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EPA Region 6 Records Ctr. PHASE 2 SUPPLEMENTAL SAMPLING AND ANALYSIS WORK PLAN Fields Brook Superfund Site Ashtabula, Ohio Prepared by de maximis, inc. December 2006 276918

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EPA Region 6 Records Ctr.

PHASE 2 SUPPLEMENTAL

SAMPLING AND ANALYSIS WORK PLAN

Fields Brook Superfund Site

Ashtabula, Ohio

Prepared by

de maximis, inc.

December 2006

276918

PHASE 2 SUPPLEMENTALSAMPLING AND ANALYSIS WORK PLAN

1. INTRODUCTION

Results from the October 2006 supplemental soil sampling event identified the general area ofelevated concentrations of PCBs in soils that might be a source of PCBS identified in theFields Brook sediments. This Work Plan provides for a truck mounted Geoprobe® Rig to beused to further define the location and extent of the PCBs within this area.

This Work Plan is organized as follows:

• History

• Scope of Work

• Sampling Procedures

• Analytical Procedures

• Quality Assurance/Quality Control

• Nomenclature

• Safety

• Project Schedule

2. HISTORY

2.1 2004 Sampling

Annual soil sampling of the Fields Brook sediments and floodplain soils is required as part ofthe Post-Closure sampling requirements for the Fields Brook Superfund Site. In August2004, sediment samples in the brook to the east of State Street indicated the presence of PCBsat concentrations in excess of the Confidence Remov?' Goal (CRG) (established for the Siteremedy) for PCBs of 50 mg/kg. In 2004, one sediment sample (SD16), located approximately130 feet east of State Street, contained 100 mg/kg PCBs. A supplemental investigationperformed in November 2004 included collecting samples at 50 foot intervals both upstreamand downstream of location FBSD16. No other locations contained PCBS in excess of theCRGs. Therefore, in May 2005, the sediments in the area of SD16 were removed and theissue was believed to be an anomaly.

2.2 2006 Sampling

Results from the August 2006 sampling event indicated elevated concentrations of PCBs insediment sample locations SD15 and SD16 (See Figure 1). The sediment samples SD15 andSDI6 indicated PCB concentrations of 130 mg/kg and 92 mg/kg, respectively. The PCBs

Phase 2 - Supplemental Soil Sampling Plan Page 1 of 5

concentrations of samples upstream and downstream of these samples were well within theCRG (5.3 mg/kg at SDH (downstream) and 0.65 mg/kg at SD17 (upstream).

A Supplemental Investigation was performed in October 2006 with two goals:

1) To further delineate the sediment within the brook that exceeds 50 mg/kg.

2) To identify the source of the PCBs. This area of the brook was fully excavated in2001 as part of the Final Remedial Action for the brook. The underlying soilswere removed and clean soils were placed as a foundation for the brook. Thebrook was then lined with a filter fabric and clean cobbles were placed on top ofthe filter fabric. The PCBs that have been identified in the brook have beendeposited in the brook since the Remedial Action was completed.

The data results from the supplemental sediment sampling are provided in Table 1. Severaladditional sediment locations were identified that exceed the Remedial Action CRG of 50mg/kg.

The data results from the soil samples collected in October 2006 are provided in Table 2.Field analysis of the samples was performed using the RaPID Assay immunoassay method byStategic Diagnostics, Inc. For further information on the immunoassay testing and otherdetails of the October 2006 sampling event, see the Site Monitoring Report - SupplementalSoil and Sediment Sampling Performed October 2006 - Fields Brook Superfund Site.

3. SCOPE OF WORK

Soil samples will be collected at approximately 19 locations identified in Figure 2 using atruck mounted Geoprobe® Rig. Each of these locations will be sampled at the 1-foot, 2-foot,and 3-foot depths below ground surface (bgs). Surface samples will not be collected sincethe top one foot of soil is clean soil that was placed as part of the Remedial Action in 2001. Ifvisual observation of the soil core collected indicates that a sample should be pulled from adifferent depth, then that judgement will be made and documented in the field log. If visualobservation indicates soil staining, then another soil boring location (with samples collectedfrom the three intervals) will be established at a location approximately 25 feet towards thedirection that is assumed to be clean. If samples south of the Millenium fence line are needed,then contact Bob Rule for direction on how to obtain access.

The samples will be packaged and transferred to CompuChem Labs in Gary, North Carolinafor PCB analysis using EPA Method SW846-8082.

Phase 2 - Supplemental Soil Sampling Plan Page 2 of 5

3.1 Sampling Procedures

The Geoprobe* will be advanced once at each location to a three-foot depth. Samples will becollected using acetate liners that will be pushed to the desired depth into the subsurface by aGeoprobe* rig. The soil boring (contained within the acetate liner) will be pulled and laid outon a clean surface (such as visqueen). Visual observations of the soil characteristics will bedocumented in a logbook. At least one discreet sample will be collected from each 1-footsection of soil to represent that section. Additional samples may be collected as appropriatefor properly characterizing contaminant conditions in the area. The sample number willdocument the lowest point of the soil interval that is selected for sampling, as explained inSection 3.4(4). As each interval is sampled, Moisture content will also be documented foreach sample interval in terms of dry, damp, moist, or saturated to determine the firstoccurrence of groundwater. Site conditions, sample locations, observations, and times, andother relevant information will be recorded in the field sampling log book maintained for theevent.

Sample containers will be provided by the laboratory (as provided for in the approved SiteQAPP). All samples to be sent to the laboratory will be transported as required by the QAPP.The sample containers will be filled, sealed, labeled, and placed in coolers. The samples willbe stored at 4 °C (± 2 °C) and shipped to the laboratory via overnight delivery.

3.2 Laboratory Analytical Procedures

Soil samples will be analyzed for PCBs (EPA Method SW846-8082) by CompuChem Labs ofGary, NC. Additional analyses may be performed based on field observations. The analyticalmethod, the laboratory method detection limits, and the laboratory-specific analytical standardoperating procedure are approved in the Project QAPP.

3.3 Quality Assurance/Quality Control

QA/QC samples will be collected at the following frequency:

• Duplicate samples will be collected for the field analysis at a rate of 1 duplicate per 10samples collected.

• MS/MSD samples will be collected for the soil samples at a rate of 1 per 20 fieldsamples.

• If dedicated equipment is not used and equipment decontamination is requiredbetween samples, then field equipment blanks will be collected at a rate of 1 blank per20 samples.

Phase 2 - Supplemental Soil Sampling Plan Page 3 of 5

3.4 Nomenclature

The unique identification numbers will be assigned in agreement with the approved QAPP, asfollows:

1) The first two characters of the sample identification code will identify the projectas "FB".

2) The next two characters of the sample identification code will identify the sampleas a soil sample, where SS is used to designate soil samples.

3) The next two characters of the sample identification code will identify the locationwith a number, starting with the number 70, and increasing (e.g., SS70, SS71,SS72...)

4) The next two characters, preceded by a hyphen (-) will represent the lower-mostdepth of the sample core, in inches, where "12" would represent the samplecollected from 12-inches bgs, etc.

5) The final four characters, preceded by a hyphen (-) will represent the month andyear of the sampling event, in the format of-MMYY, where MM identifies themonth that the sample is collected and YY identifies the year. An exampleidentification number for soil sample SS71 in a sampling event performed inDecember of 2006 is "SS71-12-1206".

6) Quality control samples will be identified as follows:

a) SS-DUPX, or SD-DUPX are used for field duplicates, where X is anumber, increasing with each duplicate sample collected in that event, andfollowed by -MMYY, where MM identifies the month that the sample iscollected and YY identifies the year. An example identification numberfor the second duplicate soil sample collected in an event on December15th of 2006is"SS-DUP2-1206";

b) EBX is used for Equipment Blanks, where X is a number, increasing witheach field blank sample collected in that event, and followed by -MMYY,where MM identifies the month that the equipment blank sample iscollected and YY identifies the year. An example identification numberfor the second equipment blank sample collected in an event on December15th of 2006 is "EB2-1206"; and

c) Matrix spike/matrix spike duplicate samples will be identified identical tothe sample identifier for the original sample from the location. Thesesamples will appear as additional samples from that location.

Phase 2 - Supplemental Soil Sampling Plan Page 4 of 5

4. SAFETY

The work planned is located in an industrial area directly north of Millennium Chemicals.This facility manufactures Titanium oxide (TiO:) and Titanium tetrachloride (TiCl4). WhenTiCU contacts water, chlorine gas forms. Releases of the chlorine gas have been known tooccur from the Millennium Chemicals facility.

An Addendum to the Project Health and Safety Plan specifically to address work in this areais attached as Appendix A to this plan.

5. REPORTING

A final report will be prepared providing a brief description of field sampling procedures andinformation on field observations made during thje sampling activities, tables presenting thelaboratory results, and copies of the data verification reports and laboratory results. Dataverification will be performed following the approved Project QAPP guidelines.

6. PROJECT SCHEDULE

Dec 19, 2006 Field sampling begins

Jan 12, 2007 3-week turnaround on laboratory samples complete

Feb 16, 2007 Sample data verification and Draft Final Report to FBAG

K:\om\719'.SamplingYPhase 2 Soil SAP 2006.doc

Phase 2 - Supplemental Soil Sampling Plan Page 5 of 5

TABLES

Table 1

Fields Brook Superfund SiteSupplemental Sediment Data

October 2006

Sample IdentificationTotal PCB

(PPm)FBSD15-02-1006FBSD16-02-1006Duplicate of FBSD16-02FBSD 16-04-1006FBSD30-02-1006FBSD31-02-1006FBSD32-02-1006FBSD33-02-1006FBSD33-04-1006FBSD34-02-1006FBSD34-04-1006FBSD35-02-1006FBSD35-04-1006FBSD36-02-1006FBSD37-02-1006Duplicate of FBSD37-02

25150110150451608419018035281501106012080

Revised Fields Brook PCB Results.xls

Table 2

Fields Brook Superfund SiteSupplemental Soil Data

October 2006

Sample Identification

FBSS30-02-1006FBSS30-06-1006FBSS30-12-1006FBSS30-24-1006FBSS30-36-1006

FBSS31-02-1006FBSS31 -06-1 006FBSS31-12-1006FBSS3 1-24-1 006FBSS31-36-1006

FBSS32-02-1006FBSS32-06-1006FBSS32-12-1006FBSS32-24-1006FBSS32-30-1006

FBSS33-02-1006FBSS33-06-1006FBSS33-12-1006FBSS33-24-1006FBSS33-36-1006

FBSS34-02-1006FBSS34-06-1006FBSS34-12-1006FBSS34-24-1006FBSS34-36-1006

FBSS35-02-1006FBSS35-06-1006FBSS35-12-1006FBSS35-24-1006FBSS35-36-1006

FBSS36-02-1006FBSS36-06-1006FBSS36-12-1006FBSS36-24-1006FBSS36-32-1006

FBSS37-02-1006FBSS37-06-1006FBSS37-12-1006FBSS37-16-1006FBSS37-24-1006FBSS37-36-1006

Range 0.58- 11.7

Field Assay Result (ppm)

0.730.701.771.251.63

2.230.801.07ND1.66

NDNDNDND1.26

3.90NDNDNDND

14.05NDND

3.14ND

NDNDND1.38ND

NDNDNDNDND

ND5.97NDNDNDND

Analytical

(ppm)

9.3

5.50

0.025 J

2.00

0.15U

11.00

0.62

0.160U

Sample Notes

Auger met refusal at 30"

Auger met refusal at 32"

Soil staining observed - sample collected for VOCanalysis also

Revised Fields Brook PCB Results.xls

Table 2

Fields Brook Superfund SiteSupplemental Soil Data

October 2006

Sample Identification

FBSS38-02-1006FBSS38-06-1006FBSS38-12-1006FBSS38-24-1006FBSS38-36-1006

FBSS39-02-1006FBSS39-06-1006FBSS39-12-1006FBSS39-24-1006FBSS39-36-1006

FBSS40-02-1006FBSS40-06-1006FBSS40-12-1006FBSS40-24-1006

FBSS41-02-1006FBSS41-06-1006FBSS41-12-1006FBSS41-24-1006FBSS41 -36-1 006

FBSS42-02-1006FBSS42-06-1006FBSS42-12-1006FBSS42-24-1006FBSS42-36-1006

FBSS43-02-1006FBSS43-06-1006FBSS43-12-1006FBSS43-24-1006FBSS43-36-1006

FBSS44-02-1006FBSS44-06-1006FBSS44-12-1006FBSS44-24-1006FBSS44-36-1006

FBSS45-02-1006FBSS45-06-1006FBSS45-12-1006

Range 0.58- 11.7

Field Assay Result (ppm)

3.565.23NDNDND

20.991.49NDNDND

3.08NDNDND

0.832.40NDNDND

NDNDNDNDND

12.5514.907.25NDND

ND3.995.985.17ND

8.0911.042.34

Analytical

(ppm)

3.80

6.80

0.97

1.200.31

0.094

7.7

0.14U

2.1

3.10

4.80

Sample Notes

Auger met refusal at 24"

Auger met refusal at 18"

Revised Fields Brook PCB Results.xls

Table 2

Fields Brook Superfund SiteSupplemental Soil Data

October 2006

Sample Identification

FBSS46-02-1006FBSS46-06-1006FBSS46-12-1006

FBSS47-02-1006FBSS47-06-1006FBSS47-12-1006FBSS47-24-1006

FBSS48-02-1006

FBSS49-06-1006

FBSS50-06-1006

FBSS5 1-06-1 006

FBSS52-02-1006FBSS52-06-1006FBSS52-1 2-1006FBSS52-1 6-1006FBSS52-24-1006

FBSS53-02-1006FBSS53-06-1006FBSS53-12-1006FBSS53-24-1006

FBSS54-02-1006FBSS54-06-1006FBSS54-12-1006FBSS54-24-1006

FBSS55-02-1006FBSS55-06-1006FBSS55-12-1006

FBSS56-02-1006FBSS56-06-1006FBSS56-12-1006FBSS56-24-1006

Range 0.58- 11.7

Field Assay Result (ppm)

6.979.621.14

14.381.94

20.57ND

8.54

ND

4.28

ND

NDND

23.9333.1018.96

41.121.282.27

35.51

1.8325.459.99ND

0.620.701.59

11.9814.07ND1.79

Analytical

(Ppm)

2.7

210

0.180 U

0.64

2700

83

1100

46.0

1.10

12

Sample Notes

Auger met refusal at 12"

Auger met refusal at 27"

black catalyst observed

Trench pile material

Trench pile material

Trench pile material

dark gray soil with brick materialAuger met refusal at 24"

black & gray soils noted from 18" to 22"Auger met refusal at 24"

Black stained soilAuger met refusal at 24"

Auger met refusal at 12"

Auger met refusal at 24"

Revised Fields Brook PCB Results.xls

Table 2

Fields Brook Superfund SiteSupplemental Soil Data

October 2006

Sample Identification

FBSS57-02-1006FBSS57-06-1006FBSS57-12-1006FBSS57-24-1006

FBSS58-02-1006FBSS58-06-1006FBSS58-12-1006FBSS58-24-1006FBSS58-36-1006

FBSS59-02-1006FBSS59-06-1006FBSS59-12-1006

FBSS60-02-1006FBSS60-06-1006FBSS60-12-1006FBSS60-24-1006

FBSS61 -02-1 006FBSS6 1-06- 1006FBSS61-12-1006FBSS61-24-1006FBSS61-36-1006

FBSS62-02-1006FBSS62-06-1006FBSS62-12-1006FBSS62-24-1006FBSS62-36-1006

FBSS63-02-1006FBSS63-06-1006FBSS63-12-1006FBSS63-24-1006FBSS63-36-1006

FBSS64-02-1006FBSS64-06-1006FBSS64-12-1006FBSS64-24-1006FBSS64-36-1006

FBSS65-02-1006FBSS65-06-1006FBSS65-12-1006FBSS65-24-1006FBSS65-28-1006

Range 0.58 -11. 7

Field Assay Result (ppm)

4.011.400.08ND

1.744.266.201.02ND

2.300.99ND

2.310.73NDND

6.001.591.94NDND

9.889.638.067.547.82

2.301.801.27NDND

2.051.63NDNDND

4.972.911.63NDND

Analytical

(ppm)

1.40

2.60

2.700.42

0.05 J0.14U

2.00

1000

0.90

0.36

0.15U

Sample Notes

Auger met refusal at 24"

asphalt encountered

Auger met refusal at 18"

Auger met refusal at 28"

from center of small island

black streaks with white specks

Slack stainingWater encountered

Surface water sample FBSW30 collected

Auger met refusal at 28"

Revised Fields Brook PCB Results.xls

Table 2

Fields Brook Superfund SiteSupplemental Soil Data

October 2006

Sample Identification

FBSS66-02-1006FBSS66-06-1006FBSS66-12-1006FBSS66-24-1006FBSS66-36-1006

Range 0.58- 11.7

Field Assay Result (ppm)

3.612.920.96NDND

Analytical

(ppm)

2.10

Sample Notes

Revised Fields Brook PCB Results.xls

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APPENDIX A

Addendum to Fields Brook Superfund Site

Post-Closure

Health and Safety Plan

TASK-SPECIFIC HASP ADDENDUM

FOR ACTIVITIES PERFORMED IN EU-8

OF FIELDS BROOK

Work Description

1. Read Task-Specific Work Plan

2. Read Fields Brook Post-Closure Health and Safety Plan

Prior to Arriving at Site

1. Subcontractors shall submit copies of OSHA HAZWOPER training/update certificates tode maximis, inc.

2. Each Subcontractor employee shall review Fields Brook HASP and provide a signedcopy of Figure 11-1, Plan Acceptance Form.

Job Safety Analysis

\. A Site Safety Meeting shall be held each day before activities begin. A Site SafetyMeeting Form shall be completed and signed by all persons to perform the work (SeeFigure 1). Directions to the hospital (Figure 2) will be reviewed.

2. Locate spoils, other materials, and equipment at least 2 feet from the side of theexcavation area (or brook)

Work Zones

1. Clearly delineate exclusion zone (EZ), contamination reduction zone (CRZ), or accesscontrol points, and support zone.

2. Limit access to EZ, CRZ and control points.

3. Maintain a log of all individuals entering the EZ.

Personnel Protective Equipment (PPE)

As defined by the Site HASP, Modified Level D PPE will be required for the work, including:

1. Tyvek, poly coated preferred due to wet conditions

2. Chemical resistant gloves, and Chemical resistant over boots.

Decontamination Procedures

Decontamination prevents the spread of potentially contaminated material from the work zones.

Personnel Decontamination

The following decontamination procedure will be used:

1. Remove boots and outer gloves

2. Remove coveralls (if worn)

3. Remove inner gloves

4. Wash hands, face and neck

Rinse waters from decontamination will be collected for disposal in the 300 gallon tank at FieldsBrook Landfill. PPE will be containerized and disposed at an approved off-site facility.

Equipment Decontamination

Equipment that comes into contact.with the soils will be thoroughly washed with soap and water.Water used for decontamination will be collected for disposal in the 300 gallon tank at Fields BrookLandfill.

To minimize tracking soil on the roads, all equipment leaving the site will be clean and free of soil ormud.

Millennium Chemicals

The work planned is located in an industrial area directly north of Millennium Chemicals. Thisfacility manufactures Titanium oxide (TiOi) and Titanium tetrachloride (TiCU). When TiCU contactswater, chlorine gas forms. Releases of the chlorine gas have been known to occur from theMillennium Chemicals facility.

Chlorine gas is dangerous even for short exposures. The gas has an irritating and pungent odor and isirritating to the nose, throat, and lungs. If an exposure has occurred, transport the affected individualimmediately to the Ashtabula General Hospital (Figure 1). A representative from MillenniumChemicals is present at the hospital after all facility releases.

In the event that a release occurs, and alarm will be sounded. The Millennium Chemicals alarms areas follows:

Minor Alarm - a continuous high pitch siren. Minor alarms indicate an alarm for inside thefacility that should not affect the area outside the property line.

Major Alarm - a High/low wavering siren.

IF A MAJOR ALARM IS SOUNDED - DON THE PROVIDED ESCAPE PACK AND NOTETHE WIND DIRECTION. TURN OFF ALL IGNITION SOURCES AND GET INDOORSIMMEDIATELY.

All Clear - Westminster Chimes

NOTE

Millennium Chemicals tests these alarms even' Friday at 9 am and 11 am.

Figure 1

Safety Meeting Form

Facility Name Fields Brook Superfund Site

Date Time Project Number_

Client Address

Facility Location

Type of Work

Chemicals Used

SAFETY TOPICS PRESENTED

Protective Clothing/Equipment

Chemical Hazards

Physical Hazards_

Emergency Procedures

Asntaouia County Medical uentet,Hospital/Clinic ^.Paramedic Phone No.

Hospital/Clinic Address. 2420 Lake Avenue phone No 440-997-2262

Special Equipment

Other

ATTENDEES

Name Printed Signature

Meeting Conducted by:_

Name Printed / Signature

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Figure HASP 11-1Plan Acceptance Form

Fields Brook Superfund Site

This form is to be completed by all personnel performing work at the Fields Brook Superfund Site in AshtabulaCounty, Ohio.

1 have read and understand the full contents of this Site-Specific Health and Safety Plan. I agree to perform all sitework in a safe manner and in accordance with the contents of the plan.

Printed Name

Signature

Date

Company

Return to the OM&M Project Manager before starting to work on subject project work site.

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