals to a small wetland area at Turkey Creek. This wetland was in
the process of being cleaned up (80% completion) when Katrina occurred, and there is a
possibility that flooding may re-contaminated the remediated area.
6.
Housing is present immediately adjacent to the wetland. This facility is located in Figure
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2.0 SAMPLING/DATA QUALITY OBJECTIVES
2.1 Data Quality Objectives
The Data Quality Objectives (DQO) process for Superfund has been used in developing
this QAPP, in accordance with the Guidance for the DQO Process (EPA QA/G-4,2000) was
followed. DQOs are useful in identifying the study objectives and decisions to be made and the
criteria by which the data will be assessed. These data are then used for decision making.
DQOs need to be established prior to data collection and integrated with the project
planning process so that sufficient data of known quality are collected to support sound decision
making. DQOs are developed using an interactive approach to decision-making based on
detailed EPA guidance. The steps are:
Problem statement
Identify the decisions
Identify the inputs into the decision
Define the boundaries of the study
Develop decision rules
Specify tolerable limits on decision errors
Optimize the design for obtaining data
2.1.1 Problem Statement
The initial step in the DQO process is to clearly define the problem so that the focus of
the investigation will be clear. During the landfall of Hurricane Katrina, a massive storm surge
flooded extensive portions of Hancock, Harrison and Jackson Counties in the Gulf Coast of
Mississippi. Within this area are located many hazardous waste facilities. It is not known what
effect, if any, the storm surge had on these facilities and the surrounding areas, with respect to
release and dispersion of hazardous materials and chemicals, particularly to residential settings
and sediment. The facilities selected for this investigation have had indications of a potential
release to surrounding soils, or conditions prior to Katrina make a release to surrounding soils
suspect The problem is identifying these potential releases to surrounding soils and sediments.
It must be strongly emphasized that this investigation is not intended to provide a comprehensive
assessment of potential releases beyond the operational perimeters of these facilities. Rather, it
is intended to provide a first look at these areas post-Katrina.
2.1.2 Identify the Decision
The purpose of this DQO step is to identify the decisions that must be supported with the
collected data. The will help define the objectives of the field investigation. The decision
needed is to determine what areas of the Mississippi Gulf Coast, in immediate proximity to the
hazardous waste facilities, may be the site of a potential release of hazardous materials to
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surrounding soils and\or sediments. To provide the supporting data for this decision, SESD will
write a report detailing the results of the investigation.
2.1.3 Decision Inputs
This step is used to identify the information needed to support the decisions. The
primary inputs needed to support the decision are surface soil and sediment samples. Analytical
results used in this decision making process will be definitive laboratory data, obtained from
analysis by a contract laboratory obtained through the EPA's Contract Laboratory Program (CLP
lab). All samples will be analyzed for metals (including mercury), volatile organic compounds
and extractable organic compounds, including pesticides and PCBs, with the exception of
samples from NCBC Gulfport where samples will be analyzed for dioxins only. Samples from
the DuPont DeLisle facility will be analyzed for dioxins in addition to these parameters.
Samples from the Chevron Refinery - Pascagoula, First Chemical, and MS Phosphates complex
will also be analyzed using gamma spectroscopy in addition to the parameters listed above.
Surface soil samples will be five-point area! composites comprised of soil from the 0" to
3" interval at each aliquot location. The sample for volatile organic compounds will be collected
from the central location. Sediment samples will also be collected from ditches or other surface
water conveyances as grab samples in the vicinity of each site to determine if releases have
occurred via these pathways.
2.1.4 Study Boundaries
The purpose of this step is to identify the boundaries of the study. The media of interest
is surface soils and sediments adjacent to the selected RMP, Tier 2 and TRI facilities, as well as
the wetland North of NCBC Gulfport. The study boundaries are defined below.
Study Area - The study area is the portions of Hancock, Harrison and Jackson counties
flooded by the storm surge associated with Hurricane Katrina. Within the larger study area are
the selected facilities. For each of the identified sites, the area to be investigated will consist of
soils and\or sediments near the facility (but outside the perimeter), including ditches or storm
water conveyances that may be present.
Sample Depth - Soil samples will be collected from the 0" to 3" below ground surface
depth. Samples collected ditches will be from a simitar interval.
Temporal Boundaries - It is anticipated that the field investigation will be conducted
the week of October 3, 2005. Additional time may be required due to the scope of the project or
delays due to inclement weather. All efforts will be made to obtain quick turnaround on the
analytical results to expedite decision making
Physical Boundaries - No sampling will be conducted beneath any concrete or asphalt
paved areas or from under any structures. Also, no samples will be collected in the immediate
vicinity of any downed power lines or under any unstable structures that may pose a collapse
hazard to the sampling team.
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2.1.5 Decision Rule
Data will be released to decision makers prior to issuance of the final report to expedite
action where warranted. The Technical Services Section in the Superfund Remedial and
Technical Services Branch, in consultation with the Regional program responsible for the
facilities and sites sampled, will review the data and make a preliminary assessment whether soil
or sediments may have been adversely impacted and whether exposure to contaminated soil or
sediment may pose an actionable human health risk. Results of the preliminary assessment will
be shared with the Office of Emergency Management and responsible program in the Region for
decisions on any further evaluations and appropriate response actions. Data from the gamma
spectroscopy analyses will be sent to Jon Richards (Region 4, Waste Management Division) for
evaluation.
2.1.6 Error Limits
Because of inherent variability introduced through sample collection, mixing, storage,
transportation, and analysis, it is important to specify the acceptable decision error rates.
Decision errors will be reduced by using standard, published protocols for sampling and
analytical procedures. Sampling protocols will follow the EISOPQAM while analytical
procedures will follow the current CLP SOW, the regional SOW for dioxins, and the NAREL
GAM-01 for gamma spectroscopy.
2.1.7 Optimize Sampling Design
The final step in the DQO process is the development of a sampling design that takes into
account data needs, key decisions, and environmental variables, such as physical and site
constraints, and how the spatial and temporal boundaries of the contamination and population at
risk will be identified. The work plan, as included in this QAPP, was developed based on the
integration of aerial imagery of the affected areas (pre-Katrina) and the EPA facility registry.
Due to the time-critical nature of the investigation, a reconnaissance of each area is not practical
or possible. As such, each sample team will approach each site with generic protocols for
sampling. As stated in Section 3.3, up to 5 samples will be collected adjacent to each facility.
Sediment samples will also be collected from ditches or other conveyances that leave the
property. It must be noted that sample locations were selected using 1:24,000 topographic maps
and quarter-quad digital orthographic quads. These maps are the most current available, but are
still several years old. In addition, they may be inaccurate by as much as 20' to 40'.
Samples will be collected on an authoritative basis, from areas deemed most likely to be
impacted. Specifically, soils will be sampled adjacent to facility perimeters and sediment
samples from drainage pathways. If samples cannot be safely collected, the sampling team will
note the location and report it to the field project leader. Proposed sampling locations are
presented in Table 1.
DuPont DeLisle, see Figure 7.
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Two grab sediment samples will be collected from ditches draining the facility to St.
Louis Bay. Three additional composite surface soil samples will be collected between the
facility and a residential area immediately north of the facility.
Chevron Refiner)'
see Figure 8.
Pascagoula, First Chemical Corporation, and Mississippi Phosphates,
Because these selected facilities are adjacent to each other, sampling will occur around
these facilities as a unit. Grab sediment samples will be collected from Bayou Cassette north of
the facilities, from the Chevron Ditch south of the facilities, and the unnamed ditch originating
on the east side of the facilities. In addition, three composite surface soil samples will be
collected beyond the northern perimeter of the facility complex, and three additional composite
soil samples will be collected south of the facility complex.
Omega Protein, see Figure 9.
Three grab sediment samples will be collected from the north bank of the Escatawpa
River, two at the facility and one downgradient. No upland soi! samples are proposed for this
facility because Morton International (which is not listed for sampling in this effort) is
immediately north.
Port Bienville Industrial Park (Polychemie, Inc.), see Figure 10.
Grab sediment samples will be collected at the three indicated locations to determine if a
potential release occurred as the storm surge receded. Two composite surface soil samples will
be collected at the indicated locations to determine if contaminants may have moved further
inland from the facility on the rising flood waters.
Ershigs Fiberglass, see Figure 11.
Four composite surface soil samples will be collected as shown, to determine if
contaminants may have been deposited between the facility and nearby housing. An additional
grab sediment sample will be collected from a small inlet draining the facility to Biloxi Bay.
Naval Construction Battalion Center (NCBC Gulfport), see Figure 12.
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Table 1
Sample Rationale and Locations
Facility
DuPont DeLisle
DuPont DeLisle
DuPont DeLisle
DuPont DeLisle
DuPont DeLisle
Chevron, First
Chemical, MS
Phosphates
Chevron, First
Chemical, MS
Phosphates
Chevron, First
Chemical, MS
Phosphates
Chevron, First
Chemical, MS
Phosphates
Chevron, First
Chemical, MS
Phosphates
Chevron, First
Chemical, MS
Phosphates
Chevron, First
Chemical, MS
Phosphates
Chevron, First
Chemical, MS
Phosphates
Sample ID
DU-SD-001
DU-SD-002
DU-SF-003
DU-SF-004
DU-SF-005
CFM-SD-
001
CFM-SD-
002
CFM-SD-
003
CFM-SF-
004
CFM-SF-
005
CFM-SF-
006
CFM-SF-
007
CFM-SF-
008
Location
Dirt road and
Ditch
Southwest of
Site
Dirt road and
Ditch South of
Site
Immediately
North of Site
Immediately
North of Site
Immediately
North of Site
Bayou
Cassette,
North of
complex
Chevron
Ditch, South
of complex
Unnamed
ditch,
Southeast of
complex
North of
complex
North of
complex
North of
complex
North of
complex
South of
complex
Rationale
Evaluate potential for hazardous constituents
to have drained from site via ditch.
Evaluate potential for hazardous constituents
to have drained from site via ditch.
Evaluate potential for hazardous constituents
to have moved North with storm surge.
Evaluate potential for hazardous constituents
to have moved North with storm surge.
Evaluate potential for hazardous constituents
to have moved North with storm surge.
Evaluate potential for hazardous constituents
to have moved North with storm surge.
Evaluate potential for hazardous constituents
to have moved drained with storm surge.
Evaluate potential for hazardous constituents
to have drained South with storm surge.
Evaluate potential for hazardous constituents
to have moved North with storm surge.
Evaluate potential for hazardous constituents
to have moved North with storm surge.
Evaluate potential for hazardous constituents
to have moved North with storm surge.
Evaluate potential for hazardous constituents
to have moved North with storm surge.
Evaluate potential for hazardous constituents
to have moved South with storm surge.
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Table 1, Continued
Chevron, First
Chemical, MS
Phosphates
Chevron, First
Chemical, MS
Phosphates
Omega Protein
Omega Protein
Omega Protein
Polychemie
Polychemie
Polychemie
Polychemie
Polychemie
Ershigs
Fiberglass, Inc.
Ershigs
Fiberglass, Inc.
Ershigs
Fiberglass, Inc.
Ershigs
Fiberglass, Inc.
Ershigs
Fiberglass, Inc.
CFM-SF-
009
CFM-SF-
010
OP-SD-001
OP-SD-002
OP-SD-003
PO-SD-001
PO-SD-002
PO-SD-003
PO-SF-004
PO-SF-005
ER-SF-001
ER-SF-002
ER-SF-003
ER-SF-004
ER-SD-005
South of
complex
South of
complex
Bank of
Escatawpa
River, South
of Site
Bank of
Escatawpa
River, South
of Site
Bank of
Escatawpa
River,
downstream of
Site
Wetland North
of Site
Canal West of
Site
Canal
downgradient
of Site
Southeast of
Site
Southwest of
Site
Northwest of
Site
West of Site
Southwest of
Site
South of Site
Southeast of
Site
Evaluate potential for hazardous constituents
to have moved South with storm surge.
Evaluate potential for hazardous constituents
to have moved South with storm surge.
Evaluate potential for hazardous constituents
to have drained South with storm surge.
Evaluate potential for hazardous constituents
to have drained South with storm surge.
Evaluate potential for hazardous constituents
to have moved downstream with storm surge.
Evaluate potential for hazardous constituents
to have drained North with storm surge
Evaluate potential for hazardous constituents
to have drained West with storm surge
Evaluate potential for hazardous constituents
to have moved downgradient with storm
surge
Evaluate potential for hazardous constituents
to have moved Southeast with storm surge
Evaluate potential for hazardous constituents
to have moved Southwest with storm surge
Evaluate potential for hazardous constituents
to have moved Northwest with storm surge
Evaluate potential for hazardous constituents
to have moved West with storm surge
Evaluate potential for hazardous constituents
to have moved Southwest with storm surge
Evaluate potential for hazardous constituents
to have moved South with storm surge
Evaluate potential for hazardous constituents
to have drained Southwest with storm surge
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Table 1, Continued
NCBC Gulfport
NCBC Gulfport
NCBC Gulfport
NCBC Gulfport
NCBC Gulfport
NC-SD-001
NC-SD-002
NC-SD-003
NC-SD-004
NC-SD-005
Wetland North
of NCBC
Wetland North
of NCBC
Wetland North
ofNCBC
Wetland North
ofNCBC
Wetland North
ofNCBC
Evaluate potential for TCDD to have
redoposited in remediated portion of wetland
due to storm surge
Evaluate potential for TCDD to have
redoposited in remediated portion of wetland
due to storm surge
Evaluate potential for TCDD to have
redoposited in remediated portion of wetland
due to storm surge
Evaluate potential for TCDD to have
redoposited in remediated portion of wetland
due to storm surge
Evaluate potential for TCDD to have
redoposited in remediated portion of wetland
due to storm surge
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3.0 INVESTIGATION MANAGEMENT PLAN
3.1 Field Project Responsibilities
The overall field investigation/sampling phase of the project and any field
decisions will be the responsibility of the Field Project Leader, Mike Neill. The Field
Project Leader will be responsible for the following field activities:
Ensure that all field activities are communicated and coordinated with the On-
Scene Coordinator, Benjamin Franco.
Monitoring overall field project quality control.
Coordinating field scheduling of work with other Section and Division
activities.
* Overseeing and managing field technical resources including non-sampling
field activities.
Coordinating sample analyses with the laboratory.
The site Health and Safety Officer (HSO), Jon Vail, will be responsible for
monitoring the health and safety of the sampling/investigative personnel.
The following is a partial list of the personnel that will be involved in the field
operations for the Katrina Response Environmental Assessment and their responsibilities:
Mike Neill, Field Project Leader
Jonathan Vail, HSO
Dan Thoman, Sample Team Leader
Brian Striggow, Sample Team Leader
Stacy Box, Sample Team Leader
Sharon Matthews, Sample Team Leader
Steve Pilcher, ESAT Contract Support for Sample Processing and Shipment
This list is subject to change and may be supplemented by other resources,
including contract personnel, to be provided on an as-needed basis. All field
investigators are required to have 40 hours of hazardous waste site safety training, and
specific knowledge and expertise of sample collection and safety techniques in
accordance with the Region 4 EPA Environmental Investigations Standard Operating
Procedures and Quality Assurance Manual (EISOPQAM), November 2001.
3.2 Site Control and Access
Post-Katrina conditions regarding control and access at each location are not
known. It is likely that, at some locations, ingress and egress controls are no longer
present or operable. Residents may be present, as well as construction workers
mobilized for the clean-up effort. Any people present on-site will be asked to remain
clear of sampling activities for their own safety. If investigation activities cannot, in the
11
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opinion of the field project leader, safety officer, or sample team leaders, be conducted
due to the proximity of unauthorized persons, then operations will cease until such time
as they can be safely resumed.
Access arrangements for RMP facilities will be made by Lael Butler, Chief, South
Programs Section, RCRA Programs Branch. Access arrangements for TRI and Tier II
facilities will be made by Ben Franco. Access to the NCBC will be arranged by Michelle
Thornton. If SESD is refused access to the site, this will be recorded in the field log book
and sampling personnel will immediately leave the property until such time as permission
or authority to sample can be obtained or re-established.
During the investigation, field vehicles will be located such that they do not
interrupt or impede flow of traffic through the area. Each field vehicle will maintain a
copy of this QAPP and the site-specific Health and Safety Plan during all investigation
activities.
3.3 Sample Collection and Handling Procedures
All samples will be collected, containerized, preserved, handled, and documented
in accordance with the EISOPQAM. A copy of the manual, in addition to the site-
specific Health and Safety Plan, will be maintained by the field project leader for
reference during all phases of the field sampling activities. If any deviations in sampling
procedures are used, these deviations should be discussed and approved by the field
project leader and will be recorded in the field log books.
The surface soil samples will, where appropriate, be collected as 5-point
composites ("X" pattern, with aliquots in center and on corners) using stainless steel hand
augers. The corners of the pattern will be 100' from the center. The pattern size,
however, should be appropriate to characterize the area in question and it may be
appropriate, at some locations, to use an irregular pattern. The aliquot pattern actually
used will be sketched in the field book. The central aliquot location for each sample will
be located using GPS to at least one meter accuracy and the locations of the other aliquots
will be determined by measuring the azimuth and distance from the central aliquot to the
outer aliquots. Each aliquot will be comprised of the 0" to 3" below ground surface
interval. All grass, roots and other vegetative material, as well as small rocks or stones,
will be removed from the sample matrix during sample mixing, prior to containerization.
Sediment samples will be collected at the selected locations using stainless steel
scoops, stainless steel spoons and/or stainless steel hand augers. The depth to be sampled
should not exceed 6" but may be less.
Soil samples will be collected, as described in Section 2.1.7, using hand augers,
spoons, or scoop as appropriate, and the aliquots will be thoroughly mixed in glass pans.
Samples for volatile organic compound analyses will be collected prior to mixing with
minimum disturbance from the central aliquot in Encoreฎ sample containers using EPA
12
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Method 5035. After mixing, the samples will be placed in the appropriate containers and
placed on ice, as specified in Appendix A of the Region 4 EISOPQAM.
3.4 Sample Analysis and Validation
All samples will be analyzed for metals, volatiles, semi-volatiles, pesticides and
PCBs, in accordance with the current Contract Laboratory Program Statement of Work,
again with the exception of the NCBC Gulfport facility where samples will be analyzed
for dioxins only. Samples from the DuPont DeLisle facility will be analyzed for dioxins
in addition to these parameters. Samples from the Chevron Refinery - Pascagoula, First
Chemical, and MS Phosphates complex will also be analyzed for Radium-226 and
radionuclides using gamma spectroscopy in addition to the parameters listed above.
Completeness will be achieved for at least 99 percent of all the samples collected
(1 percent may be lost as a result of sample breakage in the laboratory or during
transport). It is also anticipated that 99 percent of the samples analyzed will result in
valid data. Using sampling and analytical procedures as outlined in the Region 4
EISOPQAM and the Region 4 ASBLOQAM errors introduced in the decision making
process will be minimized.
3.5 Chain of Custody
All chain-of-custody and record keeping procedures will be in accordance with
the EISOPQAM. Chain-of-custody procedures are comprised of the following elements;
1) maintaining sample custody and 2) documentation of samples for evidence.
if:
As defined in the EISOPQAM, a sample or other physical evidence is in custody
it is in the actual possession of an investigator;
it is in the view of an investigator, after being in their physical possession;
it was in the physical possession of an investigator and then it was secured to
prevent tampering; and/or
it is placed in a designated secure area.
3.5.1 Sample Labels
Sample labels will be prepared and affixed to each sample container sent to either
the SESD or CLP laboratory. The labels will be prepared using waterproof, non-erasable
ink as specified in Section 3 of the EISOPQAM.
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3.5.2 Sample Custody Seals
The samples will be sealed as soon as possible following collection as specified in
the EISOPQAM. The custody seal will bear the date and the initials of the sample
custodian at the time it was sealed.
3.5.3 Chain-of-Custody Record
The field Chain-Of-Custody Record is used to record the custody of all samples
sent to the laboratory. All of these samples shall be accompanied by a Chain-Of-Custody
Record. The Chain-Of-Custody Record documents transfer of custody of samples from
the sampler/sample custodian to another person, the laboratory, or other organizational
elements. To simplify the Chain-of-Custody Record and eliminate potential litigation
problems, as few people as possible should have custody of the samples or physical
evidence during the investigation.
The Chain-Of-Custody Record also serves as a sample logging mechanism for the
laboratory sample custodian. A Chain-of-Custody Record will be completed for all
samples collected for this investigation. A separate Chain-of-Custody Record should be
used for each final destination or laboratory utilized during the investigation.
3.6 Station and Sample Identification
Sample identification numbers will be assigned using the following format:
XXX##YYZ, where:
XXX is a unique identifier for the RMP, Tier 2, TRI, or NCBC facility
## indicates surface soil (SF) or sediment SD
YY indicates the sample location number, i.e., 01 for the facility location
Z identifies splits or duplicates: "S" is split; "D" is duplicate
A split sample is a sample comprised of two samples, the primary sample and the
designated split sample, that are collected from the same sample material that has been
homogenized in a glass pan prior to filling of the sample containers. Assuming a well
mixed sample, a split helps evaluate both the field and laboratory procedures. A
duplicate sample is a co-located sample, usually collected less than six inches from the
primary sample at a location and is collected to show variability of the matrix sampled.
3.7 Site Mapping
The locations of all samples will be logged using a GPS capable of one meter
accuracy, as specified in Section 2.1.7. If a sample location is in an area where a GPS
signal cannot be received, sampling stations will be located using a tape and compass
from a known point.
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3.S Investigation Derived Waste (IDW)
The following identifies other types of investigation derived waste (IDW) that
could be generated during the investigation and their disposition:
Gloves, Tyvekฎ suits, paper towels, and other miscellaneous trash generated
during the investigation will be bagged and placed in a dumpster for disposal
at a Class D landfill. It is not anticipated that this material will constitute a
significant threat to human health and the environment..
3.9 Sample Containers
Sample containers for samples shipped to either the SESD laboratory or a CLP
laboratory will be obtained from the SESD Field Equipment Center in Athens, Georgia.
These containers comply with the requirements specified in Appendix A of the
EISOPQAM. Table 2 lists the container types and numbers to be used:
Table 2
Sample Containers and Holding Times
Analytes
Metals
VOCs
Semi-Volatiles.,
Pesticides, PCBs
Dioxins
Radium 226 and
gamma
Spectroscopy
Containers
1 8oz. glass
3 EnCore
1 8oz. glass
1 8oz. glass
1 8oz. glass
Splits
1 8oz. glass
3 EnCore
1 8oz. glass
1 8oz. glass
1 8oz. glass
Dups
2 8oz. glass
6 EnCore
2 8oz. glass
2 8oz. glass
2 8oz. glass
MS\MSD
180 days
48 hours
14 days
30 days
180 days
It should be noted that time constraints do not allow for the normal QA/QC
checks for the pre-cleaned sample containers as specified in the EISOPQAM.
3.10 Investigation Schedule
The field investigation is scheduled to begin during the week of October 3,2005.
During the investigation SESD will:
Collect soil and sediment samples from the identified properties within the
area affected by the Katrina storm surge.
Collect location data for sampling points using GPS techniques (Section 3.7).
This data will be used to produce site maps with sampling locations.
Collect and properly dispose of any non-hazardous IDW generated.
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4.0 SAMPLING DESIGN AND RATIONALE
Surface soil and sediment samples will be collected during this field investigation.
The collection of these samples will help determine if an unacceptable risk to human
health exist in the affected areas.
4.1 Sampling Design
Seven RMP, Tier II, and TRI facilities were selected for this investigation. In
addition, one superfund site that had the potential to re-release contaminants was also
selected. Three to ten sampling stations were selected for each site (or complex of sites).
These sampling stations were selected to provide preliminary information on potential
releases to nearby housing and sediments.
4.2 Data Validation/Usability
The data generated from the split and duplicate samples will be validated in
accordance with the ASBLOQAM.
Analyses for metals, VOCs, semivolatiles, pesticides and PCBs will be performed
by CLP laboratories. This data will be validated according to the National Functional
Guidelines for Organic Data Review, OSWER 9240.1-05-A-P (October 1999), the
National Functional Guidelines for Inorganic Data Review, OSWER 9240.1-45 (October
2004) and Region 4's Data Validation Standard Operating Procedures for Contract
Laboratory Program Routine Analytical Services, Revision 2,0 (January 1999).
The dioxin/furan analysis will be performed by a laboratory contracted to EPA
(Paradigm). Validation of the dioxin data will be performed by ESAT using the National
Functional Guidelines for Dioxin Data Review, OSWER540-R-02-003 (August 2002)
and Region 4's Data Validation Standard Operating Procedures for Dioxin Data Version
3.0 (May 2002) documents. The dioxin data will consist of a Level 4 - CLP type data
package that contains the C-O-Cs, instrument raw data, initial and/or continuing
calibration data/curves, bench sheets/sample preparation information, QA/QC
data/information, and case narrative detailing any problems associated with this data.
The gamma spectroscopy analyses will be performed by the National Air and
Radiation Environmental Laboratory (NAREL), using method NAREL GAM-OI.
Review and validation of all data (including screening data) from samples
collected during this investigation will be completed in an expeditious manner, utilizing
quick turnaround.
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43 Data Management/Document Control
A final report will be written at the conclusion of the investigation in accordance
with the EISOPQAM. All environmental and QA/QC data will be evaluated and data
sheets will be attached to the report. Significant QA/QC issues regarding sample
collection, handling, and analysis will be identified in the report. Results of any audits
will also be included in the report. Project files will be maintained in accordance to the
EISOPQAM. The field project leader will review the file at the conclusion of the project
to ensure completeness. Laboratory and screening data will be released to the On-Scene
Coordinator as it becomes available, if desired.
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5.0 QUALITY ASSURANCE
Quality assurance (QA) procedures must begin in the planning stage and continue
through sample collection, analyses, reporting and final review. The methods that will be
used to ensure data quality are discussed below.
5.1 Organization and Responsibilities
The field project leader has overall responsibility for field QA, Off-site
laboratory analyses for samples collected during the investigation will be conducted by
the ASB or the CLP. The precision, comparability and accuracy of sample analyses will
be addressed in accordance with the ASBLOQAM.
5.2 Field QA/QC Samples
5.2.1 Matrix Spike/Matrix Spike Duplicate
Samples for laboratory quality control analyses (matrix spike/matrix spike
duplicate, MS/MSD) will be designated as specified in the EISOPQAM. One MS/MSD
sample will be designated for every 20 samples split to the SESD or CLP laboratories.
5.2.2 Population Variability - Duplicate Samples
Co-located duplicate samples will be collected at five percent of the sample
locations to provide data for an assessment of the variability of constituents within the
designated areas. Following collection of the initial sample that is to be duplicated, the
sample will be re-collected with clean equipment. The letter 'D' will be appended to the
sample ID used for the primary sample at the duplicated location for the duplicate
containers being sent to the laboratory (see Section 3.6). One duplicate sample will be
collected per site or complex of sites.
5.2.3 Sample Handling - On-Site Splits
At five percent of the locations, split samples will be collected to assess sample
handling variability. Following collection and mixing of the sample that is to be split, the
sample will be apportioned into two identical sets of sample containers. The letter'S'
will be appended to the sample ID used for the primary sample to indicate the split
sample being sent to the laboratory (see Section 3.6). One split sample will be collected
per site, or complex of sites.
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5.3 Audits
Routine audits of laboratory activities may be conducted by the Inorganic and
Organic Chemistry Section Chiefs. Independent laboratory audits may be conducted by
the Region 4, QA Officer or her representative(s). Field audits may be conducted by the
Chief of the Superfund and Air Section. Any problems identified during these audits will
be addressed in a memo to the Field Project Leader who will take immediate steps to
correct the identified discrepancies.
5.4 Reconciliation With User Requirements
In order to determine whether the data generated are usable for their intended
purpose and meet the DQOs outlined for this particular project, the data will undergo
further assessment. This assessment will determine whether the data were collected in
the prescribed locations and depths, whether the prescribed extraction, digestion and
analytical methodologies were used and whether the laboratory noted any problems
associated with sample analysis or with the requisite QA/QC sample analysis.
Essentially this process seeks to reconcile the analytical data to the project-specific
DQOS and if any issues are raised during this assessment would require additional
evaluation of the data and may require restrictions in its use.
were the samples collected in the correct location?
were the samples collected using the appropriate sample containers and
preservative?
were the samples handled properly and did they arrive at the laboratory a 4 ฐC
or less?
were the samples recorded properly on the chain-of-custody form?
was the correct digestion/extraction and analysis performed?
* were the QA/QC results within the established limits?
were any problems noted by the laboratory?
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6.0 PROJECT SCHEDULE
Field work for this project is scheduled to begin Monday, October 3,2005 and
will continue until completed (maximum 10 days).
Lab analyses will be completed within 14 days following receipt by the CLP
Laboratory. The analytical data will then be subject to validation which will add an
additional 14 days before the final data package is available to the Project Leader.
Interim data reports and the final comprehensive report will be issued.
6.1 Facility Addresses
PolyChemie, Inc.
Port Bienville Industrial Park Rd. D.
Pearlington, MS 39572
Omega Protein
5735 Elder Ferry Rd.
Moss Point, MS 39563
Ershigs Fiberglass
200 Fifth St. (also 220 Fifth St.)
Biloxi,MS 39530-4527
DuPont DeLisle Plant
7685 Kiln DeLisle Rd.
Pass Christian, MS 39571
Chevron Refinery - Pascagoula
250 Industrial Road
Pascagoula, MS 39581-3201
First Chemical Corp.
1001 Industrial Rd.
Pascagoula, MS 39581-3237
Mississippi Phosphates
601 Industrial Rd
Pascagoula, MS 39568
Commanding Officer
Naval Construction Battalion Center (NCBC Gulfport)
5200 CBC 2nd St.
Gulfport, MS 39501-5001
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7.0
1.
2.
3.
4.
5.
6.
7.
REFERENCES
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) and the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
U.S. EPA, EPAQA/G-4, Guidance for the Data Quality Objectives
Process, EPA/600/R-96/055, August 2000.
U.S. EPA EPAQA/G-5, EPA Guidance for Quality Assurance Project
Plans, EPA/600/R-98/018, February 1998.
U.S. EPA, Region 4r Analytical Support Branch Operations and Quality
Control Manual Revision 1, (ASBLOQAM). July 2001.
U.S. EPA, Region 4, Environmental Investigations Standard Operating
Procedures and Quality Assurance Manual (EISOPQAM). November
2001.
USEPA Contract laboratory Program Statement of Work For Inorganic
Analysis, ILM05.3 March 2004.
http:/Avvvw. epa.
USEPA Contract laboratory Program Statement of Work For Inorganic
Analysis, OLM04.2, May, 1999.
21
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Appendix A
Figures
22
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I
o
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Appendix B
Laboratory Quantitation Limits
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"i \. -: J ป;>i" i , ;. & : p. > ':
if. S .i,;.-.-ป-.!:a.Sซ;-i*';Si:ii<ซ.
'ซ-*>-.!
SV-i*-S
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JK-iS-S
JS. ta!*fiซ<.
i'.'Si lii, It ft.-'j
4.5* i.'5 ?<:>
V ,Wj 5rv *'T'^
v., iv ฅ>$ ฅi.v*
V.ft >:': ift
IV.:':U S.i1! V.tf
S.ftif S.A .Vป<>
o.fc; s.a i.a
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..fi' i-.S
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:.-vS {..o ;.,^ j?.^
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..ฅS f..
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36
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37
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1. .; A,, V-":V : :
;:.'; : <-,W- ;;
;>ป?,'.*>?'ป.'
h.; 4-..': I, . ;:;.:-,,>>,..
:-.::.ป'>'.,: -.; ;;"->^.-; -,'.
38
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39
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40
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CHLORINATED D1BENZO-P-DIOXIN/CHLORINATED DIBENZOFURAN (CDD/CDF)
TARGET COMPOUND LIST (TCL) AND MINIMUM QUANTITATION LIMITS
CDD/CDF
2378-TCDD
12378-PeCDD
123678-HxCDD
123478-HxCDD
123789-HxCDD
1234678-HpCDD
OCDD
2378-TCDF
12378-PeCDF
23478-PeCDF
123678-HxCDF
123789-HxCDF
123478-HxCDF
234678-HxCDF
1234678-HpCDF
1234789-HpCDF
OCDF
CAS No.
1746-01-6
40321-76-4
57653-85-7
39227-28-6
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
57117-44-9
72918-21-9
70648-26-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
WATER
(pg/L)
10
50
50
50
50
50
100
10
50
50
50
50
50
50
50
50
100
SOLIDS
(ng/Kg)
1.0
5.0
5.0
5.0
5.0
5.0
10
1.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
10
41
ft
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RADIOCHEMICAL MDCs
Analysis
Type
Drinkin
g Water
Aliquot
Size
Drinkin
g Water
MDC
Water
(other)
Aliquot
Size
Water
(other)
MDC
Solids
Aliquot
Size
Air
MDC
Gross Alpha
500 mL
200 mL
4.4
pCi/L
0.1 g
Gross Beta
500 mL
200 mL
3.5
pCi/L
Radium-226
1L
0.02
pCi/L
Radium-228
1L
1 pCi/L
Iodine-131
2L
0.7
pCi/L
Strontium-
89
2L
IpCi/L
Strontium-
90
2L
1 pCi/L
Uranium-
234, 235,
238
Thorium-
230,232
Plutonium-
238, 239
Americium-
241
1L
0.1
pCi/L
Thorium-
227
1L
0.2
pCi/L
Thorium-
228
Tritium
1L
lOmL
0.15
pCi/L
0.1
nCi/L
42
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Requesting Program:
Responsibilities:
Media Contact
Project Lead:
Responsibilities:
Field Lead:
Responsibilities:
Task Leads:
Responsibilities:
Appendix C
Project/Task Organization
EPA Region 4 Waste Management Division
Mississippi Department of Environmental Quality
EPA WMD and MDEQ will be the end users of the data.
Data collected beyond the perimeter of facilities will be
used to evaluate potential releases. Data collected from
areas where potentially hazardous debris was deposited will
be used to determine if hazardous constituents are present
in remaining soils\sediments.
Antonio Quinones, Chief, Ecological Assessment Branch
Fred Sloan
Project lead for developing the study plan, collation of all
study data, and report preparation.
Mike Neill
Project lead for field activities/data collection
Health and Safety Officer\
Sample Team Leader:
Sample Team Leader:
Sample Team Leader
Sample Team Leader
Sample Team Leader
Sample Processing\
Sample Shipment
Jon Vail
Brian Striggow
Dan Thoman
Stacy Box
Sharon Matthews
ESAT Contract personnel
Task leads are responsible for leading field data collection
activities for specific tasks.
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