EPA Region 5 Records Ctr.

Tetra Tech EM Inc. 237507

200 E. Randolph Drive, Suite 4700 + Chicago, IL 60601 * (312) 856-8700 * FAX (312) 938-0118

May 24, 2004

Mr. Thomas AlcamoWork Assignment Manager (SR-6J)Remedial Response Unit No. 1U.S. Environmental Protection Agency Region 577 West Jackson BoulevardChicago, IL 60604

Subject: Field Sampling Plan (FSP)Bennett's Dump SiteBloomington, Monroe County, IndianaContract No. 68-W6-0037, Work Assignment No. 945-TATA-05ZZ

Dear Mr. Alcamo:

Tetra Tech EM Inc. (Tetra Tech) has prepared its FSP for fish sampling activities at the Bennett's Dumpsite in Bloomington, Monroe County, Indiana. Viacom, Inc. (Viacom), the responsible party for the site,plans to collect fish, sediment, and surface water samples on May 25 through May 28, 2004. Viacom willperform its sampling activities at three historical locations downstream of the Bennett's Dump site. TetraTech will provide oversight of all sampling activities and also collect split fish samples from Viacomduring this sampling event. The enclosed FSP briefly describes Tetra Tech's plans for field oversight andsampling and analysis activities.

If you have any questions regarding Tetra Tech's FSP, please call me at (312) 946-6491.

Sincerely,

Jeffrey LifkaSite Manager

Enclosure

cc: Henry Thompson, EPA Project Officer (letter only)Cora Stanley, EPA Contracting Officer (letter only)Lou Barinka, Tetra Tech Program Manager (letter only)File

contains recycled fiber and is recyclable

RESPONSE ACTION CONTRACT FORREMEDIAL, ENFORCEMENT OVERSIGHT, ANDNON-TIME-CRITICAL REMOVAL ACTIVITIES

IN REGION 6

FIELD SAMPLING PLAN FORBENNETT'S DUMP SITE

BLOOMINGTON, MONROE COUNTY, INDIANA

Prepared forU.S. Environmental Protection Agency

Region 5Chicago, Illinois

m

Work Assignment No.Contract No.EPA Work Assignment ManagerTelephone No.Date PreparedPrepared byTetra Tech Site ManagerTelephone No.

945-TATA-05ZZ68-W6-0037Thomas Alcamo(312)886-7278May 24, 2004Tetra Tech EM Inc.Jeffrey Lifka(312)946-6491

CONTENTSmt

Section Page

. 1.0 INTRODUCTION 1

2.0 SITE DESCRIPTION AND HISTORY 1

3.0 PROJECT OBJECTIVES 4

m 4.0 FIELD SAMPLING ACTIVITIES 6

5.0 DECONTAMINATION PROCEDURES 7

* 6.0 SAMPLE HANDLING AND ANALYSIS 7

6.1 SAMPLE CONTAINERS 7* 6.2 SAMPLE PRESERVATION 8

6.3 SAMPLE IDENTIFICATION AND DOCUMENTATION 86.4 SAMPLE CHAIN OF CUSTODY 9

•' 6.5 SAMPLE PACKAGING AND SHIPPING 10

7.0 TENTATIVE SCHEDULE FOR FIELD ACTIVITIES AND DATA REPORTING 10mm

8.0 HEALTH AND SAFETY PROCEDURES 10

i 9.0 QUALITY ASSURANCE REQUIREMENTS 10

REFERENCES 12mi

FIGURES

i Figure Page

1 SITE LOCATION MAP 2

hi 2 MAY 2004 DOWNSTREAM SEDIMENT, WATER, AND FISH SAMPLING LOCATIONS 5

TABLES-wl

Table Page

1 SUMMARY OF FISH SAMPLING AND ANALYSIS PROGRAM 6

2 SAMPLE CONTAINERS, PRESERVATION METHODS, AND HOLDING TIMES 8

. 1.0 INTRODUCTION

^ Tetra Tech EM Inc. (Tetra Tech) has prepared this field sampling plan (FSP) for the Bennett's Dump site

in Bloomington, Monroe County, Indiana, under the U.S. Environmental Protection Agency (EPA)

^ Response Action Contract (RAC) for Region 6, Contract No. 68-W6-0037, Work Assignment (WA)

No. 945-TATA-05ZZ. This FSP describes activities to be conducted by Tetra Tech personnel

performing oversight during a sampling and analysis investigation of Stout's Creek near the site.

Viacom, Inc. (Viacom), the responsible party for the site, is planning surface water, sediment, and fish

sampling activities beginning the week of May 24, 2004, at various locations in Stout's Creek. Viacom's

contractor, Normandeau Associates (Normandeau), will perform the field sampling activities. Tetra Tech

will oversee Normandeau's performance and also collect split fish samples from Normandeau during the

sampling event. All Tetra Tech quality assurance (QA) and quality control (QC) protocols associated

with the sampling and analysis activities are presented in the mini-QA project plan (mini-QAPP), which

is Appendix A of the Viacom multisite sampling and analysis plan (SAP) prepared by Tetra Tech under

EPA Region 5 WA No. 040-ANLA-05ZZ and submitted to EPA on December 13, 1999. The SAP

consists of the mini-QAPP (Appendix A), an FSP (Appendix B), and a data management plan

(Appendix C) and is among the plans prepared in accordance with Subtask 1.2 of the statement of work

*" (SOW) for this EPA Region 5 WA. This current FSP has been prepared in accordance with Subtask 1.2

of the SOW for the EPA Region 6 WA.

This FSP consists of nine sections. Section 1.0 is the introduction, Section 2.0 presents a brief site

"» description and history, Section 3.0 describes project objectives, Section 4.0 describes proposed field

sampling activities, Section 5.0 describes equipment decontamination procedures, Section 6.0 describes

in sample handling and analysis, Section 7.0 presents a tentative schedule for field activities and data

reporting, Section 8.0 describes health and safety procedures, and Section 9.0 describes QA

nn requirements. References used to prepare this FSP are provided at the end of the text.

2.0 SITE DESCRIPTION AND HISTORY

The Bennett's Dump site is located approximately 2.5 miles northwest of Bloomington, Indiana (see

Figure 1). The main fill area occupies 3.5 acres, and another fill area of 0.5 acre lies east of and adjacent

0 1000 2000

SCALE IN FEET

SOURCE: MODIFIED FROM USGS 1966.

BENNETT'S DUMPBLOOMINGTON, INDIANA

FIGURE 1SITE LOCATION MAP

Tetra Tech EM Inc.

to the main fill area. In addition, a small, satellite fill area measuring about 30 by 60 feet lies 750 feet

north of the main fill area. The site, which is no longer active, lies in a former limestone quarry area

called Bennett's Stone Quarry. The site is bordered by Stout's Creek to the west and a quarry access

road to the south and east. The site topography is characterized by numerous excavation pits remaining

from former quarry operations. The main fill area lies on a westward-sloping hillside east of Stout's

Creek.

When the site was active in the 1960s, part of the quarry was used for landfilling industrial wastes,

including electrical parts. Most of the electrical parts visible at the site had been crushed, burned, or

otherwise torn open, and insulator wrapping paper, ceramic bushings, and other electrical parts littered

the site. Westinghouse electrical capacitors, some of which contained polychlorinated biphenyls (PCS),

were among the electrical parts disposed of at the site. During this period, landfilling operations were

conducted without use of modern landfill control measures such as liners, daily cover, and leachate

collection.

A remedial action (RA) at the Bennett's Dump site began in August 1999 and was completed in

November 1999. The RA consisted of excavating soil, capacitors, and capacitor-related material

contaminated with PCBs and shipping it off site for disposal at licensed facilities in accordance with

Viacom's EPA-approved RA work plan. The former quarry area was excavated to meet industrial PCB

cleanup standards. The purpose of the RA was to remove on-site media contaminated with PCBs.

Viacom collected confirmation soil samples to ensure that PCB concentrations in remaining soil were

below the RA cleanup objective.

According to Viacom's EPA-approved RA work plan, the PCB soil cleanup objective was a maximum of

50 parts per million (ppm) with an arithmetic average of 25 ppm for the Bennett's Dump site.

Confirmation sampling performed at the site showed that the arithmetic average of all residual PCB soil

sample results was 11.3 ppm, less than the required 25-ppm arithmetic average. Viacom placed waste

excavated from the site containing PCBs at concentrations exceeding the 50-ppm maximum cleanup

objective in a Toxic Substances and Control Act (TSCA) loadout pile. The excavated TSCA waste

materials were hauled off site for proper disposal at permitted facilities. Viacom shipped a total of

36,157 tons of material containing greater than or equal to 50 ppm PCBs to Environmental Quality

Company's Wayne Disposal Landfill in Belleville, Michigan. Viacom also shipped a total of 1,756

capacitors weighing 118.72 tons to Onyx Environmental in Port Arthur, Texas, for incineration. The site

was backfilled with approximately 25,000 cubic yards of clean clay, graded for drainage, and seeded,

resulting in a minimum of 12 inches of clean cover material. In addition, all groundwater encountered

during site excavation was pumped to the on-site wastewater treatment system. Viacom's National

Pollutant Discharge Elimination System permit establishes a wastewater treatment system effluent

discharge limit for PCBs of 0.3 part per billion to Stout's Creek west of the site.

3.0 PROJECT OBJECTIVES

The overall project objective is to split six fish samples collected by Normandeau from the main branch

of Stout's Creek to evaluate potential PCB impacts to fish in Stout's Creek that may be attributable to the

Bennett's Dump site. Sampling and analysis activities will consist of a 1-week event beginning on

May 24, 2004. Three historical fish sampling locations will be sampled by Normandeau: West Hunter

Road, Acuff Road, and Maple Grove Road (see Figure 2). Normandeau will also collect several surface

water and sediment samples from Stout's Creek near the Bennett's Dump site; however, EPA has

requested that Tetra Tech collect only split fish samples from Normandeau and perform oversight of all

activities.

Tetra Tech will collect a total of six split fish samples from Normandeau, three whole-body and three

fillet fish samples. Normandeau will perform electroshocking in Stout's Creek to identify the target fish

species for collection as approved by EPA in Viacom's "Stout's Creek Fish, Water and Sediment

Sampling and Analysis Plan" dated May 10, 2004. According to the plan, all fish collected by

Normandeau will be taken to Viacom's Bloomington office for purging of their digestive tracts overnight

in 5-gallon aerated buckets. The fish samples will then be processed the following day, packaged, and

shipped to the analytical laboratory for analysis. All fish tissue samples collected from Stout's Creek

will be analyzed for (1) PCB congeners using EPA modified Method 1668A and/or PCB Aroclors using

SW-846 EPA Method 8082, and (2) percent lipids. All fish tissue samples collected from Stout's Creek

will be analyzed by Severn Trent Laboratories, Inc. (Severn Trent), of Sacramento, California. Sample

results will be used to assist with preparation of human health and ecological risk assessments in the near

future.

BENNETT'S SITE

\

Legend

• Stream sediment, water, and fish sampling location BENNETT'S DUMPBLOOMINGTON, INDIANA

FIGURE 2MAY 2004 DOWNSTREAM SEDIMENT,

WATER, AND FISH SAMPLING LOCATIONS

Tetra Tech EM Inc.

4.0 FIELD SAMPLING ACTIVITIES

Tetra Tech will split six fish samples collected by Normandeau from the main branch of Stout's Creek

during the sampling event. Figure 2 shows general sampling locations. Exact sampling locations will be

selected in consultation with the EPA WA manager based on site-specific conditions.

in

Tetra Tech will perform all field activities in accordance with the EPA-approved, multisite mini-QAPP

(Tetra Tech 1999b) and the Tetra Tech-approved field standard operating procedures (SOP) provided in

the multisite FSP submitted under the EPA Region 5 WA (Tetra Tech 1999a). When the multisite FSP

differs from the SOPs, the multisite FSP procedures will be followed. Tables 2 and 3 in the multisite

FSP present medium-specific project-required quantitation limits (PRQL). Table 1 summarizes the fish

sampling and analysis program, sample matrices, field parameters, laboratory parameters, and the number

of samples to be collected.

TABLE 1

SUMMARY OF FISH SAMPLING AND ANALYSIS PROGRAM

SampleMatrix

Fish tissue

FieldParameters

None

LaboratoryParameters*

Aroclor PCBs, totalcongener PCBs, and

percent Holds

Number ofSamples'1

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Notes:

PCB = Polychlorinated biphenyl

Aroclor PCBs and total congener PCBs are analytes listed in EPA Methods 8082 (EPA 1996)and 1668A (EPA 1999).

b The number of samples includes six fish and six QC samples (two matrix spike, two matrix spikeduplicates, and two field duplicates) collected during the fish sampling event.

Detection limits for the analytical methods will be less than or equal to the PRQLs. Project-specific

objectives for accuracy and precision will be achieved in accordance with Tables 2 and 3 of the multisite

FSP and the special analytical service (SAS) request forms in the multisite mini-QAPP (Tetra Tech

1999b). The data completeness objective will be 95 percent.

During the sampling event, Tetra Tech will collect three whole-body and three fillet split fish samples to

be analyzed for the presence of PCB Aroclors and congeners. Section 3.3.2 of the Viacom SAP provides

details regarding the collection of fish samples, including sampling locations and fish species types.

Viacom's sampling crew, Normandeau, will approach the sampling locations from downstream to

minimize sediment disturbance and will collect fish, sediment, and surface water samples from

downstream locations first. Pertinent data collected during field sampling activities will be recorded in

site logbooks in accordance with Tetra Tech SOP No. 024 (Tetra Tech 1999a). The data will include the

coordinates of each sampling location determined using a hand-held global positioning system (GPS)

device.

Section 3.4 of the Viacom SAP describes sample handling, preservation, custody, and shipment

procedures to be followed. Split sample procedures are presented in Section 3.5 of the Viacom SAP.

The type of fish species samples to be split will be determined in the field by the Tetra Tech

representative in accordance with the Viacom fish sampling priority table presented in the Viacom SAP.

5.0 DECONTAMINATION PROCEDURES

Tetra Tech will follow the equipment decontamination procedures used by Viacom. The procedures are

discussed in further detail in Section 3.7 of the Viacom SAP.

6.0 SAMPLE HANDLING AND ANALYSIS

Tetra Tech will collect split samples, complete all necessary paperwork, and prepare samples forIU

shipment. Sample containers, preservation, identification and documentation, chain of custody, and

packaging and shipping are discussed below.

6.1 SAMPLE CONTAINERS

Contaminant-free sample containers will be prepared in accordance with the procedures specified in

EPA's "Specifications and Guidance for Obtaining Contaminant-Free Sample Containers" (EPA 1992).

Tetra Tech will verify the container specifications by checking the supplier's certified statement and

analytical results for each container lot. These activities will be documented on a continuing basis, and

the documentation will be maintained in the site project file. Table 2 below summarizes sample

containers, preservation methods, and holding times, which are described in detail in Tetra Tech SOP No.

017 (Tetra Tech 1999a).

TABLE 2

SAMPLE CONTAINERS, PRESERVATION METHODS, AND HOLDING TIMES

Analytical Parameter

Aroclor PCBs

Total Congener PCBs

Percent Lipids

No. of Containers

Per Sample

One

One

One

Preservation Method

Store at 4 °C (± 2 °C)until analysisStoreat4°C(±2°C)until analysisStoreat4°C(±2°C)until analysis

Holding Time

Extract within 14 days, and analyzewithin 40 days after extractionExtract within 14 days, and analyzewithin 40 days after extractionNone

Note:

PCB = Polychlorinated biphenyl

6.2 SAMPLE PRESERVATION

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All samples will be preserved on ice and shipped to Severn Trent by overnight express carrier. Sample

preservation methods and holding times are summarized in Table 2 and Table 4-1 of the mini-QAPP

prepared under the EPA Region 5 WA (Tetra Tech 1999b) and are described in detail in Tetra Tech SOP

No. 016 (Tetra Tech 1999a).

6.3 SAMPLE IDENTIFICATION AND DOCUMENTATION

Each sample will be identified using an alphanumeric system that identifies the project, general sampling

location, and sample type. Section 3.6 of the Viacom SAP describes the sample identification procedures

to be used by Viacom and its contractor. Tetra Tech will follow the procedures set forth by Viacom;

however, a "TT-" will precede the Viacom sample identification number for the fish split samples

collected by Tetra Tech. Field duplicate samples will be designated by "TTD-." Matrix spike and matrix

spike duplicate samples will be identified in the site logbooks and will be clearly designated on chain-of-

custody forms rather than by the sample identification numbers.

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An example sample designation is provided below.

TT-BD0001: Tetra Tech split fish sample collected at Bennett's Dump, Viacom fish samplenumber 1

•M

Sampling activities will be documented in a bound logbook using a ballpoint pen in accordance with

Tetra Tech SOP No. 024 (Tetra Tech 1999a). The date and time of collection, identification number,

sampling location, sampling depth, field observations, sampler's name, and analyses will be recorded for

each sample. Each page of the logbook will be dated, numbered, and signed by a Tetra Tech staff

member.

Field data records will be maintained in accordance with National Enforcement Investigation Center

policies and procedures (EPA 1985).

6.4 SAMPLE CHAIN OF CUSTODY

All samples will be collected and handled using proper chain-of-custody procedures outlined in Tetra

• Tech SOP No. 018 (Tetra Tech 1999a). While collecting fish split samples for laboratory analysis, Tetra

Tech field personnel will complete the standard EPA Region 5 laboratory paperwork used for tracking

•» samples, including the following items:

• Traffic reports• Chain-of-custody forms• Sample tags• Custody seals

•MM

Tetra Tech will follow the procedures in the EPA Region 5 "SARA/Superfund Sample Handling

, j Manual" (EPA 1989) to complete the documentation listed above.

Upon completion of all required documents, Tetra Tech will sign and date the documents and list the

times of sample collection. Completed chain-of-custody forms will be included with each shipping

container. One custody seal will be placed across the latch of the shipping container, and another seal1' will be placed on one side of the container lid. The lid will be securely taped shut for shipment. The

pink copies of all chain-of-custody forms will be kept for the project file.

6.5 SAMPLE PACKAGING AND SHIPPING

All fish samples collected will be shipped to Severn Trent using an overnight express carrier. The

sample containers will then be placed in coolers filled with a cushioning packing material such as bubble

wrap. Double-bagged ice will then be placed in the coolers to maintain the temperature of the samples at

4° C during transport. Laboratory paperwork for the samples will be placed in a sealed, plastic bag that

will be taped to the inside of each cooler lid. The cooler lid will then be taped closed, and custody seals

will be placed on the cooler latch and lid. All samples will be packaged and shipped as low-

concentration samples. All shipping containers will be labeled as required by the U.S. Department of

Transportation. Sample packaging and shipping procedures are discussed in detail in Tetra Tech SOP

No. 019 (Tetra Tech 1999a).

7.0 TENTATIVE SCHEDULE FOR FIELD ACTIVITIES AND DATA REPORTING

The field sampling activities discussed in this FSP are expected to occur beginning the week of May 24,

2004. The sampling event is expected to last approximately 4 days, including sample preparation time.

Any last-minute changes to the schedule will not affect the FSP. Sample analytical data will be

submitted to EPA after the sampling event in trip and data validation reports within 30 days after Tetra

Tech's receipt of full data packages from the laboratory.

8.0 HEALTH AND SAFETY PROCEDURES

All field activities will be conducted in accordance with Tetra Tech's health and safety plan, which is

included in the multisite FSP prepared for the EPA Region 5 WA (Tetra Tech 1999a). Prior to initiation

of field activities, all field personnel will read and sign the health and safety plan, indicating that they

understand the plan and agree to operate in accordance with its requirements. Complete copies of this

FSP, including the health and safety plan, will be kept at the field sampling station.

9.0 QUALITY ASSURANCE REQUIREMENTS

All field sampling activities will be conducted in accordance with the mini-QAPP (Tetra Tech 1999b),

which is Appendix A of the SAP prepared for the EPA Region 5 WA. Copies of the mini-QAPP will be

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kept at the field sampling station for immediate use in resolving any QA issues that arise during field

activities.

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REFERENCES

Tetra Tech EM Inc. (Tetra Tech). 1999a. "Field Sampling Plan for CBS Corporation MultisiteSampling and Analysis Support." December 13.

Tetra Tech. 1999b. "Mini-Quality Assurance Project Plan for CBS Corporation Multisite Sampling andAnalysis Support." December 13.

U.S. Environmental Protection Agency (EPA). 1985. "National Enforcement Investigation Center(NEIC) Policies and Procedures." EPA-330/9-78/001-R. June.

EPA. 1989. "SARA/Superfund Sample Handling Manual." Region 5 Central Regional Laboratory.March.

EPA. 1992. "Specifications and Guidance for Obtaining Contaminant-Free Sample Containers." April.

EPA. 1996. "Test Methods for Evaluating Solid Waste (SW-846)." Third Edition. Office of SolidWaste and Emergency Response. Washington, DC. December.

EPA. 1999. "Method 1668, Revision A: Chlorinated Biphenyl Congeners in Water, Soil, Sediment, andTissue by HRGC/HRMS." EPA-821-R-00-002. December.

U.S. Geological Survey (USGS). 1966. 7.5-Minute Topographic Map of Bloomington, Indiana,Quadrangle. Photorevised 1990.

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