Submitted by Lockheed Martin REAC for Viacom

Figure 1
Fillet Homogenization and
Processing Procedure

INTRODUCTION

Purpose. The purpose of this Work Assignment (WA) is to evaluate the concentration of polychlorinated biphenyls(PCBs) in fish species associated with the Neal's Landfill Site, in Bloomington, Indiana (IN).

Background. The Neal's Landfill site occupies nearly 18 acres of property approximately three miles west of Bloomington, IN, and is surrounded by farms and woodlands. Several residents are located within a half-mile of the landfill and use private wells for drinking water. The landfill accepted industrial and municipal wastes from 1949 until 1972. From 1962 until 1970, Westinghouse Electric Corporation, currently doing business as CBS Corporation, disposed of waste electrical equipment and parts in the landfill, including electrical capacitors containing PCBs, PCB-contaminated capacitor insulation material, rags, and filter clay. Several springs are located at the foot of the landfill and feed Conard's Branch, a tributary to Richland Creek. Sediments and fish in Conard's Branch and Richland Creek are believed to be contaminated with PCBs. In 1985, Westinghouse, the United States Environmental Protection Agency(U.S. EPA), the City of Bloomington, Monroe County, and the Indiana State Board of Health signed a Consent Decree(CD) that required Westinghouse to perform interim control measures, to construct an incinerator, and to incinerate PCB contaminated materials from six sites in and near Bloomington, including Neal's Landfill. During the early 1990s, the State of Indiana passed a number of laws that initially delayed and ultimately blocked the construction of the incinerator remedy required by the 1985 CD. Beginning in 1994, the parties to the CD began to explore alternative remedies for the PCB sites subject to the CD.

During 1987, interim control measures at the site were implemented by Westinghouse including; removal of visible capacitors and stained soils, installation of a two foot thick clay cap over primary landfill areas, installation of a locked chain-link security fence around the site, removal of sediments and creek banks along the entire 4,500 feet length of Conard's Branch, and installation of a collection and activated carbon treatment system to treat PCB contaminated springwater. Sampling of creek sediment, water, and fish in Richland Creek demonstrated that the spring water treatment plant has abated the PCB loading to Richland Creek. In February 1996, the parties submitted a schedule to the Federal court that identified the specific steps needed to select alternative remedies for each of the six sites subject to the 1985 CD. In February 1997, the parties submitted an amended schedule to the court. The court has stated through a judicial order that the landfill must be remediated by December 31,2000. Future decisions by the U.S. EPA on expansion of the water treatment plant and sediment removal will be completed in 2001 and 2002 and are not included in the judicial order. On March 29, 1999, the U.S. EPA signed a Record of Decision Amendment for Neal's Landfill which addresses the source of the contamination. The remedy consists of the following:

• Excavation and removal of selected areas of contamination (referred to as hot spots) greater than 500 parts per million (ppm) PCBs to an offsite, permitted landfill. The estimated volume removed is between 7000 cubic yards and 50,000 cubic yards.
• The current 18 acre landfill will be reduced to 10 acres by consolidation of excavated soils and materials contaminated with less than 500 ppm PCBs. It is anticipated that through this consolidation the possibility of PCB material becoming wet and migrating from the site will be reduced and perhaps eliminated.
• All visible PCB contamination such as capacitors or capacitor parts and oil stained soil will be excavated and disposed either in an offsite landfill or treated in an offsite incinerator. Capacitors containing PCB oil must be incinerated pursuant to the Toxic Substances Control Act.
• Construction of a Resource Conservation and Recovery Act (RCRA) Subtitle C compliant cap meeting the permeability requirements of 1 X 10^-7 centimeters per second over the 10 acre landfill to address the low level threat wastes remaining.
• Areas within the site fence but outside the landfill cap will be cleaned up to 25 ppm PCBs on average with a 6 inch soil cover. Areas outside the fence will be cleaned up to 5 ppm PCBs on average witha 6 inch soil cover.
• A long-term inspection and maintenance plan for the cap, along with a groundwater and surface water monitoring program, will be implemented.

On April 19,1999, the first phase of the cleanup at Neal's Landfill was initiated by CBS Corporation. A total of 41,747 tons (83,495,000 pounds) of contaminated material with greater than 500 ppm PCBs was excavated and shipped offsite to a landfill capable of accepting PCBs. A total of 4,119 capacitors containing PCBs and weighing 484,624 pounds were excavated and shipped off-site to a commercial, permitted incinerator. Approximately 90,000 cubic yards of landfill material were consolidated to reduce the landfill size from 18 acres to 10 acres. Approximately 29,000 tires were excavated and shredded on-site and placed under the landfill cap. The final landfill cap met the permeability requirements of less than 1 X 10^-7 centimeters per second. Areas outside the fence met the cleanup criteria with an average PCB concentration of 3.3 ppm. The groundwater and surface water monitoring plan for Neal's Landfill is under development.

General Assumptions. The purpose of this WA is to evaluate the concentration of PCBs in fish species associated with the Neal's Landfill Site. Lockheed Martin will provide field, laboratory, and other technical activities under the Response Engineering and Analytical Contract (REAC). Technical REAC personnel will provide work plans, process and ship samples, evaluate data, and provide required reports. The U.S. EPA Work Assignment Manager (WAM) will serve as the liaison to the public, other U.S. EPA regions, and government agencies during all work assignment activities.

To the extent possible, the details of the sampling design are presented below. Any modifications to this Work Plan(WP) occurring during field activities will be documented on field change forms and signed by the Task Leader (TL)and the WAM.

The scope of work for this project includes receipt, processing and analysis of fish samples collected by the State of Indiana Department of Environmental Management (DEM) and the U.S. Fish and Wildlife Service (U.S. FWS). The REAC field team will assist with this sampling effort and take custody of all fish samples. Field equipment such as boats and electroshockers will be provided by the State of Indiana DEM and/or the U.S. FWS. Field work for this site is planned for the week of August 6,2001. Fish will be collected from 3 locations along Richland Creek and 2 locations along Conard's Branch. The specific sampling locations will be determined in the field by the WAM.

It is anticipated that there will be a total of 8 omnivorous fish and 5 forage fish samples collected from each location. There will also be a total of 6 upper trophic level fish collected from the 3 most downstream locations; these fish will be composited and will yield a total of two samples per location.

TECHNICAL APPROACH

Scope of Work. There will be a total of 83 fish collected, of which 65 will be analyzed as whole body and 18 will be analyzed as fillet composites. Targeted omnivorous fish include green sunfish and long ear sunfish. Targeted forage species include creek chub, stone rollers, suckers, and carp. Creek chub are the species of choice, but if this species is not available, another species will be substituted. There will be a total of 6 upper-trophic level fish collected from each of the 3 furthest downstream locations. The targeted upper-trophic level species are largemouth bass and rock bass, but smallmouth bass may be substituted if one of the target species is not available.

Investigative Strategy

Analyses Samples collected for this study will be submitted for the following chemical analyses:

• PCBs (all tissue)
• Co-planar PCB congeners (all tissue)
• Micro-extraction technique for PCBs and co-planar PCB congeners (6 fillet samples)
• % Lipids (all tissue)

Fish Collection Fish will be collected by electroshocking per Indiana State Standard Operating Procedures (SOPs). Sampling locations will be determined in the field, in areas that are likely to yield representative fish specimens, and will be based on previous sampling efforts and the extent of contamination.

Tissue Sampling Metrics including whole body weight and total length will be performed on each fish and will be recorded on fish data sheets. Forage fish and omnivorous fish will be analyzed using whole bodies. Only fillet samples will be taken from the larger, upper-trophic level species. Individual forage and omnivorous fish will be targeted for collection at each location. If the mass of an individual is not sufficient to meet analytical requirements, several similarly-sized smaller bodied fish of the same species may be composited. The required number of samples per location may therefore be comprised of both individual fish and composited samples with no more than 3 composites(of the 13 total samples) per location. Fish will be assigned sample numbers, wrapped in aluminum foil, and placed in plastic bags. The sample numbers, matrices, and other information will be recorded on Chain of Custody forms and shipped on dry ice to the laboratory for analysis.

There will be a total of 6 upper-trophic level fish collected from each of the 3 most downstream locations. The upper-trophic level fish retained for analysis will be similar in size and will be large enough to be kept by a fisherman (i.e.,of legal size). The fish will be scaled and filleted with skin on, in such a way as to maximize the edible tissue. One sideof the fish will be filleted unless there is insufficient mass to meet analytical requirements, then both sides will be filleted. Several scales will be saved from the upper trophic level fish to determine the age of the fish. The 18 fillets will be comprised of 3 fish of 2 species each from the 3 locations. (e.g., Location 1 = 3 fillets of rock bass plus 3 fillets of largemouth bass = 6 fillets from Location 1).

For a visual description of how the fillet samples will be handled please refer to Figure 1. Each individual fillet will be homogenized separately. Two aliquots will be removed from each fillet homogenate (e.g., Fillet #1 = Aliquot 1 and 2; Fillet #2 = Aliquot 3 and 4; Fillet #3 = Aliquot 5 and 6). Aliquots 1, 3, and 5 will be combined and analyzed for PCB and co-planar PCB congeners using standard methodology. Aliquots 2, 4 and 6 will be combined and analyzed for PCBs and co-planar PCB congeners using a micro-extraction technique. This will yield a total of 1 composite homogenate sample to be analyzed per species per location (e.g., one for PCBs using standard methods, one for co-planar PCB congeners using standard methods, one for PCBs using a micro-extraction method, and one for co-planar PCB congeners using a micro-extraction method)

Decontamination of Sampling Equipment. Decontamination of equipment prior and subsequent to sampling eachstation will be completed according to ERT/REAC SOP #2006, Sample Equipment Decontamination
1 physical removal of sampling matrix
2 non-phosphate detergent wash
3 potable water rinse
4 acetone rinse
5 distilled water rinse
6 air dry

Sample Documentation. Sample documentation will be completed according to ERT/REAC SOPs #2002, Sample Documentation and #4005, Chain of Custody Procedures, and #4001, Logbook Documentation.

Sample Packaging and Shipment. Sample packaging and shipment will be conducted according to ERT/REAC SOP#2004, Sample Packaging and Shipment

Waste Disposal. Investigation-derived waste (IDW) is disposed of according to the site's existing procedure. All ofthe samples collected will be maintained for 60 days after the issuance of the final report If no additional testing hasbeen requested at the end of 60 days, with the approval and concurrence of the WAM, arrangements will be made fordisposal.

Health and Safety. A site Health and Safety Plan (HASP) will be developed according to REAC SOPs # 3001, REAC Health and Safety Program Policy and Implementation and #3012, REAC Health and Safety Guidelinesfor Activitiesat Hazardous Waste Sites. The HASP will be reviewed and signed by all personnel on site. Good laboratory practices will be employed during all laboratory activities in accordance with REAC SOP #3013, REAC Laboratory Safety Programs.

STAFFING PLAN AND SCHEDULE

Staffing Plan. The REAC TL/Quality Control (QC) Coordinator is the primary REAC point of contact with the U.S.EPA WAM. The TL is responsible for the development and completion of the WP, project team organization, and supervision of all project tasks, including reports and deliverables. In addition, the QC Coordinator is responsible for ensuring field adherence to the WP and recording any deviations from the WP.

Additional REAC technical and/or administrative personnel and subcontractors may work on this project as needed. While not specifically identified, activities such as electronic technical data documentation, video documentation, photo documentation, computer graphics and support, statistics, word processing, report preparation, and purchasing support may be required in order to accomplish the objectives of this project.

The REAC QA Officer, the Health and Safety Officer, the Operations Section Leader, and the Analytical SectionLeader, are responsible for auditing and guiding the project team, reviewing/auditing the deliverables and proposing corrective action, if necessary, for a non conformity to the WP or HASP.

Cost Estimate. The estimated costs (including labor, travel, equipment, subcontractor, and analytical) to complete thisproject are depicted in the attached cost summary sheet. The estimated costs (including labor, travel, materials andequipment, subcontractor, and analytical) to complete this project are based on the hours allotted by the client and costsassociated with similar projects.

Vendor Services. The analytical testing will not be performed at the REAC organic laboratory, therefore, a subcontractlab will be required. The approximate cost for the analytical services is $85,O00.

All project deliverable and task dates are estimates based on the information available at the time of WP completion.New information, additional tasks, changes in scope, and events outside the control of REAC may result in revisionsto these dates.

QUALITY ASSURANCE:

The following QA Protocols for QA1 data are applicable to all sample matrices:

1. Sample documentation in the form field logbooks, the appropriate field data sheets, and chain of custody forms will be provided.

2. All instrument calibration and or performance check procedures/methods will be summarized and documented in the field/personal or instrument log notebook.

3. Detection limits will be determined and recorded, along with the data, where appropriate.

The following QA Protocols for QA2 data are applicable to all sample matrices: