Dec 13, 2002

INTRODUCTION

As requested by the U.S. Environmental Protection Agency (EPA), Tetra Tech EM Inc. (Tetra Tech) conducted field oversight of investigation activities in Conard's Branch and Richland Creek downstream from the Neal's Landfill site in Monroe County, Indiana. Tetra Tech performed this work for EPA under Contract No. 68-W6-0037, Work Assignment No. 943-RSBD-0539. Viacom, Inc. (Viacom), is the responsible party for the site. Norrnandeau Associates (Normandeau), a division of RME Environmental, was contracted by Viacom to conduct electrofishing and submit fish tissue samples to a laboratory for analysis. PSARA Technologies, Inc. (PSARA), collected associated sediment and surface water samples. In general, field sampling procedures were conducted in accordance with the Viacom sampling plan dated November 2002. Deviations from the plan are detailed below.

This report summarizes Tetra Tech's oversight observations for November 11 through 14, 2002; issues and developments that arose during the reporting period; and future activities. Tetra Tech's photographic log of field activities is provided in Appendix A of this oversight summary. A copy of Tetra Tech's oversight field notes is included in Appendix B. The attachment contains a copy of Normandeau's sampling log.

OVERSIGHT OBSERVATIONS

This section discusses daily fish electroshocking and sampling activities conducted in Conard's Branch and Richland Creek in Monroe County, Indiana. Deviations from Viacom's November 2002 sampling plan are discussed in the daily summaries and in the "Issues and Developments" section. The field work was conducted in conjunction with stream investigation activities at Clear Creek downstream of the Lemon Lane Landfill site in Monroe County, Indiana. Field oversight associated with Lemon Lane Landfill was conducted from November 11 through 14, 2002, under EPA Contract No. 68-W6-0037, Work Assignment No. 941-RSBD-0529. Some issues that arose during the field investigations apply to both the Neal's Landfill and Lemon Lane Landfill work assignments and are discussed in light of concurrent work activities at both creeks and Conard's Branch.

The sampling plan identifies three sampling sites as Locations 1, 2, and 3. For clarity and ease of reference, this report identifies each site by the stream location sampled, as indicated in Table 1.

Weather conditions on November 11 through 14, 2002, were mild~with foggy mornings and sunny afternoons. Midday temperatures ranged from the low 40s to the middies 50s. About 1 inch of rain fell across the region on November 10. As a result of the recent rainfall, sampling in Conard's Branch and Richland Creek was conducted under bank-full conditions.

Monday, November 11, 2002

At 8:00 a.m., Tetra Tech picked up a digital camera for the field oversight project from its Louisville, Kentucky, office and then left for Bloomington, Indiana. At about 9:00 a.m., Tetra Tech called George Christian of Normandeau and agreed to meet at the Interim Storage Facility (ISF) at the Winston-Thomas Wastewater Treatment Plant in Bloomington. At 10:00 a.m., Tetra Tech arrived at the ISF and met with Richard McCandless of PSARA and George Christian, Charles Dix, and Jeffrey Davies of Normandeau. Other personnel present for major portions of the stream investigation of Conard's Branch and Richland Creek included Dennis Williamson of the Monroe County Health Department (MCHD), Wes Chambers of PSARA, and Mike McCann of Viacom.

On November 11, 2002, while overseeing the stream investigation of Clear Creek, Tetra Tech identified sediment sampling deviations from the EPA-approved sampling plan. These deviations also apply to the investigation of Conard's Branch and Richland Creek and are discussed below.

At the Fluckmill Road site in Clear Creek, Richard McCandless indicated that PSARA planned to collect one composite sediment sample each from the upper, middle, and lower reaches and then composite the three composite samples in a resealable, plastic bag. This final composite sample was to be submitted for laboratory analysis. Mr. McCandless wore disposable gloves and collected sediment from the streambed by hand. PSARA's sediment sampling procedure deviated from the following elements of the sampling plan:

1. The sampling plan calls for three sediment samples (no mention of compositing is made) from each sampling site to be submitted for laboratory analysis.
2. The sampling plan indicates that samples will be collected with a stainless-steel scoop and transferred to 4-ounce, precleaned, labeled glass jars.
3. The sampling plan indicates that sampling equipment will be decontaminated and that rinsate samples will be analyzed.

Tetra Tech discussed PSARA's sampling approach with Mr. McCandless. Based on this approach, Tetra Tech requested that representative sediment samples be composited from anywhere in the sampling reach rather than from arbitrary locations in the stream where sediment might not be as available or as representative. Mr. McCandless indicated that he would collect samples that were representative of each area.

In addition, Tetra Tech informed PSARA that sediment should be collected from representative depositional areas and not from the fine detritus beneath masses of organic matter. Tetra Tech also informed Mr. McCandless that collecting sediment by hand might bias the sample analytical results because the smallest size fraction of the sediment would be lost during collection. Tetra Tech informed Mr. McCandless that using a scoop is a standard procedure to ensure that samples include representative fractions of the size assemblage present in the sediment. Mr. McCandless stated that PSARA was collecting samples by hand to avoid decontaminating equipment and submitting rinsate samples for analysis. Mr. McCandless also informed Tetra Tech that all surface water samples would be collected on Thursday, November 14, and that all surface water and sediment samples would be shipped to analytical laboratories at the same time. Surface water samples were being collected later because they have a shorter holding time for analysis.

Tuesday, November 12, 2002

The stream investigation of Conard's Branch and Richland Creek began on November 12, 2002. In the morning and early afternoon, Tetra Tech oversaw sampling activities in Conard's Branch and Richland Creek. In the afternoon and evening, Tetra Tech oversaw sample processing for fish collected during the previous day from the Fluckmill Road and Country Club Road sites in Clear Creek.

Tetra Tech arrived at the ISF at 7:45 a.m. Mike McCann of Viacom and Richard McCandless of PSARA arrived at 8:10 a.m., and Normandeau arrived at 8:15 a.m. All parties left the ISF for Conard's Branch at 8:35 a.m.

Mike McCann of Viacom led the group to the Conard farm on Vernal Pike. At 8:55 a.m., Dale Conard, the property owner, greeted the group and indicated where to park. The sampling reach passed through the Conard farm, and most of the streamside woody vegetation had been removed. The target species for the Conard's Branch sampling site was creek chub (Semotilus atromaculatus). Table 2 summarizes the target species, its feeding guild, and the type and number of samples submitted for analysis, and the target weight range. Stream investigation activities are documented in Photographs No. 1 through 6.

Of the three sampling sites, the Conard's Branch site is located closest to Neal's Landfill. The sampling reach was characterized by lower-order, erosional habitat with sharp, distinct meanders and steeply incised banks. One large pool was present in the lower reach. The rest of the reach was 1 to 3 feet wide and less than 1 foot deep under bank-full conditions. These geomorphic characteristics suggest that Conard's Branch experiences extreme spates, particularly during high water levels in spring. High flow velocity and the resulting mass transfer during such spates typically result in patchy distribution of in- stream features with significant interannual variation. Erosional and depositional areas are especially subject to alteration during high-discharge events. These factors may contribute to extreme variations in sediment composition, size assemblage, and contaminant partitioning.

At 9:00 a.m., while Normandeau and PSARA were preparing their sampling equipment, Tetra Tech relayed project information to Jeffrey Lifka, Tetra Tech's site manager in the Chicago, Illinois, office. Tetra Tech left him a message seeking confirmation that (1) PSARA should not collect sediment samples from beneath masses of organic matter and (2) fish samples submitted for analysis should reflect the size ranges present, with a bias toward selecting larger fish if target size samples were not available.

At 9:10 a.m., Normandeau identified the pool in the lower reach of Conard's Branch as the most likely habitat for creek chub (see Photograph No. 1). At 9:15 a.m., Wes Chambers of PSARA arrived on site to assist with sediment sampling. At 9:20 a.m., PSARA collected lower reach sediment from very fine silt in the pool (see Photographs No. 2 and 3). Dennis Williamson of MCHD arrived on site at 9:35 a.m. By 9:40 a.m., Normandeau had electrofished the entire pool habitat and had collected the largest creek chub specimens observed. Tetra Tech indicated that enough creek chub had been collected to meet the sampling requirements. The rest of the reach was shallow and scoured to bedrock. These conditions would not provide favorable habitat for larger creek chubs.

At 9:55 a.m., Tetra Tech, Mike McCann of Viacom, and George Christian of Normandeau left the Conard's Branch sampling site to determine appropriate sampling locations and access points for the Richland Creek sampling site upstream of its confluence with Conard's Branch. Tetra Tech did not observe PSARA collecting the final sediment composite sample from Conard's Branch. PSARA arrived at the Richland Creek upstream sampling site at 10:15 a.m.

Target species for the Richland Creek upstream site included creek chub and white sucker (Catostomus commersoni). Table 2 summarizes the target species, the feeding guilds, the types and numbers of samples submitted for analysis, and the target weight ranges. Stream investigation activities are documented in Photographs No. 7 through 19.

The Richland Creek site upstream from Conard's Branch was predominantly depositional habitat with long pools, gentle meanders, and sluggish flow. The middle and upper reaches (upstream of the bridge at Vernal Pike) were 10 to 20 feet wide and 1 to 3 feet deep; riffle areas were rare. The middle and upper reaches had large piles of debris and numerous snags, and streambanks were severely eroded in areas where woody vegetation had been removed. Downstream from the bridge at Vernal Pike, the lower reach was predominantly erosional habitat and was about 10 feet wide and 1 foot deep.

At 10:25 a.m., Normandeau began electrofishing upstream of the bridge at Vernal Pike (see Photographs No. 7 and 8). At the same time, PSARA collected a sediment composite from depositionalareas near the bridge. At 10:45 a.m., PSARA collected upper reach sediment downstream from a debris dam in a riffle area (see Photograph No. 9). Sediment in riffle areas does not typically contain the smallest size fraction present in a streambed.

Normandeau electrofished in an upstream direction for about 200 yards and reported that creek chub samples were within the target weight range, but that not enough white sucker samples were available in the target weight range. At 10:45 a.m., Normandeau began electrofishing in the upper reach (see Photographs No. 1 1, 13, and 14). Carl Ketchum of PSARA visited the site briefly to observe fish sampling activities with Dale Conard (see Photograph No. 10). Water clarity was reduced by runoff from an upstream quarry (see Photograph No. 12), and large snags and woody debris presented obstacles in the upper reach (see Photograph No. 15). At 12:00 p.m., Normandeau sorted and weighed the specimens obtained and determined that not enough white sucker samples had been collected (see Photograph No. 16).

Tetra Tech and George Christian of Normandeau discussed the white sucker's preference for clear, clean. silt-free water and agreed that runoff from the quarry probably degraded otherwise appropriate habitat in the upper reach. Tetra Tech indicated that Normandeau should extend the reach and electrofish immediately downstream of the bridge at Vernal Pike. At 1 1:15 a.m., after PSARA collected a sediment sample near the obstructions in the upper reach (see Photograph No. 17), all the parties returned to the bridge at Vernal Pike. Mike McCann of Viacom left the site for the day at 11:25 a.m.

At 11:35 a.m., Normandeau began electrofishing downstream of the bridge at Vernal Pike (see Photographs No. 18 and 19). By 1 1:50 a.m., Normandeau had collected white sucker samples within the target weight range and was preparing to leave for the Richland Creek sampling site downstream of Conard's Branch.

At 12:05 p.m., PSARA, Normandeau, MCHD, and Tetra Tech arrived at the Richland Creek downstream site. Target species for this sampling site included creek chub, white sucker, and longear sunfish (Lepomis megalotis). Table 2 summarizes the target species, their feeding guilds, the types and numbers of samples submitted for analysis, and the target weight ranges. Stream investigation activities are documented in Photographs No. 20 through 27.

The Richland Creek downstream site consisted of highly erosional habitat with numerous side, channel, and point gravel bars; broad riffle areas; long, shallow runs; and severely eroded banks. The reach was 10 to 30 feet wide and less than 2 feet deep under bank-full conditions. Many areas of the streambed were scoured to bedrock.

At 12: 10 p.m., while Normandeau and PSARA prepared their sampling equipment (see Photograph No. 20), Tetra Tech received a message from Jeffrey Lifka. The message confirmed that no leaf matter should be present in sediment samples and that all samples should be representative of field conditions. At 12:15 p.m., Richard McCandless of PSARA was preparing to collect sediment from the lower reach of the Richland Creek downstream site. Tetra Tech repeated its previous instruction to Mr. McCandless and informed him that sediment samples should not contain organic matter. Tetra Tech also directed PSARA to collect sediment from below a gravel bar in the middle of the channel (see Photograph No. 21). At 12:45 p.m., while collecting middle reach sediment, Mr. McCandless stated that some of the sediment samples had contained "organic mud" but that he had removed leaves and other organic matter from samples collected during the previous day at the Fluckmill Road and Country Club Road sites in Clear Creek. At 1:00 p.m., PSARA collected sediment from the upper reach.

Normandeau electrofished amid debris piles and along steeply eroded banks in the lower reach (see Photograph No. 22). In the middle reach, Normandeau electrofished in riffle and run areas (see Photographs No. 23 through 25). Streambanks in the upper reach were severely eroded in areas where woody vegetation had been removed (see Photograph No. 26). By 12:50 p.m., Normandeau had electrofished about 250 yards of the stream but had not collected enough samples of longear sunfish in the target weight range. Tetra Tech indicated that Normandeau should extend the sampling reach upstream toward the confluence with Conard's Branch (see Photograph No. 27). After electrofishing about 350 yards of the Richland Creek downstream site, Normandeau reported observing only two sizes of longear sunfish: (1) about 15 grams and (2) about 30 grams. The smaller fish were about three times more common than the larger fish. Tetra Tech indicated that Normandeau's efforts were adequate and that the longear sunfish collected were representative of the populations in the reach.

At 1:30 p.m., PSARA and MCHD left the Richland Creek downstream site. At 1:45 p.m., Tetra Tech and Normandeau left the site for lunch and agreed to meet at the ISF at 3:15 p.m.

At 3:10 p.m., Tetra Tech arrived at the ISF. Normandeau arrived at 3:20 p.m. and began processing samples from the Fluckmill Road and Country Club Road sites in Clear Creek; Normandeau processed these samples until 5:10 p.m. In addition, Normandeau sorted the fish collected from Conard's Branch and Richland Creek and placed the specimens in "purge buckets," or aerated, 5-gallon buckets. The fish were not fed and were kept in the buckets for at least 24 hours to purge their digestive tracts. Each bucket had a mesh screen taped inside, about 5 inches above the bottom of the bucket. The mesh screen prevented the fish from ingesting the purged material that settled to the bottom of the bucket. Purging the digestive tract is an alternative to removing the gut contents of each fish. The digestive tract must be either removed or purged because it is not representative of contaminant concentrations bioaccumulated in fish tissue over time.

At 5:20 p.m., Nommandeau and Tetra Tech noticed that fish collected from the Richland Creek upstream site were experiencing oxygen stress in the purge buckets. The fish were acclimated to the relatively low temperatures in the creek and probably experienced oxygen stress as they warmed in the ISF and their metabolic rate increased. In addition, warmer water holds less oxygen than colder water. Nommandeau removed dead creek chubs from the purge bucket and placed them in resealable, plastic bags in an ice slurry. Because the creek chubs died before their gut contents were purged, their gastrointestinal tract had to be removed before sampling. Nommandeau adjusted the aeration levels in the remaining purge buckets, and Nommandeau and Tetra Tech left the ISF at 5:30 p.m.

Wednesday, November 13, 2002

No field work was conducted in Conard's Branch or Richland Creek on November 13, 2002. In the morning and early aftemoon, Tetra Tech oversaw sampling activities in Clear Creek. In the afternoon and evening, Tetra Tech oversaw sample processing for fish collected during the previous day from Conard's Branch and Richland Creek.

At 3:30 p.m., after completing sampling at the Strain Ridge Road and Allen Street sites in Clear Creek, Nommandeau, Tetra Tech, and Wes Chambers of PSARA returned to the ISF in order to process samples collected the previous day. Tetra Tech oversaw sample preparation associated with Conard's Branch and Richland Creek until 9:15 p.m. Table 3 (Part 2) lists relevant details for Conard's Branch and Richland Creek samples submitted for analysis, including the sample identification numbers, the samples' conformance or nonconformance with the sampling plan, and the quality control samples used. Details of sample processing are provided below.

After checking the status of fish in the purge buckets, Normandeau sorted samples from Conard's Branch. Tetra Tech directed Normandeau to use the largest creek chub specimens available in the target weight range of 30 to 60 grams. Four whole body samples were within this range. The other four samples were composites of three to five fish. Tetra Tech directed Normandeau to provide extra sample volume for composite samples. The four composite samples weighed between 66 and 77 grams. A matrix spike/matrix spike duplicate (MS/MSD) sample weighing 214 grams was composited from 11 creek chubs.

At 4:35 p.m., Normandeau finished processing samples from Conard's Branch and began processing white sucker samples from the Richland Creek upstream site. All the white sucker samples were within the target weight range of 60 to 120 grams. A 120-gram sample was designated as an MS/MSD sample.

At 5:25 p.m., Normandeau began processing creek chub samples from the Richland Creek upstream site. Tetra Tech directed Normandeau to use the largest creek chub specimens available in the target weight range of 30 to 60 grams. Three whole body samples consisted of single, live fish within the target weight range. Some of the larger creek chub had died in the purge bucket and had to be gutted (see Photograph No. 28). Tetra Tech directed Normandeau to provide extra tissue for samples that included gutted fish. The three composite samples that contained gutted creek chub ranged in total weight from 64 to - 91 grams. After each creek chub was gutted, Normandeau decontaminated the fillet knife by scrubbing it with Alconox and rinsing it twice with deionized water (see Photograph No. 29).

By 7:00 p.m., Normandeau had finished processing white sucker samples from the Richland Creek downstream site. All six whole body samples were within the target weight range of 60 to 120 grams, and all three fillet samples weighed more than 20 grams. Tetra Tech directed Normandeau to use the largest white sucker specimen for duplicate fillet samples. A 134-gram white sucker was filleted on both sides, yielding two 21 -gram fillets (see Photograph No. 30). The fillet samples included the skin.

Normandeau decontaminated the fillet knife after processing each sample by scrubbing the knife with Alconox and rinsing it twice with deionized water. At 7:10 p.m., Normandeau collected a rinsate sample by pouring deionized water over both sides of the fillet knife (see Photograph No. 31). Wes Chambers of PSARA left the ISF at about 7:15 p.m.

From 7:20 to 7:40 p.m., Normandeau processed creek chub samples from the Richland Creek downstream site. Tetra Tech directed Normandeau to use the largest specimens available for sample preparation. Four whole body samples were within the target weight range of 30 to 60 grams. The other two samples, including an MS/MSD sample, were composited to obtain the minimum sample weight required for analysis.

At 7:40 p.m., Normandeau began processing longear sunfish samples from the Richland Creek downstream site. The 35 longear sunfish collected from the site ranged in weight from 7 to 36 grams; only three specimens were within the target weight range of 30 to 60 grams. Tetra Tech directed Normandeau to use the largest specimens available for fillet samples (see Photograph No. 32). For each of the three fillet samples, fillets from four fish were composited to obtain the 20-gram minimum weight required for analysis. The six whole body samples were each composites of two to four fish and weighed between 31 and 71 grams.

At 9:00 p.m., Normandeau finished processing the samples from Conard's Branch and Richland Creek. All the samples were placed in an ice slurry, and Tetra Tech and Normandeau left the site at 9:15 p.m.

Thursday, November 14, 2002

Tetra Tech arrived at the ISF at 8:30 a.m. Normandeau was preparing sample processing equipment and cleaning and packing field equipment. From 9:10 a.m. to 10:30 a.m., Normandeau processed samples from the Strain Ridge Road and Allen Street sites in Clear Creek.

At 10:30 a.m., Normandeau began disassembling the sampling station and packing sample processing equipment (see Photographs No. 33 and 34). At 10:40 a.m., Tetra Tech called Jeffrey Lifka to update him on the project's progress and issues. At 10:45 a.m., Charles Dix and Jeffrey Davies of Normandeau left the ISF to get ice and to return remaining fish to the appropriate sampling locations in Clear Creek, Richland Creek, and Conard's Branch. George Christian of Normandeau stayed at the ISF to complete chain of custody and other paperwork associated with the sampling effort. At 11:30 a.m., Tetra Tech and Normandeau left the ISF for PSARA's Bloomington office. Tetra Tech obtained a copy of Normandeau's sampling log and left the PSARA office at 12:30 p.m.

PSARA collected all the Conard's Branch and Richland Creek surface water samples before 12:00 p.m. Tetra Tech did not observe the collection of these samples.

Fish tissue samples were sent by overnight courier to Paradigm Analytical Laboratories in Wilmington, North Carolina, for polychlorinated biphenyl (PCB) and PCB congener analysis. Surface water samples and half of the sediment samples were shipped by overnight courier to Heritage Environmental Laboratories in Indianapolis, Indiana, for PCB analysis. The other half of the sediment samples were sent by overnight courier to Test America Inc. in Dayton, Ohio, for analysis for total organic carbon content.

ISSUES AND DEVELOPMENTS

In general, the stream investigation of Conard's Branch and Richland Creek in Monroe County, Indiana, was completed in accordance with Viacom's November 2002 sampling plan for the three sampling sites. However, PSARA collected only one composite sediment sample from each site for laboratory analysis instead of the three samples from each site called for in the sampling plan. Also, the sediment sampling technique used by PSARA may negatively bias analytical results because the smallest size fraction of the sediment may have been lost during sample collection. Although PSARA's sediment sampling technique was questioned because it was not stated in this specific event's sampling plan, it is not a deviation from Viacom's original EPA-approved sampling plan for the sites listed in the consent decree. Viacom states in its original sampling plan that it would collect sediment samples by hand or using a stainless-steel scoop. Conformance with this specific event's EPA-approved sampling plan for fish tissue can be summarized as follows:

1.Conard's Branch site (Location 1)