SEPA
United Stetw
EPA542-R-06-011
February 2006
www.epa.gov/tio
www.clu-in.org/optimization
REMEDIATION SYSTEM EVALUATION (RSE)
PEERLESS PLATING SITE
MUSKEGON, MICHIGAN
Report of the Remediation System Evaluation
Site Visit Conducted September, 2005
Final Report
February 2006
Prepared by US Army Corps of Engineers
Hazardous, Toxic, and Radioactive Waste Center of Expertise
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Executive Summary
The Peerless Plating Superfund Site is located at 2554 South Getty Street, north of the intersection of South Getty
Street and East Sherman Boulevard in Muskegon, Michigan. Copper, nickel, chromium, cadmium, and zinc
electroplating operations as well as associated activities such as burnishing, polishing, pickling, oiling, passivating,
stress relieving, and dichromate dipping were conducted at Peerless Plating from 1937 to 1983. These processes
required the use of toxic, reactive, corrosive, and flammable chemicals that were discharged into seepage lagoons at
the rear of the facility throughout Peerless Plating's history. Between 1972 and 1983 several enforcement actions
were brought forth by the State of Michigan. In June 1983, Peerless Plating closed, the owner declared bankruptcy
with the plant abandoned with plating solution, raw materials, and drummed wastes staged throughout the building.
Between 1983 and 1990, the U.S. EPA carried out various Emergency Response Actions at the site to remove and
dispose of hazardous waste and decontaminate the facility. The site was placed on the NPL in August 1990. In June
1992 the RI/FS was completed and in September 1992 the ROD was signed. In 1997 an explanation of significant
differences (BSD) was issued which revised the cleanup standards to reflect actual background conditions at the
Peerless site. The BSD refined the excavation limits in the areas under adjacent structures and the on site lagoon.
The US EPA through its contractor performed soil remediation at the site in three phases. Phase I which was
completed in 1999 removed, stabilized and disposed of approximately 7500 tons of soil, removed an underground
storage tank, and installed a soil vapor extraction system. Phase II completed in October 2000 removed an
additional 9500 tons of soil after a MDEQ and EPA investigation revealed soil contamination located in a soil layer
4 to 8 feet below ground surface. Phase III soil removal addressed contamination on the adjacent Hardware
Distributors and Asphalt Paving properties and was completed in February 2001.
Construction of the groundwater extraction and treatment system began in October 1999 with startup in June 2002.
The system consisted of six extraction wells, groundwater treatment for chlorinated volatile organic carbon
compounds and metals, followed by discharge to the Little Black Creek.
A second BSD was issued to address the need to implement deed restrictions at the site due to the presence of
contaminated soil 3 to 4 feet below the groundwater table and in an area adjacent to the bank of Little Black Creek.
A third BSD is planned to allow for the extracted groundwater to be discharged to the Muskegon Regional
Wastewater Facility (MRWF) as long as the discharge meets pretreatment standards as defined in the permit issued
August 2, 2005. The RSE team endorses implementation of the third BSD.
The current operations include extraction from the existing wells at a rate of approximately 140 gpm, treating the
flow to reduce the metals, bypassing the VOC treatment equipment, and discharge to the MRWF.
The present staff has been doing a good job of operating the plant and well field. Many improvements were already
under consideration at the time of the RSE site visit. The system is partially automated and the single operator is
responsible for doing other tasks such as data entry and investigations. The level of treatment is expected to be
further reduced (eliminating metals removal and solids management) when plant influent concentrations from the
six groundwater extraction wells verify the metals concentrations are well below the permissible levels identified on
the pretreatment permit. Elimination of the metals treatment portion of the water treatment facility should reduce
the operations effort to approximately 20 percent of the current levels.
The sampling results have shown large concentration variations between successive sampling events over the past
years. The monitoring program is currently in a state of transition from a mix of bailers and peristaltic pumps being
used, to the exclusive use of low flow sampling protocols. Use of consistent sampling protocols should reduce the
variability in concentrations between sampling rounds which should improve data quality.
The plume boundaries are not well defined, with the extent of the plume north of PZ19 being the primary
uncertainty. Additional monitoring locations may be necessary to identify the limits of the contamination. There
may need to be additional definition of the plume in the area of EW-06. Sporadic detection of contaminants is
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occurring in PZ16 and PZ17. An upgradient background monitoring point should be added to assure no off site
sources impact the site.
Based on past sampling results, the ground water concentrations and thus the exposure scenarios are unlikely to
change rapidly. The sampling frequency for monitoring wells should not be more than semi-annually. A change to
quarterly sampling, as apparently required by site documents, is not necessary for making the necessary site
decisions. In fact, some wells, such as WT02A and PZ02B or the PZ06 cluster, could be sampled less frequently,
perhaps annually, without a significant loss of information.
The analytical suite should be reduced to metals and cyanide. Based on the very low detections, the analyses for
volatile organics could potentially be eliminated or at least reduced to once every two or three years.
The aquifer contaminant plume has not responded to ground water extraction as expected. The presence of
concentrations well above the cleanup standards and the lack of a clear downward trend in ground water
concentrations suggest the duration of the project will be very long. Additional efforts directed at the removal or
stabilization of the metals in the aquifer may be useful for reducing the concentrations closer to the cleanup goals
and shortening the time to site closeout. An alternative that could be investigated further would be the in-situ
stabilization of metals. Both carbonate and sulfide could bind with the dissolved cadmium and stabilize the metal in
low solubility precipitates. Similar reactions may be possible for lead and nickel. The impact of chemical additives
on the natural geochemistry of both the aquifer and Little Black Creek is not clear. Present-worth analysis of these
avoided future costs will be necessary to fairly conduct the assessment
Though the project team is tracking the plume concentrations and adjusting the system operation, there is not a
formal, documented, incremental process to compare site conditions to specific interim goals to quantitatively
evaluate progress toward site closure goals. An exit strategy document should be prepared as a means to provide a
consistent decision framework for an evolving project team.
in
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ii
TABLE OF CONTENTS iv
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 1
1.3 DOCUMENTS REVIEWED 1
1.4 PERSONS CONTACTED 2
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS 2
1.5.1 SITE LOCATION 2
1.5.2 SITE HISTORY 2
1.5.3 SITE CHARACTERISTICS 4
1.5.3.1 HYDROSTRATIGRAPHY 4
1.5.3.2 SITE CONTAMINATION 4
1.5.3.3 SITE AND NEARBY LAND USE 4
2.0 SYSTEM DESCRIPTION 5
2.1 SYSTEM OVERVIEW 5
2.2 EXTRACTION AND INJECTION SYSTEM 5
2.3 TREATMENT SYSTEMS 5
2.4 MONITORING SYSTEM 6
3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA 7
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 7
3.2 TREATMENT PLANT OPERATION GOALS 7
3.3 ACTION LEVELS 8
4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT 11
4.1 GROUND WATER EXTRACTION AND INJECTION SYSTEM 11
4.1.1 WELL CONDITION 11
4.1.2 PLUME CAPTURE AND REMEDIATION 11
4.2 TREATMENT EQUIPMENT 12
4.2.1 AIR STRIPPER AND CARBON OFF-GAS TREATMENT 12
4.2.2 REACTOR TANK 12
4.2.3 RAPID Mix, FLOCCULATION TANK AND CLARIFIER 13
4.2.4 BAG FILTERS AND CLEARWELL 13
4.2.5 SOLIDS HANDLING, FILTER PRESS 13
4.3 MONITORING SYSTEM AND PROGRAM 14
4.3.1 GROUND WATER MONITORING 14
4.3.2 PROCESS MONITORING 14
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF MONTHLY COSTS 15
4.5 RECURRING PROBLEMS OR ISSUES 15
4.5.1 WELL ISSUES 15
4.5.2 EFFLUENT EXCURSIONS 15
4.6 REGULATORY COMPLIANCE 15
4.7 ACCIDENTAL CONTAMINANT RELEASES 16
4.8 SAFETY RECORD 16
iv
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE
ENVIRONMENT 17
5.1 GROUND WATER 17
5.2 SURFACE WATER 17
5.3 AIR 17
5.4 WETLANDS AND SEDIMENTS 17
6.0 RECOMMENDATIONS 19
6.1 RECOMMENDATIONS TO ENSURE EFFECTIVENESS 19
6.1.1 GROUND WATER EXTRACTION AND INJECTION WELL PERFORMANCE 19
6.1.2 MODIFICATION TO MONITORING PROGRAM 19
6.2 RECOMMENDATIONS TO REDUCE COSTS 20
6.2.1 BYPASS REMAINING GROUND WATER TREATMENT PLANT PROCESSES 20
6.2.2 MODIFICATION OF THE MONITORING FREQUENCY AND ANALYTICAL SUITE 20
6.2.3 REPORTING REQUIREMENTS 21
6.2.4 LEVEL OF OPERATOR SUPPORT 21
6.3 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT 21
6.3.1 INSTALL A DUST COLLECTOR OVER FESO4 HOPPER 21
6.3.2 INSTALL AN ENCLOSURE AROUND THE AIR COMPRESSOR 21
6.3.3 INITIATE A FORMAL OPERATIONS AND MAINTENANCE PROGRAM 22
6.3.4 PLACE USED EQUIPMENT ON USACE/EPA WEB SITE 22
6.4 MODIFICATIONS INTENDED TO GAIN SITE CLOSEOUT 22
6.4.1 ASSESSMENT OF THE NEED FOR ADDITIONAL TREATMENT OF SOURCE AREAS 22
6.4.1 PERMEABLE BARRIER ALTERNATIVE TO GROUND WATER EXTRACTION 23
6.5 SUGGESTED APPROACH TO IMPLEMENTATION OF RECOMMENDATIONS 23
6.6 SUGGESTED EXIT STRATEGY 24
7.0 SUMMARY 25
LIST OF TABLES
Table 1 Monitoring Wells Sampled as Part of Monitoring System 6
Table 2 Site Groundwater Cleanup and Plant Discharge Criteria 9
Table 3 Recent Extraction Well Plan Rates and Concentrations 11
Table 4 Cost Summary Table for Individual Recommendations 26
List of Figures
Figure 1. Monitoring Locations
Figure 2. Proposed Alignment, Permeable Barrier
Appendices
Appendix A Capture Zone Calculations
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1.0 INTRODUCTION
1.1 PURPOSE
At the request of HQ US EPA, the Army Corps of Engineers (USAGE) Hazardous, Toxic, and Radioactive
Waste (HTRW) Center of Expertise (CX) performed a Remediation System Evaluation (RSE) of the
Peerless Plating Superfund Site ground water corrective action. The RSE process, developed by USAGE,
is intended to be an independent and holistic evaluation of the remediation for four major purposes:
1) assess the performance and effectiveness of the system to achieve remediation objectives,
2) identify opportunities for reductions in operational costs,
3) verify that a clear and realistic exit strategy exists for the site, and
4) confirm adequate maintenance of Government-owned equipment.
The RSE at Peerless Plating is intended to achieve these four goals. In addition, the RSE was intended
to evaluate the format and content of reports on current project operations and monitoring and to
recommend changes as appropriate.
1.2 TEAM COMPOSITION
The team conducting the RSE consisted of the following individuals:
Dave Becker, Geologist, USAGE HTRW CX
Lindsey Lien, Environmental Engineer, USAGE HTRW CX
1.3 DOCUMENTS REVIEWED
The following documents were reviewed as part of the RSE:
Final Remedial Investigation Report, Peerless Plating, Donahue and Associates, September, 1991.
Groundwater Monitoring Reports for November, 2003; May, 2004; and November, 2004, TetraTech
EMI.
Form to Submit Site Information for Optimization, Prepared by Linda Martin, 2005.
Daily Operations Logs for July 2005 and August 2005, Prepared by TetraTech.
As Built Drawings Peerless Plating Superfund Site Remedial Action Groundwater Treatment,
Muskegon, MI, USEPA Region 5, Conestoga-Rovers & Associates, May 17, 2002
Substantive Requirements Document - No.MU990007, Peerless Plating Superfund Site, 2554 Getty
Avenue, Muskegon, MI, Grand Rapids District DEQ, Grand Rapids MI
Wastewater Discharge Permit #PPSS-s01a, Muskegon County Wastewater Management System,
Muskegon, MI, August 8, 2005
Groundwater Collection and Treatment System Manual, Peerless Plating Superfund Site, Muskegon,
MI, Conestoga-Rovers & Associates, April 2000
First Five-Year Review Report for Peerless Plating Superfund Site, Muskegon Township, Muskegon
County, MI, USEPA Region 5, September 25, 2002
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Operation and Maintenance Manual, Peerless Plating Superfund Site Remedial Action Groundwater
Treatment, Muskegon, MI, Conestoga-Rovers & Associates
Record of Decision, Peerless Plating Site, Muskegon, MI, USEPA Region 5, September 21, 1992
Explanation of Significant Differences (BSD) to the Record of Decision, Peerless Plating Site,
Muskegon Township, MI, USEPA Region 5, August 7, 1997.
Explanation of Significant Differences (BSD) to the Record of Decision, Peerless Plating Site,
Muskegon Township, MI, USEPA Region 5, April 5, 2001.
Final Basis for Design Report, Design Specifications, and Drawings, Rerouting of Effluent, Peerless
Plating Site, Muskegon Township, MI, Tetra Tech EM Inc., March 29, 2005.
Letter from Environmental Drilling and Contracting to Mr. Tim Fish, TetraTech, Subject: Well
Cleaning at Peerless Plating Site, dated June 17, 2004.
1.4 PERSONS CONTACTED
Linda Martin, USEPA Region V RPM
Lee Christenson, Project Manager, Tetra Tech
Andy Suminski, Construction Engineer, Tetra Tech
Sunny Krajkovic, Michigan Department of Environmental Quality RPM
Carol Nisson, Project Engineer, Tetra Tech
Tim Fish, Plant Operator, Tetra Tech
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS
1.5.1 SITE LOCATION
The Peerless Plating Site ("Site") is an abandoned electroplating facility located at 2554 Getty Avenue,
Muskegon Township, Muskegon, Michigan. The property covers approximately 1 acre in the southwest 1/4
of Section 33, T. 10 N., and R. 16 W., Muskegon Township. The land use in the vicinity of the Site is urban,
light industrial and residential. The site is located northwest of Little Black Creek and one mile north of
Mona Lake. The Site was placed on the National Priorities List ("NPL") for site cleanup in August 1990.
1.5.2 SITE HISTORY
Electroplating operations were conducted at Peerless Plating from 1937 to 1983. Electroplating operations
and processes conducted at Peerless Plating included copper, nickel, chromium, cadmium, and zinc plating,
as well as associated activities such as burnishing, polishing, pickling, oiling, passivating, stress relieving,
and dichromate dipping. These processes required the use of toxic, reactive, corrosive, and flammable
chemicals. Throughout Peerless Plating's history, process wastes with pH extremes and high heavy metal
concentrations were discharged into seepage lagoons at the rear of the facility.
Between 1972 and 1983 several enforcement actions were brought forth by the State of Michigan. In 1972
the state issued a Stipulation that required Peerless Plating monitor its discharge and install a water
treatment plant. In 1975 the owner was issued a "Notice of Noncompliance and Order to Comply,"
indicating violation of all aspects of the 1972 Stipulation. Suits were filed against Peerless Plating by the
Michigan Attorney General's office for environmental contamination in 1975, 1976, and 1978.
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The seepage lagoons were removed in 1980 following a hydrogeologic study which identified the lagoons
as an ongoing source of contamination to the groundwater, and eventual discharge to the Little Black Creek
adjacent to the site. In 1983, the MDNR conducted an investigation into the operating practices at Peerless
Plating and sampled materials in and around the plant. The MDNR found that treatment facilities still had
not been upgraded adequately, and discharge limitations were still being exceeded for chromium, cyanide,
cadmium, and zinc. The MDNR determined that manholes inside the building did not connect to the
sanitary sewer or plant treatment system, so wastes were discharged directly to the ground. MDNR files
indicated that drummed wastes had not been removed from the building since 1980, and that materials on
the ground outside the building or ground surface material contained high levels of heavy metals.
In 1983, the MDNR and the Michigan Attorney General again filed joint suit against Peerless Plating. The
County of Muskegon Waste Water Management System blocked Peerless Plating's discharge due to failure
to meet County Ordinance discharge limitations.
In June 1983, Peerless Plating closed, the owner declared bankruptcy with the plant abandoned with plating
solution, raw materials, and drummed wastes staged throughout the building. The building was not well
maintained, and access was generally unrestricted. Subsequently, personnel from Muskegon County Civil
Defense and Michigan Department of Public Health, Division of Occupational Health detected hydrocyanic
acid gas in the facility atmosphere. Additional site investigations by the Muskegon County Health
Department and the MDNR verified the presence of cyanide gas.
From September 6 until October 7, 1983, the U.S. EPA carried out an Emergency Response Action at the
site. Objectives of the emergency response action included the removal and disposal of hazardous waste
and decontamination of the facility. This action resulted in the removal of 37,000 gallons of hazardous
liquids including: sulfuric acid, nitric acid, hydrochloric acid, chromic acid, cyanide plating solution,
chromium plating solution, and trichloroethylene (TCE). Lagoons were drained; soil was removed from
lagoon areas; soils and sludges were removed from the building interior; vats, lines, tanks, sumps, debris,
floorboards, and walls were decontaminated; sewer lines were sealed; virgin and proprietary chemicals
were removed; and on-site neutralization of cyanides and nitric acid occurred.
1985, a hydrogeologic study was conducted under the direction of USEPA Region 5 Field Investigation
Team (FIT) personnel. This involved the installation of 7 monitoring wells and soil borings on the Peerless
Plating property and testing the hydraulic parameters of the aquifer. Sampling results indicated
contamination of groundwater by cadmium, chromium, copper, nickel, cyanide, TCE, and trans-1, 2-
dichloroethylene (trans-1, 2-DCE). Metals were found in all wells including upgradient wells. Benzene,
ethylbenzene, xylenes, cyanide and naphthalene were found in wells around the center of the site. The
distribution of the data with respect to the hydraulic gradient was concluded to confirm groundwater
contamination as a direct result of methods and processes employed at Peerless Plating.
The U.S. EPA conducted another emergency removal action beginning March 13, 1990 to remove and
dispose of the 2,500 gallons of liquids with elevated levels of heavy metals and cyanide liquids and sludges
contained in an enclosed above-ground tank on the site. A portion of this removal action was performed by
a Potentially Responsible Party (PRP) and involved encapsulation of an asbestos oven in the Peerless
Plating building and installation of a fence for site security. A second removal action was accomplished in
1993 to demolish and dispose of the Peerless building.
The site was placed on the NPL in August 1990. In June 1992 the RI/FS was completed and in September
1992 the ROD was signed. In 1993 and 1996 pre-design data collected revealed contamination had spread
off the Peerless property boundary. In 1997 an explanation of significant differences (BSD) was issued
which revised the cleanup standards to reflect actual background conditions at the Peerless site. Previous
cleanup standards identified in the 1992 ROD were based on background samples from the Bofors site
located elsewhere in Muskegon. The revised cleanup standards reduced the volume of soil requiring
excavation from 6600 cubic yards to 1200 cubic yards. Excavation limits in the areas under adjacent
structures and on site lagoon were defined.
The US EPA through its contractor removed, stabilized and disposed of approximately 7500 tons of soil in
1997. An additional 9500 tons of soil was removed in November 1999 after a MDEQ and EPA
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investigation revealed soil contamination located in a soil layer 4 to 8 feet below ground surface.
Construction of the groundwater extraction and treatment system began in October 1999 with startup in
July 2002.
A second BSD was issued to address the need to implement deed restrictions at the site due to the presence
of contaminated soil 3 to 4 feet below the groundwater table and in an area adjacent to the bank of Little
Black Creek.
1.5.3 SITE CHARACTERISTICS
1.5.3.1 HYDROSTRATIGRAPHY
The groundwater occurs between approximately 5 and 13 feet beneath the site within lacustrine sands. The
lacustrine sands comprise the primary aquifer beneath the site. This unconfined aquifer is separated from
the underlying Marshall Sandstone Aquifer System by a fine-grained deep water lacustrine clay aquitard
and presumably the underlying silty clay glacial till aquitard. Shallow groundwater flow is primarily
horizontal to the southeast, toward Little Black Creek. The groundwater appears to discharge to Little
Black Creek. There is a slight downward gradient at most locations away from the Creek.
1.5.3.2 SITE CONTAMINATION
Site contamination had impacted soils, ground water, and sediment. The site contaminants are
predominantly metals including cadmium, nickel, aluminum, chromium, and lead. Previous investigations
had also identified several volatile organic compounds (VOC's) including trichloroethylene, 1,1,1
trichloroethane, vinyl chloride, and chloroform. With the exception of some soil contamination under a
portion of an adjacent building, most soil contamination above the water table has been excavated for
offsite disposal.
Recent monitoring has shown cadmium at concentrations over 10 mg/L and TCE is present in ground water
at fluctuating levels between 1.0 ug/L and 26 ug/L in monitoring well M14013. Vinyl chloride and 1,1,1
trichloroethane are present at maximum concentrations of 5.1 ug/L and 1.0 ug/L, respectively. Cyanide is
also detected at concentrations above the cleanup goals (to hundreds of ppb) in ground water from a
number of monitoring wells at the site. Ground water contamination extends at least from the location of
the former plating works southeastward to Little Black Creek and southward to areas south of Sherman
Boulevard. Concentrations of some of the metals, particularly aluminum, are somewhat variable, but
cadmium is consistently high in many wells.
Past sampling of sediments in Little Black Creek indicated the presence of elevated concentrations of
metals. Other potential sources of contamination exist in the Little Black Creek basin in addition to the
Peerless Plating site. The impacts of contaminated discharges from Little Black Creek into Mona Lake,
located approximately 8000 feet southwest of the Peerless site, are the subject of public concern.
1.5.3.3 SITE AND NEARBY LAND USE
The region around the Peerless Plating Superfund Site is predominantly used for commercial and
residential purposes. Approximately 12,000 persons permanently reside in Muskegon Heights based on
2000 census data. The Superfund Site is bounded on the east and south by Little Black Creek, on the west
by Getty Street and on the north by other commercial properties. The site is generally surrounded by a
mixture of commercial and residential areas.
The treated water effluent is discharged to the nearby creek located on the southeast side of the site. The
EPA was in the process of installing a connection from the treatment plant to the Muskegon Country
Municipal WWTP during the site visit in September 2005.
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2.0 SYSTEM DESCRIPTION
2.1 SYSTEM OVERVIEW
The original remedy for the Peerless Site includes the following items:
Groundwater extraction and treatment by air stripping and metals precipitation
Contaminated soil excavation to the water table with off-site disposal
Vapor extraction of VOC-contaminated soils above the water table
The vapor extraction and excavation and disposal of contaminated soil have been completed. The
groundwater extraction and treatment system was commissioned and began operations in July 2002.
Operations have continued since that time.
2.2 EXTRACTION AND INJECTION SYSTEM
Contaminated ground water is recovered from six extraction wells. These wells are all approximately 66 to
73 feet deep and screened over 55 feet, though the pump is set in a five-foot long blank with five of the 55
feet of screen below the blank. The wells are six-inch diameter and constructed of stainless steel screen
and riser. Each well is provided with Grundfos submersible pumps. Wells EW-1 through -4 and EW-6 are
equipped with 0.5 HP pumps, EW-5 is equipped with a 1 HP pump. The wells are completed with pitless
adapters. Extraction pipelines are 2-inch diameter high-density polyethylene and run separately from each
well to the treatment plant where the flow is combined into a header. Each well is provided (in the
treatment plant) a control valve, sample port, and flow meter. The extraction wells are generally installed
in a line parallel to Little Black Creek.
2.3 TREATMENT SYSTEMS
The groundwater treatment system was designed to operate at 165 gallons per minute (gpm) with
maximum design influent concentrations for cadmium, chromium, cyanide, lead, nickel and zinc of 1460
ug/L, 26 ug/L, 0 ug/L, 1 ug/L, 201 ug/L, and 1080 ug/L respectively. In addition, the VOC design
influent concentrations for benzene, dichloroethene, trichloroethene, and vinyl chloride are 23 ug/L, 75
ug/L, 240 ug/L and 10 ug/L respectively. The treatment system consists of the following elements:
tray type air stripper
vapor phase granular activated carbon (GAC) trains (2 units operating in series)
equalization tank
reaction tank (air sparging, chemical addition and mixing)
flash mix tank
flocculation tank
clarifier
cartridge filters (operating in parallel)
treated effluent tank (with pH adjustment)
sludge dewatering system
acid, lime, ferrous sulfate and polymer feed systems.
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During the RSE site visit, the EPA was in the process of installing a sewer line that would direct the treated
effluent to the Muskegon County Wastewater Treatment Facility. The discharge was previously directed to
the Little Black Creek.
2.4
MONITORING SYSTEM
There are approximately 27 monitoring wells currently sampled as part of the semi-annual monitoring
program. These include wells of varying depth, but do not include two shallow wells that are typically dry
(PZ-18 and -19) or one that was damaged (Ml4014). The six extraction wells are also typically sampled.
No residential or other private wells wells are sampled. Wells are sampled in May and November. Table 1
shows the wells that are currently sampled as part of the semi-annual monitoring program. These wells are
shown on Figure 1.
Table 1. Monitoring Wells Sampled as Part of Monitoring Program
Well ID
M14013
M14014
M14015A
PZ2B
PZ5C
PZ6A
PZ6B
PZ6C
PZ11A
PZ11B
PZ11C
PZ12A
PZ12B
PZ12C
PZ13A
PZ13B
PZ13C
PZ14A
PZ14B
PZ14C
PZ15A
PZ15B
PZ15C
PZ16
PZ17
PZ18
PZ19
PZ20
PZ21
WT02A
Depth Interval
Shallow
Damaged
Middle
Deep
Deep
Intermediate
Deep
Deep
Shallow
Intermediate
Deep
Shallow
Intermediate
Deep
Shallow
Intermediate
Deep
Shallow
Intermediate
Deep
Shallow
Intermediate
Deep
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Diameter
Unknown
Unknown
Unknown
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
2 inch
Material of
Construction
Unknown
Unknown
Unknown
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
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3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
CRITERIA
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The remedial actions were conducted as prescribed in the ROD and BSD. The following are goals for the
remedy:
Control risks posed by ingestion of or dermal contact with groundwater and soils.
Capture and treat the contaminated ground water.
Treat the principal threat (soils) in accordance with risk based requirements as promulgated in the
1994 Natural Resource and Environmental Protection Act, PA 451 Michigan Department of
Environmental Quality (MDEQ) Part 201.
Prevent or minimize further migration of contaminants from soil source materials to the
groundwater (source control).
Prevent exposure to contaminated groundwater above acceptable risk levels by preventing
consumption of groundwater on the site and preventing the contaminant plume from reaching
drinking water wells.
Prevent or minimize further migration of the contaminant plume by removing the affected water
for treatment.
Implement institutional controls
The duration of the final remedy was estimated to require 10 years to meet cleanup standards detailed in the
ROD.
3.2 TREATMENT PLANT OPERATION GOALS
The treatment plant goals are generally consistent with the final cleanup criteria specified in the ROD and
have been consistently met. These include:
Meet permit equivalent discharge standards to Little Black Creek as identified in the ROD.
Operate the extraction and treatment system safely and effectively with minimal down time.
The average VOC plant influent concentration identified over the operating period from plant startup in
July 2002 to the present has been at or below discharge standards. The system was originally designed to
remove a VOC concentration of nearly 400 ug/L. A permit equivalent was issued for the plant water
effluent which included the metals standards as well as VOC's. Since startup VOC levels have been below
discharge criteria making the corresponding VOC treatment units unnecessary. Even though the
concentrations of VOC's are below discharge standards, best available technology (BAT) requirements for
the minor concentrations of VOC's in the influent must be complied with, according to the MDEQ Grand
Rapids District. The concentrations of metals continue to be well above discharge standards. In order to
eliminate the need to operate the VOC removal processes, the RPM investigated and approved connection
to the Muskegon County Wastewater Treatment Facility. Connecting to the Muskegon Regional Treatment
Facility (MRTF) will reclassify the treatment facility from a point discharge permitted facility to a
pretreatment facility. Due to this reclassification the VOC treatment components can, and were shut down
in August 2005. A review of the MRTF pretreatment standards reveals the groundwater extracted from the
well field could be discharged directly to the MRTF without pretreatment.
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3.3 ACTION LEVELS
The action levels for the primary contaminants of concern are the cleanup criteria specified in the Proposed
Plan and ROD. The soil cleanup criteria as amended by the August 1997 BSD are as identified in Table 2.
Applicable Federal and State groundwater cleanup levels and principal contaminants are also identified in
Table 2.
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Table 2: Site Groundwater Cleanup and Discharge Criteria
Parameter
INORGANIC
Aluminum
Antimony
Arsenic
Barium
Cadmium
Chromium III
Chromium VI
Lead
Mercury
Nickel
Silver
Thallium
Zinc
Cyanide
Phosphorus
Groundwater
Cleanup
Criteria
ug/L1
50
3
0.2
2,000
4
7,000
2
5
2
57
0.1
0.5
~
4
-
Influent
Concentration
GWTP ug/L
Design2 Actual3
43
<4
<2
55
1460 74i
26 9
12
1 <2
0.5
201 25
<3
^T
1080 99
0 35
198 NA
Discharge Criteria
To Creek4 To POTW5
Monthly
ug/L Ave ug/L
12 2,840
(total) 7,870
15
160 466
300 3,440
572
720 9,050
7 245
0.5 17,300
Ecotoxicity
Chronic
Screening Levels6
EPA Reg 4 (ug/L)
87
160
NV
NV
0.66
117.32
11
1.32
0.012
87.71
0.012
4
58.91
5.2
NV
RBC's/PRG Levels7
(Hg/L)
EPA Reg 3 EPA Reg 9
(tap water) (tap water)
NV 36,000
15 NV
0.045c 0.045 c
7300 2,600
18 18
55,000 5,500
110 110
NV NV
NV 11
730 730
180 180
2.6 2.4
11,000 11,000
730 730
NV NV
Soil Cleanup
Criteria
mg/kg8
150
10.7
30,000
210
69,000
180
400
130
960
350
28
9300
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Table 2: Site Groundwater Cleanup and Discharge Criteria
Parameter
ORGANICs
Benzene
Chloroform
1, 1 Dichloroethane
1, 2 Dichloroethane
1, 2 Dichloroethene
Ethyl Benzene
Toluene
1, 1, 1 TCA
TCE
Vinyl Chloride
Xylene
TSS
BOD
pH
Dissolved Oxygen
BTEX
Groundwater
Cleanup
Criteria
ug/L1
1
6
700
0.4
30
100
117
3
0.2
59
Influent
Concentration
GWTP ug/L
Design2 Actual3
23 ND
ND
75 ND
ND
NA
ND
ND
ND
240 ND
10 ND
NA
NA
NA
NA
NA
NA
Discharge Criteria
To Creek4 To POTW5
Monthly
ug/L Ave ug/L
5
5
5
3
500,000
300,000
6.5
4,000
20
Ecotoxicity
Chronic
Screening Levels6
EPA Reg 4 (ug/L)
53
289
NV
2000
NV
453
175
528
NV
NV
NV
NV
NV
NV
NV
NV
RBC's/PRG Levels7
(Hg/L)
EPA Reg 3 EPA Reg 9
(tap water) (tap water)
0.34 c o 35 c
0.15 c O17c
900 810
0.12 C oi?c
55 (cis)61
1,300 1,300
2300 720
1700 3,200
0.026c i 40 c
0.015c 0.020 c
210 NV
NV NV
NV NV
NV NV
NV NV
NV NV
Soil Cleanup
Criteria
mg/kg8
78
270
13,000
25
6,700
11,000
3,100
160
1.2
130,000
Notes: All values are micrograms per liter (|ig/L).
'Table 7 ROD Peerless Plating Superfund Site, Muskegon, MI, September 21, 1992
2 O&M manual CRA April 2000
3 Calculated from Quarterly Data for a flow rate =120 gpm
4Final Design Report Rerouting Effluent Discharge to the Sanitary Sewer March 29, 2005 Inorganics (Monthly Ave) Organics (Daily Max)
5 Issuance of Wastewater Discharge Permit to Peerless Plating Superfund Site by the County of Muskegon August 2, 2005 Max Flow Rate 185 gpm, minimum pH = 5.0
6 Region 4 Screening Values, November 30, 2001
7Region 9 PRG's, October 2004; Region 3 RBC's, October 2005 both reflect HI = 0.1 or 10'6 Increased Cancer Risk
8ESD 1 to ROD Peerless Plating Superfund Site, Muskegon County, MI, August 7, 1997
MCL = Maximum Contaminant Level NA = Not analyzed NC = Not calculated NV = No value given AL = Action Level
c = carcinogenic risk
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4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE
VISIT
4.1
4.1.1
GROUND WATER EXTRACTION AND INJECTION SYSTEM
WELL CONDITION
The extraction wells appear to be operating satisfactorily, with the possible exception of EW-2. Table 3
presents the typical flow rates for the wells and the concentrations of select metals measured from each
well. Note that influent concentrations for these metals have not fluctuated significantly over the past
several years.
Table 3. Recent Extraction Well Flow Rates and Concentrations
Well
EW-1
EW-2
EW-3
EW-4
EW-5
EW-6
Ave. Flow
Rate, gpm
8/051
26
16
23
17
39
15
Ave. Flow
Rate, gpm
11/042
27
26
24
14
33
16
Cone (ug/L), November 04
Cadmium
123
298
275
308
301
24
Nickel
10
16
32
29
33
13
Zinc
41
85
181
132
59
21
From daily log sheets prepared by the operator.
2From Nov 2004 Groundwater Monitoring Report
Wells EW-3, 4, 5 were throttled at the time of the site visit, but EW-3 and -4 were soon to be fully opened
as they were recently cleaned. EW-5 is normally throttled and is consistently the best producer. The
piping from EW-4 was 50% occluded before recent cleaning using acid recirculation. Fouling materials
have also been found in flow meters for the wells. Well EW-2 was showing a decline in pumping rate and
will need rehabilitation. The wells are rehabilitated when a drop in production rate is noted. Rehabilitation
is conducted about once a year for some wells. Samples of the material fouling EW-1 and -2 were black.
The material fouling in EW-3 and -4 is more of a reddish brown color. EW-5 has not yet needed
rehabilitation. Rehabilitation consists of pulling the pump from the pitless adapter, cleaning the pump,
pressure washing the discharge lines, applying a mixture of "special acid" and dispersants, and brushing
and surging. The well contractor that conducts the cleaning has done this at the Bofors Nobel Superfund
site. There are no level monitors in the extraction wells, so dynamic water levels can not be determined.
Measurements of the dynamic level would assist in assessing well performance through calculation of well
specific capacity.
4.1.2
PLUME CAPTURE AND REMEDIATION
Total flow from the extraction system is approximately 140 gpm. Individual well flow rates as of August
2005 are shown in section 4.1.1 above.
Based on the available information, the hydraulic conductivity of the aquifer is on the order of 0.026
cm/sec (75 ft/day) and the hydraulic gradient is 0.013 (November 2003 Monitoring Report). Based on an
average extraction rates, a range of capture zone widths of 50 to 125 feet is calculated (see I = lendix
[DJBi]A) for the various extraction wells. The plume is over 400 feet wide, measured alongK line of the
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extraction wells. The full width of the plume is not completely defined and the plume likely turns
southward near the stream. In most cases, it is likely the current extraction flow rates are adequate to
capture most of the known plume, with the possible exception of an area between EW-2 and EW-3 near
PZ21. In this area, the predicted capture zones would not overlap. Flow rates of 25 gpm or more from
EW-2 are likely required to assure capture (recent flow rates are less than 20 gpm). The capture zones for
the extraction wells may extend back to Little Black Creek, though the calculated distances to the down
gradient stagnation points for the wells are less than the distance between the wells and the creek. Any
contribution from the creek to the extraction flow would diminish the capture zone widths.
Contours of the water level data generally support the capture zone analysis described above. Apparent
composite cones of depression are evident around EW-1 and -2, as well as EW-3 and -4. The water levels
around PZ21 suggest a potential gap in the composite capture zones for the surrounding wells. The impacts
of the high extraction rate from EW-5 are not apparent in the piezometric contours due to a lack of nearby
piezometers; however, plume capture would probably be achieved without the use of EW-4 due to the large
extraction at EW-5.
Note again that the leading edge of the plume south of EW-6 may not yet be defined, nor is the extent north
of PZ18. Concentrations in these outlying areas are probably low, but above the cleanup goals. It is likely
these outlying areas are not captured by the existing extraction system.
4.2 TREATMENT EQUIPMENT
4.2.1 Am STRIPPER AND CARBON OFF GAS TREATMENT
Water from the six 2-inch diameter extraction well lines is combined into a 4-inch diameter header that
discharges directly into the top of the tray air stripper. The flow from the extraction wells is measured in
each of the force mains prior to discharging into the header. Well pumps are not controlled automatically.
Flow and draw down levels are controlled manually.
The air stripper is a Carbonaire Stat 180 tray type stripper with 6 trays designed to operate a water flow rate
of up to 165 gpm and an air flow rate of 650 cfm. The primary contaminants designed to be removed by the
stripper included benzene, 1, 1 DCA, and TCE at expected concentrations of 23, 75, and 240 ug/L. The
system draws ambient air through the stripper by the blower. The organic laden air then exits the top of the
stripper and passes through 2 vapor phase granular activated carbon units designed to remove the organics
prior to final discharge to the environment via a stack through the roof. The concentration of organic
constituents has been below discharge standards since the plant began operations in 2002. The MDEQ
requires the treatment facility comply with the best available technology (BAT) requirements since the
permit equivalent requires organics treatment. The air stripper and GAC off gas treatment systems were
taken out of service when the plant discharge was routed to the Muskegon Regional Treatment Facility in
August 2005.
Water exiting the stripper flows by gravity to a wet well that pumps the water to subsequent units. The
wet well also receives water from the building sump, filter press filtrate, and the filter press area wash
down sump.
4.2.2 REACTOR TANK
Water from the wet well is pumped via a variable speed pump to the 5000 gallon fiberglass reinforced
plastic (FRP) reactor tank Rl, where the metals containing groundwater is subjected to aeration and
chemical additives to enhance precipitation of target metals. Pumping rate is based on the level within the
wet well. The metals that require removal include cadmium, chromium, nickel and zinc. The reactor tank
has a 30 minute residence time. Chemicals added to the reactor tank include lime and ferric sulfate.
Sludge from the clarifier is also recycled to the reactor tank to enhance sludge characteristics. Aeration is
intended to enhance the conversion of the ferrous sulfate to ferric hydroxide which serves to co precipitate
and adsorb heavy metals present in the groundwater. Aeration flow rate is manually adjusted. Lime is
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added to adjust the pH to a level which optimizes the removal of cadmium. Based on the operators'
experience, the optimum pH is manually adjusted to approximately 10.3.
4.2.3 RAPID Mix, FLOCCULATION TANK AND CLARIFIER
Water from the reactor tank flows by gravity to the clarifier. The clarifier consists of 3 compartments, a
rapid mix tank with a detention time of 1.5 minutes, a flocculation compartment with a detention time of
9.7 minutes, and the clarifier tank. Polymer is added to reactor tank effluent in the rapid mix tank, and the
precipitated particle formation enhanced through gentle mixing causing antiparticle collisions which result
in larger particles that are more readily settled in the clarifier. The clarifier provides a detention time of
approximately 30 minutes. Sludge is recycled to the wet well prior to the reaction tank to enhance floe
formation in the processes upstream of the clarifier. The operator indicated the clarifier is the size limiting
component within the treatment facility. Excess sludge is wasted to either of 2 sludge thickening tanks
where solids content is increased as liquid is decanted back to the wet well along with the filtrate from the
filter press. Controls are adjusted manually for mixer speeds, sludge cycle pumping and diverter valves
along with the rake drive. Detention time in the flash mixer is appears to be adequate, generally 30 seconds
to 2 minutes of detention time is common for this type of application. The flocculation tank provides
slightly less than 10 minutes of detention time for the floe particles to agglomerate prior to clarification at
the plant design flow rate. Generally 30 minutes is considered to be adequate time for flocculation to occur
prior to discharge to the clarifiers. The limited detention time and potential for short-circuiting in the
mixing/equalization tank might compromise floe formation in the unit. The mixer design within the mix
tank is not optimum for flocculation to occur. The gravity settler has an overflow rate of 0.25 gpm/sf at the
design flow of 165 gpm which is generally recommended for these types of applications. The overflow
rate should be designed to assure the small floe particles have ample settling time in the units, generally
recommended near 0.25 gpm/sf. Flow from the clarifiers is directed by gravity to the effluent holding tank
T-2.
4.2.4 BAG FILTERS AND CLEAR WELL
Following discharge from the clarifier into tank T-2, the effluent is pumped through 2 vessels in series each
containing 8 filter bags. The 50 micron bags are designed to remove solids that could carry over the
clarifier exceeding the NPDES total suspended solids (TSS) limit to the Little Black Creek. Pressure loss
over the filters ranges from 13 psi when clean, to 25 psi when they require change out. Filtered water is
discharged to the 1500 gallon clear well after being metered. The clear well is a mixed tank where the final
pH is adjusted to approximately 8.0 using sulfuric acid. The tank is provided with an overflow that allows
the treated water to gravity flow to the Little Black Creek. The effluent line is equipped with a composite
sampler. If the pH in the clear well rises to 8.9, the control system is programmed to shut the plant down.
4.2.5 SOLIDS HANDLING, FILTER PRESS
The solids handling system consists of two cone-bottom, 7500 gallon sludge thickening tanks, a 15 cubic
foot recessed plate and frame filter press, 1500 gallon filtrate tank, and associated equipment such as
compressed air supply, pumps, and sludge roll off. Sludge from the clarifier is pumped either to the
thickening tanks, or recycled to the wet well upstream of the reactor tank. The sludge pump is programmed
to waste sludge to the thickening tanks approximately 20% of the time and recycle sludge to tank T-l
approximately 80% of the time. An average of one press cycle per day results in approximately 9 tons of
(F006 Plating) waste that requires disposal every 2 weeks. The thickening tanks were designed to have
adequate capacity to hold sludge for three days allowing the system to operate over a weekend without
pressing sludge. Filtrate from the press cycle, as well as process water decanted from the sludge thickening
tanks are routed to the filtrate tank (T-4) and recycled back to tank T-l. Estimated sludge solids of 4% is
extracted from the clarifier, and a final cake containing 25 - 30% solids is produced by the press operating
at a maximum feed pressure of 100 psi.
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4.3 MONITORING SYSTEM AND PROGRAM
4.3.1 GROUND WATER MONITORING
The sampling program consists of semi-annual events in May and November. Each sampling event
includes a comprehensive round of water level measurements. The results for May 2005 had been received
but the report was still being prepared as the time of the site visit. Apparently, the Substantive
Requirements Document (SRD) for the site has a requirement for quarterly sampling after three years of
system operation, anticipating that the system would be close to shut down. The project team does not see
a need for this given that the metals concentrations remain high. It is not clear if the permit requires all
monitoring points and extraction wells to be sampled quarterly. The analytical results are provided to
Tetra Tech in Adobe Acrobat and Excel format, but Tetra Tech manually enters the data into the tables in
the reports.
The state had recently installed 17 additional monitoring points, primarily down gradient and side gradient
of extraction wells EW-1 through -4. Additional points were added near EW-6 to assess adequacy of
capture. Three new piezometers near EW-6 did not yet have protective casings, but were locked.
Sampling at the site has been done by Tetra Tech staff. In the past, both standard "bail and sample" and
"low-flow" methods have been used by different crew members during the same round. One crew member
would use the peristaltic pump for low-flow sampling while another person purged another well by bailing.
The methods used for a specific well were not consistent from round to round and are only documented on
field forms now residing in Tetra Tech files. Even the low-flow purge volume was based on a goal of
removing three well volumes (casing and screen, not including filter pack) rather than geochemical
parameter stability. The field crew monitors pH, temperature, conductivity, turbidity, and dissolved
oxygen and will continue purging beyond three volumes if the parameters have not stabilized. "Stability"
is determined qualitatively.
Turbidity values are highly variable (due to the various sampling methods) and there is some apparent
correlation between turbidity and metals concentrations. The field crews have not observed a tendency for
the monitoring points to silt in, though they sound the bottom of the well before sampling. The bottles used
for the samples are pre-preserved with acid. The acid would likely leach metals from the suspended clays
and increase observed metals concentrations.
In the May 2005 sampling round, they rented two peristaltic pumps and did not use a bailer. The Tetra
Tech staff said this slowed them down since the peristaltic pump takes longer than bailing to remove 3 well
volumes.
4.3.2 PROCESS MONITORING
Process monitoring to assess the performance of individual treatment components is not routinely done at
the plant. Monthly influent and effluent sampling required by the permit as well as parameters such as pH,
pressure, flow and temperature are monitored as necessary for automatic system component control.
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4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY
OF MONTHLY COSTS
Based on information provided by the remedial project manager, the contractor bid for operating and
maintaining the system is approximately $440,000/year. This includes labor, utilities, materials, sampling
and analysis, repair, and fees. Approximately 28% of the annual cost is routine operator labor. The one
operator is employed full time (40+ hours/week) on this system. This labor includes routine plant operation
and maintenance and data entry. Project management costs are approximately $7,300/year. Consumable
reagents cost approximately $27,000 per year or about 6% of the annual costs. Disposal costs are about
$2,400/year. Ground water sampling is reported to cost approximately $7,500 in labor (though this seems
low given that the sampling is done with a crew of three people over five days twice a year). Analytical
costs (including sampling equipment) for ground water, vapor, and treatment plant process samples are
approximately $10,000/year. Costs for utilities include approximately $16,000/year for electricity, and an
additional $ 14,000 for water, gas, and phone service. This is about 7% of the total site costs.
Subcontracted services, shipping, parts, and repair are almost $239,000/year. No breakdown is provided
for these services and materials. Significant savings can be realized by cost reductions in labor, materials,
repair, and utilities.
To summarize recent annual costs:
Labor $135,000
Expendable Materials $27,000
Chemical Analyses $10,000
Utilities $29,000
Disposal $2,400
Repairs and Other Services $238.000
Total $440,000
4.5 RECURRING PROBLEMS OR ISSUES
4.5.1 WELL ISSUES
Biofouling appears to be the only consistent issue with the extraction wells. The problem appears to be
adequately addressed through the use of preventative maintenance and good rehabilitation techniques.
4.5.2 EFFLUENT EXCURSIONS
Since plant start up there have been two situations that have occurred resulting in the effluent discharges
that exceed the NPDES permit equivalent limits. In both circumstances, the polymer feed system failed
causing carryover of metals precipitated floe, too fine to settle properly, discharging to the Creek. The
polymer system was modified following the second failure and has functioned without incident ever since.
4.6 REGULATORY COMPLIANCE
As stated previously, the plant operating under its current configuration has consistently met the permit
equivalent discharge standards except as noted in paragraph 4.5.2. A series of whole effluent toxicity
(WET) tests were required by the DEQ to ensure the plant discharge was not harmful to stream biota. The
treatment plant was not allowed to discharge following two unsuccessful tests which resulted in long
periods of down time in 2004. Multiple WET tests were performed in 2005 prior to being successful, but
the DEQ allowed the plant to continue operating following the first unsuccessful test. Connection to the
MRTF will eliminate this problem from reoccurring.
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4.7 ACCIDENTAL CONTAMINANT RELEASES
There have not been any unscheduled releases of extracted ground water.
4.8 SAFETY RECORD
The facility has a commendable safety record with no lost-time accidents reported during the operation of
the remediation system. According to a plant records, there has not been a lost-time accident since plant
startup in December 2002.
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
Based on the sampling of monitoring and extraction wells since system start-up, it appears that the extent of
the full ground water plume is undefined and, therefore, the ground water extraction system is likely not
currently containing the plume as defined by the cleanup goals (e.g. 4 ug/L for cadmium). The plume
extent north of PZ19 is the primary uncertainty. Though the system is largely containing the on-site
portion of the plume, there is a potential gap in the containment between EW-2 and EW-3 in the vicinity of
PZ21. There are no users of ground water in the vicinity of the site, but ground water likely discharges to
Little Black Creek.
The rate of improvement in ground water contaminant concentrations has not been as expected.
Concentrations of metals in ground water are generally stable. The ground water contaminant plume will
persist for significantly longer than several years under current conditions. The potential risk posed by the
plume will remain for the foreseeable future.
5.2 SURFACE WATER
The plant formerly discharged into Little Black Creek which in turn empties into Mona Lake. There are
concerns that heavy metals, especially cadmium, may be impacting water quality in the lake. Although
discharge standards were very low, eliminating the discharge to the stream will eliminate the perception
that the treated ground water discharge is contributing to metals contamination in the creek and Mona Lake.
There is a possibility of contaminated ground water discharging to Little Black Creek, especially north of
EW-1. Concentrations and volumes of contaminated ground water discharging to the creek are likely to be
small, so the impact is not highly significant, but may be of concern to ecological receptors.
The effluent does not contain metal or VOC compounds at levels that pose a health risk. Based on the
EPA Region IV ecological screening levels listed in Table 2 and the effluent concentrations, cadmium may
exceed chronic ecotoxicity levels if treatment is not successful in reducing the concentration to very low
levels, less than 1 u/L. Zinc could potentially be of concern if the treatment effectiveness was less than
50%, which has not been the case. Rerouting the discharge from the creek to the MRTF will eliminate
concerns that cadmium and zinc present in the treated water discharge will result in creek contaminant
concentrations above chronic ecotoxicity screening levels.
5.3 AIR
There are currently no unacceptable impacts on air quality due to the operation of the plant. Vapors are
treated via vapor-phase carbon. An analysis of the groundwater since the plant startup reveals that the
VOC concentrations in the influent are below discharge standards. The local Michigan Department of
Environmental Quality (MDEQ) District requires compliance with the BAT as part of their permit.
Following connection to the MRWF the VOC treatment components were shut down.
5.4 WETLANDS AND SEDIMENTS
There are no wetlands downstream of the facility, or sediments in the downstream creek area that are
further impacted by remediation activities. By eliminating the groundwater discharge and direct discharges
from the plating facilities, the metals concentrations in the creek downstream of the site have decreased.
The site remediation did not address contaminated sediments within Little Black Creek. Concern has been
expressed pertaining to the sediments and water quality in Little Black Creek and Mona Lake located down
17
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stream of the site. A number of potential sources of contamination exist within the drainage basin.
Contaminants similar to those present at the Peerless site, though from undefined sources, have been found
historically in creek sediments up gradient of the site. Since the RSE site visit, the Michigan DNR has
taken sediment samples from Little Black Creek upstream, downstream and in the reach adjacent to the
Peerless site. EPA and the Michigan DNR are at the time of this writing, in the process of evaluating that
data to determine the appropriate actions to take if any, in the Little Black Creek sediments.
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6.0 RECOMMENDATIONS
6.1 RECOMMENDATIONS TO ENSURE EFFECTIVENESS
6.1.1 GROUND WATER EXTRACTION AND INJECTION WELL PERFORMANCE
The extent of the plume may not be currently fully defined, particularly to the north. In addition,
northernmost monitoring point PZ18 appears to have a modest increasing trend in concentrations of Cd, Ni,
and cyanide. Additional monitoring points located north of the existing monitoring well are necessary to
define the northerly extent of the plume. Assuming the extent of the plume is confirmed to extend beyond
the capture zone of extraction EW-1 and that the agencies desire to capture the full extent of the plume
above the cleanup goals, either an additional extraction well north of EW-1 or increased pumping from
EW-1 will be needed to assure capture of the full plume in that area. The increase in extraction could be
somewhat offset by a reduction in the pumping rate of EW-5 or EW-4. The design of any new extraction
well(s) would best be conducted following additional delineation of the plume extent. A case could be
made to allow the plume in this area to continue to migrate without certain capture, given the relatively low
concentrations and lack of human receptors.
The capture zone near extraction wells EW-2 and -3 is potentially inadequate. The feasibility of increasing
pumping from EW-2 and EW-3 should be investigated. If the rates from these wells could be increased by
approximately 25%, more certain capture could be achieved in this area,
The capture zone of EW-5 largely overlaps that of EW-4. Though this increases confidence in the capture
of the plume in this part of the site, this may unnecessarily raise costs for extracted water treatment and/or
disposal. A reduction in the total pumping from extraction wells EW-4 and -5 should be considered. If
EW-5 were used without pumping EW-4, there would be a portion of the plume between EW-5 and the
creek that would not be captured (the capture zone would only extend down gradient a portion of the
distance between the well and the creek). As such, it is recommended that both wells be pumped, but at
reduced rates to offset other increases in pumping discussed above.
There may need to be additional definition of the plume south of extraction well EW-6. Sporadic detection
of contaminants (particularly cadmium and lead) above remediation goals have been identified in
monitoring points PZ16 and PZ17. The concentrations observed in those wells are low, they are within the
capture zone of EW-6, and access is difficult immediately southwest of these wells. The relationship
between the plume edge and the EW-6 capture zone should be further investigated unless the agencies
determine the very low concentrations that potentially exist outside the capture zone are not of concern or
are related to turbidity of the samples. Increased pumpage from EW-6 may be adequate to address the
concern once the plume is fully defined.
6.1.2 MODIFICATIONS TO MONITORING PROGRAM
The primary concern about the monitoring program is the lack of plume definition north of PZ18 and
possibly south of extraction well EW-6, as discussed in section 6.1.1. In addition, there is no real up
gradient monitoring point as all up gradient points (WT-02A and PZ02B) are impacted by low
concentrations of metals. Given the potential for other sources in the vicinity, a true background point
would be beneficial. Additional permanent monitoring points are recommended west of well WT02, north
of well PZ18 and southwest of well PZ16. Another piezometer cluster would be useful near EW-5. The
estimated costs for these new wells are estimated to be approximately $48,000.
In addition, dissolved metals concentrations may be affected by inconsistent sampling methods. If not
already implemented, the sampling procedures must be converted to strictly low-flow sampling in
accordance with the EPA fact sheet on low-flow sampling (EPA/540/S-95/504. April 1996), if this change
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has not already been made. Every effort should be made to reduce sample turbidity to more truly represent
the mobile metals concentrations.
6.2 RECOMMENDATIONS TO REDUCE COSTS
6.2.1 BYPASS REMAINING GROUNDWATER TREATMENT PLANT PROCESSES
Given the low concentrations of many contaminants of concern, in particular VOC's, the discharge from the
plant was rerouted to discharge to the MRTF, which allowed for elimination of the air stripper and vapor
phase carbon treatment system. Given the concentration of the metals undergoing treatment in the plant are
below the pretreatment requirements stipulated in the MRTF permit, bypassing the remaining components
(reaction tank, metals precipitation system, sludge processing equipment) would be a logical next step. The
remediation team has already taken several steps to initiate component shutdown. The RPM has started a
third BSD that identifies a revision in the plant discharge point, and proposes changes in the treatment
requirements within the plant. The RSE team agrees with the RPM that direct discharge to the regional
treatment facility is efficient and cost effective to eliminate the remaining treatment components within the
plant. The RSE team also endorses modifications the operations staff has initiated within the plant in an
effort to reduce costs without impacting BAT requirements imposed by the DEQ. The high capacity 50
micron cartridge filters each costing about $97 each have been replaced with 100 micron bag filters at a
cost of $1 each. The cost difference between a change out every 4 days has been reduced from $776 to $8,
resulting in an annual cost savings of over $70,000 (365/4 x. $768 = $70,080). The operations staff is also
slowly reducing the amount of lime, polymer and ferrous sulfate fed to the system to further reduce costs.
Filter press cycle frequency has remained constant at 1 per day, so disposal costs will remain nearly the
same as before. The unused components could be bypassed by rerouting the existing air stripper feed line
to the clear well in the vicinity of the bag filter housings using new bypass piping, 2 valves, and control
wiring for a flow meter, and critical shut down procedures for the well field and other components as
necessary. Cost for these revisions would cost in the range of $8,000. Control modifications would require
approximately $1,000 for programming since the control system is in place, and no new control
components will be added.
Heat tracing and insulating the components left in service should be investigated to allow for a reduced
temperature, perhaps 40 degrees F, within the facility itself. Added annual cost savings of bypassing the
remaining plant components would include*:
Labor 80%$130K $100K
Chemicals 100%$33K $ 33K
Sludge Disposal 100%$30K $ 33K
Lift Rental 100%$ 9K $ 9K
Electric 75% $ 48K $ 36K
Other Costs 60% $ 27K $ 16K
Total $227,000
*Costs based on First Five Year Review, Attachment 5, September 25, 2002
Savings do not include cartridge filters which were replaced with bags at an annual savings of >$70K
6.2.2 MODIFICATION OF MONITORING FREQUENCY AND ANALYTICAL SUITE
The monitoring program reflects three primary purposes: 1) to define the limits of the plume for capture
assessment, 2) to track changes in concentrations at the sources and along the axis of the plume to assess
progress toward cleanup, and 3) to assess exposures at Little Black Creek. Results of the monitoring are
assessed to determine if other actions (e.g., changes in extraction well flow rates, locations, additional
investigations, etc.) are necessary. The ground water concentrations and thus the exposure scenarios are
unlikely to change rapidly. The sampling frequency for monitoring wells should, therefore, not be more
than semi-annually and could be reduced further. A change to quarterly sampling, as apparently required,
is not warranted and is not necessary for making the necessary site decisions. In fact, some wells could be
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sampled annually (or less frequently) without a significant loss of information. Sampling of WT02A and
PZ02B or the PZ06 cluster could be done annually (or less frequently) and would still provide adequate and
timely information about upgradient conditions or monitor for underflow of contaminant past Little Black
Creek, respectively. Such a change may reduce sampling costs by approximately 10%, discounting the
additional monitoring points recommended in section 6.1.2. Plans, including the definition of the time and
circumstances, should be made to reduce the entire sampling program to annual sampling of the monitoring
wells at some point in the future. This would reduce the sampling costs by approximately 50%.
Note that water level monitoring should continue to be made on at least a semi-annual basis and the results
should be assessed to verify the adequacy of the capture of the plume by the extraction system. The water
levels should be presented in tabular and graphical form in the site reports.
The analytical suite should be reduced to metals and cyanide. Based on the very low detections, the
analyses for volatile organics could potentially be eliminated or at least reduced to once every two or three
years. Further use should be made of electronic data deliverables from the analytical laboratory in
preparing the report tables and figures. This would avoid the potential for errors in transcription and reduce
labor costs for report preparation.
Overall, the recommended changes, including the addition of 7-10 wells discussed in section 6.1, result in a
9-42% decrease in the number of samples per year. If the above changes were implemented the total
annual savings for long-term monitoring of the existing network would be approximately $ 1,500 to
$7,300/year.
6.2.3 REPORTING REQUIREMENTS
Currently, the treatment plant contractor does not prepare any type of operations report regarding the
current state of the treatment plant operations, current and upcoming maintenance issues, changes
proposed, process sampling accomplished, repairs accomplished over the last period, repairs required in the
next reporting period, and so forth. Given the expected /proposed scenario to bypass most of the
remaining treatment units, these items should be incorporated into the groundwater monitoring reports.
6.2.4 LEVEL OF OPERATOR SUPPORT
The operational requirements of the extraction and treatment systems will decrease significantly when the
remaining process units are bypassed. The remaining level of support should be reduced by nearly 80%
(1 day per week rather than 5) as reflected in paragraph 6.2.1.
6.3 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT
6.3.1 INSTALL A DUST COLLECTOR OVER THE FESO4 HOPPER
The operator adds FeSO4 at a rate of 150 - 200 Ibs per day using bagged FeSO4. There is no dust collector
present over the hopper where the bags are broken resulting in a layer of red dust throughout the plant. This
recommendation is contingent on the plant not being shut down as is currently planned. Estimated cost for
this improvement is approximately $4,500.
6.3.2 INSTALL AN ENCLOSURE AROUND THE Am COMPRESSOR
The air compressor is quite loud and generates a good deal of heat, a benefit in the winter, but problematic
in the warm summer months. The unit should be enclosed within a properly insulated space provided with
an external air supply and exhaust to reduce the heat load within the treatment building in the warm season.
Cost for this type of enclosure would be approximately $20,000.
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6.3.3 INITIATE A FORMAL OPERATION AND MAINTENANCE PROGRAM
The site does not have a formal preventative maintenance plan in place. The operations contractor
proposes initiating a formal preventative maintenance, record keeping, spare parts inventory, and process
monitoring program for the plant and well field. The operations staff has many standard procedures that
should be formalized. The RSE team endorses the need for this program, but would recommend the final
scope of the effort be based on results of negotiations with the regulators concerning bypassing remaining
processes in the plant. Costs should be minimal since the number and complexity of procedures will likely
diminish greatly following the anticipated shut down and bypass of most of the treatment equipment in the
plant.
6.3.4 PLACE USED EQUIPMENT ON THE USACE/EPA WEB SITE FOR REUSE
Equipment taken out of service should be made available for use at other sites by posting the pertinent
information on the Used Equipment Web site managed by the Corps of Engineers.
6.4 MODIFICATIONS INTENDED TO GAIN SITE CLOSEOUT
6.4.1 ASSESSMENT OF THE NEED FOR ADDITIONAL TREATMENT OF SOURCE
AREAS
Clearly, the aquifer contaminant plume has not responded to ground water extraction as expected. The
presence of concentrations well above the cleanup standards and the lack of a clear downward trend in
ground water concentrations suggest the duration of the project will be very long. Additional efforts
directed at the removal or stabilization of the metals in the aquifer may be useful for reducing the
concentrations closer to the cleanup goals and shortening the time to site closeout. Additional excavation
of contaminated soil from below the water table, though likely beneficial, would be disruptive to site
facilities, as well as technically difficult and very costly to implement.
An alternative that could be investigated further would be the in-situ stabilization of metals. Both
carbonate and sulfide could bind with the dissolved cadmium and stabilize the metal in low solubility
precipitates. Similar reactions may be possible for lead and nickel. The impact of chemical additives on
the natural geochemistry of both the aquifer and Little Black Creek is not clear. There would likely be
impacts on the aquifer pH and oxidation/reduction potential, depending on the nature of the additives.
Additional evaluation of the appropriate geochemical approach would be necessary and is beyond the scope
of the RSE. The focus of the studies would include the permanence of the stabilization in light of natural
ground water chemistry and the presumably transient impacts to aquifer pH and redox conditions. The
evaluation should also assess the cost implications. The costs for applying the technology should be offset
by avoided operating costs in the future. Present-worth analysis of these avoided future costs will be
necessary to fairly conduct the assessment
The addition of the appropriate reagents could be performed within the footprint of the highest
concentrations in the contaminant plume. Conceptually, the process would include coupled injection of
amended water near the up gradient extent of the high concentrations (west of EW-2 and EW-3) and
extraction of contaminated water at the existing extraction wells for some period of time. Though the
coupled injection and extraction would create a circulation cell that would divert natural flux around the
cell, it would be prudent to maintain higher extraction rates than injection rates to assure capture of the
injected water. Extraction would continue at EW-1, EW-4, EW-5, and EW-6. The costs of three new
injection wells with associated piping were estimated to be approximately $70,000. It was assumed that
chemical feed systems already in place in the existing treatment plant could be modified for addition of the
necessary reagents. This would require the cessation of metals treatment at the plant, as discussed in
section 6.2.1. The feasibility of this would require further assessment.
6.4.2 PERMEABLE BARRIER ALTERNATIVE TO GROUND WATER EXTRACTION.
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The RSE team considered use of an alternative technology to ground water extraction to reduce the
required effort and cost to achieve closure. The placement of a permeable treatment barrier filled with
organic matter parallel to Little Black Creek was considered as a potential alternative for treatment of
metals in ground water prior to natural discharge to the stream. We considered a 230-foot-long trench
excavated to 25 feet below grade (approximately 15 feet below water) and filled with peat or comparable
organic materials. The trench alignment is shown in Figure 2. This would result in a significant reduction
of the flux of metals, particularly cadmium. Bench- and/or pilot-scale testing would be advisable prior to
implementation of such a remedy change. An amendment to the ROD would likely be necessary for such a
change.
There would be a significant reduction in costs for operations for such a barrier system. Though there
would be a slight rise in monitoring required for assessing barrier performance, the treatment costs (or
charges for discharge of treated or untreated water), would be avoided. The capital costs for the barrier
were estimated to be approximately $650,000, including construction of the trench, monitoring points,
design, and oversight. This includes off-site disposal of the displaced soil (some clean excavated soil is
assumed to be replaced in the trench above the peat). This investment would be recouped in a few years by
savings in the treatment costs if the treatment plant operations continue. If treatment ceases and the water
is discharged to the sewer system, the pay-back period for the investment in the trench would be longer.
6.5 Suggested Approach to Implementation of Recommendations
The additional characterization of the plume should be conducted irrespective of other actions at the site.
Similarly, changes to extraction rates of EW-2 and EW-3 to assure capture should also be conducted soon.
The changes to the ground water sampling methods should be done for the next sampling round, if not
already implemented at the site. The proposed change in the monitoring frequency from semi-annually to
quarterly should be critically examined prior to any change in sampling frequency. The reason for the
increase of sampling frequency required by the site documentation is not valid at this time (the site is not
approaching cleanup). The recommended changes to the management of the electronic analytical data from
the lab could also be implemented immediately for easier and potentially more accurate report generation.
The RSE team fully supports the change of discharge point to the sanitary sewer. The recommendation in
section 6.2.1 to bypass metals treatment, as the influent metals concentrations are below the pretreatment
standards for the sewer authority, should be pursued soon in light of all stakeholders concerns. The
potential savings would be significant. The development of a formal operations and maintenance program
recommended in section 6.3.3 should wait until this issue is resolved. If the interim period until shut down
of the metals removal system is expected to be in excess of one year, the recommendations for the dust
collector over the FeSO4 hopper and the enclosure for the air compressor should be pursued. If the metals
treatment is discontinued unneeded equipment can be offered for reuse on the web site listed in section
6.3.4 following decommissioning. Given the unlikely future need for the air stripper, this piece of
equipment could be offered for reuse now.
The changes to the monitoring frequency at selected wells as described in section 6.2.2 should be
considered in the next year. The decrease in sampling frequency at selected existing wells could be
initiated even if the monitoring network is expanded as recommended since the existing wells have a long
sampling history. New wells would require at least semi-annual sampling to assess seasonality and to
establish a good baseline concentration history.
The replacement of the ground water extraction system with a permeable barrier at some point in the future
should probably only be considered if the on-site metals treatment is continued indefinitely. This is a long-
range future change that would require amendment to the ROD, stakeholder acceptance, and verification of
effectiveness.
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The use of in-situ chemical stabilization of metals could be considered as part of a long-term strategy to
shorten time to site cleanup. There is no urgency, but the additional assessment of the potential application
of this approach could begin soon.
6.6 SUGGESTED EXIT STRATEGY
Though the project team is tracking the plume concentrations and adjusting the system operation, there is
not a formal, documented process to compare site conditions to specific interim goals to quantitatively
evaluate progress toward site closure goals. An exit strategy document should be prepared as a means to
provide a consistent decision framework for an evolving project team.
This exit strategy document should describe the basis and considerations for shut-down or restart of an
extraction well or treatment process, set targets for future plume reductions, and identify contingent actions
should capture not be maintained or target reductions go unmet. Extraction wells should be turned off
when the extracted concentrations are below MCLs or when the extracted water does not contribute
substantially to the capture of the plume (other nearby wells may be adequate to capture the plume). Those
responsible for proposing and accepting these changes should be clearly stated. The exit strategy should
consider the impact of various source reduction/treatment options on the longevity of the ground water
remediation and recommend cost-effective actions to treat or contain the source areas (see section 6.4.1).
Periodic assessments of performance by the project team should be outlined in the strategy (e.g., done on
an annual basis and documented in an annual report) and the responsibility for conducting these should be
clearly assigned. The exit strategy should also plan for periodic independent reviews (such as RSEs and/or
five-year reviews) of system performance.
Furthermore, the exit strategy would identify (in the exit strategy document or site sampling and analysis
plan) decision logic for modification of the monitoring program as the plume (hopefully) shrinks. This
would include a clear definition of the monitoring objectives and the basis for adding or excluding
monitoring points, or increasing or decreasing sampling frequency. For the Peerless Plating site the exit
strategy should consider the need to fully characterize the extent of the plume and note the potential need
for additional extraction wells should the extent of the plume requiring capture exceed the reach of the
existing extraction wells.
The strategy should also plan for the tailoring of the treatment processes to the actual extracted
concentrations. For example, if the metals concentrations in the combined influent are similar to current
levels the metals precipitation and filtration processes could be bypassed. The plant may be maintained in
a stand-by mode in the event that metals concentrations spike or if additional source area treatment is
proposed and accepted.
Finally, the exit strategy should identify what constitutes a basis for closure, including monitoring for
concentration rebound. For example, the strategy may indicate delisting would be proposed when all
monitoring wells reach the cleanup goals in two sampling rounds at least six months apart.
These are only suggestions offered as a starting point for the project team. The actual exit strategy must be
determined through consensus building and may require modeling or other studies to actually develop
trigger or target concentrations for the strategy.
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7.0 SUMMARY
The observations and recommendations given below are not intended to imply a deficiency in the work of
either the designers or operators, but are offered as constructive suggestions in the best interest of the EPA
USAGE, and the public. These recommendations obviously have the benefit of the operational data
unavailable to the original designers.
The RSE process is designed to help site operators and managers improve effectiveness, reduce operation
costs, improve technical operation, and gain site closeout. In this report several recommendations are made
with respect to system effectiveness, cost reduction, and technical improvement. The report addresses
potential ways to enhance remediation, reduce costs, improve reporting and data management.
The ground water extraction system is generally operating in a way that achieves containment of the
contaminant plume with the exception of the area near extraction wells EW-2 and EW-3. Pumping rates
from these wells should be investigated to ensure capture is achieved. Conversely the capture zone in the
vicinity of EW-4 and EW-5 overlaps and may be reduced and still obtain capture. Further characterization
of the northern, southern, and western boundaries of the plume is required. Additional extraction may be
needed.
The current treatment plant discharge has been revised from a surface discharge to the Little Black Creek to
the Muskegon County Regional Treatment Facility (MRTF). Potential savings in labor resources and
consumables is significant. Initial charges levied against the EPA by the local sewer board appear to be
well in excess of what is reasonable. The RSE team recommends the EPA RPM and state RPM, along with
the operations contractor meet with the local sewer district and clarify their fee structure. The RSE team
concurs with the revision to discharge to the MRTF and recommends the team continue to pursue the shut
down of the metals removal components within the treatment facility and discharge directly to the MRTF
without pretreatment at significant cost savings.
These and other recommendations are summarized in Table 4 below.
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Table 4. Cost Summary Table for Individual Recommendations
Recommendation
6. 1.1 Evaluation of GW
capture
6.1.2 Modification to
Monitoring Program
6.2.1 Eliminate Several GW
Treatment Processes
6.2.2 Modifications to the
Monitoring Program
6.2.3. Revise Reporting
Reqm'ts
6.2.4. Level of Operator
Support
6.3.1. Install Dust Collection
System over FeSO4 Hopper
6.3.2 Install Enclosure
Around Air Compressor to
Reduce Noise
6.3.3 Initiate a Formal O&M
Program
6.3.4 Place Used Equipment
on USACE/EPA Web Page
6.4.1. Assess Source Area
Treatment Alternatives
6.4.2. Permeable Barrier
Reason
Effectiveness
Effectiveness
Cost
Reduction
Cost
Reduction
Cost
Reduction
Cost
Reduction
Technical
Improvement
Technical
Improvement
Technical
Improvement
Technical
Improvement
Site Closeout
Site Closeout
(Cost
Reduction)
Estimated Change in
^^^^^^H
Capital
Costs
Not estimated:
depends on
model, plume
definition
($48,000)
($9,000)
$0
Not estimated
Reflected in 6.2.1
($4,500)
($20,000)
Not estimated
depends on 6.2. 1
$0
($70,000)
($650,000)
Annual
Costs
$0
Dependent upon
6.2.1
Included in 6.2.2
$218,000
(year 1)
$227,000
(year 2 and
beyond)
$1,500 (min)
Not estimated
Reflected in 6.2.1
$0
$0
Not estimated
depends on 6. 2.1
Not estimated
Not estimated
Not estimated,
could be
substantial
Life-cycle
Costs*
Not estimated, but
there will be
savings due to
reduced duration of
remedy
Included in 6.2.2
$4,531,000**
$30,000 (min)
Not estimated
Reflected in 6. 2.1
$0
$0
Not estimated
depends on 6.2. 1
Not estimated
Not estimated
Not estimated
Costs in parentheses imply cost increases.
* assumes 20 years of operation at a discount rate of 0% (i.e., no discount).
** computed costs do not reflect discharge fees to the MRTF
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