Method 8270C PAH. FD- Field Duplicate Samples

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Mr. John Rendall Maine Yankee 321 Old Ferry Road Wiscasset, Maine 04578 RE: Project No.: Maine Yankee Sediment Samples Lab Name: Katahdin Analytical Services, Westbrook, Maine Site Name: Maine Yankee Nuclear Power Plant, Wiscasset Maine Samples Collected: 04/08/2004 6 Sediment samples 1 Aqueous equipment blank sample Data package: MY147 Method 8270C PAH Samples Collected: (Client IDs) MY06SD301(0-0.4)RA FD MY06SD399(0-0.4)RA FD MY06SD303(0-0.4)RA MY06SD302(0-0.3)RA MY06SD316(0-0.4)RA MY06SD316(0-0.4) DL MY06SD301(EB) EB-Equipment Rinsate Blank FD- Field Duplicate Samples Dear Mr. Rendall: RA - Re-Analysis DL - Diluted A Tier II data validation was performed on the semi-volatiles (SVOAs) analytical data for 5 sediment samples, and 1 aqueous equipment blank sample, collected at the Maine Yankee Nuclear Power Plant, Wiscasset Maine. The laboratory, Katahdin Analytical Services, Westbrook Maine, prepared and analyzed the samples in accordance with US EPA SW-846 method 8270C. Soil samples were extracted following US EPA SW-846 method 3550 (sonication). The aqueous sample was extracted following US EPA SW-846 method 3520 (CLLE). The data validation was conducted in accordance with Region I, EPA-New England Data Validation Functional Guidelines for Evaluating Environmental Analyses (12/96) and the QAPP for Maine Yankee Decommissioning Project (rev01), and in conjunction with the individual methods and the laboratory established criteria. The following items were validated: Overall Evaluation of Data and Potential Usability Issues Data Completeness * Chain of custody documents * Sample log in documents *

Data Validation Report (continued) Page 2 Preservation and Technical Holding Times * Instrument Performance Check (Tuning)* Initial Calibrations * Continuing Calibrations Laboratory and Field Blank Analyses * System Monitoring Compounds (Surrogate Recoveries) Internal Standards Matrix spike/matrix Spike Duplicate Results Field Duplicate Results Laboratory Control Samples (blank spikes)/sensitivity Check * PE Samples/Accuracy Check (NA) Target Compound Identification (NA) Compound Quantitation and Reported Quantitation Limits Tentatively Identified Compounds (NA) * - All Criteria met NA- Not Applicable The following information was used to generate the Data Validation Memorandum Attachments: Table I Table II Recommendation Summary Table- summarizes validation recommendations: 8270C. Overall Evaluation of Data- summarizes site DQOs and potential usability issues: 8270C. Data summary tables to be provided in an electronic format. Overall Evaluation of Data and Potential Usability Issues Data Use- To determine the nature and extent of potential contamination, to identify any potential contaminant source areas requiring further evaluation, to support any remedial activities that may be necessary to minimize potential risk to human health and environment. Accuracy and precision acceptance criteria are specified in the QAPP for Maine Yankee Decommissioning Project, (rev 01). Sediment samples MY06SD301(0-0.4)RA, MY06SD399(0-0.4)RA, MY06SD303(0-0.4)RA, MY06SD302(0-0.3)RA, MY06SD316(0-0.4)RA and MY06SD316(0-0.4)DL have PAH results that exceed the project action limit for sediment samples.

Data Validation Report (continued) Page 3 Reported results were from reanalyzed analyses. Original results were not reported. Samples were reanalyzed due to internal standard deviations. Sample MY06SD316(0-0.4) was reanalyzed at a 2X dilution. The original and diluted results were submitted. Based upon the MS/MSD recoveries the phenanthrene, fluoranthene, pyrene and chrysene results for samples MY06SD301(0-0.4)RA and the field duplicate sample MY06SD399(0-0.4)RA are reported as estimated (J). Results may be biased low. MS/MSD recoveries are less than the laboratory s acceptance criteria. Samples MY06SD301(0-0.4) and MY06SD399(0-0.4) were collected as a field duplicate pair. The phenanthrene, fluoranthene and pyrene results are reported as estimated (J). The % RPDs exceed 50% and the reported results exceed the 2 X the PQL. Using professional judgment the anthracene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene and benzo(g,h,i)perylene results for MY06SD301(0-0.4) and MY06SD399(0-0.4) are reported as estimated (J). Potential sampling and/or analytical deviations are indicated. Results were reported to the laboratory s PQLs and adjusted for sample mass, dilution factors, and total percent solids. Positive results may be reported to the MDL. Positive results between the PQL and the MDL are qualified estimated (J). Results that exceed the calibration range of the instrument are qualified as estimated (J). The acenaphthene, fluorene and dibenzo(a,h)anthracene results for MY06SD301(0-0.4)RA are reported as estimated (J). The reported results are between the MDL and the PQL. The anthracene, indeno(1,2,3-cd)pyrene and dibenzo(a,h)anthracene results for MY06SD399(0-0.4)RA are reported as estimated (J). The reported results are between the MDL and the PQL. The acenaphthene result for MY06SD303(0-0.4)RA is reported as estimated (J). The reported result is between the MDL and the PQL. The naphthalene result for MY06SD316(0-0.4)RA is reported as estimated (J). The reported result is between the MDL and the PQL. The phenanthrene and pyrene result for sample MY06SD316(0-0.4)RA exceeded the calibration range of the instrument and required dilution. The phenanthrene and pyrene results are reported as estimated (J). Diluted results are included in the data package. The dibenzo(a,h)anthracene result for MY06SD316(0-0.4)DL is reported as estimated (J). The reported result is between the MDL and the PQL. No MDL study was submitted. The lowest standard for the initial calibration curves for both sediment and aqueous samples are 10 ug/ml. This concentration is at the PQLs. Chain of Custody Documents

Data Validation Report (continued) Page 4 The sampling chain of custody documents were properly signed and dated. Internal custody documents were not submitted. Review of internal custody documents is not part of a Tier II validation for this project. The laboratory provided sample pick-up. Custody seals were present and intact. Sample MY06SD301 was identified as the MS/MSD sample on the COC. Sample Log-in Documents Laboratory Sample Receipt Condition Reports (SRCR) indicate that all samples were received in good condition. The cooler temperature was between 3.1 o C. No results are qualified based upon the sample cooler temperatures. There were no additional deviations indicated on the SRCRs. The validation memo is consistent with the laboratory data package sample IDs. Preservation and Technical Holding Times All sample preservation requirements for SIM PAH were met. All samples were prepared and analyzed within holding time criteria. Instrument Performance Check (Tuning) All tuning criteria were met. Initial Calibration There was one initial calibration curve analyzed on 04/02/2004. All minimum RRF criteria for SPCC and %RSD for CCC compounds were met. All %RSD for target compounds are less than 15% and all RRFs exceed 0.05. The laboratory analyzed a 6 point standard curve. The laboratory calibrated some of the compounds from a first order linear regression. All correlation coefficient exceed 0.99. No data were qualified due to initial calibration results. Continuing Calibration There were 3 continuing calibrations analyzed for this data package. The continuing calibration standard was a 50 ug/ml standard. All minimum RRF criteria for SPCC and %D for CCC compounds were met. All %D for target compounds were less than 25%. All RRFs exceeded 0.05. All acceptance criteria were met.

Data Validation Report (continued) Page 5 These compounds were reported as non-detected (U) in equipment blank sample MY06SD301(EB). No data were qualified due to continuing calibration results. Laboratory and Field blank Analyses All aqueous and sediment extraction blank results were reported as non-detected (U). Sample MY06SD301(EB) was collected as the field equipment blank sample. All results were reported as non-detected (U). No data were qualified due to laboratory or field blank contamination. System Monitoring Compounds (Surrogate Recoveries) The laboratory reported the base surrogates only. Surrogate results that exceed the laboratory derived acceptance criteria are summarized below. Sample Number Surrogate % Recovery Acceptance Criteria WG6809-Blank 2-Fluorobiphenyl 132 45-111 MY06SD301(0-0.4)MS 2-Fluorobiphenyl 113 45-111 All surrogate recoveries are within the laboratory acceptance criteria for the field samples. No data were qualified based upon the surrogate results. Internal Standards Sediment field samples were reanalyzed due to internal standard failures. All internal standard recoveries were within the method acceptance criteria for the reanalyzed sediment samples. The laboratory reported results from the reanalyses only. The laboratory did not reanalyze the MS/MSD samples. Internal standard results that exceed the method acceptance criteria are summarized below. Sample Number Parameter IS Area Acceptable Range (IS area count) MY06SD301(0-0.4)MS Chrysene-D12 529301 2446422-611606 MY06SD301(0-0.4)MS Perylene-D12 372192 2177164-544291 MY06SD301(0-0.4)MSD Chrysene-D12 515459 2446422-611606 MY06SD301(0-0.4)MSD Perylene-D12 363372 2177164-544291 No field sample results are qualified based upon the internal standard results.

Data Validation Report (continued) Page 6 Matrix Spike/Matrix Spike Duplicate Results Sample MY06SD301(0-0.4) was analyzed as the MS/MSD pair. The laboratory used default QC limits of 60-140%. The % RPD criterion is < 50%. The QAPP provided QC criteria are for SIM PAH analyses, not SVOA method 8270C. The QAPP provided SVOA 8270C MS/MSD acceptance criteria do not include all PAH compounds, only acenaphthene. The default criteria were used for this evaluation. MS/MSD recoveries that do not meet the laboratory s acceptance criteria are summarized below. All % MS/MSD RPDs are less than 50%. Compound Spike Conc mg/kg Sample Conc mg/kg MS Conc mg/kg MSD Conc mg/kg MS % Recovery MSD % Recovery Phenanthren 2102 3010 3420 3420 20 20 e Fluoranthene 2102 2710 3180 3340 22 30 Pyrene 2102 3010 3100 3370 4 17 Chrysene 2102 1530 2460 2510 44 47 The phenanthrene, fluoranthene, pyrene and chrysene results for samples MY06SD301(0-0.4)RA and the field duplicate sample MY06SD399(0-0.4)RA are reported as estimated. Results may be biased low. No aqueous MS/MSD was analyzed. The laboratory did analyze an aqueous LCS/LCSD pair. Aqueous equipment blank sample MY06SD301(EB) was the only aqueous sample. Field/Laboratory Duplicates Samples MY06SD301(0-0.4) and MY06SD399(0-0.4) are a field duplicate pair. Conc.mg/Kg Conc.mg/Kg Compounds MY06SD301(0-0.4) MY06SD399(0-0.4) %RPD Acenaphthene 44 430 U Not Calculated Fluorene 170 430 U Not Calculated Phenanthrene 3000 1400 72.7 Anthracene 490 270 Not Calculated Fluoranthene 2700 1300 70.0 Pyrene 3000 1600 63.6 Benzo(a)anthracene 1200 690 54.0 Chrysene 1500 820 58.6 Benzo(b)fluoranthene 1100 590 60.3 Benzo(k)fluoranthene 1200 680 55.3 Benzo(a)pyrene 1200 700 52.6 Indeno(1,2,3-cd)pyrene 690 390 Not Calculated

Data Validation Report (continued) Page 7 Dibenzo(a,h)anthracene 190 170 Not Calculated Benzo(g,h,i)perylene 760 460 49.2 The phenanthrene, fluoranthene and pyrene, results are reported as estimated (J). The % RPDs exceed 50% and the reported results exceed the 2 X the PQL. Using professional judgment the anthracene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene and benzo(g,h,i)perylene results for MY06SD301(0-0.4) and MY06SD399(0-0.4) are reported as estimated (J). The acenaphthene and fluorene results for MY06SD301(0-0.4) are reported as estimated (J) because the results are between the MDL and PQL. The dibenzo(a,h)anthracene results for MY06SD301(0-0.4) and MY06SD399(0-0.4) are reported as estimated (J) because the results are between the MDL and PQL. The indeno(1,2,3-cd)pyrene result for MY06SD399(0-0.4) is reported as estimated (J) because the results are between the MDL and PQL. No laboratory duplicate was analyzed. Laboratory Control Sample Results The laboratory analyzed a soil LCS. All recoveries are within the laboratory derived acceptance criteria. The laboratory analyzed an aqueous LCS/LCSD pair. All recoveries and duplicate d% RPDS are within the laboratory derived acceptance criteria. No results are qualified based upon LCS/LCSD results. PE/Accuracy Check Performance evaluation results were not submitted. The LCS/LCSDs were from an independent, referenced source. Compound Quantitation and Reported Quantitation Limits Results were reported to the laboratory s PQLs and adjusted for sample mass, total solids, and dilution factors. Positive results may be reported to the MDL. Positive results between the PQL and the MDL are qualified estimated J. The acenaphthene, fluorene and dibenzo(a,h)anthracene results for MY06SD301(0-0.4)RA are reported as estimated (J). The reported results are between the MDL and the PQL. The anthracene, indeno(1,2,3-cd)pyrene and dibenzo(a,h)anthracene results for MY06SD399(0-0.4)RA are reported as estimated (J). The reported results are between the MDL and the PQL.

Data Validation Report (continued) Page 8 The acenaphthene result for MY06SD303(0-0.4)RA is reported as estimated (J). The reported result is between the MDL and the PQL. The naphthalene result for MY06SD316(0-0.4)RA is reported as estimated (J). The reported result is between the MDL and the PQL. The phenanthrene and pyrene result for sample MY06SD316(0-0.4)RA exceeded the calibration range of the instrument and required dilution. The phenanthrene and pyrene results are reported as estimated (J). Diluted results are included in the data package. The dibenzo(a,h)anthracene result for MY06SD316(0-0.4)DL is reported as estimated (J). The reported result is between the MDL and the PQL. No MDL study was submitted. The lowest standard for the initial calibration curves for both sediment and aqueous samples are 10 ug/ml. This concentration is at the PQLs. Tentatively Identified Compounds Library searches were not reported with this data package. Please contact Kestrel at (207) 865-1256 if you have any questions regarding this information. Sincerely, Kestrel Environmental Technologies, Inc. Timothy Lewis Validator Attachments: Table I: Validation Recommendation Summaries Worksheet Table II: Overall Evaluation of Data for 8270C PAH Analyses

Data Validation Report (continued) Page 9 Maine Yankee Samples MY147 Table I - Method 8270C PAH Recommendation Summary Sample ID Matrix Qualifier MY06SD301(0-0.4)RA FD Sediment J 1, J 2, J 3, J 4 MY06SD399(0-0.4)RA FD Sediment J 1, J 2, J 3, J 5 MY06SD303(0-0.4)RA Sediment J 6 MY06SD302(0-0.3)RA Sediment A MY06SD316(0-0.4)RA Sediment J 7, J 8 MY06SD316(0-0.4) DL Sediment J 9 MY06SD301(EB) Aqueous A A J 1 Accept all data. Report fluoranthene, phenanthrene, pyrene and chrysene results as estimated (J). MS/MSD recoveries are below the laboratory s acceptance criteria. Reported results may be biased low. J 2 Report fluoranthene, phenanthrene and pyrene results as estimated (J). The field duplicate % RPDs exceed 50% and the results are greater than 2 X the PQL. Potential sampling and/or analytical deviations are indicated. J 3 J 4 J 5 J 6 J 7 Report anthracene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene and benzo(g,h,i)perylene results as estimated (J). Field duplicate precision indicates potential sampling and/or analytical deviations. Professional judgment was used because one or both results were less than 2 X PQL. Report acenaphthene, fluorene and dibenzo(a,h)anthracene results as estimated (J). Reported results are between the MDL and the PQL. Report anthracene, indeno(1,2,3-cd)pyrene and dibenzo(a,h)anthracene results as estimated (J). Reported results are between the MDL and the PQL. Report acenaphthene results as estimated (J). Reported results are between the MDL and the PQL. Report naphthalene results as estimated (J). Reported results are between the MDL and the PQL. J 8 J 9 Report pyrene and phenanthrene as estimated (J). Reported results exceed the calibration range of the instrument. Report dibenzo(a,h)anthracene results as estimated (J). Reported results are between the MDL and the PQL.

Data Validation Report (continued) Page 10 TABLE II EPA NE-Data Validation Worksheet Overall Evaluation of Data MY147 Katahdin Analytical Services DQOs PAH 8270C Sampling/ Measurement Error Analytical Analytical Sampling Sampling Variability Potential Usability Issues To determine the nature and extent of potential contamination, to identify any potential contaminant source areas requiring further evaluation, to support any remedial activities that may be necessary to minimize potential risk to human health and environment. Sediment samples prepared by 3550, Aqueous sample prepared by 3520. All samples analyzed by 8270C. J 1 J 2 Report fluoranthene, phenanthrene, pyrene and chrysene results as estimated (J). MS/MSD recoveries are below the laboratory s acceptance criteria. Reported results may be biased low. Report fluoranthene, phenanthrene and pyrene results as estimated (J). The field duplicate % RPDs exceed 50% and the results are greater than 2 X the PQL. Potential sampling and/or analytical deviations are indicated. J 3 Report anthracene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene and benzo(g,h,i)perylene results as estimated (J). Field duplicate precision indicates potential sampling and/or analytical deviations. Professional judgment was used because one or both results were less than 2 X PQL.

Data Validation Report (continued) Page 11 TABLE II EPA NE-Data Validation Worksheet Overall Evaluation of Data MY147 Katahdin Analytical Services DQOs PAH 8270C Sampling/ Measurement Error Analytical Analytical Sampling Sampling Variability Potential Usability Issues To determine the nature and extent of potential contamination, to identify any potential contaminant source areas requiring further evaluation, to support any remedial activities that may be necessary to minimize potential risk to human health and environment. Sediment samples prepared by 3550, Aqueous sample prepared by 3520. All samples analyzed by 8270C. J 4 J 5 Report acenaphthene, dibenzo(a,h)anthracene and fluorene results as estimated (J). Reported results are between the MDL and the PQL. Report anthracene, indeno(1,2,3-cd)pyrene and dibenzo(a,h)anthracene results as estimated (J). Reported results are between the MDL and the PQL. J 6 Report acenaphthene results as estimated (J). Reported results are between the MDL and the PQL. J 7 Report naphthalene results as estimated (J). Reported results are between the MDL and the PQL. J 8 Report pyrene and phenanthrene as estimated (J). Reported results exceed the calibration range of the instrument.

Data Validation Report (continued) Page 12 TABLE II EPA NE-Data Validation Worksheet Overall Evaluation of Data MY147 Katahdin Analytical Services DQOs PAH 8270C Sampling/ Measurement Error Analytical Analytical Sampling Sampling Variability Potential Usability Issues To determine the nature and extent of potential contamination, to identify any potential contaminant source areas requiring further evaluation, to support any remedial activities that may be necessary to minimize potential risk to human health and environment. Sediment samples prepared by 3550, Aqueous sample prepared by 3520. All samples analyzed by 8270C. J 9 Report dibenzo(a,h)anthracene results as estimated (J). Reported results are between the MDL and the PQL. Validator: Date: