6.1 Quality Assurance Strategy

The Enhanced Source Removal project was designed to address the following research objectives:

• To evaluate, on a common basis, the performance of nine technologies for extracting NAPL from saturated subsurface formations.



• To compile performance and design data needed to facilitate the further development and implementation of the technologies which exhibited potential for NAPL removal.

After the selection of Operable Unit 1 (OU1) at Hill Air Force Base as the demonstration site, the following ancillary objectives were added by the Base Environmental Restoration Directorate in order to address specific remediation needs for the site:

• To obtain and document data of suitable quantity and quality to evaluate these innovative technologies in Feasibility Studies (FS) for their potential inclusion in the Record of Decision (ROD) for OU1.



• To obtain design information necessary for scaling up and implementing the technologies at Hill AFB.

Thus, the demonstrations served both research and regulatory purposes with Hill AFB assuming responsibility of combining research and regulatory data requirements to meet site specific needs. Because of the added objectives, the demonstrations were conducted as Treatability Studies. To expedite the initiation of the field work and to simplify regulatory review of work plans, the study was planned and conducted in two phases. The first phase included site characterization and test cell location, cell installation, cell characterization, and laboratory studies required to design the field demonstrations. The second phase included the technology demonstrations, performance assessment and comparison, and documentation of results. A detailed Work Plan was prepared for each phase of the study.

Careful attention was given to the design of all aspects of the project in order to assure the collection of scientifically valid and defensible data. This included the development of a Quality Assurance Project Plan (QAPP) for each phase of the study. The QAPP for Phase II of the project is included as Section 6.2 of this document. These quality assurance plans document procedures for the collection, processing, and interpretation of data and were followed, to the extent possible, for all levels of data (Levels I, II, & III) collected under this project. In some cases, however, deviations from the plans were necessary during the collection of Level I or Level II data. For example, because of the research nature of some of the tasks, standard analytical methods were not available or were deemed less reliable than experimental methods. In all cases, the need for good analytical and quality control procedures was emphasized.

To the extent possible, samples from all the demonstration cells were analyzed at a common laboratory to ensure consistency. The bulk of all soil core analyses were conducted at Michigan Technological University with selected duplicate samples analyzed at the Environmental Protection Agency Robert S. Kerr Environmental Research Center or at a certified commercial laboratory. Tracer and ground-water samples were generally analyzed by the university or organization conducting the demonstration. For these samples, standard operating procedures were developed and followed by each laboratory. Selected duplicates of these samples were analyzed by ManTech Environmental Services, a contractor for EPA.

6.1.1 Data Quality Evaluations

6.1.1.1 Hill Air Force Base through a contract with Montgomery Watson conducted an assessment of soil and ground-water sample data collected as part of this study( ). The data were evaluated with respect to comparability, precision, accuracy, representativeness, and completeness. The report concluded that the data collected as a part of this project met the data quality objectives.

6.1.1.2 Quality control information accompanying reports of soil sample analysis for each demonstration and each sampling event indicated that the data were of consistently high quality and met the data quality objectives. These unpublished reports were prepared by Michigan Technological University and submitted to the EPA Subsurface Protection and Remediation Division.