1.0 INTRODUCTION

Viacom has periodically sampled fish, water and sediments in creeks near and in Bloomington, Indiana. These samples have been taken in association with investigation activities at several sites in the Bloomington area that received PCBs from a former Westinghouse Electric Corporation (the predecessor to Viacom Inc.) manufacturing plant located in Bloomington. The sampling described by this plan follows from previous efforts and continues to support the understanding of PCB levels in fish in Conard's Branch and Richland Creek.

1.1 OBJECTIVES AND DESCRIPTION OF CURRENT PROJECT

1.1.1 Objectives

This sampling plan covers the collection of fish in the Richland Creek stream system. Richland Creek and Conard's Branch, one of its tributaries, is the drainage system associated with Neal's Landfill. Figure 1 shows the general site and stream locations. The Neal's Landfill site was remediated for PCB contamination by Viacom in 1999. This sampling effort will generally support the evaluation of PCB levels in fish in the streams. Specific objectives are:

• To compare PCB levels in fish collected this year with PCB levels from past sampling events at some of the same locations to evaluate trends.
• To collect additional data on PCB levels in fish in portions of the Richland Creek system to support risk assessment.

1.1.2 Proposed Study Activities

To satisfy the stated objectives, the following specific project activities will be performed:

• Collect fish samples from two locations, one in Conard's Branch and the other one in Richland Creek, for total congener PCB analysis. The proposed locations have a history of samples that can be used for trend analysis.

1.2 PLANNING DOCUMENTS

This plan has been developed based upon a review of available site information, prior site visits and past data that is available for trend analysis and risk assessment.

This plan presents the overall approach and describes project activities that will be used for this project. Section 2 of the plan provides additional background information concerning the site.

A discussion of the Data Collection Plan is provided in Section 3. It outlines the rationale underlying the number and location of sampling points and analytical parameters. Field sampling procedures and lab analytical procedures for fish analyses have been approved in previous project QAPjPs. The lab selected for PCB analysis of fish is Paradigm Analytical of Wilmington, NC. Paradigm is the same lab that USEPA used for its fish analyses conducted in 2001 at Richland Creek and that Viacom used for fish analyses conducted in November 2002 and May 2003.

2.0 BACKGROUND

2.1 SITE LOCATION AND SETTING AND HISTORY

Richland Creek is a tributary to the West Branch of the W trite River. It originates in several small branches within a few miles of the Neal's Landfill site. Figure 2 shows Richland Creek near Neal's Landfill. The landfill drainage is contained in springs to the northwest of the site at the headwaters of Conard's Branch. Conard's Branch flows to the north-northwest and joins the main stem of Richland Creek a little more than a half mile (straight line distance) from the landfill. Richland Creek from this point flows to the southwest.

In 1985, Viacom and the government parties entered into a consent decree to remediate PCB sites in and around Bloomington, including the Neal's Landfill site. Included in this settlement were provisions to remove all the sediments and most of the immediate bank soils from Conard's Branch and a portion of Richland Creek and to capture and treat the spring waters emanating northwest and south of the site.

In 1987 and 1988 the sediment and bank soil removal was completed. The spring water collection and treatment system was completed in 1990. This system collects up to 500 gpm, treats the water for removal of PCBs and then discharges the water back to Conard's Branch. This system has been in continuous operation since 1990.

2.2 RESULTS FROM PREVIOUS STUDIES

Fish have been sampled on numerous occasions in both creeks. The Conard's Branch and first Richland Creek stations have been sampled most recently in 1998, 2001, 2002 and 2003. These two stations are shown as NL-1 and NL-2, respectively, in Figure 2. Fish at these two stations were analyzed using both Aroclor (GC-ECD) and congener (GC-HRMS) methods. References a, b, c and d list the historical data available.

3.0 SAMPLE COLLECTION AND ANALYSIS

This investigation is designed to evaluate the congener PCB concentrations in the fish in these creeks. In the past, concurrent with fish collections, limited surface water samples had been taken at each location. This will not be done with this plan because a more detailed evaluation of water and sediments will be performed in these areas later this year under a separate plan. This section describes the types of field and analytical chemistry data that will be collected for this project.

3.1 FISH SAMPLING

Fish will be collected from a total of two stations in the Richland Creek system, as discussed below.

• NL-1: In Conard's Branch, approximately midway between the landfill and the confluence with Richland Creek, as shown on Figure 2. This station corresponds with Fish Site 1 that was sampled by Viacom in 1998 and 2002, and the USEPA in 2001. Target species, sample type and number of samples for this event are six whole body creek chubs. Sizes of interest for the creek chubs are the same as those collected in 1998, 2001, and 2002, which ranged from 10 to 36 grams for each fish. All seven creek chub samples will be analyzed for congener PCBs, percent lipids and percent moisture. For the congener analysis, a sample of approximately 20 grams will be required. Composite samples of multiple fish can be used to meet this goa I if necessary.
• NL-2: In Richland Creek, approximately half a mile downstream of the confluence with Conard's Branch and 500 feet downstream of West Vernal Pike, as shown on Figure 2. This station corresponds with Fish Site 2 that was sampled by Viacom in 1998 and 2002, and the USEPA in 2001. Target species, sample type and number of samples for this event at this site are: six whole body creek chubs and six whole body longear sunfish. Sizes of fish should range from 30 to 60 grams for creek chubs and sunfish. All fish of each species will be analyzed for total congener PCBs, percent lipids and percent moisture. All samples will require at least 20 grams of total tissue. Composite samples of multiple fish can be used if necessary.

To obtain the number and size of the target species at each sampling site, the sampling team may move upstream or downstream a few hundred feet from the specified location. Should any target fish species not be available for collection at any sampling location, fish belonging to the same Genus as the target species should be substituted.

The procedures for the collection of fish are presented in relevant sections of Field Procedure No. 23: Protocol for Evaluating Fish Populations and Sampling Fish Tissue (WEC, 1997) (Reference e). All fish samples will be analyzed for total congener PCBs (reference method USEPA 1668A) and percent lipids. The analyses will be performed at Paradigm Labs in Wilmington, NC in accordance with previously approved SOPs listed in Table 2.

For whole body analyses, the gastrointestinal (Gl) tract will be removed from the large fish that are collected to remove contaminated material from the analysis that have not been assimilated into the body of the organism. Similarly, the creek chubs, crayfish and smaller specimens of sunfish and rock bass that are collected from each location will have their gut contents purged by placing the organisms in a holding tank filled with water from the source water body for 24 hours prior to analysis.

In addition to sampling for lab PCB analysis, a scale sample will be collected from each fish and returned to Normandeau Assoicates, Inc. Biological Laboratory for Age and Growth analysis. Two scale samples from each species and sample location will be analyzed to determine the age and length-at-annulus (at the end of each year's growth) of each fish.

A few extra fish for each species at each location will also be collected. These fish will not be analyzed for PCBs but will have the contents of their guts removed. The gut contents will be sent to the Normandeau Biological Laboratory to identify the principal diets of the fish.

3.2 SAMPLE HANDLING, PRESERVATION, CUSTODY AND SHIPMENT

Fish samples will be purged if required then frozen while awaiting transport to the lab. Note that fish samples will be cooled with dry ice. Chain of custody will be completed on all samples prior to transfer of custody to the lab.

3.3 ANALYTICAL PROGRAM

The estimated number of samples are presented by location in Table 1. Table 1 also lists the analytical parameters to be obtained at each sample location. Table 2 summarizes the analytical methods, sample preservation requirements and holding times. Paradigm Labs in Wilmington, NC will perform all fish analyses in accordance with SOPs approved for this project.

The lab will analyze for PCB congeners using EPA method 1668A. This method utilizes a GC- HRMS technique. The lab will report a result for all 209 congeners.

Since method 1668A requires spiking with labeled compounds for every sample, the need for separate MS/MSD samples is obviated. It is also problematic to prepare adequate field duplicates for fish samples (especially since no filet samples are to be analyzed in this round).

However, as a check on the lab's precision, the lab will be directed to prepare lab duplicates from excess fish tissue provided for two samples. Nominally, 20 grams of tissue is required to support PCB and lipid analysis. To accommodate lab duplicates, at least two fish will be collected of at least 40 gram total weight.

3.4 SAMPLE INDENTIFICATION AND LABELING

A sample numbering system will be used to identify each sample, including duplicates and blanks. The field activity manager will maintain a listing of sample identification numbers in the sampling logbook. Each sample number will consist of the following two components:

• A two digit project identification code (e.g., NL for Neal's Landfill)
• A four digit sequential sample number

Sample numbers will not be repeated. Duplicate samples will not be distinguished within the sample numbers, but will be distinguished through the subsample identification within the sample tracking and data management systems. This is done to eliminate potential bias in the analyses of the samples.

3.5 EQUIPMENT AND PERSONNEL DECONTAMINATION PROCEDURES

This section provides the general guidelines for the decontamination of personnel, sampling and monitoring equipment and sample bottles. A portable decontamination area will be established at the site to contain liquid and solid waste generated during the decontamination of equipment and personnel between sampling locations. All waste generated from decontamination will be containerized and sampled for proper disposal.

Site personnel will perform the following decontamination procedures whenever the potential for contamination exists after completion of tasks and when leaving the contaminated area:

1. Wash boots in TSP solution, and then rinse with water. If disposable latex booties are worn over boots in the work area, rinse with TSP solution, remove, and discard.
2. Wash outer gloves in TSP solution, rinse, remove, and discard.
3. Remove respirator if worn.
4. Remove disposable coveralls (e.g., Tyveks) and discard.
5. Remove inner gloves and discard.
6. At the end of the workday, shower entire body, including hair, either at the work site or at home.
7. Sanitize respirator if worn.

The water sampling equipment will be decontaminated between each sample collection using the following procedures if dedicated equipment is not used:

1. Scrape solids from sampler.
2. Wash sampler in a 2.5 percent by weight solution of non-phosphate detergent, such as Liquinox or an equivalent, in tap water.
3. Wash sampler in a 2.5 percent by weight solution of non-phosphate detergent, such as Liquinox or an equivalent, in tap water. Rinse with tap water.
4. Wash sampler in a 2.5 percent by weight solution of non-phosphate detergent, such as Liquinox or an equivalent, in tap water. Spray rinse with 10 percent methanol or 70% isopropanol solution
5. Wash sampler in a 2.5 percent by weight solution of non-phosphate detergent, such as Liquinox or an equivalent, in tap water. Spray rinse with Dl water.
6. Wash sampler in a 2.5 percent by weight solution of non-phosphate detergent, such as Liquinox or an equivalent, in tap water. Place on plastic and allow to air dry.

All other sampling equipment will be decontaminated between sampling locations by the following procedures:

1. Wash contaminated equipment contact surfaces with non-phosphate detergent.
2. Wash contaminated equipment contact surfaces with non-phosphate detergent. Rinse with potable water.
3. Spray rinse with 10 percent methanol solution or 70% isopropanol.
4. Rinse with Dl water and air dry.

3.6 INVESTIGATION DERIVED WASTES

It is anticipated that the Investigation Derived Waste (IDW) that will be generated during the field investigation will include the following items:

• Personnel protective equipment (PPE) - Including disposable coveralls, gloves, booties and other PPE.
• Disposable equipment - Which may include plastic sheeting and equipment covers, aluminum foil, broken or unused sample containers, sample container boxes, tape, and other related items.
• Decontamination fluids - Any spent solvents and wastewater
• Packing and shipping materials.

Solid non-hazardous IDW, which includes PPE, disposable equipment, and packing and shipping materials, will be disposed as municipal solid waste in a dumpster or similar container. Rinse water from decontamination of sampling equipment, which does not contain any organic solvents that were used for decontamination, will be disposed in a sanitary sewer.

Spent organic solvents used for decontamination will be containerized separately from the aqueous decontamination fluid wastes. The containers will be labeled and disposed of by Viacom at an appropriate treatment and disposal facility within 90 days of generation, in accordance with USEPA regulations.

3.7 DATA INTERPRETATION AND REPORTING

Following completion of the field investigation and chemical analyses, a letter report will be prepared which will include the following elements: