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 and water in Conard's Branch and Richland Creek.

OBJECTIVES AND DESCRIPTION OF CURRENT PROJECT

1.1.1 Objectives

This sampling plan covers the collection of fish and water 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 l 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 and water collected this year with PCB levels from past sampling events at 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 three locations, one in Conard's Branch and the other two in Richland Creek, for total congener PCB analysis. The proposed locations have a history of samples that can be used for trend analysis.
• Collect water samples at each fish sampling location.

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 and water 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. Heritage Environmental Services of Indianapolis, Indiana will perform all water analyses.

2.0 BACKGROUND

2.1 SITE LOCATION AND SETTING AND HISTORY

Richland Creek is a tributary to the West Branch of the White 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 8pm, 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

Surface water and fish have been sampled on several occasions in both creeks. The Conard's Branch and first Richland Creek stations have been sampled most recently in 1998, 2001 and 2002. 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. Fish at the second station in Richland Creek, shown as NL-3 in Figure 2, were last sampled in 1998 and were analyzed using the Aroclor method. References a, b and c 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. Concurrent with fish collections, limited surface water samples will be taken at each location. This section describes the types of field and analytical chemistry data that will be collected for this project.

3.1 SURFACE WATER SAMPLING

The objective of the surface water characterization is to create a record of the Aroclor PCB content of the surface water at the fish sample locations. One surface water sample will be taken at each fish location. In Conard's Branch, PCB levels are expected to be above the standard limit of detection used for the Bloomington project (0.1 ppb). Therefore at this location, NL-I, the standard sampling technique and the standard lab analysis will be used. One 1 liter jar (per grab sample) will be filled at this sample site.

At the Richland Creek locations, it is expected that the PCB level will be below the 0.1 ppb standard limit of detection used for the Bloomington project. Therefore, at these locations a modification will be made to the standard sampling technique and the standard lab analysis to allow a lower limit of detection. Grab samples will be taken. Specifically, two 1 liter jars (per grab sample) will be filled at the sample sites in Richland Creek. Both bottles will be extracted at the lab and the extracts combined. Additionally, the combined extract will be concentrated to l milliliter versus the standard 5 milliliters. This should allow a detection limit of approximately 0.01 ppb.

Apart from these modifications, all other procedures for the collection of surface water will be per Field Procedure No. 4: Surface Water and Sediment Sampling (WEC, 1995) (Referenced).

3.2 FISH SAMPLING

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

Three stations are to be sampled. See Figure 2 for the locations.

• NL-I: 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 I 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 seven whole body creek chubs and 3 whole body crayfish. 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 and percent lipids. For the congener analysis, a sample of approximately 20 grams will be required. Composite samples of multiple fish can be used to meet this goal if necessary. The size of interest for the crayfish is 30 to 34 grams, which is the size of those collected in 1998. All 3 crayfish samples will be analyzed for congener PCBs and percent lipids.
• 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, six whole body longear sunfish, six whole body white suckers, three fillets of longear sunfish, three fillets of white suckers, three whole body crayfish and three fillets of rock bass. Sizes of fish should range from 30 to 60 grams for creek chubs and sunfish. The white sucker fish samples should range from 60 to 120 grams. The size of interest for the crayfish is the same as those collected in 1998, 21 to 34 grams. The size of interest of the rock bass is 60 to 110 grams (to match up with the sizes sampled in 1998) or larger if there are larger sized rock bass present. All fish of each species will be analyzed for total congener PCBs and percent lipids. All samples will require at least 20 grams of total tissue. Composite samples of multiple fish can be used if necessary.
• NL-3: In Richland Creek near Hendricksville, approximately three miles downstream of the SR48 crossing of Richland Creek (approximately 5.5 miles downstream of Neal's Landfill). This location is shown on Figure 2 to be just upstream of an unnamed tributary. This station corresponds with Fish Site 3 that was sampled by Viacom in 1998. Target species, sample type and number of samples for this event at this site are: three whole body shorthead redhorse suckers and three fillets of shorthead redhorse suckers. If enough shorthead redhorse suckers are not available, then three whole body white suckers and three fillets of white suckers can be sampled instead. The size of interest for each fish is 50 to 100 grams. 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. At NL-3 the fish samples should be obtained upstream of the unnamed tributary, if possible. 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. Protocolfor 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 (GI) tract will be removed from the large f sh 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. Fillets will be skin on and scaleless.

3.3 SAMPLE HANDLING, PRESERVATION, CUSTODY AND SHIPMENT

All water samples taken will be immediately sealed, labeled and then placed in an iced cooler while awaiting transport to the lab. 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.

3.4 ANALYTICAL PROGRAM

The estimated number of samples, field QC samples (i.e., field duplicates, rinsate blanks), and laboratory QC samples (i.e., MS/MSD samples) are presented by location in Table 1. Table l also lists the analytical parameters to be obtained at each sample location. Table 2 summarizes the analytical methods, sample preservation requirements, and holding times. Heritage Environmental Services in Indianapolis will perform all water analysis in accordance with SOPs approved for this project. Paradigm Labs in Wilmington, NC will perform all fish analyses in accordance with SOPs approved for this project.

Additional sample volume may be required for the field duplicates or MS/MSD samples. Field duplicates will consist of a split from the same fish (i.e. a fish cut in half for a whole body duplicate or two filets from the same fish for filet duplicates). The USEPA is also expected to request about 10% (about 5 samples) field splits for analysis. These field splits will be field duplicates sent to a different analytical lab.

The lab will analyze for PCB congeners using EPA method 1668A. This method utilizes a GC- HRMS technique. While 209 pcb congeners are possible in a sample, previous total congener analyses of these fish have shown that a subset of these 209 is present in the fish. The lab will use this previous experience to focus on the analysis of just those congeners. However, standards will be run for all congeners and if a previously unseen congener is presented in a "significant" (significant is defined as any additional or sum of additional congeners that would change the resultant total congener amount by more than 1%) amount, the lab will quantify it.

3.5 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.

3.6 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 after completion of tasks whenever the potential for contamination exists 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. Rinse with tap water.
4. Spray rinse with 10 percent methanol or 70% isopropanol solution
5. Spray rinse with DI water.
6. Place on plastic and allow to air dry.

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