Long-Term Monitoring Network
     Optimization Evaluation

               for

Wash King Laundry Superfund Site
      Lake County, Michigan
                  \
              June 2006

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             Solid Waste and         EPA 542-R-06-004
             Emergency Response     December 2006
             (5102P)              www.epa.gov
  Long-Term Monitoring Network
      Optimization Evaluation

                 for

Wash King Laundry Superfund Site
      Lake County, Michigan
               June 2006

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              FINAL
 LONG-TERM MONITORING NETWORK

    OPTIMIZATION EVALUATION

               FOR

WASH KING LAUNDRY SUPERFUND SITE
      LAKE COUNTY, MICHIGAN
             June 2006

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                          TABLE OF CONTENTS

                                                                          Page

LIST OF ACRONYMS	iv


SECTION 1 -INTRODUCTION	1-1


SECTION 2 - SITE BACKGROUND INFORMATION	2-1

2.1     Site Location and Operational History	2-1
2.2     Environmental Setting	2-2
       2.2.1  Topography	2-2
       2.2.2  Geology	2-3
       2.2.3  Hydrogeology	2-3
       2.2.4  Surface Water Hydrology	2-6
2.3     Nature and Extent of Contamination	2-6
       2.3.1  Shallow Portion of the Surficial Aquifer	2-9
       2.3.2  Deep Portion of the Surficial Aquifer	2-12
       2.3.3  Middle Branch Pere Marquette River	2-12

SECTION 3 - LONG-TERM MONITORING PROGRAM AT WASH KING	3-1

3.1     Description of Monitoring Program	3-1
3.2     Summary of Analytical Data	3-4

SECTION 4 - QUALITATIVE LTMO EVALUATION	4-1

4.1     Method for Qualitative Evaluation of Monitoring Network	4-2
4.2     Results of Qualitative LTMO Evaluation for Groundwater	4-3
       4.2.1  Extraction Wells	4-3
       4.2.2  Monitoring Wells Screened in the Shallow Portion of the
             Surficial Aquifer	4-9
       4.2.3  Monitoring Wells Screened in the Deep Portion of the Surficial
             Aquifer	4-11
4.3     Data Gaps	4-13
       4.3.1  Shallow Portion of the Surficial Aquifer	4-13
       4.3.2  Deep Portion of the Surficial Aquifer	4-14
4.4     Analytical Program	4-15
4.5     LTM Program Flexibility	4-15
                                     -i-
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                  TABLE OF CONTENTS (Continued)

                                                                        Page

SECTION 5 - TEMPORAL STATISTICAL EVALUATION	5-1

5.1    Methodology for Temporal Trend Analysis of Contaminant Concentrations	5-1
5.2    Temporal Evaluation Results for Groundwater Wells	5-4

SECTION 6 - SPATIAL STATISTICAL EVALUATION	6-1

6.1    Geostatistical Methods for Evaluating Monitoring Networks	6-1
6.2    Spatial Evaluation of the Monitoring Network at Wash King	6-3
6.3    Spatial Statistical Evaluation Results	6-5

SECTION 7 - SUMMARY OF LONG-TERM MONITORING
             OPTIMIZATION EVALUATION	7-1

7.1    Groundwater Monitoring Network Summary	7-1

SECTION 8 - REFERENCES	8-1

Appendix A - Comments and Responses on Draft Report


                             LIST OF TABLES

No.                                  Title                               Page
2.1    Basecase Groundwater Monitoring Program	2-7
3.1    PCE Data Date Distribution	3-3
3.2    Summary of Occurrence of Groundwater Contaminants of Concern	3-5
3.3    Most Recent Groundwater COC Concentrations	3-6
4.1    Monitoring Network Optimization Decision Logic	4-2
4.2    Monitoring Frequency Decision Logic	4-3
4.3    Qualitative Evaluation of Groundwater Monitoring Network	4-4
5.1    Temporal Trend Analysis of Groundwater Monitoring Results	5-7
6.1    Best-Fit Semivariogram Model Parameters	6-4
6.2    Results of Geostatistical Evaluation Ranking of Wells by Relative Value
      of PCE in Shallow Zone Wells	6-7
6.3    Results of Geostatistical Evaluation Ranking of Wells by Relative Value
      of PCE in Deep Zone Wells	6-8
7.1    Summary of Long Term Monitoring Optimization Evaluation of Wash
      King Groundwater Monitoring Program	7-2
7.2    Summary of Revised and Basecase Monitoring Programs	7-9
                                   -11-
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                      TABLE OF CONTENTS (Continued)
                              LIST OF FIGURES

No.                                   Title                               Page
2.1     Potentiometric Surface for Shallow Zone	2-4
2.2     Potentiometric Surface for Deep Zone	2-5
2.3     Relative Well Screen Intervals	2-8
2.4     Most Recent Total Chlorinated Ethene Concentrations in the Shallow
       Zone	2-10
2.5     Most Recent Total Chlorinated Ethene Concentrations in the Deep Zone	2-11
3.1     Monitoring and Extraction Wells	3-2
4.1     Qualitative Evalution Sampling Frequency Recommendations for
       Shallow Zone Wells	4-7
4.2     Qualitative Evalution Sampling Frequency Recommendations for Deep
       Zone Wells	4-8
4.3     OWE PCE Concentrations over Time	4-10
5.1     PCE Concentrations Through Time at Well MW-212D	5-2
5.2     Conceptual Representation of Temporal  Trends and Temporal Variations
       in Concentrations	5-3
5.3     Conceptual Representation of Continued Monitoring at Location Where
       No Temporal Trend in Concentrations is Present	5-5
5.4     Temporal Trend Decision Rationale Flowchart	5-6
5.5     Shallow Zone Temporal Trend Results for PCE in Groundwater	5-9
5.6     Deep Zone Temporal Trend Results for PCE in Groundwater	5-10
6.1     Idealized Semivariogram Model	6-3
6.2     Impact of Missing Wells on Predicted Standard Error	6-6
6.3     Geostatistical Evaluation Results Showing Relative Value of Spatial
       Information of PCE Distribution in Shallow Wells	6-9
6.4     Geostatistical Evaluation Results Showing Relative Value of Spatial
       Information of PCE Distribution in Deep Wells	6-10
7.1     Combined Evalution Recommendations  for Shallow Zone Wells	7-5
7.2     Combined Evalution Recommendations  for Deep Zone Wells	7-6
7.3     Combined Evalution Summary Decision Logic	7-7
                                    -111-

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                           LIST OF ACRONYMS
am si
bgs
CERCLA

COC
DCE
ESRI
ft/day
ft/ft
ft/yr
GIS
OWE
LTM
LTMO
MCL
MDEQ
MDNR
mg/L
MNO
NAPL
ND
PCE
RAO
RI
ROD
TCE
USEPA
UST
VOCs
microgram(s) per liter
above mean sea level
below ground surface
Comprehensive Environmental Response, Compensation, and
Liability Act
contaminant of concern
dichloroethene
Environmental Systems Research Institute, Inc.
foot per day
foot per foot
feet per year
geographical information system
groundwater extraction
long-term monitoring
long-term monitoring optimization
maximum contaminant level
Michigan Department of Environmental Quality
Michigan Department of Natural Resources
milligrams per liter
monitoring network optimization
non aqueous-phase liquid
not detected
tetrachloroethene
remedial action objective
remedial investigation
record of decision
trichloroethene
United States Environmental Protection Agency
underground storage tank
volatile organic compounds
                                    -IV-
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                                  SECTION 1

                              INTRODUCTION
   Groundwater monitoring programs have two primary objectives (U.S. Environmental
Protection Agency [USEPA],  1994; Gibbons, 1994):

      1.  Evaluate long-term  temporal  trends in contaminant concentrations  at one  or
         more  points within  or outside the remediation zone as a means of monitoring
         the performance of the remedial measure (temporal objective) and

      2.  Evaluate the extent to which contaminant migration is occurring, particularly if
         a potential exposure point for a susceptible receptor exists (spatial objective}.

   The relative success of any remediation system and its  components  (including the
monitoring network) must be  judged based on the degree to which it achieves the stated
objectives of the  system.  Designing an effective  groundwater  monitoring program
involves  locating monitoring points   and developing a  site-specific  strategy  for
groundwater sampling and analysis to maximize the amount of relevant information that
can be  obtained  while minimizing  incremental costs.  Relevant information is that
required to effectively address the temporal and spatial objectives of monitoring.  The
effectiveness of a monitoring network in achieving these two primary objectives can be
evaluated quantitatively using statistical techniques.   In addition, there may be  other
important considerations associated with a particular monitoring network that are most
appropriately addressed through a qualitative assessment of the network.  The qualitative
evaluation may consider such factors as hydrostratigraphy, locations of potential receptor
exposure points with respect to a  dissolved contaminant plume, and the direction(s) and
rate(s) of contaminant migration.

   This  report  presents a description  and evaluation  of the groundwater monitoring
program  associated with the Wash King Superfund  Site located in Pleasant  Plains
Township, Lake County, Michigan.  This report does not address the larger issue  of
remedial process  optimization for this  site.  A monitoring network consisting of 44
groundwater monitoring wells and five groundwater extraction wells was evaluated  to
identify potential opportunities to  streamline monitoring activities while still maintaining
an effective monitoring program.  A three-tiered approach, consisting of a qualitative
evaluation, a statistical evaluation of temporal trends in contaminant concentrations, and
a  spatial  statistical analysis  assessed  the degree to  which the  monitoring network
addresses the   objectives of the monitoring  program, as well  as  other  important
considerations.  The qualitative evaluation addressed all 49 monitoring  and  extraction
wells. The temporal evaluation addressed  those wells with adequate historical analytical
data (>4  sampling events)  to conduct a trend analysis,  and the  spatial  statistical

                                      1-1

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evaluations included separate evaluations for those wells  screened  in the shallow and
deep aquifers. The results of the three evaluations were combined and used to assess the
optimal frequency of monitoring and the spatial distribution of the components of the
monitoring  network.    The  results  of the  analysis  were  then  used  to  develop
recommendations for optimizing the monitoring program at Wash King.
                                      1-2
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                                 SECTION 2

                 SITE BACKGROUND INFORMATION
   The location, operational history, environmental setting (i.e., geology, hydrogeology,
and  surface water  hydrology), and  remediation  history  of Wash King are briefly
summarized in the following subsections. This information was derived primarily from
published  and unpublished information received  from the Michigan Department of
Environmental Quality (MDEQ) and the Record of Decision (ROD) prepared for the site
in 1993 (USEPA, 1993).

2.1    SITE LOCATION AND OPERATIONAL HISTORY

   The Wash King Laundry site is located south of the city of Baldwin in Pleasant Plains
Township,  Lake  County,  Michigan.    The site  is bordered  on the east by  a line
approximately 300 feet east of highway M-37, on the south by Star Lake Road (76th
Street), on the west by the C&O Railroad, and on the north by the Middle Branch Pere
Marquette River.  At the time that the ROD was published in 1993, the Pere Marquette
Subdivision Plat, which comprises the site,  included 123 residential lots, most of which
were not used on a year-round basis. Housing in the area consisted primarily of mobile
homes, trailers, and cottages.   Numerous  commercially developed lots  existed  along
Highway M-37. Current land use conditions are not known.

   The former Wash King Laundry was granted permission to discharge soapy  laundry
wastewater to four nearby unlined seepage  lagoons in  1962.  The lagoons were located
approximately 500 feet west of the laundry building in a wooded area.  Dry  cleaning
services later supplemented  laundry  operations,  and  spent  dry  cleaning  solvent
(tetrachloroethene [PCE]) was discharged to the lagoons in the  1970s. All dry cleaning
operations  ceased in 1978, but detergent  laundry  operations  continued,  with lagoon
discharge of the wash water, until 1991, when the owner filed for bankruptcy.

   An underground  storage tank (UST) was located approximately 20 feet south of the
former Laundromat  in September 1999.  The tank contained approximately 170 gallons
of fluid, believed to be mostly old boiler  fuel and water;  however, the possibility of
solvent contamination could not be ruled out.  The fluid was pumped into drums and
disposed of off-site.

   A chronological summary of investigative and remedial activities performed at the site
is provided below.

   August  1973:    Laundry  detergent  wastes and PCE  were  first detected in the
groundwater at the site via sampling of nearby water wells.

                                     2-1

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   1976: Further groundwater contamination was discovered.

   1977:  Additional investigations were performed by the  Michigan Department of
Natural Resources (MDNR).

   1979-1980:  Additional investigations  performed to clearly show that the laundry
facility was the source of the PCE contamination (MDNR, 1980).

   1982:   The  extent  of groundwater  contamination was  further  documented via
additional investigative activities.

   1988:  A remedial investigation (RI) was initiated to define the nature and extent of
contamination at the site and characterize the potential  threats to public heath and the
environment.

   1992: A baseline risk assessment and feasibility study were  completed.

   1993:  A ROD was issued presenting the selected remedial actions for the site. The
selected  remedy  for groundwater consists  of extraction and ex-situ  treatment  of
groundwater, deed restrictions, and long-term monitoring (LTM).  The ROD states that
treated water would be discharged to the Middle Branch Pere Marquette River; however,
treated water is  actually discharged to the seepage lagoons.  The selected remedy for
contaminated  sediments/soils within the lagoon consisted of excavation and off-site
disposal.  In addition, a soil vapor extraction  system was installed to remediate volatile
organic compounds (VOCs) in vadose  zone soils; the dates of operation of this system
and its current status  are not  known.  Available data indicate that the original six-well
groundwater extraction system (EW-1 through EW-6) was installed in the second half of
2000, and analytical results for the six original wells date back to April 2001. Extraction
well EW-5A was installed in December 2000.  Both EW-5 and EW-5A are reportedly
pumped, but EW-5 is relatively low-yielding.  EW-3 is reportedly not pumped.  The
extraction system reportedly pumps at a total combined rate of approximately 250 gallons
per minute.

   There is no current use of groundwater in the surficial aquifer by  area residents or
businesses. All area water supply wells are screened in the lower sandy aquifer below the
clay aquitard; site-related contamination has not been detected in this lower aquifer.

2.2    ENVIRONMENTAL SETTING

2.2.1    Topography

   The site is generally flat except for a steep embankment leading down to the Middle
Branch Pere Marquette River  on the north side of the site.  The ground surface elevation
at the majority of site wells  ranges between 812  and  818 feet above mean  sea level
(amsl).  In contrast, the ground surface elevation near the river at wells MW-102S/D and
MW-202 is approximately 802 feet amsl.
                                     2-2
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2.2.2    Geology

   The site soils are generally composed of fine- to medium-grained sands with some
clay and/or silt lenses to a depth of approximately 75 to 100 feet below ground surface
(bgs).  The ROD (USEPA,  1993) indicates that these are predominantly glacial outwash
deposits. These deposits are underlain by a thicker clay layer that subdivides the shallow
sandy aquifer from a deeper, predominantly sandy aquifer that extends to a depth of
approximately 350 feet bgs.  The lateral extent and continuity of the clay layer that forms
the base of the surficial aquifer is not well  defined.  The reported thickness of the clay
layer is variable, ranging from 20 to 56 feet.

2.2.3    Hydrogeology

   Figures  2.1  and 2.2 depict the  potentiometric surfaces for  the  shallow and deep
portions of the upper, unconfmed aquifer, respectively based on water level data collected
on  April 6, 2006, while the groundwater  extraction (GWE)  system was operational.
Groundwater in the upper, unconfmed  aquifer generally flows  to the north-northeast,
discharging into the Middle Branch Pere Marquette River. It is anticipated that localized
cones of depression resulting from groundwater extraction are centered around the GWE
wells. These cones of depression are not evident in all cases on Figures 2.1 and 2.2, most
likely because  the water level data set and  contour  interval  used are not  sufficiently
detailed.  On May 11, 2001, the depth to groundwater in the  surficial aquifer ranged from
approximately 17 to 30 feet bgs with an average depth of approximately 26 feet bgs.  In
March 2005, the depth to groundwater in this aquifer ranged from approximately 13 to 31
feet bgs with an average depth of approximately 25  feet bgs.  The average depths to
groundwater in December 2002, October 2003, and August 2004 were about 25 feet, 27
feet, and 25 feet bgs, respectively, indicating that seasonal fluctuations in the water table
are relatively minor.

   The RI report states that the estimated average groundwater flow velocity in the upper
aquifer is 185 feet per year (ft/yr). Based on groundwater elevation data shown on Figure
2.1, the hydraulic  gradient in the shallow portion of the surficial aquifer ranges from
approximately 0.003 to  0.008 foot per foot (ft/ft) (average  0.0055 ft/ft).   The hydraulic
gradient in the deep portion of the surficial aquifer (Figure 2.2) had a similar range (0.004
to 0.007 ft/ft, average 0.0055 ft/ft).  These gradients are the same order of magnitude as
that calculated from April 1989 data during the RI (0.004 ft/ft).  Using the groundwater
flow velocity of 185 ft/yr (0.5 foot per day  [ft/day]) presented in the ROD (USEPA,
1993), an estimated effective porosity for a predominantly sandy aquifer of 0.25, and the
average hydraulic gradient of 0.0055 ft/ft, the hydraulic conductivity  of the shallow  and
deep  portions  of the  surficial aquifer  is  calculated to be  approximately 23  ft/day.
Hydraulic conductivity values derived from slug tests  performed in 11 monitoring wells
during the RI ranged from 0.9 to 340 ft/day, with an average  value of 43 ft/day.

   Comparison of water level elevations measured on 11 May 2001 in  10 monitoring well
pairs,  each  consisting of a  shallow  and deep  well, indicate that  both upward  and
downward vertical hydraulic gradients were present on that  date.  The well pairs used in
the vertical  gradient calculations included  MW-3S/D, MW-8S/D, MW-101S/D, MW-
204S/D,  MW-205S/D,  MW-206S/D, MW-207S/D,  MW-211S/D,  MW-212S/D,   and
MW-213S/D.  Four of the 10 vertical gradients were calculated to be upwardly directed

                                      2-3

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(MW-204S/D, MW-205S/D, MW-206S/D, MW8S/D),  with magnitudes ranging  from
0.0003  ft/ft to 0.01  ft/ft  (average  0.005 ft/ft).  The remaining  six  gradients  were
downwardly directed, with magnitudes ranging  from 0.002 ft/ft to  0.027 ft/ft (average
0.015 ft/ft).  It is likely that upward vertical  gradients become more prevalent near the
Middle  Branch Pere  Marquette River given that groundwater in the surficial aquifer
reportedly discharges into the river.  The  four well pairs that exhibited upward vertical
gradients on 11 May 2001  are clustered nearer the river than the six pairs that exhibited
downward gradients,  which were  more widely  distributed in the southern and  central
portions of the site.  These observations  are consistent with data presented in  the  RI
report,  which indicated a slight  downward gradient,  averaging 0.0016  ft/ft,  in the
southern portion of the site, and a relatively strong upward gradient, averaging 0.022 ft/ft,
in the northern portion of the site near the Pere Marquette River.

2.2.4    Surface Water Hydrology

   Site-specific information  regarding  the  hydrology of the  Middle  Branch  Pere
Marquette River was not available.  However, it is assumed that the  reach of the river
adjacent to the site is gaining as  a  result of groundwater discharge  from the surficial
aquifer.

2.3    NATURE AND  EXTENT OF CONTAMINATION

   The  primary  contaminants  of  concern  (COCs)  at  Wash  King  are  PCE and
trichloroethene (TCE) given their elevated concentrations in Wash King groundwater
relative to cleanup goals, their potential to have significant negative impacts on potential
receptors,  or both.  The cleanup goals presented in  the ROD (USEPA,  1993) are 307
Type B Cleanup Criteria (0.7 micrograms per liter {|ig/L} for PCE and 3 |ig/L for TCE).
For discussion purposes, the surficial aquifer,  which extends to a depth of approximately
75 to 100 feet bgs, was subdivided into shallow and deep portions relating to the intervals
monitored by the shallow and deep monitoring and extraction wells installed at the site.

   The Wash King monitoring and extraction wells  are listed in  Table  2.1, along with
their screen intervals, which are depicted graphically  on Figure 2.3 As indicated on this
figure, the portions of the surficial aquifer (in a vertical sense) that are monitored by the
shallow and deep wells  are not consistent  across the  site.  It is assumed that previously-
collected groundwater quality data (i.e., from vertical profiling activities and monitoring
well sampling) were used to determine optimal  screen intervals.  Most "shallow" wells
are screened above an elevation of 760 feet amsl, corresponding to an approximate depth
of 42 to 60 feet bgs (the ground surface elevation across the site  generally ranges from
802 to 820 feet amsl). The ground surface elevation  at the majority of site wells ranges
between 812 and 818 feet amsl.  Given groundwater elevations that generally range from
785 to 790 feet bgs (using March 2005 data),  the shallow wells are generally monitoring
groundwater  within the uppermost 25 to 30 feet of the  saturated zone.  In contrast,
screens  for "shallow" wells  MW-205S, MW-212S,  MW-301S,  MW-204S,  and MW-
206D are relatively deep, and monitor a similar depth interval to that monitored by some
"deep" wells; thus, these wells are included in the deep zone for purposes of the LTMO
analysis.
                                      2-6
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                                              TABLE 2.1
                        BASECASE GROUNDWATER MONITORING PROGRAM
                                 LONG-TERM MONITORING OPTIMIZATION
                                  WASH KING LAUNDRY SUPERFUND SITE
Well Name
EW-1
EW-2
EW-4
EW-5
EW-6
MW-101D
MW-101S
MW-205D
MW-205S
MW-207D
MW-207S
MW-208
MW-209
MW-210
MW-212D
MW-212S
MW-213D
MW-213S
MW-301D
MW-301S
MW-302
MW-303
MW-304D
MW-304I
MW-304S
MW-305D
MW-305I
MW-305S
MW-3D
MW-3S
Zone
Extraction
Extraction
Extraction
Extraction
Extraction
Deep
Shallow
Deep
Deep
Deep
Shallow
Shallow
Shallow
Shallow
Deep
Deep
Deep
Shallow
Deep
Deep
Deep
Deep
Deep
Deep
Shallow
Deep
Deep
Shallow
Deep
Shallow
Current Sampling
Frequency
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Semi-annual
Earliest Sampling
Data Available
4/26/01
4/26/01
4/26/01
4/26/01
4/26/01
10/22/97
10/22/97
8/7/01
8/7/01
10/17/00
10/17/00
10/19/00
8/6/01
8/6/01
8/7/01
2/27/02
10/17/00
10/17/00
9/4/02
9/4/02
9/5/02
9/5/02
9/4/02
9/5/02
9/5/02
9/3/02
9/3/02
9/3/02
10/22/97
10/22/97
Most Recent
Data Used
6/13/05
6/13/05
6/13/05
6/13/05
6/13/05
8/30/05
8/30/05
8/29/05
8/29/05
8/30/05
8/30/05
8/29/05
8/29/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/24/05
3/31/05
8/29/05
8/30/05
8/30/05
8/30/05
8/30/05
8/29/05
8/29/05
8/29/05
8/29/05
8/29/05
Screen Interval
50-70
37-42
65-90
58.5-78.5
77-97
89-94
43-48
85-90
70-75
65-70
35-40
30-35
30-35
30-35
85-90
65-70
60-65
45-50
80-90
65-75
75-95
77-97
97-102
78-83
24-29
105-110
62-67
24-29
65-75
25-35
Wells Not (Currently Sampled
MW-103
MW-104
MW-105
MW-201
MW-202
MW-204D
MW-204S
MW-206D
MW-206S
MW-215
MW-2D
MW-4
MW-8D
MW-8S
IVTW-7S
MW-102D
MW-102S
Deep
Deep
Deep
Shallow
Shallow
Deep
Deep
Deep
Deep
Shallow
Deep
Deep
Deep
Shallow
Shallow-
Deep
Shallow
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
Not Sampled
10/22/97
10/22/97
10/19/00
10/16/00
9/4/02
10/17/00
10/17/00
10/22/03
12/3/02
8/8/01
10/22/97
10/22/97
10/22/97
10/22/97
10/19/00
10/22/97
10/22/97
10/23/03
10/23/03
10/22/03
10/22/03
10/22/03
10/22/03
10/22/03
10/22/03
10/22/03
10/23/03
10/23/03
10/23/03
8/7/01
8/7/01
10/19/00
5/13/99
5/12/99
80.3-85.3
63.5-70.5
68.5-73.5
30-35
30-35
85-90
55-60
85-90
65-70
50-55
65-75
65-75
65-75
25-35
25-35
91.1-96.1
17-22
             [Deep
JWell has "S" designation, but classified as "deep" based on screen interval for LTMO
S:\ES\WPVPROIECTS\744461 - USAGE LTMO\3.xls
                                                  2-7

-------
                                      Approximate Base of Shallow Zone
                                                                                 FIGURE 2.3
                                                                              RELATIVE WELL
                                                                           SCREEN ELEVATIONS
Extraction well
Well with "D" designation
Well with "S" designation
Well with "I" designation
Well with no designation
LONG-TERM MONITORING OPTIMIZATION
 WASH KING LAUNDRY SUPERFUND SITE
                                                2-8

-------
   The vertical interval of the surficial aquifer monitored by the majority of "deep" (D)
and "intermediate" (I) wells ranges from  755  amsl to 718 amsl (Figure 2.3).  Given
typical ground surface elevations of 812 to 818 feet amsl, the majority  of "deep" and
"intermediate" wells are screened within  the 57- to 100-foot bgs  depth interval; this
corresponds to an interval extending from about 30 to 70 feet below the water table,
based on March 2005 groundwater elevations.

   Extraction well EW-2 is screened in the shallow portion of the surficial aquifer, while
EW-4, EW-5A, and EW-6 are screened in the deep portion.   The EW-1 screen has an
intermediate location, spaning both the base of the  shallow interval and the top of the
deep interval (Figure 2.3). EW-5 is reportedly still pumped, but is relatively low-yielding
compared to EW-5 A.

2.3.1    Shallow Portion of the Surficial Aquifer

   Figures  2.4 and 2.5  show the most recent  COC results and associated chlorinated
ethene plume for the shallow and deep zones, respectively.   The VOC present at the
highest concentrations in the shallow portion of the surficial aquifer at the Wash King site
is PCE. It  is interesting to note that the VOC plume appears to be primarily sourced in
the immediate vicinity of the former laundry building rather than in the  vicinity of the
former seepage lagoons located  approximately 500 feet west-southwest of the former
laundry.  The highest PCE concentrations  detected in surficial aquifer groundwater
(21,000 micrograms per liter [|ig/L] in August 2005) were detected at well MW-101S,
located immediately downgradient of the former laundry (Figure 2.4). Groundwater from
nearby shallow extraction well EW-2  contained a PCE concentration of 2,500  |ig/L in
June 2005.   In contrast, the shallow well nearest the former seepage lagoons (MW-215)
contained a PCE concentration  of only  5  |ig/L in October 2003 (the most recent data
available for that well).  It should be noted that MW-215 is screened near the base of the
shallow zone.  The elevated PCE concentrations near the former laundry indicate the
presence of a significant, continuing PCE source in this area.  Cohen and  Mercer (1993)
state that, typically, dissolved contaminant concentrations greater than 1  percent of the
aqueous  solubility of the compound are highly suggestive of the presence of non
aqueous-phase liquid (NAPL).  The aqueous solubility of PCE is 150 milligrams per liter
(mg/L); therefore,  dissolved PCE concentrations exceeding  approximately  1.5  mg/L
(1,500 |ig/L) may indicate the presence of NAPL.

   The PCE plume in the shallow portion  of the surficial aquifer, shown on Figure 2.4,
extends to the north to near the Middle Branch Pere Marquette River, as evidenced by the
detection of this compound at a concentration of 3.6 |ig/L in downgradient well MW305S
in  August 2005.  This well is located  about 200 feet from the river; therefore,  it is not
known whether the shallow portion of the plume actually extends to and discharges into
the river.   VOCs  have historically not been  detected in groundwater  samples from
shallow well MW-102S, located north of the river.   It should be noted that most of the
"shallow" wells installed to define the VOC plume  north of the former laundry (MW-
205S, MW-202S, MW-206S, MW-204S, and MW-301S) are screened across relatively
deep intervals, as discussed in Section 2.3  and depicted on Figure 2.3.  Therefore, VOC
concentrations within the uppermost 30 feet of the  saturated zone  north of the former
laundry building are not well defined.


                                     2-9

S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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   The presence of TCE  and (occasionally)  cis-l,2-dichloroethene (DCE) in shallow
wells indicates  that  some  reductive  dechlorination  of PCE  to  TCE  is  occurring.
However, TCE and especially DCE concentrations are generally relatively low compared
to concentrations of the parent solvent (PCE), indicating that geochemical conditions in
the shallow zone are not well-suited for reductive dechlorination to occur.  Groundwater
in the shallow portion of the surficial aquifer is likely  somewhat aerobic and oxidizing,
although geochemical data are not available to confirm this supposition.  Both PCE and
TCE are generally resistant to biodegradation under these conditions; in contrast, DCE
may be aerobically degraded.

2.3.2    Deep Portion of the Surficial Aquifer

   Maximum PCE concentrations detected in the deep portion of the surficial aquifer are
substantially lower than  in  the shallow portion  (maximum of 360 |ig/L in well MW-205S
as of August 2005, Figure  2.4), indicating that, if significant NAPL is present at the site,
it is restricted to more shallow depths. As described in Section 2.3, despite having an "S"
designation, MW-205S is  screened substantially below the depth interval in which most
other "shallow"  wells are screened and is therefore considered to be a deep well for
purposes of this LTMO  evaluation.  This well  is located approximately 850 feet north of
the former Wash King laundry. PCE concentrations detected in MW-205S, MW-205D,
MW-303, and EW-6 all indicate that the "hotspot" of the deep portion of the VOC plume
is located in the vicinity of these wells, approximately  500 feet from the Middle Branch
Pere Marquette River.   There are no deep wells installed between the MW-205S/205D
well pair and the river; therefore, VOC concentrations in the deep portion of the surficial
aquifer between this well pair and the river are not being characterized.

   Similar to the shallow portion of the aquifer, data for MW-102D, located on the north
side of the river, suggest that the VOC plume in the deep portion of the aquifer does not
extend beneath the river in this area.  It should be noted however, that MW-102D is
screened at a relatively deep interval (706 to 711 feet amsl, Figure 2.3), and a distance of
approximately 69 feet separates the bottom of the MW-102S screen and the  top of the
MW-102D  screen.    Therefore, the data from well MW-102D  do  not definitively
demonstrate that the deep portion of the plume  does not underflow the river.

   As with the shallow  portion of the surficial aquifer, the relatively low magnitude of
reductive dechlorination daughter product concentrations (TCE and DCE) at most wells
relative to PCE concentrations indicates that geochemical conditions in the deep zone are
not conducive to the widespread and sustained occurrence of reductive dechlorination.
However, the presence of daughter products indicates that some reductive dechlorination
of PCE and TCE is occurring, and that this process is more pronounced in localized areas
(i.e., MW-303, MW-206D, MW-2D).

2.3.3    Middle Branch Pere Marquette River

   According to the ROD (USEPA, 1993), sampling of surface water and sediment at
three locations did not indicate levels of site-related contamination that would pose a risk
to human health or the environment.
                                     2-12
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

-------
                                 SECTION 3

     LONG-TERM MONITORING PROGRAM AT WASH KING
   The existing groundwater monitoring program at Wash King was  examined  to
identify  potential  opportunities  for  streamlining  monitoring  activities while  still
maintaining an effective monitoring program. The monitoring program at Wash King is
reviewed in the following subsections.

3.1    DESCRIPTION OF MONITORING PROGRAM

   The  Wash King  monitoring program examined  in  this  long-term monitoring
optimization (LTMO) consists of 49 groundwater wells, including 5 extraction wells, 25
active (i.e., currently sampled) monitoring wells, and 19 inactive monitoring wells.  The
extraction wells  are  currently sampled quarterly, and the  active monitoring wells are
sampled semiannually.  The wells included in this analysis are listed in Table 2.1 and
shown on Figure 3.1 classified by their well type and sampling status (e.g., extraction
well, currently sampled well, well not currently sampled). Table 3.1 displays the number
of groundwater samples collected for VOC analysis from each well from 1997 to 2005.
As shown in Table 3.1, limited analytical results exist for the period prior to the start-up
of the extraction  system in 2001.  In addition, only one round of sampling was conducted
in 2004 due to a transition in site management.

   The objectives  of the  groundwater monitoring program at  Wash King  are  not
specified in the information reviewed for this LTMO evaluation. However, it is assumed
that the objectives are consistent with the  primary spatial and temporal  objectives  of
groundwater monitoring programs outlined in Section 1  as summarized below:

   •   Evaluate groundwater at the Wash King Site for compliance with cleanup goals;

   •   Evaluate  the  effectiveness of  natural attenuation  processes, the groundwater
      extraction system, and source  reduction/removal activities  at decreasing VOC
      levels in groundwater; and

   •   Evaluate plume  dynamics (i.e.,  is the plume increasing, stable,  or decreasing in
      extent both laterally and vertically).

   Likely additional objectives for the  groundwater monitoring program are 1) to ensure
that the remedy  is protective of potential receptors, including the Middle Branch  Pere
Marquette River and area residents and businesses (via vapor intrusion into  occupied
                                     3-1
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

-------

-------
                                                   TABLE 3.1
                                       PCE DATA DATE DISTRIBUTION
                                     LONG-TERM MONITORING OPTIMIZATION
                                      WASH KING LAUNDRY SUPERFUND SITE
Well Name
EW-1
EW-2
EW-4
EW-5
EW-6
MW-101D
MW-101S
MW-205D
MW-205S
MW-207D
MW-207S
MW-208
MW-209
MW-210
MW-212D
MW-212S
MW-213D
MW-213S
MW-301D
MW-301S
MW-302
MW-303
MW-304D
MW-304I
MW-304S
MW-305D
MW-305I
MW-305S
MW-3D
MW-3S
Wells Not Currently Sam
MW-103
MW-104
MW-105
MW-201
MW-202
MW-204D
MW-204S
MW-206D
MW-206S
MW-211S
MW-211D
MW-215
MW-2D
MW-4
MW-8D
MW-8S
MW-7S
MW-102D
MW-102S
Number of PCE Samples per Year
1997





1
1





















1
1
1998





2
3





















2
2
1999






1






















1
2000





1
1


1
1
1




1
1











1
2001
18
17
18
18
18


2
2
2
2
2
2
2
2

2
2










2
2
2003
8
8
8
8
8
4
3
3
3
3
3
3
3
1
2
2
3
4
3
3
3
3
3
3
3
3
3
3
3
3
2004
4
3
4
4
4


1
1
1
1
1

1
1

2
1


1
1
1
1

1
1
1
1
1
2005
2
2
2
2
2
3
3
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
1
2
1
2
2
2
pled
1
1







2
2

















1
1
1

1
1







2
2


1
1
1
1
1
1
1
1
1


















Not sampled
Not sampled

1
1
1
1

1
1

2
2
2
2

2
2


1
1
1

1
1

1
1
1
1
1


2
1

1
1



1
1
1





















                          Note: duplicate samples not counted
                          Only one sampling round conducted in 2004
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\3.xls
                                                       3-3

-------
structures); and 2) to provide data for five-year reviews of remedy implementation as
required by the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA).

3.2    SUMMARY OF ANALYTICAL DATA

   The monitoring program for this  plume was  evaluated using results for sampling
events performed  from October  1997 through August 2005.  Hardcopy  data were
received from the MDEQ, and were subsequently entered into an electronic database to
facilitate performance of this LTMO evaluation.  The database was processed to remove
duplicate data by  retaining the maximum result for  each duplicate sample pair.  As
discussed in Section 2.3, the COCs identified for Wash King include PCE and TCE. Cis-
1,2-DCE is also included in the analysis because it has been detected in site groundwater.
Table 3.2 presents  summaries of the occurrence of detected chlorinated ethenes based on
all historical data collected from Wash King for monitoring and extraction wells.     For
all data groupings, PCE is the primary COC, with the highest percentage of detections
and 307 Type B criterion exceedances, followed by TCE.  PCE has exceeded the 0.7-
Hg/L standard in 54% of samples and at 23 of the 42 monitoring wells.   Although DCE
has been detected, concentrations have never exceeded  the 70-|ig/L USEPA MCL (a
Type B criterion for cis-l,2-DCE is not specified in the ROD); therefore, this compound
is not considered to be a significant COC in site groundwater.

   Table 3.3 and Figures 2.4  and  2.5 present the most  recent concentrations of PCE,
TCE,  and cis-l,2-DCE  for the groundwater monitoring and extraction wells screened in
the shallow and deep zones, respectively.  Wells  depicted on Figures  2.4 and 2.5 are
classified based on their most recent PCE values (e.g., PCE concentrations greater than
1,000 |ig/L are identified at EW-2 and MW-101S by their red color) and most  recent
sampling event (currently sampled wells are circled by blue and inactive wells by pink).
Samples from 15 of the  30 currently sampled monitoring and extraction wells (50%) have
at  least one COC that exceeds a 307  Type B criterion and/or MCL based on the most
recent data available for each well (all 15 have  PCE exceedances and 8 have TCE
exceedances).  Six of the 17 wells that have available groundwater quality data and are
not currently  sampled had at least one COC that exceeded a cleanup goal during their
most recent sampling event; all six had a PCE exceedance,  and four also had a TCE
exceedance.
                                     3-4
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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                                         TABLE 3.3
                MOST RECENT GROUNDWATER COC CONCENTRATIONS
                           LONG-TERM MONITORING OPTIMIZATION
                            WASH KING LAUNDRY SUPERFUND SITE
Well Name
EW-1
EW-2
EW-4
EW-5
EW-6
MW-101D
MW-101S
MW-207D
MW-207S
MW-210
MW-212D
MW-212S
MW-213D
MW-213S
MW-303
MW-304D
MW-304I
MW-304S
MW-205D
MW-205S
MW-208
MW-209
MW-302
MW-305D
MW-305I
MW-305S
MW-3D
MW-3S
MW-301D
MW-301S
Most Recent
Sampling Event
6/13/05
6/13/05
6/13/05
6/13/05
6/13/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/30/05
8/29/05
8/29/05
8/29/05
8/29/05
8/29/05
8/29/05
8/29/05
8/29/05
8/29/05
8/29/05
8/24/05
3/31/05
PCE
Standard=0.7|ig/L
26
2500
4.3
71
270
11
21000
4.3
1.5
ND
32
20
24
83
34
ND
ND
ND
140
360
ND
ND
ND
ND
ND
3.6
ND
ND
ND
1.7
TCE
Standard=3ug/L
5.1
ND
ND
21
ND
5.8
360
ND
ND
ND
9.5
ND
5.2
ND
86
ND
ND
ND
14
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
cis-DCE
MCL=70ug/L
ND
ND
ND
7.4
33
ND
ND
ND
ND
ND
ND
ND
ND
ND
1.3
ND
ND
ND
3.8
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Wells Not Currently Sampled
MW-103
MW-104
MW-215
MW-2D
MW-4
MW-105
MW-201
MW-202
MW-204D
MW-204S
MW-206D
MW-206S
MW-8D
MW-8S
MW-7S
MW-102D
MW-102S
10/23/03
10/23/03
10/23/03
10/23/03
10/23/03
10/22/03
10/22/03
10/22/03
10/22/03
10/22/03
10/22/03
10/22/03
8/7/01
8/7/01
10/19/00
5/13/99
5/12/99
ND
33
5
28
81
ND
ND
ND
ND
ND
4.9
3.7
ND
ND
ND
ND
ND
1.7
4.7
ND
44
ND
ND
ND
ND
ND
ND
13
9.2
ND
ND
ND
ND
ND
2.6
ND
ND
1.9
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
            ND = analyte not detected
           b/Results in ug/L
            Exceedances highlighted in yellow
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\3.xls
                                            3-6

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                                 SECTION 4

                  QUALITATIVE LTMO EVALUATION


   An  effective  groundwater monitoring program  will provide information regarding
contaminant plume migration and changes in chemical concentrations through time at
appropriate locations, enabling decision-makers to verify  that contaminants  are  not
endangering potential receptors, and that remediation is occurring at rates sufficient to
achieve remedial action objectives (RAOs) within a reasonable time frame.   The design
of the  monitoring  program should therefore include consideration of existing receptor
exposure pathways as well as exposure pathways arising from potential future use of the
groundwater.

   Performance monitoring wells located within and downgradient from a contaminated
area provide a means of evaluating the effectiveness of a groundwater remedy relative to
performance criteria.  LTM of these wells also provides information about migration of
the contamination  and  temporal trends in  chemical  concentrations.   Groundwater
monitoring wells located downgradient  from the leading edge of a  contaminated area
(i.e., sentry wells) are used to evaluate possible changes in the extent of the plume and, if
warranted, to trigger a contingency response action if contaminants are detected.

   Primary factors  to consider when developing  a groundwater  monitoring program
include at a minimum:

   •  Aquifer heterogeneity,

   •  Types of contaminants,

   •  Distance to potential receptor exposure points,

   •  Groundwater seepage velocity and flow direction(s),

   •  Potential surface-water impacts, and

   •  The effects of the remediation system.

These  factors will  influence the locations  and spacing  of monitoring  points  and  the
sampling frequency.  Typically, the  greater the seepage velocity and  the  shorter  the
distance to receptor exposure points, the more frequently groundwater sampling should
be conducted.
                                     4-1
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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   One of the most important purposes of LTM is to confirm that the contaminant plume
is behaving as predicted.  Graphical and statistical tests can be used to evaluate plume
stability. If a groundwater remediation system or strategy is effective, then over the long
term, groundwater-monitoring  data  should demonstrate  a  clear   and  meaningful
decreasing trend in concentrations at appropriate monitoring points.  The groundwater
monitoring program  at Wash King was evaluated to identify potential  opportunities for
streamlining monitoring activities while still maintaining  an effective  performance and
compliance monitoring program.

4.1    METHOD FOR QUALITATIVE EVALUATION OF MONITORING
NETWORK

   The qualitative LTMO evaluation included 47 groundwater monitoring and extraction
wells with historical data located in the Wash King area.  These sampling points, their
associated  depth zones and basecase monitoring frequencies, and the earliest  and most
recent sampling data used in the LTMO analysis are listed in Table 2.1; their locations
are depicted on Figure 3.1.

   Multiple factors were considered in developing recommendations for continuation or
cessation of groundwater monitoring at each well. In some cases, a recommendation was
made to  continue monitoring a  particular well,  but at  a reduced frequency.   A
recommendation to discontinue monitoring at a particular well based on the information
reviewed does not necessarily  constitute a recommendation to physically abandon the
well.  A change in site conditions might warrant resumption of monitoring at some time
in  the future  at wells that are not currently recommended for continued sampling.
Typical factors considered in developing recommendations to retain  a well in, or remove
a well from, an LTM program are summarized in Table 4.1.  Typical factors considered
in developing recommendations for monitoring frequency are summarized in Table 4.2.

                                   TABLE 4.1
        MONITORING NETWORK OPTIMIZATION DECISION LOGIC
                    LONG-TERM MONITORING OPTIMIZATION
                           WASH KING SUPERFUND SITE
Reasons for Retaining a Well in
Monitoring Network
Well is needed to further characterize the
site or monitor changes in contaminant
concentrations through time
Well is important for defining the lateral or
vertical extent of contaminants.
Well is needed to monitor water quality at a
compliance or receptor exposure point
(e.g. , water supply well)
Well is important for defining background water
quality
Reasons for Removing a Well from
Monitoring Network
Well provides spatially redundant
information with a neighboring well (e.g.,
same constituents, and/or short distance
between wells)
Well has been dry for more than two yearsa/
Contaminant concentrations are
consistently below laboratory detection
limits or cleanup goals
Well is completed in same water-bearing zone as
nearby well(s)
a/ Periodic water-level monitoring should be performed in dry wells to confirm that the upper boundary of the saturated
  zone remains below the well screen. If the well becomes re-wetted, then its inclusion in the monitoring program
  should be evaluated.
                                      4-2
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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4.2    RESULTS OF QUALITATIVE LTMO EVALUATION FOR
GROUNDWATER
   The results of the qualitative evaluation of monitoring wells at the Wash King site are
described  in this subsection.  The  evaluation  included the 47 groundwater monitoring
wells listed in Table 2.1.  The qualitative LTMO evaluation for groundwater considered
historical analytical results for the  three primary COCs (PCE,  TCE, cis-l,2-DCE) and
whether continued monitoring of each well was desirable in light of the Wash King
groundwater monitoring goals listed in Section 3.1. In addition,  potential data gaps were
considered.

                                   TABLE 4.2
               MONITORING FREQUENCY DECISION LOGIC
                    LONG-TERM MONITORING OPTIMIZATION
                          WASH KING SUPERFUND SITE
Reasons for Increasing
Sampling Frequency
Groundwater velocity is high
Change in contaminant concentration would
significantly alter a decision or course of action
Well is necessary to monitor source area or
operating remedial system
Cannot predict if concentrations will change
significantly over time, or recent significant
increasing trend in contaminant concentrations at a
monitoring location resulting in concentrations
approaching or exceeding a cleanup goal, possibly
indicating plume expansion
Reasons for Decreasing
Sampling Frequency
Groundwater velocity is low
Change in contaminant concentration would not
significantly alter a decision or course of action
Well is distal from source area and remedial system
Concentrations are not expected to change
significantly over time, or contaminant levels have
been below groundwater cleanup objectives for
some prescribed period of time
   Table 4.3 includes recommendations for retaining  or removing each  well, the
recommended sampling frequency,  and the  rationale  for the recommendations.   The
qualitative analysis results are depicted  on Figures 4.1 and 4.2 for the shallow and deep
zone wells,  respectively, and are summarized by well  type  and aquifer zone in the
following subsections.

4.2.1    Extraction Wells

   Five GWE wells were considered during the qualitative evaluation, including EW-1,
2, 4, 5, and 6.   Sampling results for EW-3  were not available and this well was not
included in the evaluation. EW-3 is reportedly not located in an optimum location and is
not always pumped.  A sixth GWE well, EW-5A, exists and reportedly is the primary
operating  well  of the EW-5/EW-5A  pair.   Both wells  are  operational,  but  EW-5
reportedly is relatively  low-yielding.   However, sampling results received from the
MDEQ indicate that they are for EW-5;  sample IDs containing "EW-5A" were not
                                     4-3
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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received.  It is assumed that EW-5 and EW-5A are spatially co-located and screened at
approximately the same depths.

   Graphs of PCE  concentrations versus time  for the extraction wells are shown on
Figure 4.3. These wells are currently sampled quarterly.  As shown on Figure 4.3, PCE
concentrations in wells EW-1,  2, 4, and 5 exhibit relatively stable trends.   The PCE
concentrations in EW-1 and EW-4 have not varied by more than 4 |ig/L and 1.6 |ig/L,
respectively, over the most recent six sampling events. The PCE concentration at EW-5
fluctuated between  130 and 210 |ig/L over 22 sampling events from February 2002 to
March 2005.   The most  recent four data  points for EW-2 suggest that the PCE
concentration may be stabilizing, and data for EW-6 exhibit a steady decreasing trend.

   The recent stable trends in four of the five GWE wells (described above) indicate that
the sampling frequency  at these wells can  be reduced with little loss of important
information.  Continued frequent monitoring at locations where no temporal trend in
contaminant concentrations is present serves  merely to confirm the results  of previous
monitoring activities at that location; results of continued monitoring  through time are
likely to fall within  the historic  range of concentrations that have already been detected.
Therefore, reduction in the  monitoring frequency for EW-1, 2, 4, and 5 to semiannual is
recommended.   Historic data for EW-6 indicate that either the deceasing trend  will
continue in the future or PCE concentrations  will begin to stabilize.  Given the  lack of
significant fluctuations in contaminant concentrations in this well over the past two years,
and the likelihood that future contaminant concentrations will fall within  a relatively
narrow and predictable range, semiannual sampling of this well is also deemed to be
appropriate.  Semiannual sampling of these wells should allow for adequate definition of
mass removal rates  and remedial progress over time.  However, if future concentrations
deviate significantly from the expected trends, then  resumption of quarterly sampling
should be considered.

   Mass removal rates  at EW-4  are currently extremely low given the low magnitude of
VOC concentrations in the  extracted water (PCE at 3 to 5 |ig/L over the most recent six
sampling events). However, the PCE concentrations do exceed the 307 Type B Cleanup
criterion of 0.7 |ig/L; therefore,  continued sampling of this well at a lower frequency is
recommended to track future progress on achieving cleanup goals in this area.

4.2.2    Monitoring Wells Screened in the Shallow Portion of the Surficial Aquifer

   A total of 16 monitoring wells screened in the shallow portion of the surficial aquifer
were evaluated qualitatively.  The shallow portion of the  surficial aquifer is defined for
purposes of this LTMO evaluation to extend vertically  downward to an elevation  of
approximately 760 feet amsl, roughly corresponding to the uppermost 25 to 30 feet of the
saturated zone.  Nine of the 16 wells are currently sampled on a semiannual basis, six of
the remaining seven wells are not sampled on a regular basis, and there are no available
sampling results for one well  (MW-211S).  As described  in Section 2.3,  five wells
containing an "S"  designation  (MW-204S, 205S, 206S,  212S, and  301S) appear  to
actually be screened at elevations more similar to some of the "deep" wells (Figure 2.3);
therefore,  they were  considered to be deep wells  for the purposes  of  the  LTMO
evaluation.
                                     4-9
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                                  FIGURE 4.3
                 GWE PCE CONCENTRATIONS OVER TIME
                    LONG-TERM MONITORING OPTIMIZATION
                          WASH KING SUPERFUND SITE

90 - -
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-05

   Four of the nine shallow wells that are currently sampled are recommended  for
deletion from  the LTM program because they are cross-gradient and distant from  the
VOC plume; these wells include MW-208, 209,  210, and  304S (Table  4.3 and Figure
4.1).  Shallow wells MW-7S and 8S are also recommended for deletion for the  same
reason.  Chlorinated ethenes have never been detected  in these wells, and continued
sampling of these wells does not provide any information about the remaining areas of
concern.

   If collection of background groundwater geochemical  data is desired  in the future to
support a natural attenuation evaluation, then all or a subset of the cross-gradient  wells
could be sampled for that purpose. Similarly, if data regarding upgradient groundwater
quality were desired in the future (e.g., if there is reason to believe that an upgradient
source of chlorinated ethenes is present that is contributing to the Wash King plume),
then MW-7S could be sampled for that purpose.
                                    4-10
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   Future  sampling of 10 existing shallow wells on an annual to biennial (every other
year) basis is recommended, as detailed in Table 4.3 and on Figure 4.1. Five of these
wells (MW-101S, 207S,  213S,  305S, and 3S) are currently sampled semiannually as part
of ongoing LTM activities.  The remaining five wells (MW-201,  202,  21 IS, 215, and
102S)  are  not  currently sampled  and are recommended for future inclusion  in  the
monitoring program.

   MW-3S, MW-201, MW-211S, and MW-202 are recommended for future sampling to
assist in the definition of the lateral plume boundaries over time in the shallow zone. The
recommended sampling frequency for MW-3S, MW-201,  and MW-211S  is biennial
given their inferred cross-gradient location relative to the VOC plume and the apparently
stable  to diminishing extent of the plume footprint over the last  several  years; this
frequency should be conditional on new data continuing to indicate VOC concentrations
less  than cleanup  goals for wells that have not been sampled recently.  However, if
hydraulic conditions change (e.g., change in on-site pumping conditions or initiation of
off-site groundwater extraction in the  vicinity), or the sampling results indicate plume
expansion, then more frequent sampling should be considered. Annual sampling of MW-
202  is  recommended given its location at the downgradient end of the plume near the
river.

   Five of the remaining six shallow wells (MW-101S, 207S, 213S,  305S, and 215) are
recommended for  continued sampling  because their plume-interior locations facilitate
assessment of remedial progress over time. MW-305S is the furthest downgradient well
containing a detectable concentration of a COC, and continued monitoring of this well
provides some indication of plume stability.  MW-215 was last sampled in October 2003
and  contained a PCE concentration that exceeded the 307 Type  B cleanup level.   If
current VOC concentrations in this well are below cleanup levels over at least two
consecutive monitoring events then removal of this well from the LTM program could be
considered. An annual to biennial sampling frequency for these five plume-interior wells
is  recommended (annual for  all wells except MW-207S).   A reduction in sampling
frequency relative to the  current semiannual  program is  supported  by the lack  of
increasing trends in these wells, the generally  stable to diminishing nature of the  plume,
and the perceived low degree of risk posed by the plume to potential receptors.

   Shallow well MW-102S  functions as a downgradient sentry well and provides useful
information regarding the northern extent of the plume.  Chlorinated ethenes have never
been detected in this well, and there is no reason to believe that this will change given
that  groundwater in the shallow zone  likely  discharges to the Pere Marquette River.
Therefore, a relatively low (biennial) sampling frequency is recommended.

4.2.3   Monitoring Wells  Screened in the Deep Portion of the Surficial Aquifer

   A total of 28 monitoring wells screened in the deep portion of the surficial  aquifer
were evaluated qualitatively.   The deep portion of  the surficial aquifer is  defined for
purposes of this LTMO evaluation to extend from roughly 25 to 30 feet below the water
table to the clay aquitard  that is believed to separate the  surficial aquifer from  the
underlying sandy drinking water aquifer (i.e., from roughly  30 to at least 60 or  65 feet
below  the water table).  Sixteen of the  28 wells are  currently sampled  on a  semiannual
basis, 11  of the remaining 12 wells are not sampled on a regular basis,  and there are no

                                     4-11

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available sampling results for one well (MW-211D) .  The five wells containing an "S"
(shallow)  designation (MW-204S, 205S,  206S,  212S,  and 301 S) that are actually
screened at deeper elevations  than  the  other "shallow"  wells, and  the  two  wells
containing an "I" (intermediate) designation (MW-304I and 3051) are lumped into the
"deep" zone for purposes of the LTMO evaluation (see Figure 2.3 for depiction of screen
intervals).

   Two of the 16 deep wells that  are currently sampled are recommended for deletion
from the LTM program because they are cross-gradient and distant from the VOC plume;
these wells include MW-304I and 304D (Table 4.3 and Figure 4.2).  Chlorinated ethenes
have never been detected in these wells, and continued sampling of these wells does not
provide any useful information about the remaining areas of concern.

   Deep zone wells MW-301S and 301D are located adjacent to GWE well EW-4, near
the inferred western edge of the VOC plume. MW301D has been non-detect for COCs
throughout its monitoring  history  (since September 2002),  and  there is no reason to
believe  that this will change  unless hydraulic conditions in the surficial  aquifer change.
Monitoring of nearby well  MW204D, screened in a similar  depth interval, would  allow
assessment of the western plume boundary over time in this area.  The screen interval of
MW-301S corresponds to the uppermost 10 feet of the screen interval of EW-4, and PCE
concentrations in both wells are similar. Continued monitoring of EW-4 should indicate
future remedial progress in this area, eliminating  the  need  to continue  sampling  MW-
301S.

   Well MW302 is spatially  redundant with well pair MW-205S/205D; the latter wells
contain  elevated concentrations of COCs, while MW-302 (which has a relatively long
screen  interval)  has been  non-detect for COCs  over seven monitoring events  since
December  2002  and is  not  providing  useful  information.    Therefore,   continued
monitoring of MW-205S/205D and removal of MW302 from the monitoring  program is
recommended.

   MW-211D is spatially redundant with MW-204D  and they are  screened at similar
depths as shown on Figure 2.3.  Sampling of both of these wells is not required to define
the western  plume  boundary  in  this  area; continued sampling  of  MW-204D  is
recommended.

   Future  sampling of 20  existing deep zone wells on an  annual to biennial basis  is
recommended, as detailed  in Table 4.3.  Eleven of these 20 wells (MW-101D,  205D,
205S, 207D, 212D, 212S,  213D,  303,  305D, 3051,  and 3D) are currently sampled
semiannually as part of ongoing LTM activities.  The remaining nine wells (MW-103,
104,  204D, 204S,  206D, 206S, 2D, 4, and 102D) are not currently  sampled and are
recommended for future inclusion in the monitoring program.

   MW-3D, 103, 204S, 204D, 3051, and 305D are recommended for future sampling to
assist in the definition of the lateral plume boundaries over time in the deep  zone.  The
recommended  sampling frequency for these wells is  annual  (MW-305I/D  only) to
biennial  given their inferred cross-gradient location relative to the VOC plume and the
apparently stable to diminishing extent of the plume footprint over the last several years.
However,  if hydraulic conditions change (e.g., change in  on-site pumping conditions or

                                    4-12

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initiation of off-site groundwater extraction in the vicinity), or if new sampling results for
wells not sampled recently indicate plume expansion,  then  more  frequent sampling
should be considered.

   Thirteen of the remaining 14 deep wells (MW-101D, 205D, 205S, 207D, 212D, 212S,
213D,  303,  104,  206D, 206S, 2D, and 4) are recommended  for continued sampling
because their plume-interior locations facilitate assessment of remedial progress  over
time.  The most recent sampling event performed in each of these wells has indicated the
presence of at least one COC at concentrations that exceed 307 Type B cleanup goals.
Available data indicate that five of these 13 wells (MW-104, 206D, 206S, 2D, and 4)
were last sampled in October 2003; those sampling results indicate PCE concentrations
ranging from 3.7 to 81 |ig/L (compared to the Type B cleanup criterion of 0.7 |ig/L) and
TCE concentrations ranging from non-detect to 44 |ig/L (compared to a Type B cleanup
criterion of 3 |ig/L). If current VOC concentrations in these five wells are below cleanup
levels over at least two consecutive monitoring events, then removal of these wells from
the LTM program could be considered. An annual sampling frequency for 11 of the  13
plume-interior wells (all except for MW-303 and MW-207D, see Table 4.3 for details) is
recommended.  A reduction in sampling frequency relative to the current semiannual
program is supported by the lack of increasing trends in these wells and the fact that there
are no nearby  receptors (the distance from the most downgradient of these well to the
Pere  Marquette  River is  approximately 500  feet,  versus  an  estimated average
groundwater flow velocity of 185 feet per year). The plume in the deep  zone appears to
be generally stable to diminishing under the influence of the GWE system and natural
attenuation processes.

   The last deep well recommended for continued sampling (MW-102D) is located  on
the north  (downgradient) side of the river, and was non-detect for  COCs during  four
sampling events performed from October 1997 to May 1999. Additional sampling of this
well  at a low (biennial) frequency is recommended given that it serves as a sentry well to
verify the lack of plume underflow beneath the river in the deep  zone of the surficial
aquifer.

4.3    DATA GAPS

   Specific data gaps in the groundwater monitoring network were assessed during
performance of the qualitative evaluation, as summarized in the following subsections. It
is our understanding that additional groundwater quality data (apart from the monitoring
and  extraction well  data assessed for this LTMO evaluation) were collected during
previous site characterization activities.  For  example, the database contains vertical
profiling VOC  data for "GP"-series sampling points (perhaps referring to  Geoprobe
points).  However, the locations  of these additional samples were not provided  to
Parsons. Therefore, the validity of the recommendations for additional well installations
provided below should be weighed in light of all available data.

 4.3.1   Shallow Portion of the Surficial Aquifer

   COC concentrations in the shallow portion of the surficial aquifer are not well defined
downgradient of the source area, as shown on Figures 2.4 and 4.1.  This is partly because
five of the wells designated as being "shallow" are screened in what appears to be the

                                    4-13

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upper portion of the "deep" zone, as shown on Figure 2.3. Therefore, there are no plume
interior wells  installed between EW-2 (located near  the  source  area) and  MW-305S
(located near the downgradient plume toe). As a result, the current extent and magnitude
of the plume in the shallow zone downgradient of the source area is not well defined, and
remedial progress in this area cannot be assessed  (assuming that there is  significant
groundwater contamination present in this area—the  presence of PCE concentrations
exceeding the 307 Type B criterion in MW-305S suggests that there is).  The  only GWE
well screened  entirely  in the  shallow zone  is  EW-2; EW-1  is screened in the lower
portion of the  shallow zone and the upper portion of the deep zone (Figure 2.3).   As a
result, much of the shallow zone between EW-2 and the river may not be impacted by the
GWE system, depending on the capture zones of the deeper extraction wells..

  Installation  of up to approximately seven  new shallow zone monitoring  wells (S-l
through S-7) at the locations shown on Figure 4.1 would better define the  extent and
magnitude of the  shallow zone  plume and facilitate assessment of progress in achieving
cleanup goals in the shallow zone across  the site. This information would permit more
accurate assessment of the schedule and cost to complete  site remediation.  The screen
intervals of these wells  should be based on the results of historical COC  data for
monitoring wells as well as vertical  profiling  data collected in the  1990s during site
characterization activities.  In  addition,  the  MDEQ  has  indicated that MW-202 has
reportedly been destroyed; this well should be replaced with  a new well at the same
location.

  Installation  of  wells S-4 and S-5 should be conditional  on sampling results from S-2
and S-3. If S-2 and S-3 appear to bound the higher-concentration portion of the dissolved
contaminant plume, then installation of S-4 and/or S-5 may  not be necessary.  If installed,
it is assumed that  these wells would be sampled annually for at least three years, followed
by re-evaluation of the monitoring frequency based on results obtained.

4.3.2    Deep  Portion of the Surficial Aquifer

  Groundwater quality in the  deep portion of the surficial aquifer is well characterized
along an east-west-trending band located approximately 500 feet from the Pere Marquette
River.  Several wells screened in the deep  zone have been installed in the general vicinity
of GWE wells EW-4, 5, and 6 to define dissolved chlorinated ethene concentrations and
the lateral plume boundaries in this  area (Figure 4.2). The next best-characterized area in
terms of groundwater quality is located near the southern edge of the plume, where four
monitoring wells  and one GWE well have been  installed.  There is a large area between
the  two  areas  described above that  is  relatively devoid  of deep zone  wells,  and
installation of up to three  deep monitoring wells in this area  (D-l, D-2, and D-3), as
shown on Figure  4.2, would allow better definition of the extent and magnitude of the
plume to monitor remedial progress over time.  Installation of D-3 could be optional and
dependent on sampling results from D-2.

  Installation  of a fourth new well (D-4) directly downgradient of the elevated VOC
concentrations detected at the MW-305S/306D well pair is recommended to better define
the downgradient extent of elevated VOC concentrations and the proximity of the plume
toe to the river. The degree to which the plume is discharging to the river is not known at
this time.   Installation  of two  additional new deep zone  wells (D-5 and D-6) is also

                                     4-14

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recommended to pair the recommended new shallow wells S-6 and S-7 and better define
groundwater quality near the river.  If installed, it is assumed that these wells would be
sampled  annually for at least three years, followed by re-evaluation of the monitoring
frequency based on results obtained.

4.4    ANALYTICAL PROGRAM

   Groundwater samples are analyzed  by the MDEQ Environmental Laboratory for  a
total of 66 VOCs using method 8260.   In addition, analysis for  metals  is routinely
performed, although it is not clear if all samples are analyzed for metals during every
sampling event.  Generation of significant metals contamination at a laundry/dry-cleaner
site  would  not typically  be  expected,  and  the  degree  to  which detected  metal
concentrations may be representative of background conditions in the aquifer is not well
understood.    The following recommendations pertaining to the groundwater analytical
program should be considered:

   1) Discuss optimizing the target VOC list to a short-list of key compounds (i.e., the
chlorinated ethenes PCE, TCE, DCE, and vinyl chloride) with the analytical laboratory.
Potential  advantages  include lower  laboratory  analytical  costs  and  lower  data
management/validation/reporting costs.

   2)  Compare detected metal  concentrations to background concentrations from
upgradient and cross-gradient wells to assess the degree to which they are representative
of background conditions. If adequate background wells do not exist, consider installing
a small number of background wells to allow this question to be definitively addressed.

   3) Confirm that wells with elevated metal concentrations do not have metal screens
that  could be  contributing to the elevated  concentrations  detected  in groundwater
samples.

   3) If background comparisons indicate that detected  metal concentrations are site-
related as opposed to representative of background conditions (and if metal screens are
not an issue), then optimize the metals analysis program to a short-list of key analytes and
sampling points using the principles and procedures outlined in this report.

   4) If  sufficient  dissolved  oxygen  and  oxidation-reduction potential data  are  not
available, then obtain field data for these parameters  in the source  area to  support
evaluation of appropriate  source  remediation approaches (such as in  situ chemical
oxidation).

4.5    LTM PROGRAM FLEXIBILITY

   The LTM program recommendations summarized in Table 4.3 are based on available
data regarding current (and assumed future) site conditions.  Changing site conditions
(e.g., periods of drought or excessive rainfall or changes in hydraulic stresses  such as
number and location of pumping wells or pumping rates) could affect contaminant fate
and transport.  Therefore, the LTM program should be reviewed if hydraulic conditions
change  significantly,  and  revised as  necessary  to  adequately  track changes  in  the
magnitude and extent of COCs in environmental media over time.

                                     4-15

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                                  SECTION 5

               TEMPORAL STATISTICAL EVALUATION
   Chemical concentrations measured at different points in time (temporal data) can be
examined graphically or using statistical tests, to evaluate dissolved-contaminant plume
stability. If removal of chemical mass is occurring in the subsurface as a consequence of
attenuation processes or  operation of a  remediation system, mass  removal will be
apparent as a decrease in chemical concentrations through time at a particular sampling
location, as a decrease in chemical concentrations with increasing distance from chemical
source areas, and/or as a change in the suite of chemicals detected through time or with
increasing migration distance.

5.1    METHODOLOGY FOR TEMPORAL TREND ANALYSIS OF
CONTAMINANT  CONCENTRATIONS

   Temporal  chemical-concentration  data can  be  evaluated  for  trends  by  plotting
contaminant concentrations through time  for individual monitoring wells (e.g., Figure
5.1), or by plotting contaminant concentrations versus downgradient distance from the
contaminant source for several wells along  the  groundwater flowpath  over  several
monitoring events. Plotting temporal concentration data is recommended for any analysis
of plume stability (Wiedemeier and Haas, 2000);  however, visual identification of trends
in plotted data may  be a subjective process, particularly if (as is likely) the concentration
data do not exhibit a uniform trend, but are variable through time (Figure 5.2).

   The possibility of arriving at incorrect conclusions regarding the fate and transport of
dissolved contaminants on the basis of visual examination of temporal concentration data
can be reduced by examining temporal trends in chemical concentrations using various
statistical procedures, including regression analyses and the Mann-Kendall test for trends.
The Mann-Kendall  nonparametric test (Gibbons, 1994) is well-suited for evaluation of
environmental data  because the sample size can be small (as few as four data points), no
assumptions are made regarding the underlying statistical distribution of the data, and the
test can be adapted to account for seasonal variations in the data. The Mann-Kendall test
statistic can be calculated at a specified level  of confidence to evaluate whether  a
statistically  significant  temporal trend  is  exhibited  by  contaminant concentrations
detected through time in samples from an individual well. A negative slope (indicating
decreasing contaminant concentrations through  time) or a positive  slope  (increasing
concentrations through time) provides  statistical confirmation of temporal trends that may
have been identified visually from  plotted data  (Figure  5.2).   In this analysis, a 90%
confidence level is used to define a statistically significant trend.
                                      5-1
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                                  FIGURE 5.1
                  PCE CONCENTRATIONS THROUGH TIME
                              AT WELL MW-212D
               LONG-TERM MONITORING NETWORK OPTIMIZATION
                      WASH KING LAUNDRY SUPERFUND SITE
       300
       250
       200
     o
     o
     U
     LU
     O
     Q.
       150
       100
        50
         0
         Dec-00  Jun-01   Dec-01   Jun-02   Dec-02  Jun-03   Dec-03   Jun-04   Dec-04   Jun-05   Dec-05
   The relative value of information obtained from periodic monitoring at a particular
monitoring well can be evaluated by considering the location of the well with respect to
the dissolved contaminant plume and potential receptor exposure points, and the presence
or absence of temporal trends in contaminant concentrations in samples collected from
the well.  The degree to which the amount and quality of information that can be obtained
at a particular monitoring point serves  the  two primary  (i.e.,  temporal and  spatial)
objectives of monitoring (Section 1) must be considered in this evaluation.  For example,
the continued non-detection  of a target contaminant in  groundwater at a particular
monitoring location  provides no  information  about  temporal trends  in contaminant
concentrations at that location, or  about  the extent to which contaminant migration is
occurring, unless the monitoring location lies along a groundwater flowpath between a
contaminant  source and a potential receptor exposure point (e.g.,  downgradient of a
known contaminant  plume).    Therefore, a monitoring  well  having  a  history  of
contaminant concentrations below  detection limits may be providing little or no useful
information, depending on its location.
                                     5-2
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            Decreasing Trend
Increasing Trend
No Trend
            Confidence Factor
                  HIGH
Confidence Factor
      LOW
                Variation
                  LOW
    Variation
      HIGH
                                                              FIGURE 5.2

                                                 CONCEPTUAL REPRESENTATION OF
                                                 TEMPORAL TRENDS AND TEMPORAL
                                                   VARIATIONS IN CONCENTRATIONS
                                                     Long-Term Monitoring Optimization
                                                     Wash King Laundry Superfund Site
draw\739732\diffusion\williamsA.cdr pg1 nap 4/3/02
                                         5-3

-------
   A trend of increasing contaminant concentrations in groundwater at a location between
a contaminant source and a potential receptor exposure point may represent information
critical in evaluating whether contaminants are migrating to the exposure point, thereby
completing an exposure pathway.   Identification of a trend of decreasing contaminant
concentrations at the same location may be useful in evaluating decreases in the areal
extent of dissolved contaminants, but does not represent information that is critical to the
protection  of a  potential  receptor.   Similarly, a  trend  of decreasing contaminant
concentrations in groundwater near  a contaminant  source  may represent important
information regarding  the progress of remediation near, and downgradient from,  the
source.  By contrast, the absence of a statistically significant (as defined by the Mann-
Kendall test with a 90% confidence level) temporal  trend in contaminant concentrations
at a particular location within or downgradient from a plume indicates  that virtually no
additional information  can be obtained by frequent  monitoring of groundwater at that
location, in that the results of continued monitoring through time are likely to fall within
the historic range of  concentrations  that have already been detected (Figure 5.3).
Continued  monitoring  at   locations  where   no   temporal   trend  in  contaminant
concentrations is present serves merely to confirm the results of previous monitoring
activities at that location.

   The temporal trends and relative location of wells can be weighed to determine if a
well should be retained, excluded, or  continued  in the program with reduced sampling.
Figure 5.4 presents a flowchart demonstrating the method for using trend results to draw
these conclusions.

5.2    TEMPORAL EVALUATION RESULTS FOR GROUNDWATER WELLS

   The  analytical  data for groundwater samples collected  from the  47 groundwater
monitoring and  extraction wells  in the Wash King LTM  program from April 2001
through August 2005 were examined  for temporal trends using the  Mann-Kendall test.
Note that only recent (i.e. post-extraction well start up) analytical results were used in this
analysis.  The temporal analysis is intended to measure trends obtained from a "steady
state" system, so using results obtained before the extraction system was implemented
could lead to spurious trends.  The objective of the evaluation was to identify those wells
having increasing or decreasing concentration trends for each COC,  and to consider the
quality of information represented by the existence or absence of concentration trends in
terms of the location of each monitoring point.  Increasing or decreasing trends are those
identified as having positive or negative slopes, respectively,  by the Mann-Kendall trend
analysis with a confidence level of 90%.

   Summary results of Mann-Kendall  temporal trend analyses for COCs in groundwater
samples from Wash King are  presented in Table 5.1.  Table 5.1 also contains the relative
location designation assigned  to each well and the number of results used in the analysis.
Trends for the three COCs (PCE,  TCE, and DCE) were  evaluated to  assess the value of
temporal information provided by each well.  As implemented, the algorithm  used to
evaluate concentration trends  assigned a value of "ND" (not detected) to those wells with
sampling  results that were consistently below analytical detection limits through time,
rather than assigning a  surrogate value corresponding to the detection  limit - a procedure
that could generate potentially misleading and anomalous "trends" in concentrations.


                                      5-4

S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

-------
      c
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                                                    CONCEPTUAL REPRESENTATION

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                                                    LOCATION WHERE NO TEMPORAL

                                                      TREND IN CONCENTRATIONS

                                                              IS PRESENT

                                                         Long-Term Monitoring Optimization
                                                         Wash King Laundry Superfund Site
draw\739732\diffusion\williamsA.cdr pg2 nap 4/3/02
                                         5-5

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                                        FIGURE 5.4
          TEMPORAL TREND DECISION RATIONALE FLOWCHART
                 LONG-TERM MONITORING NETWORK OPTIMIZATION
                         WASH KING LAUNDRY SUPERFUND SITE
                                       Recent
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                                           5-6
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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   The color-coding of Table  5.1 entries denotes the presence or absence of temporal
trends,  and  allows those  monitoring points  having  nondetectable concentrations,
decreasing or increasing concentrations, or no discernible trend in concentrations to be
readily identified.   Those trend  that have confidence levels between 90 and 95% are
indicated  by the "probably  increasing"  and "probability decreasing" classifications
("increasing" and "decreasing" classifications correspond to confidence levels of over
95%).  Trend results with bold borders indicate those analytical results that contained
over 50% non-detections, historically.  Although these chemical trends are not deserving
of the "ND" classification and resulting decision process, decisions made based on these
trends should take the high number of non-detects into consideration.

   Fourteen of the seventeen monitoring wells that are not currently sampled had fewer
than four analytical results for each of the COCs  could not be analyzed using the Mann-
Kendall trend analysis,  and have a "<4Meas" designation. Figures 5.5 and 5.6 display the
Mann-Kendall results  for PCE  thematically  by well, along with the relative plume
location for the shallow and deep zone wells, respectively.

   The basis for the decision to exclude, reduce the sampling frequency, or retain a well
in the monitoring program based on the value  of its temporal information is described in
the "Rationale" column of Table 5.1, and a flow chart of the decision logic applied to the
temporal trend analysis results is presented on Figure 5.4.  Trend results for PCE were
given more weight than those from the other COCs, given  its relatively higher impact;
however, the most conservative trend was used in all cases (e.g., if TCE trend resulted in
a recommendation to retain a well, that well would be recommended for retention.)

   Wells that have decreasing trends in a source area in which concentrations are above
standards  (e.g.,  MW-101D)  are  valuable because they provide  information  on the
effectiveness of the remedial actions performed to date and are thus recommended for
retention in the monitoring system; conversely, wells located downgradient area that have
either decreasing concentrations  (e.g., MW-212S, EW-4) will provide limited valuable
temporal information in the future  and are   recommended for exclusion or reduced
sampling.  Downgradient wells with increasing concentrations (e.g.,  EW-2, EW-4  and
MW-213D) are valuable because they identify areas where the plume may be expanding
or where remedial systems are not effective. Wells with stable (low variation), 'no trend'
results (e.g., MW-205D and MW-305S) were  recommended for exclusion or monitoring
reduction because continued frequent sampling would not likely yield new information,
while wells with highly variable COC concentrations (e.g., wells MW-101S and MW-
303) were recommended for retention.

   Table 5.1 summarizes recommendations  to  retain 10  and  exclude or reduce the
frequency for 26 of the 36 wells analyzed in  the temporal evaluation (not including the
non-sentry wells with fewer than four measurements). The recommendations provided in
Table 5.1  are based on the evaluation of temporal statistical results only, and must be
used in conjunction with the results of the qualitative and spatial evaluations to generate
final recommendations  regarding retention of monitoring points in the LTM program, and
the frequency of monitoring at particular locations in Wash King.


                                     5-8

S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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                                 SECTION 6

                SPATIAL STATISTICAL EVALUATION
   Spatial statistical  techniques also can be  applied to the design and evaluation  of
groundwater monitoring programs to assess the quality of information generated during
monitoring and to evaluate  monitoring networks.   Geostatistics, or the theory  of
regionalized variables (Clark, 1987; Rock,  1988; American Society of Civil Engineers
Task  Committee  on Geostatistical  Techniques in Hydrology,  1990a and  1990b),  is
concerned with variables having values dependent on location, and which are continuous
in space but  vary in  a manner too complex for simple mathematical  description.
Geostatistics is based on the premise that the  differences in values  of a spatial variable
depend only on the distances between sampling locations, and the relative orientations of
sampling locations - that is, the values of a variable  (e.g., chemical concentration)
measured at two locations that are spatially close together - will be more similar than
values of that variable measured at two locations that are far apart.

6.1    GEOSTATISTICAL METHODS FOR EVALUATING MONITORING
NETWORKS

   Ideally,  application of geostatistical  methods  to the  results  of the  groundwater
monitoring program  at Wash King could be  used to  estimate COC concentrations at
every point within the dissolved contaminant plume, and also could be used to generate
estimates of the "error,"  or uncertainty,  associated with  each  estimated concentration
value.  Thus, the monitoring program could be optimized by using available information
to identify those  areas having the  greatest uncertainty  associated with the  estimated
plume extent and  configuration.  Conversely, sampling  points could be successively
eliminated  from simulations, and the  resulting  uncertainty examined, to evaluate if
significant  loss of information  (represented  by  increasing  error or uncertainty  in
estimated chemical concentrations)  occurs as the number of sampling locations  is
reduced.  Repeated application of geostatistical estimating techniques, using tentatively
identified sampling locations, then could be used to generate a sampling program that
would provide an acceptable level  of uncertainty regarding the distribution of COCs with
the minimum   possible  number  of  samples  collected.   Furthermore, application  of
geostatistical methods can provide unbiased representations of the distribution of COCs
at different locations in the subsurface, enabling the extent of COCs to be evaluated more
precisely. The application of geostatistics at hazardous, toxic, and radioactive waste sites
is discussed in greater depth in USAGE Engineer Technical Letter 1110-1-175 (1997).

   Fundamental to geostatistics is the concept of semivariance [j(h)], which is a measure
of the spatial dependence between sample variables (e.g.,  chemical  concentrations) in a
                                     6-1
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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specified direction.  Semivariance is defined for a constant spacing between samples (h)
by:


                             y(h) = — JL[g(x) - g(x + h) ]2            Equation 6-1


Where:

   j(h)     =  semivariance calculated for all samples at a distance h from each other;

   g(x)     =  value of the variable in sample at location x;

   g(x + h) = value of the variable in sample  at a distance h from sample at location x;

              and

   n       =  number of samples in which the variable has been determined.

   Semivariograms  (plots  of y(h) versus h) are  a means of depicting graphically the range
of distances over which,  and the degree to which,  sample values at a given point are
related to sample values at adjacent, or nearby, points, and conversely, indicate how close
together sample points must be  for  a value  determined at one point to  be useful in
predicting unknown values at other points.  For h = 0, for example, a sample is being
compared with itself, so normally y(0)  = 0  (the semivariance at a spacing of zero, is
zero), except where a so-called nugget effect is present (Figure 6.1), which implies that
sample values are highly variable at distances less than the sampling interval. Analytical
variability  and sampling error can  contribute to the nugget.  As the distance between
samples  increases,  sample  values  become  less  and  less closely related,  and  the
semivariance therefore increases, until a "sill" is eventually reached, where y(h) equals
the overall variance (i.e., the  variance around the average value).  The sill is reached at a
sample  spacing called the "range of influence," beyond which  sample values are  not
related.  Only values between points at spacings less than the range  of influence can be
predicted; but within that distance, the semivariogram provides the proper weightings,
which apply to sample values separated by different distances.

   When a semivariogram is calculated for a variable over an area (e.g., concentrations of
PCE  in the Wash King shallow  zone), an irregular spread  of points  across  the
semivariogram plot is the  usual result (Rock, 1988).  One of the most subjective tasks of
geostatistical analysis is to identify a continuous, theoretical semivariogram model that
most closely follows the real  data. Fitting a theoretical model to calculated semivariance
points is accomplished  by trial-and-error, rather than  by a formal statistical procedure
(Davis,  1986; Clark,  1987; Rock, 1988).   If a "good" model fit results, then  y(h) (the
semivariance) can  be  confidently estimated for any  value of h, and  not  only at  the
sampled points.
                                      6-2
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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                                  FIGURE 6.1
                   IDEALIZED SEMIVARIOGRAM MODEL
               LONG-TERM MONITORING NETWORK OPTIMIZATION
                     WASH KING LAUNDRY SUPERFUND SITE
      3500  -

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used in the deep well set because they are screened significantly below the other deep
wells; MW-304D and MW-305D both have associated "intermediate" wells that would
be more appropriate to include, as shown in Figure 2.3.

   The commercially available geostatistical software  package Geostatistical Analyst™
(an extension to the Arc View® geographic information system [GIS]  software package)
(Environmental Systems  Research Institute, Inc. [ESRI], 2001) was used to develop
semivariogram models depicting the spatial variation in the shallow and deep aquifers for
PCE in groundwater.

   As  semivariogram  models  were  calculated for   each  scenario (Equation  6-1),
considerable scatter of the data was apparent during fitting of the models.  Several data
transformations  (including  a   log   transformation)   were   attempted   to   obtain  a
representative   semivariogram  model.    Ultimately,  the  concentration  data  were
transformed to  "rank statistics,"  in which, for example, the  24 wells in the deep zone
were ranked from 1 (lowest concentration)  to 24 (highest concentration) according to
their most recent PCE concentrations. Tie values were assigned the median rank of the
set of ranked values;  for example, if five wells had non-detected concentrations, they
would each be ranked "3", the median  of the set of ranks: [1,2,3,4,5].  Transformations of
this type can be less sensitive to outliers, skewed distributions, or clustered  data than
semivariograms based on raw concentration values, and thus may enable recognition and
description of the underlying spatial structure of the data in cases where ordinary data are
too "noisy."

   The rank statistics were used to develop semivariograms that most accurately modeled
the spatial  distribution of the data in the two scenarios.  The parameters for  best-fit
semivariograms for the two spatial evaluations are listed in Table 6.1.

                                   TABLE 6.1
            BEST-FIT SEMIVARIOGRAM MODEL PARAMETERS
               LONG-TERM MONITORING NETWORK OPTIMIZATION
                     WASH KING LAUNDRY SUPERFUND SITE
Parameter
Model
Range (ft)
Sill
Nugget
Shallow Zone
Circular
1000
17.5
0
Deep Zone
Circular
600
45
15
   After the semivariogram models were developed, they were used in the kriging system
implemented by the Geostatistical Analyst™ software package (ESRI, 2001) to develop
two-dimensional kriging realizations (estimates  of the spatial  distribution of PCE in
groundwater at Wash King), and to calculate the associated kriging prediction standard
errors.  The median kriging standard deviation was obtained from the standard errors
calculated using the entire monitoring network for each scenario (e.g., the 24 wells in the
deep zone). Next, each of the wells was sequentially removed from the network,  and for
each resulting well network configuration, a kriging realization was completed using the

                                      6-4
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COC concentration rankings from the remaining wells.  The "missing-well" monitoring
network realizations were used to calculate prediction standard errors, and the median
kriging standard deviations  were  obtained  for  each "missing-well" realization  and
compared with the median kriging  standard deviation for the "base-case" realization
(obtained using the complete monitoring network), as a means of evaluating the amount
of information loss (as indicated by increases in kriging error) resulting from the use of
fewer monitoring points.

   Figure  6.2 illustrates  an example of the spatial-evaluation procedure  by showing
kriging prediction  standard-error maps for three kriging realizations for the 15 shallow
zone wells.  Each map shows the predicted standard error associated with a given group
of wells based  on the  semivariogram parameters  discussed above.   Lighter colors
represent areas with lower spatial uncertainty, and  darker colors  represent areas  with
higher uncertainty; regions in the vicinity of wells  (i.e.,  data points)  have the lowest
associated uncertainty. Map A on Figure 6.2 shows the predicted standard error map for
the "base-case"  realization  in which all  15 wells  are included.   Map B shows the
realization in which well MW-207S was removed from the monitoring network, and Map
C shows the realization in which MW-201 was removed. Figure 6.2 shows that when a
well is removed from the network,  the predicted standard error in the vicinity of the
missing well  increases (as indicated by a darkening of the shading in the vicinity of that
well).  If a "removed" (missing) well is in an  area with several other wells (e.g., well
MW-207S; Map B on Figure 6.2), the predicted standard error may  not increase as much
as if a well (e.g.,  MW-201; Map C) is removed from an area with fewer surrounding
wells.

   Based on the  kriging evaluation, each  well received a relative  value of spatial
information "test statistic" calculated from the ratio of the median "missing well" error to
median "basecase" error. If removal of a particular  well from the monitoring network
caused very  little  change in the resulting  median kriging standard deviation, the test
statistic equals one, and that well was regarded as contributing only a limited amount of
information to the LTM  program.  Likewise, if removal of a well  from the monitoring
network produced  larger increases in the kriging standard deviation (typically more than
1 percent), this was regarded as an indication that the  well contributes a  relatively greater
amount of information and is relatively more important to the monitoring network. At
the conclusion of the kriging realizations, each well  was ranked from  1  (providing the
least information)  to the  number of wells included in the zone analysis  (providing the
most  information), based on the amount of information  (as measured by changes in
median kriging standard  deviation) the well contributed toward describing the spatial
distribution of PCE, as shown in Tables 6.2 and 6.3. Wells providing the least amount of
information represent possible candidates for exclusion from the monitoring network at
Wash King.

6.3    SPATIAL  STATISTICAL EVALUATION RESULTS

   Figures 6.3 and 6.4 and Tables 6.2  and 6.3  present the test statistics and associated
rankings of the evaluated subsets of monitoring locations for PCE in the  shallow and
deep zones, respectively.  The wells are ranked from least to most spatially relevant based
on the relative value of the associated recent COC information provided by each well, as
calculated based on the kriging realizations.  Examination of these results  indicate that

                                      6-5

S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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                               A) Basecase (All wells)
                               B) Missing well MW-207S:
                                   relative small change in
                                   spatial uncertainty
                               C) Missing well MW-201:
                                   relative large change in
                                   spatial uncertainty
Legend
      Well missing from
      kriging realization
      Predicted Standard Error Map
      Less spatial uncertainty
o
      Greater spatial uncertainty
          FIGURE 6.2

   IMPACT OF MISSING WELLS
ON PREDICTED STANDARD ERROR
                                    LONG TERM MONITORING OPTIMIZATION
                                        PARSONSD

-------
                                          TABLE 6.2

          RESULTS OF GEOSTATISTICAL EVALUATION RANKING OF WELLS
                 BY RELATIVE VALUE OF PCE IN THE SHALLOW ZONE
                           LONG-TERM MONITORING OPTIMIZATION
                             WASH KING LAUNDRY SUPERFUND SITE
Well Name ^
MW-304S
MW-207S
MW-213S
MW-208
MW-101S
MW-102S
MW-209
MW-305S
MW-210
MW-7S
MW-202
MW-215
MW-8S
MW-201
MW-3S
Kriging
Metric
1.0025
1.0050
1.0072
1.0073
1.0122
1.0160
1.0193
1.0210
1.0252
1.0303
1.0336
1.0436
1.0580
1.0702
1.1400
Kriging
Ranking b/
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Exclude
X
X
X
X
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~
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X
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         z Well set includes 15 "shallow zone" wells designated in Table 2.1.
         b/1= least relative amount of information; 15= most relative amount of information.
         c/ Well in the "intermediate" range; received no recommendation for excludsion or retention.
           (see Section 6.2).
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\3.xls
                                              6-7

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                                            TABLE 6.3

   RESULTS OF GEOSTATISTICAL EVALUATION RANKING OF WELLS BY RELATIVE
                             VALUE OF PCE IN THE LOWER ZONE
                             LONG-TERM MONITORING OPTIMIZATION
                              WASH KING LAUNDRY SUPERFUND SITE
Well Name ^
MW-301D
MW-301S
MW-206D
MW-206S
MW-303
MW-212S
MW-205D
MW-212D
MW-302
MW-101D
MW-205S
MW-204S
MW-204D
MW-213D
MW-104
MW-304I
MW-4
MW-3D
MW-207D
MW-105
MW-2D
MW-8D
MW-103
MW-305I
Kriging
Metric
0.9998
0.9998
0.9999
.0000
.0001
.0003
.0005
.0005
.0005
.0011
.0013
.0016
.0022
.0024
.0032
.0035
.0041
.0062
.0089
.0123
.0139
.0159
.0195
.0312
Kriging
Ranking b/
1
2
3
4
5
6
gC/
8
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Exclude
X
X
X
X
X
X
X
X
X
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—
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X
X
X
X
X
X
X
 Well set includes "deep zone" wells designated in Table 2.1, excluding MW-304D, MW-305D, and MW-102D.
b/1= least relative amount of information; 24= most relative amount of information.
c/ Tie values receive the median ranking of the set.
* Well in the "intermediate" range; received no recommendation for excludsion or retention.
  (see Section 6.2).
 S:\ES\WP\PROJECTS\744461 - USAGE LTMO\3.xls
                                                 6-8

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-------

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monitoring wells in close proximity to several other monitoring wells (e.g., red color
coding on Figures 6.3 and 6.4) generally provide relatively lesser amounts of information
than do wells at greater distances from other wells or wells  located in areas having
limited numbers of monitoring points (e.g., blue  color coding on Figures 6.3 and 6.4).
This is intuitively obvious, but the analysis allows the most valuable and least valuable
wells to be identified quantitatively. For example, Table 6.3 identifies the wells ranked 8
and below that provide the relative least amount of information, and the wells ranked at
or above  18 that provide  the greatest amount of  relative information regarding the
occurrence and distribution of PCE in groundwater among those wells in the lower zone.
The  lowest-ranked  wells are potential candidates for exclusion  from the Wash King
groundwater monitoring program, and  the highest-ranked wells are  candidates for
retention   in  the   monitoring  program;  intermediate-ranked   wells  receive  no
recommendation for removal or retention in the monitoring program based on the spatial
analysis.   The recommendations  provided in Tables  6.2  and 6.3 are based  on the
evaluation of spatial statistical results only, and  must be used in conjunction with the
results of the  qualitative and  temporal  evaluations to generate final  recommendations
regarding  retention of monitoring points in the LTM  program,  and the frequency of
monitoring at particular locations in Wash King. Also note that due to the limitations of
the data (e.g.,  2005 results are not available for all wells) the qualitative and temporal
results are given more weight in the combined analysis.
                                     6-11
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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                                 SECTION 7

   SUMMARY OF LONG-TERM MONITORING OPTIMIZATION
                               EVALUATION
  Forty-nine groundwater monitoring and extraction wells at Wash King were evaluated
qualitatively  using hydrogeologic, hydrologic,  and  contaminant  information,  and
quantitatively using temporal and  spatial  statistical techniques.  As each tier of the
evaluation was performed, monitoring points that provide relatively greater amounts of
information  regarding the occurrence  and distribution of COCs  in groundwater  were
identified, and were distinguished from those monitoring points that provide relatively
lesser amounts of information. In this section, the results of the evaluations are combined
to generate  a refined monitoring program that potentially  could provide  information
sufficient to address the primary  objectives of monitoring, at reduced cost.  Monitoring
points  not  retained in the refined  monitoring network could be  removed from the
monitoring program with relatively  little loss of information.  It should  be noted that
development of an optimized long-term monitoring program for the site would benefit
from a better understanding of the hydraulic effects of the current pump-and-treat system.
In addition, further evaluation of how the persistence of the VOC plume could be reduced
(e.g., via additional source removal efforts) should be considered.

7.1     GROUNDWATER MONITORING NETWORK SUMMARY

  The results of the qualitative,  temporal, and spatial  evaluations for the groundwater
monitoring and  extraction wells are summarized in Table  7.1,  along with the  final
recommendations for  sampling point retention or exclusion and sampling frequency.
These final recommendations are  also shown on Figures 7.1  and 7.2.  The results of the
evaluations were combined and summarized in accordance with the decision logic shown
on Figure 7.3 and described below.

      1. Each well retained in the monitoring network on the basis of the qualitative
        hydrogeologic evaluation was  recommended to be retained in  the  refined
        monitoring program.

     2. Those wells  recommended for exclusion from the monitoring program on the
        basis of all three evaluations, or on the basis of the qualitative and temporal
        evaluations (with no recommendation resulting from the spatial evaluation)
        were recommended for removal from the monitoring program.

     3. If a well was recommended for removal based on the qualitative evaluation and
        recommended for retention based on the temporal or spatial evaluation, the final
        recommendation was based on a case-by-case review of well information.

                                     7-1

S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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-------
                                   FIGURE 7.3
           COMBINED EVALUTION SUMMARY DECISION LOGIC
               LONG-TERM MONITORING NETWORK OPTIMIZATION
                      WASH KING LAUNDRY SUPERFUND SITE
                                                                Retain Monitoring Point
                                                             (Increase Frequeno/on a Case-
                                                                  by-Case Basis)
                                Reduce Monitoring Frequency
                                    (Case-By-Case)
   Exclude Well from Futwe
        Sampling
     4.  If a well was recommended for retention based on the qualitative evaluation and
         recommended for removal based on the temporal and spatial evaluation, the
         well was  recommended to be retained, but the possibility  of reducing the
         sampling frequency was evaluated based on  a case-by-case  review of well
         information.

   It should  be  noted,  as stated in number four above, that  the  final recommended
monitoring frequencies that resulted from the combined analysis are not, in all cases, the
same as those recommended as a result of the qualitative evaluation. The justifications for
the final recommendations are provided in the "Rationale" column in Table 7.1, and fall
into the following general categories:

   •  Temporal and/or spatial statistical results  confirm the  sampling frequency
      recommendations from the qualitative evaluation.  For example, well MW-301S is
      recommended for exclusion from the network or for sampling frequency reduction
      by both the temporal and spatial statistical results; thus, the  statistics confirm the
                                      7-7
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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      qualitative  recommendation to exclude the well.   Similarly, well MW-207S is
      recommended for exclusion  or reduction by the temporal and spatial statistical
      results; thus the statistics confirm the relatively low (biennial) sampling frequency
      recommended by  the  qualitative  evaluation.    Likewise, well  MW-303  is
      recommended for retention based on  the temporal  statistical evaluation, which
      confirms maintaining the relatively  higher (semiannual)  sampling frequency
      recommendation stemming from the qualitative evaluation.

   •   Increase monitoring frequency based on statistics. For example, well MW-101S
      is recommended for annual sampling based on the qualitative evaluation, but for
      semiannual sampling based on the summary evaluation due to the increasing TCE
      trends identified in the temporal evaluation.

   •   Qualitative factor overrides statistics recommendations.   For example,  although
      well MW-205S is recommended  for exclusion or  reduction  based on the limited
      value of its temporal trend information, the qualitative evaluation noted that the
      concentrations are decreasing post December 2002, and thus override  the high
      variation no trend results driving the temporal evaluation recommendations that
      considered  a longer time period.  Additionally, although wells MW-8D and MW-
      8S  are  recommended for retention based  on the  spatial  evaluation,  they  are
      ultimately recommended for exclusion from the  monitoring  program because the
      qualitative evaluation points out that these wells are outside of the area of interest
      of the plume.

   Table 7.2 presents a summary of the revised monitoring network as compared to the
basecase  network (number  shown  in parentheses).  For the Wash King groundwater
monitoring wells, the LTMO results indicate  that  a refined  monitoring  program
consisting of 35 existing wells  sampled  less frequently  (11  wells sampled biennially, 16
sampled annually, and 8 sampled semiannually) and 10 primary and 2 optional new wells
(sampled  annually) would be  adequate to  address the  two  primary  objectives of
monitoring listed  in Section 1.  This refined network (including the two optional  new
wells) would result in an average of 49.5 well-sampling events per year, compared to 50
per year under the current quarterly (EW) and semi-annual (MW)  monitoring program.
A well-sampling event is defined as a single sampling of a single well.  Implementing
these recommendations for optimizing the LTM monitoring program  at  Wash King
would increase the number  of wells sampled from 30 to 47 (including the two optional
new  wells), but entail essentially the same number of groundwater well-sampling events
per year.    The costs of the basecase and refined monitoring programs would  likely be
similar given the similar number of well-sampling events per year.
                                     7-8
S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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                                     TABLE 7.2
    SUMMARY OF REVISED AND BASECASE MONITORING PROGRAMS
                     LONG-TERM MONITORING OPTIMIZATION
                       WASH KING LAUNDRY SUPERFUND SITE
Well Type
Monitoring
Extraction
Total Wells
Monitoring Frequency3'
Exclude
14(17)
0(0)
14 (17)
Biennial
11(0)
0(0)
11(0)
Annual
28b/(0)
0(0)
28(0)
Semiannual
3(25)
5(0)
8(25)
Quarterly
0(0)
0(5)
0(5)
Total Sampling
Points

42 (25)
5(5)
47 (30)
37 Basecase sampling frequency corresponding to Table 2.1 shown in parentheses.
b/ Number includes 10 primary and 2 optional new wells.
                                       7-9
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                                SECTION 8

                               REFERENCES
American  Society  of Civil  Engineers (ASCE)  Task Committee  on Geostatistical
      Techniques in Hydrology.  1990a. Review of Geostatistics in Geohydrology - I.
      Basic concepts. Journal of Hydraulic Engineering 116(5):612-632.

ASCE Task Committee on Geostatistical Techniques in Hydrology.  1990b.  Review of
      Geostatistics  in Geohydrology -  II.   Applications.    Journal of Hydraulic
      Engineering 116(6): 63 3 -65 8.

Clark, I. 1987. Practical Geostatistics.  Elsevier Applied Science, Inc., London.

Cohen, R.M. and J.W. Mercer.  1993.  DNAPL Site Evaluation. CRC Press, Inc.

Environmental Systems Research Institute, Inc. 2001.  ArcGIS Geostatistical Analyst
      Extension to ArcGIS 8 Software. Redlands, CA.

Gibbons, R.D. 1994.  Statistical Methods for Groundwater Monitoring. John Wiley &
      Sons, Inc., New York, NY.

Michigan Department of  Natural Resources (MDNR).   1980.  Groundwater Quality
      Investigation, Wash King Laundry, Baldwin, Michigan.

Rock, N.M.S. 1988. Numerical Geology.  Springer-Verlag, New York, NY.

U.S. Army  Corps of Engineers.  1997.  Proactive Aspects of Applying Geostatistics at
      Hazardous, Toxic, and Radioactive Waste Sites, Technical Lett No. 1110-1-175,
      June 30.

U.S. Environmental Protection  Agency (USEPA).  1993.  EPA Superfund Record of
      Decision: Wash King Laundry, EPA ID MID980701247, OU1, Pleasant Plains
      TWP,MI. March 31.

USEPA.   1994. Methods for Monitoring Pump-and-Treat Performance.   Office of
      Research and Development. EPA/600/R-94/123.

Wiedemeier, T.H., and P.E. Haas. 2000. Designing Monitoring Programs to Effectively
      Evaluate  the  Performance  of Natural Attenuation.   Air  Force  Center for
      Environmental Excellence (AFCEE).  August.

                                    8-1

S:\ES\WP\PROJECTS\744461 - USAGE LTMO\2.doc

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              APPENDIX A




COMMENTS AND RESPONSES ON DRAFT REPORT

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Monitoring Network Optimization Evaluation, Parsons, 1
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I concur with the data gaps identified and the recommendations for the new wells. I
am distressed by the apparent loss of locations for vertical profiling VOC data (the
GP-series). Depending on the location and results where the vertical profiling was
done, this data might be able to show some of the proposed wells unnecessary.

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Is recommended well S-7 proposed with an annual sampling frequency as shown in
this table or is it a potential well as shown on Figure 4.1? There is an S-8 in table
4.3 ; it does not appear on Figure 4. 1 and text talks about up to seven new shallow
zone monitoring wells. Is there really an S-8?

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According to the report the algorithm for calculating Mann-Kendall assigned a value
of ND to non-detects rather than assuming and assigning a numerical value. While
the Mann-Kendal does not require a quantitative value, it does require a qualitative
ranking. How were the NDs used? Were all detection limits consistent within an
individual trend analysis? rf detection limits differed, how was this handled? Were
there any detections (usually qualified with a "j") below the detection limit? How
were these handled; were they deemed higher than a ND? hi other words, would a
value detected at less than the detection limit be treated as greater than the detection
limit in this algorithm?

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This is an admittedly picky comment. There is considerable information in this
table, however, it is not the easiest table to understand. The intensity of some of the
colors (blue and green particularly) obscures the printing (even if the words are made
redundant by the colors). The bolded boundaries are not as intuitively obvious as
one would like. Once I finally identified the bolded cells, they seemed obvious
thereafter, but on several separate occasions I studied the table without discerning the
differences.

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I am not quite sure how the geostatistical analysis would best handle this issue, but

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report will be modified accordingly to
include these new recommendations.
Recent water level elevation data sets
provided to Parsons do not contain data
for all site wells (e.g., data for shallow
wells MW-8S and MW-202 are not
included). It would be helpful to prepare
potentiometric surface maps using water
level data for all site wells in order to
make them as accurate and useful as
possible.
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Agreed that the spatial analysis has
limitations based on the limitations on the
data and the well zone classifications and
would be a good idea to re-conduct after
more data is obtained. However, data
from 2003 was included only after review
to ensure that it was in-line with 2005
results, and the spatial evaluation results
are used only as one of three-tiers of the
lines of evidence. More value was given
to both the qualitative and temporal results
in the combined evaluation. Text will be
added to clarify the above comments in
the report.
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addressing the site-specific analytical
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made in this report could be implemented
now, rather than waiting for data gaps to
be addressed. The LTM plan should be






























dynamic and should be periodically re-
evaluated as new information is obtained.






























Money saved by implementing the
recommended changes to the current






























sampling program could be better spent
filling data gaps and performing a holistic
remedial process optimization evaluation
to ensure that the cleanup effort is
optimized.

































Comment noted; we will contact you to
discuss the minor edits.
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