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REVISED FIELD SAMPLING PLAN FOR
ASEA BROWN BOVERI FACILITY AND BENNETT'S DUMP SITE
MONROE COUNTY, INDIANA

Prepared for
U.S. Environmental Protection Agency
Region 5
June 20, 2002

1.0 INTRODUCTION

Tetra Tech EM Inc. (Tetra Tech) has prepared this revised field sampling plan (FSP) for the former Asea Brown Boveri (ARE) facility and Bennett's Dump site in 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. 944-ANLA-OSZZ. This FSP describes activities to be conducted by Tetra Tech and Earth Tech (Tetra Tech's subcontractor) personnel during a sampling and analysis investigation of the West Fork of Stout's Creek. The headwaters of the West Fork of Stout's Creek is located an estimated 500 feet north of the ABB facility. The West and East Forks of Stout's Creek meet at the west property boundary of the Bennett's Dump site. 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 sampling and analysis plan (SAP) prepared by Tetra Tech under EPA Region 5 WA No. 040-ANLA-OSZZ 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 the EPA Region 5 WA. The 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 sample handling and analysis procedures, 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 requirements. References used to prepare this FSP are provided at the end of the text.

2.0 SITE DESCRIPTION AND HISTORY

This section briefly summarizes the history of the ABB facility and Bennett's Dump site. Figure 1 shows the site locations.

2.1 ASEA BROWN BOVERI FACILITY

In 1958, Westinghouse Electric Corporation (Westinghouse; now Viacom, Inc. [Viacom]) constructed and began operating the ABB facility in Bloomington, Indiana, to produce equipment that transmitted and distributed electricity, including capacitors. During the facility operating period of 19S8 to 1976, Westinghouse used a dielectric fluid (brand name "Inerteen") in the capacitors that contained polychlorinated biphenyls (PCB). Westinghouse operated the facility alone or in conjunction with ABB until 1990, when ABB became the sole facility owner (S.E. Technologies, Inc. 2001). A number of sampling events were conducted at the facility between 1977 and 1998, including events conducted by both the Indiana Department of Environmental Management (IDEM) and EPA. Sampling results showed elevated PCB concentrations in facility soils and surface water. In May 1989, EPA issued a unilateral administrative order to Westinghouse requiring the cleanup of PCB- impacted soil at the facility. From 1989 to 1992, the activities below were conducted at the facility (S.E. Technologies, Inc. 2001).
  • Additional sampling was conducted.
  • Westinghouse developed a work plan for soil remediation.
  • Water that collected in a shallow excavation was sampled and found to contain PCBs.
  • One heating oil underground storage tank (UST) was removed.
  • Two heating oil USTs and one mineral oil UST were closed in place.
  • Piezometers were installed to gather information on the groundwater under the facility.
  • An oil recovery well was installed in the drum storage pad area of the site.

The first phase of site remediation was conducted by Westinghouse from July to December 1992. About 11,000 cubic yards of soil was excavated and temporarily stored on site, and about 660 cubic yards of soil was excavated and disposed of at a licensed incineration facility operated by Aptus, Inc. The second phase of remediation began in August 1993 and continued until January 1994. About 360 cubic yards of soil containing PCBs at concentrations greater than 500 parts per million (ppm) was excavated and temporarily stored on site, and about 5,320 cubic yards of soil containing PCBs at concentrations less than 500 ppm was excavated and disposed of at Greyback Mountain Landfill, a licensed landfill in Utah. In 1994, the excavated soil that had been temporarily stored on site during the remediation was disposed of at the Grayback Mountain Landfill. In 1995 and 1996, a final phase of sampling and remediation was conducted. About 5,130 cubic yards of soil was excavated and disposed of at the GraybackMountain Landfill during this phase (S.E. Technologies, Inc. 2001).

2.2 BENNETT'S DUMP SITE

The Bennett's Dump site is located approximately 2.5 miles northwest of Bloomington, Indiana. The main fill area occupies 3.5 acres, and another fill area of 0.5 acre lies east of and adjacent to the main fill area. In addition, a small, satellite fill area measuring about 30 by 60 feet lies 7SO 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 PCBs, 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.

The remedial action (RA) at the Bennett's Dump site began in August 1999 and was completed in November 1999. The former quarry area was excavated to meet industrial PCB cleanup standards. The purpose of the RA at the site was to remove on-site media contaminated with PCBs. 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. 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 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 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 established 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 sample surface water in the West Fork and main branch of Stout's Creek to evaluate potential PCB impacts attributable to the ABB facility as well as PCB concentrations adjacent to and downgradient of the Bennett's Dump site. Sampling and analysis activities will consist of two events, a wet-weather grab sampling event and a wet-weather continuous monitoring event (using an autosampler over the length of the storm event). A few of the sampling locations do not flow under nonstorm conditions; therefore, grab sampling and autosampling will be performed at each location.

Wet-weather grab sampling will be conducted when precipitation has occurred for I day totaling at least 1 inch of rain in the area. During the grab-sampling event, surface water will be sampled at five locations where spring flow into the West Fork of Stout's Creek has been identified. These five locations were identified during a field inspection conducted in April 2002 by Tetra Tech and Earth Tech (see Figure 2). Two additional surface water samples will be collected near the Bennett's Dump site. One of these samples will be collected from the West Fork of Stout's Creek just before its confluence with the East Fork of Stout's Creek; the other sample will be collected from Stout's Creek just downgradient of the Bennett's Dump site (see Figure 3).

Wet-weather autosampling will be conducted during or immediately after a rainfall event large enough to result in an increase in flow in Stout's Creek. An appropriate rainfall event will be identified in consultation with the EPA WA manager (WAM). Sampling locations for the wet-weather autosampling event will be based on analytical results for samples collected during the grab-sampling event. A total of eight surface water samples will be collected at 1-hour intervals upon activation of the autosampler by a flow level gauge at each location. The autosamplers will be checked immediately after a storm event and samples gathered for shipment to the laboratory. Autosamplers have storage for ice; therefore, Tetra Tech will fill the autosamplers with ice in anticipation of a storm event.

All surface water samples collected from Stout's Creek will be analyzed for PCBs and total suspended solids (TSS) by TriMatrix Laboratories, Inc., of Grand Rapids, Michigan, using EPA Methods 8082 and 160.2, respectively. Sample results will be used to determine if PCBs are present at concentrations above detection limits established by the EPA SW-846 method (EPA 1996).

4.0 FIELD SAMPLING ACTIVITIES

Tetra Tech, in coordination with the EPA WAM, will collect grab and continuous monitoring surface water samples during the wet-weather conditions from the main branch and the West Fork of Stout's Creek. Figures 2 and 3 show general sampling locations. Exact sampling locations will be selected in consultation with the EPA WAM based on site-specific conditions. Some of the sampling locations are located on private property. Before any sampling activities are conducted on private property, permission to access the locations will be obtained from the appropriate property owners.

Tetra Tech will perform all field activities in accordance with the EPA-approved, multisite mini-QAPP and the Tetra Tech-approved field standard operating procedures (SOP) provided in the multisite FSP (Tetra Tech 1999a) submitted under the EPA Region 5 WA. 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). The sampling and analysis program is summarized in Table I below, which also specifies sample matrices, field parameters, laboratory parameters, and the number of samples to be collected.

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 wet-weather grab sampling event, one surface water sample will be collected from each of the five locations in the West Fork of Stout's Creek identified during the April 2002 field inspection. Two additional surface water samples will be collected from near the Bennett's Dump site. One of these samples will be collected from the West Fork of Stout's Creek just before its confluence with the East Fork; the other sample will be collected from the main branch of Stout's Creek just downgradient of the Bennett's Dump site. A total of seven surface water investigation samples will be collected to assess whether PCBs are present.

TABLE 1-SUMMARY OF SAMPLING AND ANALYSIS

Sampling crews will approach the sampling locations from downstream to minimize sediment disturbance and will collect 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.

Before sample collection at each location, a water quality meter will be used to measure pH, specific conductance, and temperature in accordance with Tetra Tech SOP No. 012 (Tetra Tech 1999a). The methods used for surface water sampling will depend on the depth of the water at the time of sampling. For surface water sampling locations with less than I foot of water, samples will be collected by immersing a clean sample bottle below the water surface and filling the bottle with the necessary volume of water. For surface water sampling locations with more than I foot of water, surface water samples will be collected from half the water's depth using a Kemmerer-type water sampling device that is remotely triggered. At such locations, a measuring rod marked in feet and inches with a flat surface at one end to detect the bottom will be used to determine the water depth before sampling begins. The line to the sampler will also be marked in feet and inches so that the sample can be collected at half the water's depth. Once the water sampler is open and set, it will be lowered to the desired depth, the trigger will be released, and the ends of the sampler will close, thereby collecting a sample. The sampler will be hauled to the surface, and the trapped water will be emptied into the appropriate sample bottle. This procedure will be repeated until the required sample volume has been collected.

Sample collection bottles will be rinsed at least once with surface water before samples are collected. Care will be taken not to disturb bottom sediment so that sediment is not included in the surface water samples. Surface water samples will be placed on ice in insulated coolers and shipped by overnight courier to the laboratory for chemical analysis.

During the wet-weather continuous monitoring sampling event, samples will be collected at up to four locations based on the analytical results for samples collected during the wet-weather grab sampling. The sampling event will generally be conducted as described for the grab sampling event; however, flow- triggered peristaltic pumps (ASCOT autosamplers) will be used to collect the samples. The pumps will be started using a flow-activated switch installed inside a stilling well. The sample will be pumped into an appropriate sample container contained within a protective plastic housing. Upon activation of the pump, eight samples will be collected at each location at l-hour intervals during the wet-weather event.

All surface water samples will be analyzed for PCBs and TSS. To establish PRQLs for surface water analyses, Tetra Tech will use the EPA Region 9 surface water preliminary remediation goals (PRO) and ambient water quality criteria presented in Table 3 of the FSP prepared under the EPA Region 5 WA (Tetra Tech 1999a). The more conservative of these values will be used as PRQLs.

S.O DECONTAMINATION PROCEDURES

Sampling equipment will be decontaminated on plastic liners on a newly constructed decontamination pad. The exact location of the decontamination pad will be determined in the field. All sampling equipment, such as the Kemmerer-type device, will be decontaminated prior to sample collection at each location. Decontamination will consist of removing all visible evidence of contamination from the sampling equipment using Alconox. soap and water and rinsing the equipment with distilled water. The decontaminated equipment will then be allowed to air-dry. Decontamination procedures are discussed in further detail in Tetra Tech SOP No. 002 (Tetra Tech 1 999a). Disposable equipment such as plastic tubing, coveralls, gloves, and boot covers will be used wherever possible to minimize the possibility of cross-contamination. Tetra Tech will collect an equipment rinsate blank for PCB analysis to verify that the sampling equipment was properly decontaminated (including one sample for each of the peristaltic ISCO. autosamplers that have an autorinse feature that occurs in between collection of samples).

6.0 SAMPLE HANDLING AND ANALYSIS PROCEDURES

Tetra Tech will collect samples, complete all necessary paperwork, and prepare samples for 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 specifications for the containers 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. Sample container requirements are summarized in Table 2 below and are described in detail in Tetra Tech SOP No. 017 (Tetra Tech 1999a).

6.2 SAMPLE PRESERVATION

All samples will be preserved on ice and shipped to the appropriate laboratory by overnight express carrier on the day of collection. Sample preservation methods and holding times are summarized in Table 2 below 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).

Requirements for surface water sample bottles, preservation methods, and holding times will also apply to equipment rinsate blanks.

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. Each sample will also have designations that indicate the sampling location number and sampling depth. Field duplicate samples will be designated by "DUP." Equipment rinsate blanks will be designated by "ER." 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.

Example sample designations are provided below.

  • ABB-SC-SW-1-06: Surface water sample collected from ABB facility, location 1 in the West Fork of Stout's Creek, at a depth of 0 to 6 inches
  • BD-SC-SW-2-01/02: Surface water sample collected from Bennett's Dump site, location 2 in the main branch of Stout's Creek, at a depth of 1 to 2 feet

Sampling activities will be documented in bound logbooks 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 logbooks 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 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:

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

Tetra Tech will follow the procedures in the EPA Region 5 "SARA/Superfund Sample Handling Manual" (EPA 1989) to complete the documentation listed above.

Tetra Tech will appoint one of its field personnel as the sample custodian. Upon completion of all required documents, the sample custodian will sign and date the documents and list the times of sample collection. The sample custodian will also confirm the completeness of all descriptive information on the chain-of-custody forms, which will be included with each shipping container. One custody seal will be placed across the latch of the shipping container, and another seal will be placed on one side of the container lid. The lid will be securely taped shut for shipment. The sample custodian will retain the pink copies of all chain-of-custody forms for the project file.

6.5 SAMPLE PACKAGING AND SOPPING

All samples collected will be shipped to the appropriate laboratory on the day of collection using an overnight express carrier. Sample containers will be placed in plastic bags in case containers break during shipment. 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 4ø 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 June 3, 2002. Based on sample analytical results, up to four autosamplers will be assembled and placed at sampling locations during the week of July 8, 2002. The two sampling events are expected to last approximately 2 days each including preparation time. Any last-minute changes to the schedule will not affect the FSP. Sample analytical data will be submitted to EPA after each 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 QUAL1IY 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 kept at the field sampling station for immediate use in resolving any QA issues that arise during field activities.

REFERENCES

S.E.Technologies, Inc. 2001. "Remedial Activities Completion Report, Volumes I and II, Former Westinghouse Facility, 300 North Curry Pike, Bloomington, IN." Prepared for Viacom, Inc. September 20.

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

Tetra Tech. 1999b. "Mini-Quality Assurance Project Plan for CBS Corporation Multisite Sampling and Analysis 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 Solid Waste and Emergency Response. Washington, DC. December.


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