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Nyanza Superfund Site SAP: Rev#2 October 2014 Page 1 of 11 FINAL SAMPLING AND ANALYSIS PLAN Fish sampling in Reservoir 2 of the Sudbury River Nyanza Superfund Site, Framingham, Massachusetts October 2014 Superfund SAP Acceptance SITE: ____j^V£KL2S. IX EPA Projepi Officer Acceptance:-' / OTHER: Q P-J/M Bart Hoskins, EPA/OEME/ECAf* Date Biology Laboratory Lrfat! L V // ij'i *Dave McDonald, EPA/OEME/ECA 1 Date ECA Quality Assurance Officer *^> /°\ /ol Diane Switzer, EPA/OEME/ECA \\Date TephLaw, Inc./ESAT Program Manager Acceptance: / '/Co ./JtASAJ /oX/'** f kbuis Maori Date Tech Law, IncJESAT Field Sampling Coordinator Acceptance: . - z^z^/Z/v Michael Ferrier Date SEMS DocID 590596

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Page 1: FINAL SAMPLING AND ANALYSIS PLAN (SAP), FISH SAMPLING …

Nyanza Superfund Site SAP: Rev#2 October 2014 Page 1 of 11

FINAL SAMPLING AND ANALYSIS PLAN

Fish sampling in Reservoir 2 of the Sudbury River Nyanza Superfund Site, Framingham, Massachusetts

October 2014

Superfund

SAP Acceptance SITE: ____j V£KL2S.

I X EPA Projepi Officer Acceptance:-' / OTHER: Q

P-J/M Bart Hoskins, EPA/OEME/ECAf* Date

Biology Laboratory Lrfat!

L V // i j ' i *Dave McDonald, EPA/OEME/ECA 1 Date

ECA Quality Assurance Officer

* > /°\ /ol Diane Switzer, EPA/OEME/ECA \\Date

TephLaw, Inc./ESAT Program Manager Acceptance:

/ '/Co ./JtASAJ /oX/'** f kbuis Maori Date

Tech Law, IncJESAT Field Sampling Coordinator Acceptance:

. - z^z /Z/v Michael Ferrier Date

SEMS DocID 590596

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Nyanza Superfund Site SAP: Rev#2 October 2014 Page 2 of 12

TABLE OF CONTENTS

1.0 PROJECT OBJECTIVES 4 1.1 Project Organization 4

2.0 INTRODUCTION 4

3.0 PROJECT DESCRIPTION 4

4.0 FIELD SAMPLING 4.1 Introduction 5 4.2 Fish sampling 6

5.0 PROCESSING AND ANALYSES 7 5.1 initial Sample Handling, Processing and Preservation 7 5.2 Fish tissue processing 1 8 5.3 Analytical Parameters g

6.0 DATA USAGE 10

7.0 SCHEDULE OF TASKS 10

8.0 FIELD SAFETY

9.0 DATA QUAUTY REQUIREMENTS AND ASSESSMENT 11 9.1 Precision and Accuracy 11 9.2 Data Representativeness 12 9.3 Data Comparability and Completeness 12 9.4 Validation and Usability 12

9.4.1 Data Review. 12 9.4.2 Corrective Action 12

10.0 CLOSE-OUT REPORT 12

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TABLES

TABLE 1: KEY PROJECT PERSONNEL 4

TABLE 2: NEW ENGLAND REGIONAL LABORATORY STANDARD OPERATING PROCEDURE FOR SAMPLE COLLECTION AND PROCESSING 6

TABLE 3: ANALYTICAL PARAMETERS FOR THE FISH TISSUE SAMPLES 8

TABLE 4: LABELING FISH SAMPLES AFTER TISSUE PROCESSING A 9

TABLE 5: FISH TISSUE ANALYTICAL METHODS AND DQOS 10

ATTACHMENTS

Attachment 1: Fillet fish data collected during the 2003 sampling effort at Reservoir 2.

Attachment 2: Fish data collected during the 2008 sampling effort at Reservoir 2.

Attachment 3: Fish sampling requirements for the 2014 sampling effort at Reservoir 2.

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1.0 PROJECT OBJECTIVES

1.1 Project Organization

Table 1 lists key personnel involved in project organization, field sampling, chemical analyses, and data quality assurance, if necessary, the ESAT field sampling coordinator will communicate with the Environmental Protection Agency (EPA) Task Order Contract Officer Representative (TOCOR) to address any outstanding issues related to field sampling, sample handling, or sample preservation.

Table 1: Key Project Personnel

Name Title Organization Telephone Number

Bart Hoskins Project Lead EPA Region 1 (617)918-8375 Dave McDonald Biology Laboratory Lead EPA Region 1 (617)918-8609

Louis Macri Program Manager ESAT Region 1 TechLaw, Inc. (978) 275-9731

Michael Ferrier Field Sampling and Laboratory Coordinator ESAT Region 1 TechLaw, Inc. (617)918-8612

ESAT-Enviroflmental Services Assistance Team

This SAP is organized as follows: Section 2.0 provides an introduction; Section 3.0 provides a project description. Section 4.0 describes the field sampling, Section 5.0 discusses fish tissue processing and Hg analyses, Section 6.0 describes the data usage, Section 7.0 provides the schedule for the various tasks under this Sampling and Analysis Plan (SAP), Section 8.0 summarizes field safety issues, Section 9.0 describes the data quality requirements and assessments and, Section 10.0 describes the contents of the close-out report

2.0 INTRODUCTION

This SAP outlines a program to collect fish from the three lobes of Reservoir 2 (Reach 3) on the Sudbury River in Framingham, MA. This reservoir is located downstream of the Nyanza Chemical Waste Dump Superfund Site in Ashland, MA. Total mercury (tHg) in fish tissue samples will be determined using both Cold Vapor Atomic Fluorescence Spectrometry (CVAFS) using method 1631E and a Milestone Direct Mercury Analyzer (DMA). All fish collected will be aged. Otoliths retrieved during fish tissue processing will be the primary method for aging, while scales will also be collected from iargemouth bass and yellow perch as a second aging resource if otoliths cannot be retrieved, are broken, or cannot be read. The objective of this program is to determine if tHg levels measured in fish collected from Reservoir 2 have changed compared to the fish tHg levels measured during past sampling efforts in 2003 and 2008. The data from this effort will be used in ongoing trend analysis offish age and mercury concentrations in this reach, and to update the human health risk calculations performed for the 2006 human health risk assessment for Nyanza OUIV.

^PROJECT DESCRIPTION

3.0 PROJECT DESCRIPTION

This project will provide fish tissue tHg data for Iargemouth bass, yellow perch, and bullheads, (brown and yellow) collected from the three lobes of Reservoir 2 of the Sudbury River. Those data will be compared to data collected in 2003 and 2008 from the same lobes, fish species, and size ranges. This matching approach will ensure that the tissue residue data will be comparable over time and space to the best extent possible.

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The fish tissue samples will be analyzed for tHg at the US EPA New England Regional Laboratory (NERL) in North Chelmsford, MA using the Milestone DMA and by a contract lab using CVAFS following EPA Method 1631E. As was done in 2003, the contract laboratory will receive and analyze a wet weight fillet from each fish selected for analysis. Otoliths will be collected from the bullheads, largemouth bass and yellow perch during sample processing to age the fish. Scales will be collected from largemouth bass and yellow perch as a backup ageing method. The tissue samples from those fish that are found to be of the targeted age range (see Attachment 3) will be processed for tissue

' residue. Bullheads will be matched up by size only due to the lack of historical age data. Otoliths will be collected from bullheads {brown and yellow) for aging so that any future monitoring of these species can be informed by age data.

4.0 FIELD SAMPLING

4.1 Introduction

Real-time field notes will be kept to provide a foil and detailed record of ail the field activities. Only dedicated, bound, hard-cover notebooks with sequentially numbered pages will be used for this purpose.

All notebook entries will be made using permanent ink; entries using pencils or erasable ink pens will not be allowed. Each new page will be dated. If necessary, corrections can be made by striking a single line through the text The author will then date and initial the correcfion(s).

The field notebook will be used to record the following types of information, as applicable:

• the date and time when each activity starts and ends • the weather conditions at the start of the day and significant changes in weather during the day • the names and organizations of personnel performing a particular task • a summary of equipment maintenance or decontamination activities, if applicable

. • a description of sample collection and processing activities, such as:

o sampling locations o Global Positioning System (GPS) coordinates, if applicable o number and type{s) of samples collected o records of photographs taken, if applicable o fish species collected

• o fish length (cm)

• descriptions of problems encountered while in the field and corrective actions taken (if any) • any other pertinent information • signature of person recording the information

Table 2 summarizes the NERL SOPs which will be used to support the fish collection and tissue processing. The most current and complete NERL SOPs can be found in the Lotus Notes SOP database at the NERL in North Chelmsford, MA.

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T^bte^Jjjgw^England^^gtonaLLaboratory Standarrf Operating Procedure tor sample collection and processing

Title, revision and/or number; date Originating organization

Equipment Identification

Modified for project work?

The SampTmg of Fish in Wadeabla Streams and Boats Through the Use of Bectm-Fishmg

ECASOP-EFISH3 - Eiectrofishing SOP - Rev. 3.0; 3/11/10 EPA-Region I Not applicable no

Sample Control Procedures for Samples Associated with Ore Biology Laboratory

ECASOP BIOIAB SAMPLE RECEIPT - Rev. 2; 2/20/14 EPA-Region I Not applicable no

Standard Operating Procedure for Fish Processing

ECASOP-RshProcessing4 - Rev. 4; 4/23/14 EPA-Region I Not applicable no

4.2 Fish sampling

The target fish will be collected from all three lobes of Reservoir 2 using an eiectrofishing boat in accordance with "The Sampling of Fish in Wadeabla Streams and Boats Through the Use of Electro-Fishing" (ECASOP-EFISH3 - Eiectrofishing SOP - Rev. 3.0; 3/11/10). Reservoir 2 has boat access via a gated dirt road off Winter Street in Framingham, MA. All the stunned fish will be netted out of the water and placed in the live well on the eiectrofishing boat On-board staff will measure the fish and determine if they fall within the desired species-specific size ranges. A fish will be released back into the water if it is 3 cm larger or smaller than the required size range. All fish within 3 cm of their range will be kept in the five well. Professional judgment will be used to select fish that fail slightly outside their ideal size range, but only if the sampling effort does not produce enough fish of the required size. The fish retained for tissue residue analyses will be killed with a blow to the head, individually wrapped in aluminum foil, and placed in clean, labeled Ziploc plastic bags on ice. Fishing at the next lobe will start only after ail fish from one lobe have been processed and bagged. The same routine will be repeated at each lobe. Fishing on separate lobes may occur at the same time if more than one eiectrofishing boat is available to support the sampling effort.

Bullhead species do not respond well to the eiectrofishing method. Therefore, trotlines consisting of a main weighted heavy fishing line or wire with several small lines with hooks hanging from the main fine, will be set at each lobe in Reservoir 2. Trotlines will be baited (e.g., earthworms, com, cubed chicken) and will be checked every 12-18 hours or whenever possible. All bullheads caught on the trotlines will be measured and any fish within the required size range (± 3 cm) will be kept for residue analysis. Professional judgment will be used to select fish that fall slightly outside their ideal size range, but only if the sampling effort does not produce enough fish of the required size. Fish caught on the trotlines which are not bullheads will be gently unhooked and immediately released. The line connecting foe hook to the main trot line will be cut without removing the hook if a fish has swallowed the hook too deep for it to be removed without causing extensive tissue damage. Bass and perch may also be collected using standard hook-and-iine fishing if and as needed when eiectrofishing resources are not available.

The number offish collected in 2014 and retained for analysis will, to the extent possible, replicate the samples collected in 2003 only. Note, however, that the desired size range for each fish species is based on the minimum and maximum fish lengths collected in both 2003 and 2008. Attachment 1 list the fish collected from each lobe in 2003, whereas Attachment 2 lists foe fish collected from each lobe in 2008. Attachment 3 provides the number and size range of the targeted fish to be collected in 2014 under this SAP.

The fish caught in 2003 showed that individuals of foe same length could differ in age by several years. Therefore, the largemouth bass and yellow perch totals shown in Attachment 3 are larger than foe

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numbers collected in 2003 in order to provide extra specimens to ensure that enough fish of the required age will be available. The number of bullheads in Attachment 3 is the same as those collected in 2003 because none of those fish were aged. Hence, length is the only available criterion to retain a bullhead for tHg analysis. EPA will determine, after all the fish have been aged, which of the fish should be retained fortHg analysis.

The fish will be measured in the field to ascertain that they fall within the optimum size ranges. However, the actual length and weight data will be officially recorded during fish processing at the NERL (see Section 5.1 below).

The fish wilt be brought to the NERL on ice and accompanied by a completed Chain-Of-Custody (COC) form. All samples will be received into the Biology Lab and logged into the Biology Sample Receipt Log Book as directed in SOP "Sample Control Procedures for Samples Associated with the Biology Laboratory (ECASOP BIOLAB SAMPLE RECEIPT - Rev. 2; 2/20/14). All samples will be stored at s 4°C in a monitored Biology sample refrigerator until processing. Samples will be processed as per this SAP and following "Standard Operating Procedure for Fish Processing" (ECASOP-FishProcessing4 -Rev. 4; 4/23/14).

5.0 PROCESSING AND ANALYSES

5.1 Initial Sample Handling, Processing and Preservation

Table 3 lists the target parameter, required sample containers, analytical methods, sample preservation, and maximum holding times for the fish tissues to be collected from Reservoir 2.

The field-collection effort outlined in the previous section is expected to generate the number of fish from each lobe in each size class as listed in Attachment 3. All fish will go through an initial processing to collect scales (largemouth bass and yellow perch) and otoliths (all fish), as well as to record the length and weight and any visible abnormalities (e.g., mouth sores, gill parasites, fin rot, etc.). Fish will also be filleted during the initial processing. The initial fish processing will occur within 48 hours of the fish samples arriving at the NERL however, otolith removal may take place during the following week. The initial processing will follow the steps below:

• Step 1: Weigh the fish then measure it from nose to tail, pinching together the tail fin. • Step 2r. Record any visible abnormalities. • Step 3: Remove scales (from largemouth bass and yellow perch) by carefully scraping the flank

of the fish below fire dorsal fin with a fillet knife. About 20 scales are transferred to a folded piece of clean white paper and placed in a small envelope. The envelope is labeled with the same sample ID that will be used on the fish tissue sample (see Table 4).

• Step 4: Fillet the right side of the fish, remove the skin and weigh the fillet. At least 10 grams of tissue is needed for tHg analysis. The other side of the fish must also be filleted and skinned if one fillet does not meet the minimum 10g requirement.

• Step 5: Wrap the skinless fillet in a dean piece of aluminum foil and place it in a labeled Ziploc bag. Immediately place the bagged fillet in a biology laboratory freezer.

• Step 6: The two otoliths will be collected from each fish collected if a qualified team member, experienced in otolith removal, is available during the initial processing. Otherwise, place the offal (i.e., the remaining fish carcass and skin from fil)et(s)) in a labeled Ziploc bag and store it in a biology laboratory freezer. The otoliths will be removed from the fish carcasses in the following week.

Both otoliths will be removed from the head of each bullhead, largemouth bass and yellow perch. The otoliths will be rinsed with Dl water and placed in small glass vials with a smail amount of cotton to prevent them from moving around and potentially breaking. Each glass vial will be properly

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labeled to correspond to the fish ID from Table 4.

Collected otoliths and scales will be sent under COC to Paul Overbeck, at the Academy of Natural Sciences of Drexel University (1900 Benjamin Franklin Parkway, Philadelphia, PA 19103). The scales obtained during sample processing will be used as a secondary source and will only be prepared for aging if the otoliths cannot be collected, are broken during collection or transport, or cannot be read by the staff at Drexel University.

Only those largemouth bass and yellow perch of the same or comparable age as those collected In 2003 from each lobe will be analyzed via CVAFS. The EPA Project Officer Bart Hoskins, will determine, in consultation with the site RPM, which fish should be selected for CVAFS tHg analysis if the ages of some of the fish from the 2014 sampling effort do not exactly match the age of fish collected in 2003. As noted previously, all bullheads collected will be processed because no bullheads were aged in 2003 such that length is the only criterion for comparison between the two data sets. Samples to be analyzed via CVAFS will be aged prior to shipping. All DMA samples will be analyzed regardless of fish age.

Parameter

Total Hg

Total Hg

Table 3: Analytical parameters for the fish tissue samples

Method

Milestone •MA

CVAFS

No. of Samples to

Lab

226*

Up to 40*

Field Sample Container

Aluminum fbl in 1 gal. Ziplocbag

Lab Sample Container

1.0 ml Cryovial

4 oz glass Jar w/Teflon-lined cap

NERLSOP

ECASOP-MBestone

SOP2

EPA Method 1631 E

Sample Preservation

on Ice, then @ £-20"C

on ice, then ( £-20*C

Holding Time

Uptol year

Uptol year

"Samples to be analyzed by the Milestone DMA are inclusive of 148 skin-on and skin off tissue plugs (duplicates included) and 79 fillet paste aliquots (duplicates included). **32 Samples will be identified to match, as closely as possible, the ages and species used in the 2006 Human Health Risk Assessment for Nyanza OUIV. The remaining 8 analytical slots available under the laboratory contract will be filled with fish chosen to expand the existing database of fish to track the relationship between fish age and mercury concentrations in Reservoir 2.

5.2 Fish tissue processing

All fish fillets will be processed following "Standard Operating Procedure for Fish Processing" (ECASOP-FishProcessing4 - Rev. 4; 4/23/14). Each fillet will be removed from the freezer and homogenize using a blender or food processor. A sufficient amount of each homogenized fish tissue to support the analysis as well as the required laboratory quality assurance measures will be transferred to properly labeled sample jars as noted in Table #3 above. Homogenized samples selected for CVAFS will be stored frozen at £ -20°C until shipping to the analytical laboratory. Homogenized samples selected for DMA will be stored frozen at s -20°C until analysis. Samples selected for DMA will be analyzed on the Milestone DMA80 THg Analyzer as described in "Totaf Mercury in Tissue, and Water by Thermal Decomposition, Amalgamation, and Atomic Absorption Spectrophotometry (ECASOP-MilestoneSOP2 Mercury Analysis by Milestone DMA-80 Revision #2 April 7,2010).

If the target number of fish listed above cannot be obtained, teen tee Project Lead will select offal samples to be processed and sent for additional analysis. The fillets will be homogenized using a food processor or meat grinder and placed in labeled sample jars.

Care will be taken to clean tee cutting tools, blenders, grinder and all other equipment between each fish sample to avoid cross-contamination. For the purpose of this project, the decontamination procedure for the tissue processing equipment will be as follows:

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• rinse with soapy water • rinse with tap water • rinse with 10% nitric acid • rinse with distilled deionized water

Proper paperwork, including labeling and COC forms will be maintained at all times during this project All processing associated activities including times in and out of designated storage units will be recorded in the Biology Sample Processing Log Book.

Each sample container will be labeled according to Table 4 as follows:

Table 4: Labeling fish samples after Tissue processing'

EPA Label Descriptor Interpretation

Required Information on the Label

Comments

Sample Identification

Fish sample Species # - sample type - Lobe # This Information is pre-printed on the labels Examples of ID = LMB1- FIL-lobel

(largemouth bass, sample no.1, fillet from lobe 1)

LMB1 -OFL4obe1 (largemouth bass, sample no. 1, offal from

lobe 1)

Project Project name Nyanza Superfund Site This information Is pre-printed on the labels

Collection Date/Time

MM/DD/YYYY and the time of sampling

This information Is written on the labels at sampling

Analyses Chemical analyses to be performed on the fish tissue samples

DMAT 3 total mercury (by DMA-80 Mercury Analyzer)

CVAFS- cold vapor atomic fluorescence spectrometry

This Information is pre-printed on the labels Include contracting lab on label of CVAFS

sample jars.

Preservation - 20°C This mfbrmation is pre-printed on the labels

"The fish collected in the field will be wrapped in aluminum foK and placed on Ice In labeled Zlploc bags, as explained in Section 4.2. Only the processed fish samples will be placed in the labeled sampling jars described in this table.

5.3 Analytical Parameters

Table 5 references specific analytical methods and summarizes quality control criteria for each fish tissue analyte.

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Analyte

Table 5: Ffsh Tissue Analytical Methods and DQOs

Analytical Method Reporting Limits

Data Quality Objectives (DQOs)

Lab Duplicate Precision (%RPD)

Matrix Spike Accuracy

(% Recovery)

Completeness (% Valid data)

Total Mercury (DMAT)

Mercury Milestone Direct

Analyzer 1 ng <30% 75-125% 90%

Total Mercury (Coid vapor)

Mercury Cold Vapor Atomic

Fluorescence Spectrometry

O.Q2ng/L <24% 71-125% 90%

Nojg that laboratory duplicates and matrix spikes should occur for every 20 samples per sample delivery group (SDG). '

The data generated at OEMS by Milestone analysis will be presented in a standard analytical data report for Milestone data following OEME analytical reporting protocols. Data generated by the outside contract laboratory, Brooke Rand LLC of Portland, OR, will be a full data package that can support validation equivalent to EPA Contract Laboratory Program (CLP) Tier II validation. The data report from the contract laboratory will include the following elements: narrative, sample Information, analytical results, accuracy and precision summary, method blanks and reporting limits, chaln-of-custody forms, shipping labels, instrument calibration results, full sequence Information, preparation and bench sheets, and instrument print-outs.

6.0 DATA USAGE

All results will be reviewed in accordance to the NERL Quality Manual: Revision 7/10/2014 to determine if the data meet minimum data quality requirements for the project The analytical data will be used to determine if the Hg levels in the four fish species collected from the three lobes in Reservoir 2 of Hie Sudbury River have changed from the reported levels in the past and to ascertain the potential for human health and ecological risk.

7.0 SCHEDULE OF TASKS

below. The proposed schedule for the fish sampling work at the Nyanza Superfund Site is summarized

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Draft SAP to EPA

Final SAP to EPA

SAP Revision #2

Fish collection by EPA/ESAT

Decontaminate and return all sampling equipment to storage

Fillets processing for analytical chemistry

Compile all field notes and sampling documentation

Complete analyses of fish tissue samples

.by June 2014

.by June 2014

.October 2014

July 2014

August 2014

.by November 2014

.by December 2014

.by February 2015

Some of the time lines may shift depending on other EPA work priorities, scheduling conflicts or weather conditions. After the project activity dates have been finalized, it will be the responsibility of the Project Lead to inform key project personnel of any changes due to unforeseen circumstances. The Project Lead may have to shift the dates for one or more of the project activities depending on scheduling req uirements or adverse weather conditions.

The initial SAP for this project was based on detailed discussions on data needs and scope between Bart Hoskins and Daniel Keefe, the Remedial Project Manager (RPM) for Nyanza OU IV. These deliberations, as well as coordination with the OEME Biology Laboratory coordinator David McDonald, for Milestone analysis and sampling handling. These scoping discussions were conducted in May and June of 2014. Revisions became necessary to account for the fact tiiat an outside lab will be conducting the cold vapor analysis, and the fact tire originally planned analysis of ffeeze-dried and cryo-milled samples was deemed by Bart Hoskins to be an unnecessary time and budget drain in a time of heavy demand on EPA and ESAT resources. Finally, the contractor performing fish aging recommended to EPA that bullheads be included in the aging and that otoliths, not pectoral fins, should be used to obtain accurate aging. These changes emerged between September and October when fish were collected, but had not been processed. This SAP revision reflects the final sample handling and disposition for all fish collected.

8.0 FIELD SAFETY

All personnel identified for this project have received the 40-hour OSHA training and the yearly 8-hour OSHA refresher course. Only field personnel certified in electrofishing procedures through the U.S. Fish and Wildlife certification program will be allowed on the electrofishing boat In addition, ail boat safety precautions, including those specifically associated with electrofishing, will be implemented and rigorously followed to avoid accidents during fish sampling.

9.0 DATA QUALITY REQUIREMENTS AND ASSESSMENT

9.1 Precision and Accuracy

The precision and accuracy of the data must be within ranges associated with the specific approved protocols. See Table 5 for QC goals and reporting limits for the two analytical methods. Refer to parameter methods and SOPs for more information. The quality control measures followed at the Academy of Natural Sciences of Drexel University are to have every fish otolith aged independently by two analysts. Any age discrepancy between the two readings is then resolved between the two analysts.

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9.2 Data Representativeness

Samples must be representative of conditions existing at the time of sample collection. Standardized procedures will be used to ensure representativeness of conditions at the site. AH samples must be preserved as described In Table 3. Field and laboratory conditions which may affect sample integrity will be documented in the field notebook or laboratory logs.

9.3 Data Comparability and Completeness

Data must be comparable for all samples within each media (i.e., all analyzed with the same detection limits and method for each parameter). Analytical methods will be those cited in Table 3. At least 90% of the data must be determined to be valid/useable for the project to be considered complete.

9.4 Validation and Usability

9.4.1 Data Review

For NERL Hg analysis, the review process will be approved as per EGA Biology Lab product review protocol defined in the NERL Quality Manual: Revision 1 (7/10/2014). Following final approval the results will be released to the TOCOR or client

9.4.2 Corrective Action

When it is discovered that data are incomplete or that results are unacceptable, the Project I pari and/or Biology Laboratory QAO may determine that one or more of the following procedures for corrective action shall be undertaken:

1. Incomplete data: Omissions from logs, notebooks, and worksheets place the entire analysis in question. If the data do not meet the 90% data completeness requirement, a meeting will be held with the analyst and QAO to determine an appropriate response. Incomplete field sampling data may require re-sampling of the questionable location(s). Incomplete laboratory data usually calls for re-introduction or re-analysis of the questionable sample, if feasible.

2. Conflicting or poor quality data: The available data will be reviewed by the Project Lead and QAO when results from replicates, spikes, blanks, etc. do not meet the described QC goals. Upon examination, all or some of the following actions may be applied:

• Systems audit for the analyte in question. • Determination of matrix Interference. • Re-sampling of the questionable sample. • Reconsideration of acceptable limits with statements explaining the results of the

action/rationale taken. • Rejection of data and exclusion from the report with a written explanation. • Rejection of the entire sample/site location with recommendation of relocation of sample

site or reconsideration of results.

10.0 CLOSE-OUT REPORT

The field notes, sampling documentation, and tissue processing notes will be compiled and delivered to the Project Lead. The report will summarize the field activities, including field notes of conditions at Reservoir 2. It will also'include, as attachments, any field photographs and fish riata (i.e., target species, number of fish processed per species, total length, total weight, fillet weight and any descriptions of lesions, parasites, or other similar observations).