SRS - REMOVAL ASSESSMENT REPORT FOR THE BETHEL … · Final Report. Prepared for: U.S....

REMOVAL ASSESSMENT REPORT

BETHEL AVENUE PAINT SITE INDIANAPOLIS, MARION COUNTY, INDIANA

Final Report

Prepared for:

U.S. Environmental Protection Agency

Emergency Response Branch, Region 5

77 West Jackson Boulevard

Chicago, IL 60604

TDD No.:

Date Prepared:

Contract No.:

Prepared by:

START Project Manager: Telephone No.:

U.S. EPA On-Scene Coordinator:

Telephone No.:

S05-0001-16-03-001

June 23rd, 2016

EP-S5-16-01

SRS

Raghu Nagam

(312) 220-7171 Jason Sewell

(317) 517-6987

79 West Monroe Street Suite 1119

Chicago, IL 60604

Removal Assessment Report

Bethel Avenue Paint Site

TDD:0001/S05-0001-16-03-001

i

TABLE OF CONTENTS

Section Page

1 INTRODUCTION ......................................................................................................... 1

2 SITE BACKGROUND .................................................................................................. 2

2.1 Site Description………………………………………………. ................................ 2

2.2 Site History ................................................................................................................ 2

3 REMOVAL ASSESSMENT ACTIVITIES .................................................................. 5

3.1 Site Reconnaissance ................................................................................................... 5

3.2 Field Screening and Sampling ................................................................................... 6

3.3 Container Inventory ................................................................................................... 7

4 SAMPLE ANALYTICAL RESULTS ......................................................................... 10

5 POTENTIAL SITE RELATED THREATS ................................................................ 12

6 SUMMARY ................................................................................................................. 14

7 REFERENCES ............................................................................................................ 15

FIGURES

Figure Page

Figure 1. Site Location Map ................................................................................................................... 3

Figure 2. Site Features Map ……………………………………………………………………………4

TABLES

Table Page

Table 1. Sample Summary .................................................................................................................... 8

Table 2. Container Inventory Estimate ................................................................................................. 9

Table 3. Sample Analytical Results .................................................................................................... 11

APPENDICES

A PHOTOGRAPHIC LOG

B VALIDATED ANALYTICAL DATA PACKAGE



TDD: S05-0001-16-03-001 1

1 INTRODUCTION

Sustainment and Restoration Services LLC (SRS) performed the Removal Assessment (RS) of the Bethel

Avenue Paint Site (Site) located at 3150 Bethel Avenue in Marion County, Indianapolis, Indiana. SRS,

the Superfund Technical Assessment and Response Team (START) contractor was tasked by the United

States Environmental Protection Agency (U.S. EPA), under contract number EP-S5-16-01 and Technical

Direction Document (TDD) No. S05-0001-16-03-001, to perform this RS. START was tasked to prepare a

site-specific Health and Safety Plan (HASP) and a field Sampling and Analysis Plan (SAP); procure the

services of an analytical laboratory; collect paint, stains, sealers and stripper samples; document on-site

conditions with written logbook notes and still photographs; evaluate analytical data; and prepare this RS

Report. SRS START members Raghu Nagam and Katherine Cooper conducted the field investigation and

sampling on April 22nd

, 2016. START member Katherine Cooper conducted Site container inventory on

May 27th, 2016.

This RS report summarizes the Site background; discusses the assessment; provides a summary of the

analytical data; and discusses potential site-related threats. The appendices for this report include a

photographic log (Appendix A) and the validated sample analytical results (Appendix B).

2 Removal Assessment Report


TDD: S05-0001-16-03- 001

2 SITE BACKGROUND

This section provides a description of the Site and the Site history.

2.1 Site Description

The Bethel Avenue Paint Site is a former paint business located inside a closed strip mall at 3150 Bethel

Avenue, Indianapolis, Indiana (Figure 1). The former Bethel Avenue paint business occupies an

approximate area of 3,000 square feet (ft2) in three adjacent business suites - 3138, 3142, and 3150

Bethel Avenue. The Site is physically bounded to the north side by Van Buren Street, to the south by

Bethel Avenue, to the east by open land, and to the west by Perkins Avenue. The Site area is a mix of

residential and commercial properties. A park is located next to the open land on its east side and several

residences are located all around the strip mall. (Figure 2 – Site Features Map).

2.2 Site History

The Site premise was previously utilized as a paint business and it involved paint, stains, sealers, and

strippers. After the paint business shut down its activities, several hundred paint, stain, sealers, and

stripper containers were left abandoned inside the three suites. The Marion County Public Health

Department requested U.S. EPA assistance to address any threats from abandoned paints and other

potentially ignitable and corrosive material at the Site.

Disclaimer: This map is intended for visual orientation use only.In no way is this map to be used for precise locational use.

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TDD No. S05-0001-16-03-001

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4 Removal Assessment Report


TDD: S05-0001-16-03-001

Legend

Site boundary

Feet 100 50 0

Scale

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BETHEL AVENUE PAINT - RS

INDIANAPOLIS, MARION COUNTY, INDIANA

TDD No. S05-0001-16-03-001

FIGURE 2. SITE FEATURES MAP

Van Buren Street

3150 Bethel Avenue

3142 Bethel Avenue

3138 Bethel Avenue




TDD: S05-0001-16-03-001

5

3 REMOVAL ASSESSMENT ACTIVITIES

On April 22nd, 2016, U.S. EPA On-Scene Coordinator (OSC), Jason Sewell and START members mobilized

to the Site to perform RS activities, which included a site reconnaissance and collection of liquid

samples. On May 27th, 2016 OSC Jason Sewell and START member Katherine Cooper mobilized to

the Site to perform a container inventory. These assessment activities are discussed below.

A site-specific SAP was developed prior to mobilizing for conducting the assessment and to perform

the field work. The SAP described the data quality objectives (DQO), sampling strategy, sampling

locations, sampling methodology, and analytical procedures for analyzing the samples.

This section summarizes site reconnaissance (subsection 3.1) and sampling (subsection 3.2). Table 1

presents a summary of collected samples. Photographic documentation is provided in Appendix A.

3.1 Site Reconnaissance

Site reconnaissance was performed in level “D” personal protective equipment (PPE) in accordance

with the approved site-specific HASP. START calibrated U.S. EPA’s MultiRAE® Plus

photoionization detector (PID) multi-gas monitor and the Ludlum model 192 gamma radiation monitor

prior to conducting the Site reconnaissance. The MultiRAE® Plus PID measures carbon monoxide

(CO), volatile organic compounds (VOCs), hydrogen sulfide (H2S), lower explosive limit (LEL), and

oxygen(O2). The Ludlum model is a high-sensitivity gamma radiation MicroR survey meter.

The strip mall consisted of one main building, with three access doors to business suites 3138, 3142, and

3150. Inside of each suite were numerous containers of paints, stains, sealers, strippers, and other solvents.

Evidence of multiple roof leaks were observed, including puddles of water on the floor, wet cardboard

boxes, and water pooling on top of containers in each of the suites. Numerous containers were corroded and in

poor condition. A previous investigation performed by the local fire marshal found the wiring of the building

to be a potential threat for electrical fire hazards.

In addition to paints, suite 3138 contained several mattresses (see photograph 3, 4, 5, and 6) indicating

potential residential occupation. Suite 3142 had multiple rooms, all stored with paint and related

containers. Suite 3142 had several containers stored in a hap-hazardous way and physical movement

was restricted due to the quantity and placement of containers. Several corroded and swollen containers

were observed here, including a



TDD: S05-0001-16-03-001

6

swollen Sherwin Williams container adjacent to a pool of foam near the rear of the first room of suite

3142 (see photograph 7, 8, 9, 10).

The door to suite 3150 had a posted “No Smoking” sign. Evidence of a fire, including burnt debris inside

of a melted garbage can was observed within this suite. A plastic container wrapped in duct tape with a

corrosive label was observed near a container labeled flammable liquid. Two tables have been constructed

using the paint, stains, sealers, and stripper containers as legs and boards as the table top to hold this

container. More containers are stacked on top of similarly constructed tables. Most of the table tops are

bowing from the combined container weight (see photograph 11-18). The adjoining room to the back of

suite 3150 contained bulk containers. Three to five of the bulk containers were labelled flammable (see

photograph 19 and 20). Another room in the back of suite 3150 housed numerous containers stacked from the

floor to the ceiling. Containers occupied the majority of the space inside of the room. The floor of this suite

had pools of water indicating potential roof leaks.

3.2 Field Screening and Sampling

Field screening was performed using a MultiRAE® Plus PID multi-gas monitor to screen samples for

VOCs prior to collection of samples. MultiRAE® Plus readings from a container labelled Sherwin

Williams – Pro Industrial – High Performance Epoxy indicated 100 parts per million (PPM) VOCs. This

container was selected for laboratory sample collection and analysis for Total VOCs. Some of the

containers chosen for sampling and laboratory analysis had labels indicating corrosive or ignitable

contents. The plastic container wrapped in duct tape had a label indicating corrosive contents. Containers

labeled Sherwin Williams Isopropyl Alcohol, Sherwin Williams Sher-Wood Catalyst, and Flood Paint

Solutions Penetrol had flammable warnings on the label.

Seven containers from suite 3150 were chosen to be sampled based on label information and/or on

monitoring instrument readings. Six of the seven containers were moved to a central location within the

suite prior to sampling. The seventh container, labeled corrosive, was left at its original location to avoid

disturbing the container and a sample was collected from its original location (see photograph 30).

A total of nine liquid samples, including two duplicates, were collected during the RS investigation.

Duplicate sample BP-6 was collected for flashpoint analysis, as the duplicate of BP-4. Duplicate sample

BP-7 was collected for pH and Total VOCs analyses, as the duplicate of BP-1.

START collected liquid samples by directly decanting liquid from the containers into lab-supplied



TDD: S05-0001-16-03-001

7

glass sample containers. Sample containers were labeled and placed on ice for shipment to the

laboratory. Samples collected at the Site are summarized in Table 1.

Liquids samples were collected from the abandoned containers located on-site. All samples were

collected in level C PPE gear. Samples were submitted to Test America laboratory for corrosivity

determination by pH in accordance with EPA method SW-846 9045D, ignitability determination by

flashpoint in accordance with D92, and Total VOCs in accordance with SW-846 8260B.

3.3 Container Inventory

START conducted the container inventory on May 27th, 2016. START documented approximately

2,520 quarts, 6,858 gallon containers, and 1,175 5-gallon containers of paint, stains, sealers, and

strippers located inside suites 3138, 3142, 3150 (see Table 2). Many stain containers were Sherwin

Williams stains labeled Sher-Wood BAC Wiping Stain. Numerous other containers were labeled

Urethane Hardener, High Performance Epoxy, and Acrylic Enamel. The container inventory is an

estimate due to the volume and organization of the containers at the Site. Containers were stored by

stacking containers on top of one another in numerous rows.



TDD: S05-0001-16-03-001

8

Notes:

a BP-6 is the duplicate sample of the native sample BP-4 analyzed for Flashpoint.

b BP-7 is the duplicate sample of the native sample BP-1 analyzed for pH and Total VOCs

BP-01 Bethel Avenue Paint Site sample identification

VOCs Volatile Organic Compounds

pH Measure of acidity or basicity of the solution

Samples were collected on April 22nd, 2016 under TDD No: S05-0001-16-03-001

Table 1

Sample Summary

Bethel Avenue Paint – RS

Indianapolis, Indiana

Sample ID Sample Container Laboratory Analysis

BP-1 Sherwin Williams - Sherwood -

Catalyst

pH

Flashpoint

Total VOCs

BP-2 Sherwin Williams - Chemical Coating Flashpoint

VOCs

BP-3 SuperTuff - Deck and Roof Cleaner

Pro Strength pH

BP-4 Flood Paint Solutions - Penetrol Flashpoint

BP-5 Sherwin Williams - Polyurethane

Hardener Part B

pH

Total VOCs

BP-6a Flood Paint Solutions - Penetrol Flashpoint

BP-7b Sherwin Williams - Sherwood -

Catalyst

pH

Total VOCs

BP-8 Vana Trol (HCl) pH

BP-9 Sherwin Williams - Pro Industrial -

High Performance Epoxy Total VOCs



TDD: S05-0001-16-03-001

9

Table 2

Container Inventory Estimate

Bethel Avenue Paint Site - RS


Container Type

Suite Total

3150 3142 3138

Quart 961 1,307 252 2,520 quarts

Gallon 1,407 5,339 112 6,858 gallons

5 Gallon 665 415 95 1,175 5-gallon

Notes:

Inventory was performed on May 27, 2016, by U.S. EPA and START members.

Containers included paint, stains, sealers, and strippers.

Container inventory is an estimate due to the volume and arrangement of containers at

the Bethel Avenue Paint Site.



TDD: S05-0001-16-03-001

10

4 SAMPLE ANALYTICAL RESULTS

START reviewed the sample analytical data and supporting quality assurance/quality control (QA/QC)

data provided by Test America Laboratories Inc. and performed data validation of the results. The

validated analytical data package is included in Appendix B. Based on START’s data validation, the data

are acceptable for use as qualified. The following section summarizes laboratory analytical results for

samples collected during the RS field activities. For purposes of evaluating hazardous characteristics,

samples were compared to the Code of Federal Regulations (CFR) sections which verify the characteristics

of a hazardous waste for ignitability and corrosivity, 40 CFR § 261.21 and § 261.22. Detected

concentrations of Total VOCs were compared against 40 CFR § 261.24 TCLP regulations for determining

toxicity characteristics of the samples. Table 3 summarizes all detected analytical results for liquid

samples.

The analytical results of samples collected and analyzed for corrosivity determination by pH indicated that

four out of five samples exhibited characteristic of corrosivity (Sample BP-1, BP-3, BP-7 and BP-8). A

liquid meets the characteristics of corrosivity as defined by 40 CFR § 261.22, if it has a pH of greater than

or equal to 12.5 SU or less than or equal to 2 SU. Sample BP-8 had the lowest pH at 0.54 standard unit

(SU). Sample BP-8 was collected from the container labeled Vana-Trol and corrosive. The highest pH was

documented in sample BP-3, which was collected from a container labeled SuperTuff Deck and Roof

Cleaner Pro Strength.

Analytical results for ignitability determination by flashpoint indicated that two out of four samples

exhibited characteristic of ignitability. A liquid meets the characteristics of ignitability as defined by 40

CFR § 261.21, if it has a flash point of less than 140 °F. Samples BP-1 and BP-2 documented liquid having

flash point temperatures of 102 °F and 112 °F respectively.

One of the four samples analyzed for Total VOCs indicated benzene and methyl ethyl ketone

concentrations greater than the CFR Regulatory Levels (RLs) (BP-09). Results from sample BP-09

indicated a benzene concentration of 27 ppm and methyl ethyl ketone concentration of 290 ppm, above the

respective RL values of 0.5 ppm and 200 ppm respectively.



TDD: S05-0001-16-03-001

11

Table 3

Sample Analytical Results

Bethel Avenue Paint - RS


Parameter Regulatory Limit Sample Identification

BP-1 BP-2 BP-3 BP-4 BP-5 BP-6a BP-7b BP-8 BP-9

Flashpoint (°F) <140 °F 102 112 NA 157 NA 167 NA NA NA

pH (SU) ≤2 or ≥12.5 1.57 NA 13.5 NA 5.32 NA 1.61 0.54 NA

Total VOCs (ppm)1

Benzene 0.5 5 2.5 NA NA 13 NA 5 NA 27

Methyl Ethyl Ketone 200 100 50 NA NA 250 NA 100 NA 290

Notes:

Bold and highlighted - Result exceeds the Regulatory Limit

< Less than

≤ - Less than or equal to

≥ - Greater than or equal to 1 - Total and TCLP VOCs are considered the same for liquid samples from this Site

NA - Not analyzed

BP-01 Bethel Avenue Paint Site sample identification number

VOCs Volatile organic compounds

pH Measure of acidity or basicity of the solution

a BP-6 is the duplicate sample of the native sample BP-4 analyzed for Flashpoint.

b BP-7 is the duplicate sample of the native sample BP-1 analyzed for pH and Total VOCs.

Samples were collected on April 22nd, 2016 under TDD No: TO-01-14-03-1035.

Samples analyzed for ignitability, corrosivity, and Total VOCs were compared to 40 CFR § 261.21,

261.22, and 261.24.



TDD: S05-0001-16-03-001

12

5 POTENTIAL SITE RELATED THREATS

Threats posed by on-site contamination and site conditions were evaluated in accordance with The

National Oil and Hazardous Substances Pollution Contingency Plan (NCP) criteria for initiating removal

action listed under Title 40 of the CFR, Section 300.415(b) (2). Paragraph (b) (2) of 40CFR Section

300.415 lists factors to be considered when determining the appropriateness of a potential removal action

at a site. Potential site-related threats to human health and the environment were evaluated based on the

criteria listed in 40 CFR, Sections 261.20 through 261.31. Factors that may be applicable to the Site are

discussed below.

Actual or potential exposure of nearby human populations, animals, or the food chain to hazardous

substances or pollutants or contaminants (40 CFR 300.415(b)(2)(i))

Analytical results from samples BP-1 and BP-2 documented liquid having flash points less than 140°F,

which, per 40 C.F.R. § 261.21 regulation, meets the characteristic of ignitability (D001).

Analytical results from liquid samples BP-1, BP-3, BP-7, and BP-08 indicate pH level greater than or equal

to 12.5 SU or less than or equal to 2 SU. This result, per to 40 C.F.R. § 261.22 regulation, meets the

characteristic of corrosivity (D002).

The presence of confirmed hazardous material inside suites with broken roof pose a threat to vandals and

trespassers through direct exposure. Presence of mattresses inside the suites also indicate potential

inhabitation by vandals or trespassers. Human contact with these materials can result in exposure to

corrosive, ignitable, and other hazardous materials.

Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage

containers that may pose a threat of release (40 CFR 300.415(b)(2)(iii))

During the Site investigation, U.S. EPA and START observed and documented the presence of 1,175 5-

gallon containers, 6,858 gallon containers, and 2,520 quart containers. Many containers contained labels

such as “Flammable” and “Corrosive”. Numerous containers were in poor and dilapidated condition.



TDD: S05-0001-16-03-001

13

Analytical results of the samples confirmed the presence of ignitable and corrosive waste at the Site.

These containers were deteriorating, with visible spilled material on the floors. Leaking roofs may

accelerate deterioration of the containers leading to the release of hazardous substances and migration of

the hazardous material to off-site locations.

Threat of fire or explosion (40 CFR 300.415(b)(2)(vi))

Analytical results from the removal assessment documented that material in the containers were flammable

liquids and pose a threat of fire or explosion. This removal assessment documented two liquid samples

having flashpoint results below 140 °F, which is the criterion for ignitibility for a hazardous waste.

Previous inspection performed by a fire marshal found the wiring of the building to be a potential electrical

fire hazard at the Site which coupled with ignitable and VOC materials pose a threat of fire or explosion at

the site. Any fire at the site has the potential to release hazardous material to the atmosphere and expose

nearby residents to the toxic fumes related to the fire.



TDD: S05-0001-16-03-001

14

6 SUMMARY

On April 22nd, 2016, U.S. EPA and START conducted a removal assessment at the Bethel Avenue Paint

Site located in Indianapolis, Indiana. Field screening with a PID for VOCs was performed on container

contents prior to sampling. During sampling, nine liquid samples were collected and submitted for pH

and/or flashpoint determination, as well as Total VOCs analysis.

The analytical results for samples collected and analyzed for corrosivity determination by pH indicated

four out of five samples as meeting the characteristic of corrosivity. The result according to 40 CFR §

261.22 meets the characteristic of a hazardous waste for corrosivity. Analytical results from samples

BP-1 and BP-2 documented liquid as having flash points less than 140 °F, which, according to 40

CFR§ 261.21, meets the characteristic of a hazardous waste for ignitability. VOCs including benzene

and methyl ethyl ketone were detected above the applicable RLs.

Abandoned containers holding hazardous waste are present on the Bethel Avenue Paint property. Based

on the proximity of residential properties, the corrosive and ignitable wastes pose a potential direct

contact threat to the public. Additionally, the deteriorated condition of the containers poses a threat of

release. The ignitable waste also poses a potential threat of fire and release to the environment.



TDD: S05-0001-16-03-001

15

7 REFERENCES

1. Title 40, Code of Federal Regulations, Sections 261.21 through 261.24. http://www.ecfr.gov/cgi-

bin/retrieveECFR?gp=&SID=ed2b3385fdb87b20b76f206d98312575&n=40y27.0.1.1.2&r=PART

&ty=HTML#40:27.0.1.1.2.3.1.2. Accessed May 20, 2016.

2. Title 40, CFR, Section 300.415. http://www.ecfr.gov/cgi-bin/text-

idx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr300_main_02.tpl. Accessed May 20, 2016.

http://www.ecfr.gov/cgi-

http://www.ecfr.gov/cgi-

http://www.ecfr.gov/cgi-bin/text-

http://www.ecfr.gov/cgi-bin/text-

APPENDIX A

PHOTOGRAPHIC LOG

- 1 -

Site: Bethel Avenue

Paint Site - RS

Contract: EP-S5-16-01

TDD: TO-01-13-11-

1032

OSC: Jason Sewell

Date: April 22, 2016

Time: 1459

Photographer:

Katherine Cooper

Official Photograph No.1:


facing north-east.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1527

Photographer:

Katherine Cooper



facing north-west.

- 2 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1557

Photographer:

Katherine Cooper


Outside suite 3138 facing

north

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1608

Photographer:

Katherine Cooper


View of mattresses and

containers from outside

suite 3138 door.

- 3 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1629

Photographer:

Katherine Cooper


Mattresses and ceiling

inside suite 3138.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1653

Photographer:

Katherine Cooper


Containers inside suite 3138.

Photo also shows spilled

material and corroded

containers

- 4 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 0830

Photographer:

Katherine Cooper


Door to suite 3142.

Site: Bethel Avenue

Paint Site – RS


TDD: TO-01-13-11-1032

OSC: Jason Sewell


Time:

Photographer:

Katherine Cooper


View of containers from

outside suite 3142 door.

- 5 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1440

Photographer:

Katherine Cooper


Swollen Sherwin Williams

container and pool of foam

in suite 3142.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-1032

OSC: Jason Sewell


Time: 1050

Photographer:

Katherine Cooper


Container conditions, wet

card board box and ground

inside suite 3142.

- 6 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-1032

OSC: Jason Sewell


Time: 1022

Photographer:

Katherine Cooper


Suite 3150 address posted

outside.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1127

Photographer:

Katherine Cooper


View of containers from

outside suite 3150 door.

- 7 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 0919

Photographer:

Katherine Cooper

Official Photograph No. 13:

“No smoking” sign posted on

suite 3150 door.

Site: Bethel Avenue

Paint Site - RS


TDD: TO- 01-13-11-

1032

OSC: Jason Sewell


Time: 0940

Photographer:

Katherine Cooper

Official Photograph No. 14: “No smoking sign” posted on suite 3150 door.

- 8 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 0919

Photographer:

Katherine Cooper

Official Photograph No.

15: Evidence of fire in suite

3150.

Site: Bethel Avenue

Paint Site – RS


TDD: TO-01-13-11-1032

OSC: Jason Sewell


Time: 0920

Photographer:

Katherine Cooper

Official Photograph No. 16: Container labeled flammable liquid and container wrapped in duct tape labeled ‘8’ corrosive inside suite 3150.

- 9 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO- 01-13-11-

1032

OSC: Jason Sewell


Time: 1513

Photographer:

Katherine Cooper


17: Container storage in

suite 3150 on a make-shift

table that is buckling

Site: Bethel Avenue

Paint Site - RS


TDD: TO- 01-13-11-

1032

OSC: Jason Sewell


Time: 0946

Photographer:

Katherine Cooper

Official Photograph No. 18: Container storage in suite 3150.

- 10 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1556

Photographer:

Katherine Cooper


19: Bulk containers stored

in back room of suite 3150.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1357

Photographer:

Katherine Cooper

Official Photograph No. 20: Bulk containers labeled flammable liquid stored in back room of suite 3150.

- 11 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1109

Photographer:

Katherine Cooper


21: Water dripping from

ceiling pooling in

aluminum trays, containers,

and container lids, in back

room of suite 3150.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1120

Photographer:

Katherine Cooper

Official Photograph No. 22:

- 12 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1142

Photographer:

Katherine Cooper


23: Sample BP-1 submitted

for flashpoint and pH

determination, as well Total

VOCs analysis.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1150

Photographer:

Katherine Cooper

Official Photograph No. 24: Sample BP-2 submitted for flashpoint determination and Total VOCs analysis.

- 13 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1142

Photographer:

Katherine Cooper



for flashpoint and pH

determination, as well Total

VOCs analysis.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1150

Photographer:

Katherine Cooper

Official Photograph No. 24: Sample BP-2 submitted for flashpoint determination and Total

VOCs analysis.

- 14 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1156

Photographer:

Katherine Cooper



for pH determination.

Site: Bethel Avenue

Paint Site – RS


TDD: TO-01-13-11-1032

OSC: Jason Sewell


Time: 1159

Photographer:

Katherine Cooper

Official Photograph No. 26: Sample BP-4 submitted for flashpoint determination.

- 15 -

Site: Bethel Avenue

Paint Site - RS Contract:

EP-S5-16-01 TDD: TO-

01-13-11-1032

OSC: Jason Sewell


Time: 1207

Photographer:

Katherine Cooper



for pH determination and

Total VOCs analysis.

Site: Bethel Avenue

Paint Site - RS Contract:

EP-S5-16-01 TDD: TO-

01-13-11-1032

OSC: Jason Sewell


Time: 1218

Photographer:

Katherine Cooper

Official Photograph No. 28: Sample BP-6 collected for flashpoint determination.

- 16 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1556

Photographer:

Katherine Cooper



for pH determination and

Total VOCs analysis.

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell

Sample Location: MDP6


Time: 1247

Photographer:

Katherine Cooper

Official Photograph No. 30: BP-8 submitted for pH determination.

- 17 -

Site: Bethel Avenue

Paint Site - RS


TDD: TO-01-13-11-

1032

OSC: Jason Sewell


Time: 1259

Photographer:

Katherine Cooper



for Total VOCs analysis

APPENDIX B

VALIDATED DATA PACKAGE

Sustainment and Restoration Services, llc 79 W. Monroe St, Suite 1119Chicago, IL 60603(312) 220-7171

MEMORANDUM

Date: May 31, 2016 To: Jason Sewell, OSC, US EPA Region 5

Raghu Nagam, Project Manager, SRS Superfund Technical Assessment and Response Team (START) for Region 5

Prepared by: Richard Baldino, START QAO for Region 5 QA/QC Concurrence by:

Subject: Data Validation for Bethel Avenue Paint Site Indianapolis, IN Project TDD No. S05-0001-16-03-001

Laboratory: Test America, Chicago, IL Sample Delivery Group (SDG): 500-110631

1.0 INTRODUCTION

The START QAO for Region 5 validated analytical data for 9 liquid samples for analysis of Volatile Organic Compounds (VOCs), Corrosivity, and Flashpoint. Samples were collected at the Bethel Avenue Paint Site located in Indianapolis, IN on April 22, 2016. The samples were analyzed under SDG 500-110631 by Test America, Inc. of Chicago, IL using U.S. Environmental Protection Agency (U.S. EPA) methods 8260B and 9045D.

Laboratory data were validated using guidelines set forth in the U.S. EPA Contract Laboratory Program National Functional Guidelines (NFG) for Organic Data Review (EPA-540-R-014-002, August 2014), NFG for Inorganic Data Review (EPA-540-R-013-001, August 2014), and applicable methodologies. The purpose of the chemical data quality evaluation process is to assess the usability of data for the project decision-making process. Flashpoint was analyzed using ASTM Method D92.

Organic data validation consisted of a review of the following QC audits:

Chain of custody and sample receipt forms review Sample preservation and holding time Blank results Surrogate recoveries Matrix spike and Matrix Spike Duplicate (MS/MSD) recovery results Laboratory Control Sample (LCS)/Laboratory Control Sample Duplicate (LCSD) recovery results

Inorganic data validation consisted of a review of the following QC audits:

Chain of custody and sample receipt forms review Sample preservation and holding time Blank results Duplicate Sample Results LCS recovery results MS/MSD recovery results

Section 2.0 of this memorandum discusses the results of organic data validation. Section 3.0 of this memorandum discusses the results of inorganic data validation. Section 4.0 presents an overall assessment of

Data Validation for Bethel Avenue paint Project TDD No. S05-0001-16-03-001 Page 2

the data. The attachment to this memorandum contains the laboratory reporting forms as well as START’s handwritten data qualifications where warranted.

2.0 ORGANIC DATA VALIDATION RESULTS

The results of START’s organic data validation are summarized below by QC audit reviewed. The data qualifiers listed below were applied to sample analytical results where warranted (see attachment):

J – The analyte was detected. The reported concentration was considered estimated. U – The analyte was not detected. UJ – The analyte was not detected. The reporting limit was considered estimated.

After the START project staff received the data packages, they were inventoried for completeness and then reviewed according to matrix-specific protocols and data quality objectives established for the project.

2.1 LIQUID SAMPLES BY METHOD 8260B

2.1.1 SAMPLE HANDLING

Chain of custody documentation and sample receipt forms were reviewed to ensure requested analyses were performed and that samples arrived at the laboratory intact. Solid samples were collected on April 22, 2016 and were received on ice by the laboratory on April 23, 2016. No discrepancies were noted.

2.1.2 SAMPLE PRESERVATION AND HOLDING TIME

VOC samples were analyzed within holding time criteria. No discrepancies were noted.

2.1.3 BLANK RESULTS

The purpose of laboratory (or field) blank analysis is to determine the existence and magnitude of contamination resulting from laboratory (or field) activities. A laboratory method blank sample (MB 500-333992/6) was run with this SDG. No method blank detects were noted.

2.1.4 SURROGATE RECOVERIES

Laboratory performance on individual samples is established by means of fortifying each sample with surrogate compounds. Surrogate spike compounds included tetrachloro-m-xylene and decachlorobiphenyl. Surrogate recoveries were acceptable. No discrepancies were noted.

2.1.5 MS/MSD RECOVERY RESULTS

Data for MS/MSDs are generated to determine long-term precision and accuracy of the analytical method on various matrices and to demonstrate acceptable compound recovery by the laboratory at the time of sample analysis.

MS/MSD samples were not requested for this SDG. No qualification was attempted based on missing MS/MSD audit results.

2.1.6 LCS/LCSD RECOVERY RESULTS

Data for the LCS/LCSD is generated to provide information on the accuracy of the analytical method and on the laboratory performance. The LCS/LCSD is fortified with Aroclor 1260 and analyzed with each batch of samples. The LCS/LCSD accuracy performance is measured by Percent Recovery (%R). LCS/LCSD recoveries were acceptable. No discrepancies were noted.


2.1.7 FIELD DUPLICATES

Data for field duplicates were collected and analyzed for chemical constituents to measure the cumulative uncertainty (i.e., precision) of the sample collection, splitting, handling, storage, preparation and analysis operations, as well as natural sample heterogeneity that is not eliminated through simple mixing in the field. Field duplicates are two samples prepared by mixing a volume of sample and splitting it into two separate sample containers that are labeled as individual field samples.

Field duplicate samples were not collected. No qualification was attempted based on missing field duplicate audit results.

2.1.8 GENERAL LABORATORY OBSERVATIONS

The laboratory noted that multiple samples were diluted due to high native VOC concentrations. The resulting reporting limits were elevated.

3.0 INORGANIC DATA VALIDATION RESULTS

The results of START’s inorganic data validation are summarized below by QC audit reviewed. The data qualifiers listed below were applied to sample analytical results where warranted:

J – The analyte was detected. The reported concentration was considered estimated. U – The analyte was not detected. UJ – The analyte was not detected. The reporting limit was considered estimated.

After the START project staff received the data packages, they were inventoried for completeness and then reviewed according to matrix-specific protocols and data quality objectives established for the project.

3.1 LIQUID SAMPLES BY METHOD 9045




Samples were analyzed within the holding time criteria. No discrepancies were noted.

3.1.3 BLANK RESULTS

The assessment of blank analysis results is to determine the existence and magnitude of contamination resulting from laboratory and/or field activities. Laboratory method blank samples are not required for method 9045. No discrepancies were noted.

3.1.4 LCS RECOVERY RESULTS

The LCS serves as a monitor of the overall performance of each step during the analysis, including the sample preparation. The LCS is fortified with each analyte of interest and analyzed with each batch of samples. The LCS accuracy performance is measured by %R. LCS recoveries were acceptable. No discrepancies were noted.


The spiked sample analysis is designed to provide information about the effect of each sample matrix on the sample preparation procedures and the measurement methodology. The MS/MSD accuracy performance is measured by %R.


MS/MSD audits are not required for method 9045. No discrepancies were noted.


Data for field duplicates were collected and analyzed for chemical constituents to measure the cumulative uncertainty (i.e., precision) of the sample collection, splitting, handling, storage, preparation and analysis operations, as well as natural sample heterogeneity that is not eliminated through simple mixing in the field. Field duplicates are two samples prepared by mixing a volume of sample and splitting it into two separate sample containers that are labeled as individual field samples.



No laboratory observations were noted.

3.2 LIQUID SAMPLES BY METHOD ASTM D92




Samples were analyzed within the holding time criteria. No discrepancies were noted.

3.2.3 BLANK RESULTS

The assessment of blank analysis results is to determine the existence and magnitude of contamination resulting from laboratory and/or field activities. Laboratory method blank samples are not required for method D92. No discrepancies were noted.

3.2.4 LCS RECOVERY RESULTS

The LCS serves as a monitor of the overall performance of each step during the analysis, including the sample preparation. The LCS is fortified with each analyte of interest and analyzed with each batch of samples. The LCS accuracy performance is measured by %R.

LCS audits are not required for method D92. No discrepancies were noted.


The spiked sample analysis is designed to provide information about the effect of each sample matrix on the sample preparation procedures and the measurement methodology. The MS/MSD accuracy performance is measured by %R.

MS/MSD audits are not required for method D92. No discrepancies were noted.


Data for field duplicates were collected and analyzed for chemical constituents to measure the cumulative uncertainty (i.e., precision) of the sample collection, splitting, handling, storage, preparation and analysis operations, as well as natural sample heterogeneity that is not eliminated through simple mixing in the field.


Field duplicates are two samples prepared by mixing a volume of sample and splitting it into two separate sample containers that are labeled as individual field samples.



No laboratory observations were noted.

4.0 OVERALL ASSESSMENT OF DATA

The analytical results meet the data quality objectives defined by the applicable method and validation guidance documentation. The analytical data is usable and acceptable as reported by the laboratory.

ATTACHMENT

SUMMARY OF VALIDATED ANALYTICAL RESULTS

AND

CHAIN-OF-CUSTODY

Client Sample ResultsTestAmerica Job ID: 500-110631-1Client: Sustainment & Restoration Services, LLC

Project/Site: Bethel Avenue Paint Site

Lab Sample ID: 500-110631-1Client Sample ID: BP-1Matrix: WasteDate Collected: 04/22/16 11:42

Date Received: 04/22/16 15:40

Method: 8260B - Volatile Organic Compounds (GC/MS)RL MDL

Benzene 5.0 U 5.0 2.9 mg/Kg 04/24/16 17:35 05/05/16 18:34 20000

Analyte Dil FacAnalyzedPreparedUnit DResult Qualifier

20 7.7 mg/Kg 04/24/16 17:35 05/05/16 18:34 20000Carbon tetrachloride 20 U

20 7.7 mg/Kg 04/24/16 17:35 05/05/16 18:34 20000Chlorobenzene 20 U

20 7.4 mg/Kg 04/24/16 17:35 05/05/16 18:34 20000Chloroform 20 U

20 7.8 mg/Kg 04/24/16 17:35 05/05/16 18:34 200001,2-Dichloroethane 20 U

20 7.8 mg/Kg 04/24/16 17:35 05/05/16 18:34 200001,1-Dichloroethene 20 U

100 42 mg/Kg 04/24/16 17:35 05/05/16 18:34 20000Methyl Ethyl Ketone 100 U

20 7.4 mg/Kg 04/24/16 17:35 05/05/16 18:34 20000Tetrachloroethene 20 U

10 3.3 mg/Kg 04/24/16 17:35 05/05/16 18:34 20000Trichloroethene 10 U

10 5.2 mg/Kg 04/24/16 17:35 05/05/16 18:34 20000Vinyl chloride 10 U

1,2-Dichloroethane-d4 (Surr) 93 71 - 127 04/24/16 17:35 05/05/16 18:34 20000

Surrogate Dil FacAnalyzedPreparedQualifier Limits%Recovery

Toluene-d8 (Surr) 98 04/24/16 17:35 05/05/16 18:34 2000075 - 120

4-Bromofluorobenzene (Surr) 100 04/24/16 17:35 05/05/16 18:34 2000071 - 120

Dibromofluoromethane 95 04/24/16 17:35 05/05/16 18:34 2000070 - 120

General ChemistryRL MDL

corrosivity by pH 1.57 0.200 0.200 SU 04/29/16 15:15 1


40.0 40.0 Degrees F 05/04/16 00:17 1Flashpoint 102

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Benzene 2.5 U 2.5 1.5 mg/Kg 04/24/16 17:36 05/05/16 18:08 10000









5.0 1.6 mg/Kg 04/24/16 17:36 05/05/16 18:08 10000Trichloroethene 5.0 U

5.0 2.6 mg/Kg 04/24/16 17:36 05/05/16 18:08 10000Vinyl chloride 5.0 U



Toluene-d8 (Surr) 100 04/24/16 17:36 05/05/16 18:08 1000075 - 120




Flashpoint 112 40.0 40.0 Degrees F 05/04/16 00:33 1


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Benzene 13 U 13 7.3 mg/Kg 04/24/16 17:38 05/05/16 19:27 50000


50 19 mg/Kg 04/24/16 17:38 05/05/16 19:27 50000Carbon tetrachloride 50 U

50 19 mg/Kg 04/24/16 17:38 05/05/16 19:27 50000Chlorobenzene 50 U

50 19 mg/Kg 04/24/16 17:38 05/05/16 19:27 50000Chloroform 50 U

50 20 mg/Kg 04/24/16 17:38 05/05/16 19:27 500001,2-Dichloroethane 50 U

50 20 mg/Kg 04/24/16 17:38 05/05/16 19:27 500001,1-Dichloroethene 50 U


50 19 mg/Kg 04/24/16 17:38 05/05/16 19:27 50000Tetrachloroethene 50 U


25 13 mg/Kg 04/24/16 17:38 05/05/16 19:27 50000Vinyl chloride 25 U



Toluene-d8 (Surr) 99 04/24/16 17:38 05/05/16 19:27 5000075 - 120






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Benzene 5.0 U 5.0 2.9 mg/Kg 04/24/16 17:40 05/05/16 19:01 20000










10 5.2 mg/Kg 04/24/16 17:40 05/05/16 19:01 20000Vinyl chloride 10 U



Toluene-d8 (Surr) 102 04/24/16 17:40 05/05/16 19:01 2000075 - 120






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Benzene 27 13 7.3 mg/Kg 04/24/16 17:42 05/05/16 19:54 50000


50 19 mg/Kg 04/24/16 17:42 05/05/16 19:54 50000Carbon tetrachloride 50 U

50 19 mg/Kg 04/24/16 17:42 05/05/16 19:54 50000Chlorobenzene 50 U

50 19 mg/Kg 04/24/16 17:42 05/05/16 19:54 50000Chloroform 50 U

50 20 mg/Kg 04/24/16 17:42 05/05/16 19:54 500001,2-Dichloroethane 50 U

50 20 mg/Kg 04/24/16 17:42 05/05/16 19:54 500001,1-Dichloroethene 50 U

250 110 mg/Kg 04/24/16 17:42 05/05/16 19:54 50000Methyl Ethyl Ketone 290

50 19 mg/Kg 04/24/16 17:42 05/05/16 19:54 50000Tetrachloroethene 50 U


25 13 mg/Kg 04/24/16 17:42 05/05/16 19:54 50000Vinyl chloride 25 U



Toluene-d8 (Surr) 101 04/24/16 17:42 05/05/16 19:54 5000075 - 120



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Login Sample Receipt Checklist

Client: Sustainment & Restoration Services, LLC Job Number: 500-110631-1

Login Number: 110631

Question Answer Comment

Creator: Scott, Sherri L

List Source: TestAmerica Chicago

List Number: 1

TrueRadioactivity wasn't checked or is </= background as measured by a survey meter.

TrueThe cooler's custody seal, if present, is intact.

TrueSample custody seals, if present, are intact.

TrueThe cooler or samples do not appear to have been compromised or tampered with.

TrueSamples were received on ice.

TrueCooler Temperature is acceptable. Received same day of collection; chilling process has begun.

TrueCooler Temperature is recorded. 9.3

TrueCOC is present.

TrueCOC is filled out in ink and legible.

TrueCOC is filled out with all pertinent information.

TrueIs the Field Sampler's name present on COC?

TrueThere are no discrepancies between the containers received and the COC.

TrueSamples are received within Holding Time (excluding tests with immediate HTs)

TrueSample containers have legible labels.

TrueContainers are not broken or leaking.

TrueSample collection date/times are provided.

TrueAppropriate sample containers are used.

TrueSample bottles are completely filled.

TrueSample Preservation Verified.

TrueThere is sufficient vol. for all requested analyses, incl. any requested MS/MSDs

TrueContainers requiring zero headspace have no headspace or bubble is <6mm (1/4").

TrueMultiphasic samples are not present.

TrueSamples do not require splitting or compositing.

N/AResidual Chlorine Checked.

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