June 20, 2003

Tetra Tech EM, Inc.

Mr. Thomas Alcamo Work Assignment Manager
Remedial Response Unit No. I
U.S. Environmental Protection Agency Region 5
77 West Jackson Boulevard
Chicago, IL 60604

Dear Mr. Alcarno:

Tetra Tech EM Inc. (Tetra Tech) has prepared the enclosed summary to document its oversight of fish and crayfish tissue sampling and surface water sampling activities in Conard's Branch and Richland Creek downstream of the Neal's Landfill site on May 27 and 28, 2003. Normandeau Associates and PSARA Technologies, Inc., conducted the field sampling activities as contractors to Viacom, Inc., the responsible party for the site. Appendix A of the summary contains Tetra Tech's photographic log of field activities, Appendix B contains a copy of Tetra Tech's field notes, and the attachment contains a copy of the Normandeau Associates sampling log.

If you have any questions about the enclosed summary, please call me at (312) 946-6491.

Sincerely,
Jeffrey Lifka
Site Manager

Tetra Tech Oversight Personnel: Regina R. Bergner

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 two sites in 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. Normandeau Associates (Norrnandeau), a division of RME Environmental, was contracted by Viacom to conduct fish electroshocking and submit fish and crayfish tissue samples for analysis. PSARA Technologies, Inc. (PSARA), collected associated surface water samples. In general, field sampling procedures were conducted in accordance with the EPA- approved Viacom sampling plan dated May 2003.

This report summarizes Tetra Tech's oversight observations for May 27 and 28, 2003; issues and developments that arose during the reporting period; and future activities. Minor deviations from Viacom's May 2003 sampling plan are discussed in the daily summaries and in the "Issues and Developments" section. Appendix A provides Tetra Tech's photographic log of field activities, and Appendix B provides a copy of Tetra Tech's oversight field notes. The attachment contains a copy of Normandeau's sampling log.

This section discusses fish electroshocking and sampling activities conducted to investigate polvchlorinated biphenyl (PCB) contamination resulting from past operations at the Neal's Landfill site. Fish tissue and surface water sampling were conducted at one location in Conard's Branch and two locations in Richland Creek. Conard's Branch is a first-order stream that originates in the former landfill area and flows north into Richland Creek. Viacom's EPA-approved sampling plan identifies the three sampling locations as NL-1, NL-2, and NL-3. For clarity and ease of reference, this report identifies each location by the stream location sampled (see Table I).

Weather conditions on May 27 and 28, 2003, were fair and mild, with clear skies and light winds in the afternoons. Midday temperatures ranged from the high 60s to the mid-70s øF. Thunderstorms occurred throughout the region 2 to 3 days before sampling began. As a result of the recent rainfall, water levels in the streams were elevated. Flow in the main channel ranged from less than 0.5 meter per second (m/s) in the Conard's Branch pool to more than 3 m/s downstream of the ford at the Richland Creek 5-mile site.

Tuesday, May 27, 2003

On Tuesday, May 27, Tetra Tech oversaw fish electroshocking and sampling at all three locations, beginning at Conard's Branch and proceeding downstream to the Richland Creek locations.

Target species for the Conard's Branch sampling location included creek chub (Semotilus atromaculatus) and crayfish. Crayfish most likely to be present in the Richland Creek watershed include various species of the genera Orconectes and Cambarus. No attempt was made to identify the genus or species of crayfish samples collected. Table 2 summarizes the target species, their feeding guild, the type and number of samples submitted for analysis, and the target weight range. Photographs No. 1 through 4 in Appendix A show stream investigation activities.

Most the stream reach at the Conard's Branch site consists of first-order, erosional habitat with sharp, distinct meanders and steeply incised banks 3 to 5 feet high. One large pool was present in the reach. The rest of the reach was 1 to 3 feet wide and less than 6 inches deep under high water conditions.

At 9:30 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 in Appendix A). By 9:55 a.m., Normandeau had electroshocked the entire pool habitat and had collected the largest creek chub specimens available (see Photographs No. 2 and 3 in Appendix A). Normandeau weighed specimens in the field to determine if the samples would be within the target weight range. Creek chub specimens were adequate,to meet sample requirements, and some compositing of smaller fish within the target weight range was required. Tetra Tech and Normandeau concurred that the target weight range of 30 to 34 grams for crayfish, as stated in the Viacom sampling plan, was for composite samples. Individual crayfish specimens in the Orconectes or Cambarus genera typically weigh no more than about 5 grams. Normandeau collected 70 crayfish weighing a total of 220 grams, for an average weight of about 3 grams (see Photograph No. 4 in Appendix A). Tetra Tech called John Dirgo in Tetra Tech's Chicago office to confirm that crayfish samples would be composites.

At 10:00 a.m., Richard McCandless of PSARA had completed water sampling at the upstream end of the pool, and all parties prepared to leave the site for the Richland Creek l-mile site. Normandeau placed creek chub and crayfish specimens in live wells in the stream and planned to retrieve them after sampling the Richland Creek l-mile site.

PSARA, Normandeau, MCHD, and Tetra Tech arrived at the Richland Creek l-mile site at about 10:15 a.m. Target species for the site included crayfish, creek chub, white sucker (Catosroma commersoni), longear sunfish (Lepomis megalotis), and rock bass (Ambloplites rupestris). Table 2 summarizes the target species, their feeding guilds, the types and numbers of samples submitted for analysis, and the target weight ranges. Photographs No. 5 through 10 in Appendix A document stream investigation activities.

The Richland Creek l-mile site consists of highly erosional habitat with numerous side, channel, and point gravel bars; broad riffle areas; long, shallow runs; occasional deeper pools; and severely eroded banks. Most of the reach was 10 to 30 feet wide and less than 2 feet deep under high water conditions. Most creek chub and crayfish specimens were collected in the downstream portion of the reach in shallower habitat. Deeper runs and pools upstream of the bridge at Vernal Pike provided suitable habitat for white sucker and sunfish species.

At about 10:25 a.m., while Normandeau prepared to begin electroshocking, Richard McCandless of PSARA collected surface water samples and water quality measurements (see Photograph No. 5 in Appendix A). At 10:30 a.m., Normandeau began electroshocking fish amid debris piles and gravel bars in the lower reach (see Photograph No. 6 in Appendix A). Normandeau proceeded upstream, electroshocking fish in shallow pool areas (see Photograph No. 7 in Appendix A). In the upper reach upstream of the bridge at Vernal Pike, Normandeau electroshocked fish in longer, deeper pools within steeply eroded banks (see Photographs No. 8 and 9 in Appendix A). At 11:45 a.m., Normandeau completed sampling in the upper reach and weighed specimens to determine if weight requirements had been met (see Photograph No. 10 in Appendix A). At about 1 1:50 a.m., Richard McCandless of PSARA left the site and agreed to meet at the Richland Creek 5-mile site at 2:00 p.m.

Specimens collected during more than 1 hour of electroshocking at the Richland Creek 1-mile site were minimally adequate to meet sample requirements for white sucker and longear sunfish. Some specimens were at the low end of the target weight range, and some samples required compositing. Tetra Tech requested that Normandeau continue to electroshock fish in an upstream direction toward the confluence with Conard's Branch in an attempt to collect more specimens in the target weight range. By 12:25 p.m., Normandeau had collected two more white sucker specimens at the low end of the target weight range. No additional longear sunfish specimens were obtained. Tetra Tech indicated to Normandeau that these additional sampling efforts were sufficient because the specimens collected were representative of the stream conditions encountered.

At 12:55 p.m., Tetra Tech and Normandeau left the Richland Creek 1-mile site for the PSARA warehouse. On the way to the warehouse, Tetra Tech retrieved the Conard's Branch specimens that had been placed in live wells in the stream. At 1:20 p.m., Tetra Tech arrived at the PSARA warehouse. Normandeau was sorting specimens and placing them in "purge buckets," which are 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. Purging the digestive tract is an alternative to removing the gut contents of each fish. The digestive tract must either be removed or purged because it is not representative of contaminant concentrations bioaccumulated in fish tissue over time. Each bucket had a mesh screen taped inside about 5 inches above the bottom of the bucket to prevent the fish from ingesting the purged material that had settled to the bottom of the bucket.

Tetra Tech, PSARA, and Normandeau arrived at the Richland Creek 5-mile site at about 2:10 p.m. Target species for the site included shorthead redhorse (Moxostoma macrolepidorum). Table 2 summarizes the target species, its feeding guild, the type and number of samples submitted for analysis, and the target weight range. Photographs No. ll through 15 in Appendix A document stream investigation activities.

The stream reach at the Richland Creek 5-mile site consisted of a mix of (l ) deep pools full of woody debris and (2) long shallow riffle areas resulting from engineered alterations to the stream bed, including a ford across the creek at the downstream end of the reach. In some parts of the lower reach, the tree canopy covered the entire stream corridor, providing ideal shaded pool habitat necessary for larger fish. Where the tree canopy had been removed or was not complete, the stream channel was steeply eroded and incised, with banks 12 feet high in some places. Most of the reach was 10 to 20 feet wide under high water level conditions. One long pool just upstream of the ford was 3 to 4 feet deep. Water clarity was excellent throughout the reach.

At 2:15 p.m., Richard McCandless of PSARA collected water samples and recorded water quality data upstream of the ford across the creek (see Photograph No. ll in Appendix A). Normandeau began electroshocking fish in the long, deep pool upstream from the ford (see Photographs No. 12 and 13 in Appendix A). After negotiating around woody debris in the stream, Normandeau continued electroshocking upstream in shallower pools within steeply incised banks (see Photograph 14 in Appendix A). Normandeau electroshocked for about 30 minutes and collected 14 large, mature redhorse specimens. Smaller specimens were not observed. Two species were collected in equal abundance and in the same size class of about 200 to 300 grams: black redhorse (M. duquesni) and shorthead redhorse (see Photograph No. 15 in Appendix A). All specimens collected were at least twice as large as the average target weight range. Tetra Tech and Normandeau agreed that the redhorse specimens were typical of mature Moxostoma species, were representative of the stream assemblage present, and were of the size and weight most likely to be eaten by area residents. Tetra Tech directed Normandeau to retain all 14 of the redhorse specimens pending consultation with EPA. In addition to the numerous large redhorse, Tetra Tech observed at least 10 large specimens of white bass (Morone chrysops) and largemouth bass (Microptems salmoides). Bass specimens that surfaced during electroshocking in the pools at the Richland Creek 5-mile site were about 8 to 12 inches long.

Normandeau completed electrofishing at 2:50 p.m., and Richard McCandless of PSARA left the site at 3:00 p.m. Because of the earlier difficulty negotiating equipment around woody debris in the stream corridor, Normandeau left the electroshocking equipment upstream and returned to the ford to retrieve its vehicle. After moving the vehicle to an upstream access point, Normandeau loaded equipment and specimens. At about 3:10 p.m., Tetra Tech attempted to call John Dirgo to inform him that the redhorse species were larger than the target weight but were typical of mature redhorse. Cell telephone reception was poor, and the call could not be completed. Tetra Tech and Normandeau left the site area at 3:30 p.m. and arrived at the PSARA warehouse at 3:45 p.m.

Upon arrival at the warehouse, Tetra Tech telephoned Tom Alcamo and John Dirgo to inform them that all the target species were obtained at all three locations and that most were within the target weight range. Tetra Tech left messages indicating that for some species, sample volumes may be only minimally sufficient for the required quality control and split samples. Tetra Tech also asked for direction regarding the large redhorse specimens and indicated that they were typical of mature Moxostoma species and that they were the type and size likely to be eaten by people fishing in the creek.

By 4:15 p.m., Normandeau had placed the redhorse specimens in purge buckets and had checked on the specimens collected from the Conard's Branch site and the Richland Creek 1-mile site. All the fish were alive, and none appeared to be experiencing oxygen deprivation stress. At 4:30 p.m., Tetra Tech and Normandeau left the warehouse.

Wednesday, May 28, 2003

• The target weight range specified for crayfish is for composite samples, not for individual specimens (see Photograph No. 16 in Appendix A).
• The target weight range (50 to 100 grams) specified for shorthead redhorse is smaller than typical weights of mature fish in the Moxostoma genus. Smaller specimens were not observed in similar abundance during electroshocking efforts at the Richland creek 5-mile site. George Christian indicated that Normandeau would return to the sampling location and attempt to collect smaller specimens if necessary. Russ Cepko of Viacom stated that previous samples collected from the sampling location weighed 50 to 100 grams and that he would consult with EPA before instructing Normandeau to return to the stream to collect smaller specimens.

At 8:45 a.m., Tetra Tech called John Dirgo in the Chicago office, who initiated a three-way conference call with Tom Alcamo at EPA. Tetra Tech indicated that mature redhorse are among the largest fish in stream assemblages and that the specimens collected would be in the size range likely to be eaten by subsistence and recreational fishermen. Tetra Tech recommended that EPA require Viacom to submit fillet samples of the large specimens. While the issue was being resolved, Normandeau processed crayfish and creek chub samples from Conard's Branch.

At 9:10 a.m., after discussing the issue with Russ Cepko of Viacom and reaching a compromise, EPA indicated that Normandeau should prepare fillet samples of large redhorse specimens and should return to the sampling location site to find smaller specimens for whole body samples. At 9:40 a.m., EPA indicated that Normandeau should prepare fillets of the large specimens by choosing one large, one medium, and one small fish exceeding the specified target weight range.

Normandeau finished processing samples from the Conard's Branch site at 9:55 a.m. Table 3 summarizes information for samples collected from the sampling location. Composite whole body samples of crayfish were all within the target weight range. A matrix spike/matrix spike duplicate (MS/MSD) sample was submitted for the crayfish. Creek chubs from Conard's Branch were also within the target weight range of 10 to 36 grams, but for two samples, composites were prepared to meet the minimum 20-gram weight required for analysis with replication. The two composite samples were prepared as duplicates by cutting the four smallest creek chubs in half and placing two head sections and two tail sections in each duplicate sample (see Photograph No. 17 in Appendix A).

Tetra Tech directed Normandeau to prepare a whole body duplicate split sample for EPA using one of the larger creek chub. The EPA sample consisted of one whole fish with the same weight and sex as Normandeau sample NL0004. The EPA split sample was not prepared by splitting individual fish in half because creek chub were not available in sufficient quantity to provide composite splits. For deep- bodied fish, split samples prepared in this manner should be composite samples, as was the case with the small creek chub duplicate samples. Because creek chub do not have a laterally compressed body shape, internal organs are not positioned symmetrically and would not likely divide evenly when the fish is cut in half in either direction. As a result, two very similar fish are more likely to have equivalent contaminant concentrations than two halves of the same fish. Composite split samples of multiple fish reduce the random error introduced by the partitioning of organs during dissection. This issue is especially significant for wide- or deep-bodied fish and for contaminants like PCBs that tend to partition in fatty tissues in and around major organ systems. Because additional creek chub were not available for composite split samples of larger specimens, Tetra Tech chose to submit a large whole body duplicate sample as a split sample. One alternative may have been to submit composite split samples of the smallest specimens used for Normandeau duplicate samples NL0011 and NL0012; however, smaller specimens would be subject to greater within-group variability because they would not be as likely to have bioaccumulated PCBs at the same rate over time and space in the available habitat. Larger, older specimens would be expected to have experienced the same average environmental conditions over their life span.

After completing sample processing for specimens collected from Conard's Branch, Tetra Tech and Normandeau left the PSARA warehouse for the Richland Creek 5-mile site. Tetra Tech and Normandeau arrived at the site at 10:05 a.m. and began preparing to electroshock fish for smaller shorthead remorse specimens (see Photograph No. 18 in Appendix A). At 10:10 a.m., Normandeau began electroshocking at the ford crossing the stream and proceeded in an upstream direction (see Photographs No. 19 and 20 in Appendix A). Normandeau electroshocked about 200 meters of the stream before encountering extensive woody debris and steeply incised banks about 12 feet high. Because the upstream reach was impassable, Normandeau returned to the ford and prepared to electroshock downstream of the reach sampled on the previous day. Normandeau weighed the only two small shorthead remorse specimens collected in the upper reach and determined that only one was within the target weight range. The other sample weighed 125 grams and was retained as a contingency sample if other smaller specimens were not available.

At 10:50 a.m., Normandeau began electroshocking downstream of the ford (see Photograph No. 21 in Appendix A). Electroshocking continued until shortly before noon, when a fuse blew in the electroshocking equipment. Normandeau returned to the ford area to repair the equipment. While Normandeau was replacing the blown fuse, Brian Mann, the property owner, arrived on site. Mr. Mann introduced himself and asked Normandeau and Tetra Tech about the stream investigation. He indicated that although he and his family did not eat fish from the creek, other people in the area eat fish from Richland Creek despite being informed of the potential for PCB contamination.

At 12:10 p.m., after replacing the blown fuse, Normandeau resumed electroshocking about 150 meters downstream of the ford (see Photographs No.22 and 23 in Appendix A). At about 12:30 p.m., Normandeau collected another small specimen of shorthead redhorse about midway between the ford and the bridge at Route 43. At 12:55 p.m., obstructions in the lower reach again prevented Normandeau from proceeding any further down the stream channel. Normandeau returned to the ford and moved all of its equipment south to the bridge at Route 43.

At 1:10 p.m., Normandeau began electroshocking downstream of the bridge at Route 43 (see Photograph No. 24 in Appendix A). In the muddy upper reach, water clarity was obscured to less than 1 foot. Normandeau obtained the third small redhorse sample below the bridge and prepared to return to the PSARA warehouse. Tetra Tech and Normandeau arrived at the warehouse at 1:35 p.m. and resumed sample processing. Tetra Tech called Tom Alcamo at EPA to inform him that after 3 hours of electroshocking, three smaller specimeris of shorthead redhorse were obtained. Tetra Tech indicated that Normandeau would submit the three small redhorse specimens as whole body samples and that fillet samples of larger specimens would include an EPA split sample, a field duplicate sample, and an MS/MSD sample.

At 1:45 p.m., Tetra Tech left the warehouse to get bags of ice for sample shipment. The sampling plan indicates that samples would be shipped with dry ice, but according to Mike McCann of Viacom and Dennis Williamson of MCHD, dry ice is no longer commercially available in Bloomington. The dry ice that Normandeau had brought and stored in the freezer at the PSARA warehouse had evaporated, and additional ice was needed for the shipment of the EPA split samples.

Tetra Tech returned to the warehouse at 2:05 p.m. to observe sample processing for specimens from the Richland Creek 1-mile site. Table 3 summarizes information for samples collected from the sampling location. Tetra Tech directed Normandeau to use the largest specimens available in each sample category. Crayfish and creek chub samples were all within the target weight range, and an MS/MSD was prepared using the excess crayfish specimens.

At 2:30 p.m., Richard McCandless of PSARA stated that water samples collected on May 27 had been shipped to Heritage Environmental Laboratories in Indianapolis, Indiana, earlier in the day.

Tetra Tech directed Normandeau to prepare fillet samples of the largest white sucker specimens collected from the Richland Creek l-mile site. All the white sucker specimens used for the fillet samples were within the target weight range of 60 to 120 grams. The largest specimen was selected for duplicate fillet samples (Normandeau samples NL0026 and NL0027). Fillets were taken from both sides of the fish and were submitted with the skin on and the scales removed. One fillet met the 20-gram minimum requirement for sampling with no replication. The other fillet weighed only 16 grams, which will allow for only one set of sample analysis without replication. Of the six white sucker whole body samples submitted for analysis, three were within the target weight range, two were less than the target weight range (45 and 50 grams), and one was a composite. The composite sample was submitted as an NIS,MSD sample and consisted of seven white sucker specimens ranging from 25 to 38 grams.

For the reasons stated above for the creek chub split sample (see the discussion of sample processing for Conard's Branch), Tetra Tech directed Normandeau to prepare an EPA split sample as a whole body duplicate sample of one of the larger white sucker specimens remaining after fillet sample processing. The two fish chosen as duplicate split samples weighed 82 and 83 grams. The specimen submitted for the EPA split sample was male, while the corresponding duplicate sample submitted by Normandeau w as female. Female fish typically have a higher lipid-to-body-weight ratio than male fish. As a result, contaminant concentrations in Normandeau sample NL0030 may be greater than in the EPA split sample: however, contaminant concentrations in the EPA split sample should be greater than the concentrations present in the 72-gram male sample submitted as Normandeau sample NL0029.

At 3:00 p.m., Normandeau began preparing rock bass fillet samples from the Richland Creek l-mile site. Two of the three specimens slightly exceeded the target weight range of 60 to 110 grams; the third sample was within range at 106 grams. All of the rock bass fillet samples from the Richland Creek l-mile site exceeded the 20-gram minimum weight required. For all three samples, fillets were taken from both sides of the fish and were submitted with the skin on and the scales removed. Tetra Tech directed Normandeau to prepare an EPA split sample from the largest rock bass specimen weighing 128 grams (see Photograph No. 25 in Appendix A). One fillet from the largest rock bass was submitted as an EPA split sample, and the other was submitted as Normandeau sample NL0035. Normandeau prepared duplicate fillet samples from the next largest rock bass specimen weighing 115 grams Normandeau samples NL0036 and NL0037). The third sample included both fillets from the 106-gram rock bass to meet the 20-gram sample weight requirement (Normandeau sample NL0038).

Three longear sunfish fillet samples were prepared from specimens collected at the Richland Creek l-mile site. Tetra Tech directed Normandeau to fillet the largest specimens and reserve the remaining specimens for whole body samples. For all three samples, fillets were taken from both sides of the fish and were submitted with the skin on and the scales removed. Two of the fillet samples met the 20-gram minimum sample weight requirement. The two fillets from the third largest sunfish weighed only 15 grams, which does not meet the minimum weight required for analysis with replication. Three of the five whole body samples of longear sunfish were within the target weight range of 30 to 60 grams. The other two samples weighed 20 and 22 grams, which provided adequate sample volume for analysis with replication. Additional specimens in the same size class were not available for compositing.

At 3:30 p.m., Tetra Tech directed Normandeau to prepare an EPA split sample of two female longear sunfish weighing 30 and 35 grams. Adequate sample volume was available for composite split samples of two longear sunfish of the same sex and size class. Tetra Tech requested that Normandeau cut the to o fish in half and include one half of each fish in the EPA split sample, with the other two halves constituting Normandeau sample NL0047. Unlike creek chub and white sucker, longear sunfish have a slim, laterally compressed body shape, and their internal organs are more likely to be arranged symmetrically. This body shape minimizes within-group variation resulting from the asymmetrical partitioning of organs during dissection.

Normandeau prepared samples from the Richland Creek 5-mile site until about 5:00 p.m. Table 3 summarizes information for samples collected from the sampling location. Specimens of shorthead redhorse submitted for whole body analysis were within the target weight range of 50 to 100 grams. The whole body samples of the smaller redhorse obtained earlier in the day were all gutted rather than purged because whole body samples must be purged for 24 hours before being submitted for analysis. The gastrointestinal tract must be removed because recently ingested material is not representative of contaminant concentrations that may have bioaccumulated in fish tissue. Redhorse specimens prepared as fillet samples all exceeded the target weight range. The largest sample consisted of two fillets removed from a 368-gram redhorse specimen. The 117-gram sample was submitted as an MS,ZvISD sample Normandeau sample NL0049). The second largest redhorse specimen weighed 244 grams and was prepared as an EPA split sample. One fillet from the fish was submitted as Normandeau sample NL0052, and the other fillet was submitted as an EPA split sample. Fillets from a third redhorse specimen weighing 137 grams were submitted as duplicate field samples (Normandeau samples NL0052 and NL0053). All redhorse fillet samples were submitted with the skin on and the scales removed.

Normandeau decontaminated the fillet knife after processing each sample by scrubbing the knife with Alconox and rinsing it twice with deionized water. At 5:00 p.m., Normandeau collected an equipment rinsate sample by pouring deionized water over both sides of the fillet knife (see Photograph No. 26 in Appendix A). The equipment rinsate sample also included deionized water poured over the fish measuring board and other equipment used to process the samples.

At 5:15 p.m., Tetra Tech received copies of Normandeau's sampling logs and began preparing the split samples for shipment to Axys Analytical Services in Sidney, British Columbia, Canada, for analysis of total PCB congeners and percent lipids. At 5:35 p.m., Tetra Tech left the PSARA warehouse to deliver samples to Federal Express for overnight shipment.

Normandeau's fish tissue samples were sent by overnight courier to Paradigm Analytical Laboratories in Wilmington, North Carolina, for analysis of total PCB congeners and percent lipids. Surface water samples collected on May 27 were shipped on May 28 to Heritage Environmental Laboratories in Indianapolis, Indiana, for PCB Aroclor and total suspended solids analyses.

In general, the stream investigation of Conard's Branch and Richland Creek in Monroe County, Indiana, was completed in accordance with Viacom's May 2003 sampling plan for the three sampling sites. All target species were obtained at each site, although some were not in the specified target weight range. Conformance of this specific event with the EPA-approved sampling plan for tissue samples is summarized below.

1.Conard's Branch site

• Composite crayfish whole body samples were within the target weight range.
• All individual creek chub specimens were within the target weight range of 1(J to 36 grams. Composite samples were required for two of the five samples in order to provide the 20-gram minimum required for analysis.

2.Richland Creek 1-Mile Site

• Individual creek chub specimens and composite crayfish whole body samples were within the target weight range.
• Three of the whole body samples of white sucker were within the target weight range of 60 to 120 grams, and three were not. Of the three that were not within the target weight range, two consisted of individual fish weighing 45 and 50 grams, and the third was a composite of seven smaller fish submitted as an MS/MSD sample.
• For the white sucker fillet samples, all specimens were within the target weight range, but only three of the four fillets met the 20-gram requirement for analysis with replication. Samples NL0026 and NL0027 were prepared as duplicate fillets from a 120-gram white sucker specimen. One fillet weighed 21 grams, but the other weighed only 16 grams.
• For the longear sunfish fillet samples, two of the three samples met the 20-gram minimum weight required for analysis with replication. The third sample included both fillets from a 37-gram fish, but the total fillet sample weight was only 15 grams.
• Three of the five longear sunfish whole body samples were within the target weight range of 30 to 60 grams. Two weighed slightly less at 20 and 22 grams.
• All rock bass fillet samples were within the target weight range.

3.Richland Creek 5-Mile Site

• Redhorse specimens for fillet samples were gutted rather than purged. Both methods are included in the EPA-approved sampling plan.
• Specimens prepared as whole body samples were all within the target weight range
.
• Specimens prepared as fillet samples all exceeded the target weight range.

As directed by EPA, Tetra Tech will conduct oversight of future activities conducted in association with the Neal's Landfill site and will provide EPA with field oversight summaries. Planned future activities for the Neal's Landfill site include (1) further Viacom investigations associated with water treatment alternatives and (2) further characterization of fish, surface water, and sediment.