Long-Term Groundwater
    Monitoring Optimization
Clare Water Supply Superfund Site
 Permeable Reactive Barrier and
       Soil Remedy Areas
        Clare, Michigan

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          Solid     and        EPA 542-R-07-010
          Emergency Response    August 2007
          (5203P)              www.epa.gov
Long-Term

         Supply

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                                Notice and Disclaimer
Work described herein was performed by GSI Environmental, Inc., Houston, TX, for the
U.S. Environmental Protection Agency (U.S. EPA) and Parsons, Inc., Denver CO, for the
U.S. Army Corps of Engineers (USAGE). It has undergone technical review by EPA and
USAGE. Work conducted by GSI Environmental, Inc., including preparation of this
report, was performed under EPA contract 68-W-03-038 to Environmental Management
Support, Inc., Silver Spring. Maryland. Work conducted by Parsons, Inc., was performed
under USAGE Purchase Order W9128F-05-P-0041. Reference to any trade names,
commercial products, process, or service does not constitute or imply endorsement,
recommendation for use, or favoring by the U. S. EPA, USAGE, or any other agency of
the United States Government. The views and opinions of the authors expressed herein
do not necessarily state or reflect those of the United States Government or any agency
thereof.  For further information, contact

 Kathy Yager                              Kirby Biggs
 U.S. EPA/OSRTI                           EPA/OSRTI
 617-918-8362                             703-299-3438
 yager.kathleen@epa.gov                    biggs.kirby@epa.gov.
A PDF version of this report is available for viewing or downloading from EPA's
Hazardous Waste Cleanup Information (Clu-In) website at http://clu-in.org/optimization
by clicking on "Application" and then "Long-Term Monitoring." PDF copies also are
available on the Federal Remediation Technologies Roundtable website at
http://www.frtr.gov/optimization/monitoring.htm.

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March 22, 2007
                           Table of Contents
1.0   Project Objectives	1
2.0   Site Background Information	2
      2.1    PRBArea	2
      2.2    Soil Remedy Area	3
3.0   Methods	4
      3.1    Qualitative Evaluation	4
      3.2    MAROS Statistical Methods	5
      3.3    Data Input, Consolidation, and Site Assumptions	5
4.0   PRBArea Results	6
      4.1    Qualitative Reviewforthe PRBArea	6
      4.2    MAROS Statistical Reviewforthe PRBArea	10
      4.3    Recommendations for the PRBArea	11
5.0   Soil Remedy Area Results	12
      5.1    Qualitative Reviewforthe Soil Remedy Area	12
      5.2    MAROS Statistical Review for the Soil Remedy Area	14
      5.3    Recommendations for the Soil Remedy Area	15
6.0   Long-Term Monitoring Program Flexibility	16
7.0   References Cited	16
Tables
Table 1    Summary of Site-Wide Long-Term Groundwater Monitoring Plan
Table 2    Aquifer Input Parameters
Table 3    Qualitative Evaluation of PRB Area Groundwater Monitoring Network
Table 4    Well Trend Summary Results For PRB Area: 1999-2006
Table 5    Well Redundancy Analysis Summary Results For PRB Area
Table 6    Final Recommended Groundwater Monitoring Network For PRB Area
Table 7    Qualitative Evaluation of Soil Remedy Area Groundwater Monitoring Network
Table 8    Well Trend Summary Results For Soil Remedy Area: 1999-2006
Table 9    Final Recommended Groundwater Monitoring Network For Soil Remedy Area
Figures
Figure 1   Groundwater Monitoring Locations: PRB and Soil Remedy Areas
Figure 2a  Approximate Well Screen Intervals for PRB Area
Figure 2b  Approximate Well Screen Intervals for Soil Remedy Area
Figure 3   Qualitative Evaluation Results for PRB Area
Figure 4   Temporal Trend Results: Vinyl Chloride PRB Area
Figure 5   Well Sufficiency Vinyl Chloride PRB Area
Figure 6   Final Recommended Monitoring Network PRB Area
Figure 7   Qualitative Evaluation Results for Soil Remedy Area
Figure 8   Temporal Trend Results: TCE Soil Remedy Area
Figure 9   Final Recommended Monitoring Network Soil Remedy Area
Attachments
A:        Geologic Cross-Sections
B:        MAROS 2.2 Methodology
C:        MAROS Reports
D:        Electronic Database (on CD)
E:        Selected  November 2006 Data
F:        Review Comments and Responses

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                  LIST OF ACRONYMS AND ABBREVIATIONS

|jg/L               microgram(s) per liter
bgs                below ground surface
c/s-1,2-DCE         c/s-1,2-dichloroethene
cm/sec             centimeters per second
COCs              constituents of concern
CUO               cleanup objective
DCE               dichloroethene
DO                dissolved oxygen
DPE               dual-phase extraction
FS                 Feasibility Study
ft amsl              feet above mean sea level
ft/day              feet per day
GSI                Groundwater Services, Inc.
LTM               long-term monitoring
MAROS            Monitoring and Remediation Optimization System software
MCES              Modified Cost Effective Sampling
MCL               Maximum  Contaminant Level
mg/L               milligram(s) per liter
MNA               monitored natural attenuation
MNO               monitoring network optimization
ORP               oxidation-reduction potential
Parsons            Parsons Infrastructure  and Technology Group, Inc.
PCE               tetrachloroethene
PRB               Permeable Reactive Barrier
Progressive         Progressive Engineering & Construction, Inc.
Rl                 Remedial Investigation
ROD               Record  of Decision
TAL               target analyte list
TCE               trichloroethene
USEPA             United States Environmental Protection Agency
VC                 vinyl chloride
VOCs              volatile organic compounds
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           GROUNDWATER MONITORING NETWORK OPTIMIZATION
                        PRB AND SOIL REMEDY AREAS

                   CLARE WATER SUPPLY SUPERFUND SITE

The following  memorandum contains a review of the long-term groundwater monitoring
network for the Permeable Reactive Barrier (PRB) and Soil  Remedy Areas at the Clare
Water  Supply Superfund  Site  in  Clare, Michigan.   The review was a joint effort
performed  by Groundwater  Services, Inc.  (GSI)  of Houston, Texas and  Parsons
Infrastructure  and Technology Group,  Inc. (Parsons) of Denver, Colorado. The current
monitoring  network  in each area was evaluated using a formal  qualitative  approach
(performed by Parsons) and statistical tools  found  in the Monitoring  and Remediation
Optimization System software (MAROS) (performed by GSI).  Following performance of
the qualitative and quantitative evaluations, Parsons and GSI collaborated to derive final
recommendations for the groundwater monitoring  networks  using the  results of the
qualitative and quantitative evaluations.
Recommendations are made for groundwater sampling frequency and location based on
available data pertaining  to current hydrogeologic  and contaminant conditions.  The
report  evaluates the PRB Area and Soil Remedy Area  monitoring networks using
analytical   data  obtained  from   Progressive   Engineering   &   Construction,   Inc.
(Progressive).  PRB Area  data extended from March 1994 to May  2006, although most
wells only had data extending from May  2005 to May 2006.   Soil Remedy Area data
extended from June 1988  to May 2006, although most wells only had data for the period
from March 1999 to May  2006.  Additional data for the PRB and Soil Remedy Areas
collected in November 2006 were received  after the monitoring network optimization
(MNO) evaluation had been completed.   These data were  qualitatively reviewed to
assess any impacts on MNO recommendations,  but were not formally incorporated into
the complete evaluation described in this report. The  November 2006 sampling results
are provided in Attachment E.
1.0    Project Objectives
The goal of the monitoring network optimization (MNO) evaluation for the PRB and  Soil
Remedy Areas is to design monitoring programs that are cost and time efficient as well
as protective  of potential  receptors. The monitoring program should  provide sufficient
data to support site management decisions.   The evaluation  focuses on the following
objectives:
   •   Evaluate  well locations  and  screened  intervals  within  the  context  of  the
      hydrogeologic regime to determine if they  meet  site characterization and decision
      support objectives.  Identify possible data gaps.
   •   Evaluate  overall  plume stability qualitatively and through trend and  moment
      analysis.
   •   Evaluate individual  well concentration  trends  over time for target constituents of
      concern (COCs) both qualitatively and statistically.
   •   Develop sampling  location  and frequency  recommendations  based  on  both
      qualitative and quantitative statistical analysis  results.

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2.0    Site Background Information
Site background information was primarily obtained from 1) the 2005 Annual Monitoring
Report for the  Clare  Water Supply  Superfund Site  (Progressive,  2006), 2) personal
communications with  Progressive personnel, and 3) the draft five-year review report
prepared in 2006 (USEPA,  2006).  The five-year review report states that the site soils
create two different hydrologic regimes within the investigation area.  The first hydraulic
regime consists of a perched water zone created by the low-permeability clay/till unit(s)
in the western half of the site (where the PRB and Soil Remedy Areas are located).  The
second is created by aquifer sand underlying till.  The aquifer  is 20 to 40 feet thick in a
sand  unit beginning  at 30 to  40 feet  below the ground  surface.   In  the western,
industrialized portion of the site, 30 to 40 feet of clay and glacial till overlie the  aquifer.
The inferred goals of the groundwater monitoring program at these two areas are to:
   •   Determine the  combined impact of engineered remedial  measures and natural
      attenuation  on  concentrations of priority  chlorinated  constituents dissolved  in
      groundwater; and
   •   Ensure that groundwater contamination is not posing  unacceptable  risks  to
      potential receptors.
2.1     PRB Area
The PRB groundwater remedy consists of two PRBs in sequence that were installed to a
depth of  17 feet below ground surface (bgs) along the property boundary of the former
Mitchell source area in December 2004 (see Figure 1).  The PRBs are designed to treat
shallow groundwater contaminated with chlorinated volatile organic compounds  (VOCs)
as it migrates through  the treatment walls.  They are reportedly filled with iron-encrusted
foundry sand.
The uppermost 8 to 23 feet  of the soil column in the vicinity of the PRBs consists of sand
backfill material (filling  a  former contaminated  soil excavation) having  a hydraulic
conductivity of approximately 1 x 10"4 centimeters per second (cm/sec). The water table
is  present within  5 feet of the  ground  surface.  The sand is underlain and encased
laterally  by  low-permeability  native material  having a  hydraulic  conductivity  of
approximately 1 x 10"7  to  5  x 10"7  cm/sec (see cross sections from Progressive  in
Attachment A).  The shallow groundwater flow  direction is  inferred to be south  to
southeast, across the  PRBs, based  on hydraulic  potential data.  The groundwater flow
direction  in the deep zone appears to range from  north to east in the vicinity of the PRB
Area,  based on potentiometric surface maps contained in the 2005  Annual Monitoring
Report (Progressive, 2006). A representative groundwater seepage velocity for the site
provided  by Progressive is 0.27 foot per day (ft/day) based on data contained in a Secor
(November 2004) design report. According to Progressive, this seepage velocity is more
representative of the sand backfill than of the surrounding native materials, which have a
relatively low permeability.
According to Progressive, the recent and  historical hydraulic data  suggest a perched
water table  in the vicinity of  the  PRB  and  Soil Remedy Areas.   The remedial
investigation  (Rl)  and feasibility study (FS) concluded  that lateral flow in the perched
water-bearing zone is  possible in some areas, but is likely limited due to seasonal water
table  changes,  and  vertical flow  is possible  through  assumed  (but  not  verified)
desiccation cracks in the glacial till.

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A  drainage channel  (the  U.S.  10  Drainage  Ditch) is located immediately  south
(downgradient) of the PRB Area.  The drainage ditch empties into a small wetlands area
which directly recharges the aquifer in the vicinity of water supply wells MW2 and MW5
(USEPA, 2006).  According to Lithologic Cross Section A-A', transmitted by Progressive
and contained in Attachment A, this ditch is approximately 7 to 8 feet deep with a bottom
elevation of approximately 835 to 836 feet above mean sea level (ft amsl).  However, a
review comment for the draft report submitted by Progressive indicates that the ditch is
only 2 to 3 feet deep with a bottom elevation of approximately 840 ft amsl.  Assuming
that Progressive is  referring to the same ditch, this discrepancy should be reviewed and
the actual  depth of the ditch should  be  confirmed.   Given the shallow  depth  to
groundwater in the  perched zone, it is possible that some groundwater discharge to this
ditch occurs if it is indeed 7 to 8 feet deep.  Progressive reports that the channel is only
seasonally  wetted,  with minimal flow, and even if PRB Area groundwater discharges to
the swale, sampling data indicate that it poses no unacceptable risk to the  downstream
wetland area or to  the water supply wells themselves. Therefore, Progressive reports
that there are no significant receptor impacts related to  PRB Area groundwater.  The
clean-up objective (CUO) for this area is the Michigan ground to surface water criterion
for VC (15  micrograms per liter [ug/L]), as opposed to the US Environmental  Protection
Agency (USEPA) maximum contaminant level (MCL) of 2 ug/L.  However, if groundwater
in  the vicinity of the PRB is found to be in communication with the deeper aquifer used
for municipal water supplies, the MCL would apply.
2.2     So/7 Remedy Area
Soil from the former Mitchell  and ExCello properties was placed on the existing land
surface beneath an engineered cap within the former ExCello property.  A slurry wall
was installed around the cap, and a dual-phase extraction (DPE) system was installed to
treat vapor and groundwater removed from the  contained area.  The soil  remedy was
constructed in 1999, and the DPE system  began operating  in April 1999.  The DPE
system continues to operate on a cyclic basis, with treated water discharged to the local
wastewater treatment plant.
The  area on which the excavated soils were stockpiled was not excavated, but did
contain soils with high concentrations of contaminants to depths up to about 15 to 28
feet bgs. No liner exists beneath the  emplaced  soils. The cap overlying the emplaced
soils (from surface downward)  consists of 1) vegetative cover, 2) a geonet underlain by a
minimum 2-foot-thick soil cover,  and 3)  a low-density polyethylene 40-mil membrane
liner.  The native soils at the original land surface consist of silty sand underlain by low
permeability clay and then low permeability till at varying depths.   Geologic cross-
sections created by Secor  in  2005  and transmitted  by  Progressive are contained in
Attachment A.   The DPE wells are 30  feet deep and  extend  to beneath the silty
sand/clay interface.  The water table in  the shallow wells  installed north of the soil
remedy cell (DMW-1S, -2S,   and  -3S)  in  May and November 2005  ranged from
approximately 8 to  13 feet bgs, a few feet below the bottom  of the emplaced soils and
near the top of the native clay and glacial till.
The slurry wall surrounds the entire cap and reportedly varies  in depth from about 14 to
22 feet bgs (deeper to the north); it extends a minimum of two feet beneath the clay/till
interface. The permeability of the slurry wall (per the design) was to be less than 1x10"7
cm/sec.  Per the Rl report the average hydraulic conductivities are as follows: till 10"7
cm/sec, clay 10"7 cm/sec, silty sand  10"3 cm/sec, and clayey sand 10"5 cm/sec. The
cap/slurry wall does not contain all of the area of soil impacts originally  defined at Ex-
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Cello;  the  area north of the  cap close to  US10 could not be excavated  due  to
utilities/sewers and right of way issues - some impacts remained  in place near DMW-
1S, 2S, and 3S.  Also, one of the DPE wells (EW-13) is located outside the slurry wall to
the south,  potentially due to the presence  of impacted soils that were  left in place,
although the reason is not known with certainty. According to Progressive, there are no
potential receptors for the Soil Remedy Area groundwater.
The groundwater  seepage velocity outside of the soil treatment cell, obtained from
Progressive, is 2.9 x 10"5 foot per day (0.01 foot per year).  This velocity is  based on the
calculated seepage velocity for the vicinity of groundwater extraction well PRP-1  using a
hydraulic conductivity of 2.67 x 10"7 cm/sec reported in the Rl report (Dames & Moore,
1990).  Based  on the  author's professional judgment and experience, this velocity is
likely biased low,  and the  actual  average  seepage velocity at  the site  is  likely
substantially higher.
3.0    Methods
Evaluation  of the groundwater monitoring networks in the vicinity of the PRB and Soil
Remedy Areas  consisted  of  both qualitative  evaluation of site  analytical  data and
hydrogeologic conditions and a quantitative,  statistical evaluation of site analytical data.
These two  methods were combined to  recommend  a final groundwater monitoring
strategy to support site monitoring objectives.
3.1     Qualitative Evaluation
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 groundwater quality 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.  In general,  continuation of  water level measurements in all site
wells to facilitate groundwater flow  direction and hydraulic gradient evaluation  is
recommended.   Typical factors considered in  developing  recommendations to retain a
well in, or remove a well from, a long-term monitoring (LTM) program are summarized in
the table below.
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 years3'
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.
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Once the decision has been made to retain a well in the network, data are reviewed to
determine a  sampling frequency supportive of site  monitoring objectives.   Typical
factors  considered  in developing  recommendations  for  monitoring  frequency  are
summarized below.
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 overtime, 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 overtime, or contaminant levels
have been below groundwater cleanup
objectives for some prescribed period of time
3.2
MAROS Statistical Methods
Statistical methods  in the MAROS 2.2 software were used  along with the qualitative
evaluation of the network to evaluate concentration trends, concentration stability,  and
spatial uncertainty in the PRB and Soil Remedy Areas.  MAROS is a collection of tools in
one software package  that is used in an explanatory, non-linear but linked fashion to
statistically evaluate groundwater monitoring programs. The software includes individual
well trend and plume stability analysis tools, spatial statistics, and empirical relationships
to assist the user in improving  a  groundwater monitoring  network system.   Results
generated from the software tool were  used to develop lines of evidence, which, in
combination with results  of the qualitative analysis, were  used  to  recommend  an
optimized monitoring network for the PRB and  Soil Remedy Areas.  A description of
each tool used in the MAROS software is provided as Attachment B.  For a detailed
description of the structure of the software and further utilities, refer to the MAROS 2.2
Manual (AFCEE, 2003; http://www.gsi-net.com/software/maros/Maros.htm) and Aziz et
al., 2003.
3.3     Data Input, Consolidation, and Site Assumptions
Data for the PRB and Soil Remedy Areas were supplied by Progressive, supplemented
with information from historic site reports. Chemical analytical data were organized by
Progressive  in a database, from which summary statistics were calculated. It should be
noted that the  dataset transmitted by Progressive  was not complete in that not all
historical analytical  data collected  for site  wells  were  included.  A complete set of
historical analytical  results  was not  available  to Progressive when they assumed
responsibility for site monitoring.  Specifically, data for VC and tetrachloroethene (PCE)
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collected prior to May 2005 were not included for most wells. This evaluation assumed
that the missing data were generally non-detect; however, this should be confirmed to
the extent practical and feasible before final changes to the LTM program  are made.
Wells and sampling frequencies in the current groundwater monitoring  program are
shown in Table 1.  Each of the wells listed in Table 1 was considered in the qualitative
evaluation.  Data for 18 wells at the PRB Area (all wells listed in Table 1 except SW-11)
and 9 wells at the Soil Remedy Area (all wells listed in Table 1 except EW-series wells)
were used in the quantitative (MAROS) analysis.
The monitoring wells in each area are grouped into shallow, intermediate, and  deep
categories based on their screen intervals  in the underlying aquifer. Screened intervals
for wells at the PRB  and Soil Remedy  Areas are illustrated on  Figures  2  and 3,
respectively.  All but four of the wells at the PRB area are screened in the shallow zone
near the water table, with the remaining wells assigned to the intermediate (1 well) and
deep  (3 wells)  zones.   In the Soil Remedy Area, the  monitoring wells  are primarily
shallow (4 wells) or deep (4 wells), while the dual-phase extraction wells are classified
as intermediate-depth.    For  both the PRB  and  Soil Remedy  Areas  shallow  and
intermediate groundwater zones were considered together as one two-dimensional slice
for the quantitative evaluation (MAROS). The deep zone was considered separate from
the shallow/intermediate zone.  For the qualitative evaluation, the zones were viewed as
largely independent.
A list of aquifer physical parameters assumed for the analysis is shown in Table 2. Two
screening levels were  identified for concentrations of VC in groundwater at the PRB
Area.   The draft 5-year review report for the  Clare Superfund Site prepared by the
USEPA (2006) states  that The goal of the PRB  installation  "was to degrade  Vinyl
Chloride within  the groundwater to levels below the Michigan Part  201 Ground
Water/Surface Water Interface (GSI) standards or below 15 pg/l before it discharged into
the drainage ditch or otherwise migrates off the former Mitchell  facility property and
enters the water supply aquifer." Therefore, a CUO for VC of 0.015 milligrams per liter
(mg/L) was assumed, while the USEPA  MCL  for VC  of 0.002 mg/L was  used as a
general screening level  for water  quality in the aquifer.   The  USEPA MCL  for
trichloroethene  (TCE) of 0.005 mg/L was  used as a general screening level for water
quality in the Soil Remedy Area, where TCE is the primary COC.  Groundwater seepage
velocities  obtained  from  Progressive  and  discussed in  Section  2.0  were  used.
Groundwater flow directions were inferred from potentiometric surface elevation data
contained in the 2005 annual monitoring report (Progressive, 2006).
4.0    PRB Area Results
The  qualitative  and  quantitative  evaluation results are  discussed  in the following
subsections.
4.1     Qualitative Review for the  PRB Area
   •   Details of the qualitative evaluation are shown on Figure 4  and Table 3.  Wells
      recommended  to be retained in the monitoring program were those that best
      defined the magnitude and  extent of the plume and indicated the VOC removal
      effectiveness of the PRBs.
   •   Most of the monitoring  wells present at  the  PRB Area were sampled quarterly
      from May 2005 to May 2006 (total of five events). After May 2006,  the sampling
      frequency for these wells  was reduced to semiannual,  with  the next event
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      occurring in November 2006.  These wells include 300A and MW-301  through
      MW-313. Wells 220, 300B, and 300C have been sampled semiannually and were
      not sampled quarterly from May 2006 to May 2006.
   •   A total of five wells were recommended for exclusion from the monitoring program
      because the qualitative evaluation determined that additional sampling would not
      provide  useful  information.    A  reduction  in  the  sampling frequency  was
      recommended for an additional two wells (MW-312 and MW-313).  The rationale
      for the sampling frequency reductions is provided on a well-specific basis in Table
      3.
   •   In  general, a semiannual sampling frequency  for most  wells is  recommended
      because 1) at least six monitoring events have been performed at each well as of
      November 2006, including five quarterly sampling events for  the most recently
      installed wells  (MW-301  through  MW-313), providing  a baseline to assess
      temporal trends and  observe any seasonal  variations  in  concentrations;  2)
      increasing concentration trends were not observed for  most wells; 3) reducing
      sampling frequency would not endanger potential  receptors based  on available
      information;  and 4) semiannual  monitoring  will still  provide  sufficient  data to
      assess the effectiveness of the PRBs and determine temporal trends qualitatively
      and/or statistically.
   •   The  available data indicate  a high degree of  vertical variation in  contaminant
      concentrations over  short distances at some  locations, even within what is
      identified as sand backfill material on Cross-Sections  A-A' and B-B' provided by
      Progressive (see Attachment A).  For example,  total combined concentrations of
      TCE+c/s-1,2-dichloroethene  (DCE)+VC at vertical profiling borehole VAS-301
      (Figure 3) varied from 2 ug/L at 8 to 10.5 feet bgs to 2,040 ug/L at 10.5 to 13 feet
      bgs,  a  total vertical distance of only five feet.   Similarly, VC concentrations at
      VAS-302 decreased by an order of magnitude from 870 ug/L from 7.5 to 10 feet
      bgs to 90 ug/L from 10 to 12.5 feet bgs.  It  appears that the vertical profiling data
      were used to select well screen intervals. However, the groundwater quality data
      obtained from the subsequently-installed wells  at the same location sometimes
      vary  significantly in magnitude from the vertical profiling data.  For example,  the
      VC concentration in MW-302 in  May 2005 was 99 ug/L, compared  to vertical
      profiling concentrations in the same depth interval of 1,010 to 1,700 ug/L in VAS-
      301 (January 2005).  Therefore, the wells may not always be accurate indicators
      of maximum VOC concentrations  present in the  shallow aquifer. The only way to
      achieve better resolution  would be to have  multiple  short,  discrete screens at
      various depths at a given location.
   •   The target  analyte list (TAL)  for the PRB  area includes  VOCs (SW8260B) and
      selected  field  parameters (pH,  conductivity, temperature,  turbidity,  dissolved
      oxygen [DO], oxidation-reduction  potential  [ORP], and ferrous  iron). In addition,
      samples from six wells are analyzed for Michigan 10 metals.  Wth the exception
      of  Michigan 10  metals and ferrous iron, this TAL is reasonably optimized.
      However, the following recommendations are offered:
      o  Discuss optimizing the target VOC list  to a short-list of key contaminants of
         concern  (e.g., chlorinated ethenes) with the analytical laboratory.   Potential
         advantages  include  lower  laboratory analytical costs  and  lower data
         management/validation/reporting costs.  However,  all constituents targeted for
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         analysis  should be entered into the site database for each sampling event.
         Data gaps in the current database create uncertainty in the evaluation of lower
         priority constituents.
      o  Continued  analysis  for ferrous iron  during  every sampling  event is  not
         necessary.  Groundwater from wells MW-301 through MW-313 was analyzed
         for ferrous iron three times in 2005.  Ferrous iron concentrations provide an
         indication of whether iron-reducing conditions are present, which facilitates an
         evaluation  of  whether certain chlorinated VOCs can be  readily  degraded.
         However,  once  ferrous  iron  conditions  are  established,  the  sampling
         frequency can be reduced substantially to at least biennial (every other year)
         to allow periodic remedy evaluations.
      o  Delete Michigan 10 metals analysis based on the August 2005 metals data.
         There was only one very slight exceedance of an MCL (arsenic of 0.011 mg/L
         at MW-311 compared to MCL of 0.01 mg/L).
   •   In general, hydraulic monitoring for all wells located within the area of interest and
      screened within the depth  zones of interest is  recommended to  maximize the
      accuracy of  potentiometric surface maps.  This recommendation is based on the
      observation  that measurement of water levels in  monitoring  wells is  generally
      relatively fast and inexpensive relative to water quality monitoring, and provides
      very  important site  characterization information.    However,  if  multiple wells
      screened at similar  depths are clustered  in  a small area  and have similar
      groundwater elevations, one or more could be considered  for removal from the
      hydraulic  monitoring   program  unless   more  detailed  delineation  of  local
      groundwater flow  patterns is desired.  At least two  years of quarterly hydraulic
      monitoring is recommended to determine seasonal impacts  on the potentiometric
      surface  in  the vicinity  of  the  PRB Area.   After  that,  semiannual  hydraulic
      monitoring during relatively wet and dry times (e.g.,  spring and fall, concurrent
      with the groundwater sampling events) should be  sufficient unless the quarterly
      monitoring  results indicate  significant seasonal  variability  that  needs to  be
      monitored more frequently.   Hydraulic monitoring  of all wells at the PRB area is
      recommended.
   •   The  following  potential  data gaps  were  noted  during  performance  of  the
      qualitative evaluation  for the PRB Area.   They should be reviewed with the
      objective of verifying whether or not the current level of plume definition is
      acceptable in terms of 1) risks posed to potential receptors and 2) estimating the
      time and cost to achieve CUOs in groundwater.
      o  The  downgradient  extent  of  the VOC  plume  is  not well  defined.   VC
         concentrations in  the most downgradient wells  in May 2006 ranged up to 58
         ug/L (well MW-308); in November 2006 the VC concentration in this well  had
         decreased to  20 ug/L.   VC concentrations that exceed  the  cleanup  goal
         appear to be  bypassing the PRBs in the shallow zone, as indicated by VC
         concentrations detected at MW-310 (21 to 27  ug/L  in  May and  November
         2006).   There are  no wells  installed  that could  be  used  to  define  the
         downgradient  extent of the contamination detected at MW-310  based  on
         inferred  groundwater flow directions for the shallow zone.  A surface water
         drainage channel  borders the site on the south side.  Given the shallow depth
         to the water table  at the site (within approximately 2 feet of the ground surface
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         at MW-308)  and  the  assumed depth  of  the  adjacent  drainage  channel
         (approximately 7-8 feet based on Lithologic Cross Section A-A' in Attachment
         A), it appears likely that some discharge of contaminated groundwater to the
         surface water  drainage  occurs.    However,  information  obtained  from
         Progressive indicates that surface water and other sampling has indicated that
         this potential  exposure pathway is  not  of concern (Personal  communication
         from Bridget Morello, 23 October 2006).
      o  Appropriate sampling should continue to be performed to confirm that surface
         water is not  an exposure/migration pathway of concern that will  result in
         unacceptable   levels   of   risk  to   human  or   ecological   receptors.
         An aerial photograph of the site obtained from the USEPA indicates that an
         areally  extensive,  undeveloped,  partially forested  area is located on the
         downgradient (south) side of the drainage channel.   Any contaminants that
         underflow the drainage channel would  migrate beneath this area.   The
         boundary of the Clare Water Supply Superfund Site is located approximately
         400 feet south of the PRBs. The stakeholders should verify that the current
         level of plume definition is acceptable in terms of risks posed  to  potential
         receptors.
      o  Intermediate-depth well 300B contained 200 ug/L of VC in May 2006 and 140
         ug/L in  November 2006.  This is the only intermediate-depth  well at the site
         and is screened from  approximately 3 to 13 feet below  the bottom  of the
         PRBs.   Therefore, the detected contamination  is likely not  treated by the
         PRBs.   The areal extent and magnitude of contamination in the intermediate
         depth zone is not defined.   Similarly, groundwater quality in the deep zone is
         not well defined, given that there are only three wells screened in this zone at
         the site, one of which is cross-gradient of the plume (well 220) and one which
         is south of the drainage channel (MW-312). Therefore, the vertical extent of
         groundwater contamination is not well delineated.  There  are no deep wells
         installed at the  PRB Area downgradient of  300C, which has  had  recent
         exceedances of the CUO for VC.  In addition, well 300C may be screened in a
         more permeable sand aquifer underlying the till based on geologic information
         presented in Section 2.0. As stated above, the stakeholders should verify that
         the current level of plume  definition is acceptable in terms of risks posed to
         potential receptors and that sufficient data are available to properly  estimate
         the time and cost required to achieve CUOs and site closure.
      o  Although monitored  natural attenuation (MNA)  is  not  part  of the remedy
         specified in the Record  of Decision (ROD; USEPA, 1992), the degree to which
         natural   attenuation   processes   are  reducing  dissolved  contaminant
         concentrations at the PRB Area is of interest because VC  concentrations
         exceeding CUOs  are migrating downgradient from the PRBs, and the PRBs
         are not deep enough to treat all of the CUO exceedances (i.e., at well 300B).
         Therefore, it is desirable to determine the effectiveness of MNA at treating the
         residual contamination in  order  to assess the time and cost  required to
         achieve CUOs and  whether they  can be achieved within  a  reasonable
         timeframe.  Some important natural attenuation indicator parameters that can
         provide insight into the ability of the groundwater system to degrade the  COCs
         are already measured (i.e., DO and ORP).  It should be noted however, that
         the  biogeochemical   nature  of  the  shallow   groundwater  environment
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         immediately downgradient of the PRBs is impacted by the PRBs, and may not
         be representative of the groundwater environment farther downgradient.  The
         Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
         in Ground Water (EPA/600/R-98/128, 1998) provides guidance on evaluating
         the site-specific effectiveness of MNA for chlorinated VOCs.
4.2     MAROS Statistical Review for the PRB Area
   •   The MAROS COC Assessment ranked VC as the priority constituent for the  PRB
      area.  VC was, therefore,  chosen as the  target monitoring constituent for the
      MAROS evaluation. Qualitative consideration was given to cis-1,2-DCE and the
      less frequent detections of TCE and PCE.
   •   Individual well trend analyses for VC were determined in MAROS using analytical
      data collected between 1999 and 2006. Results are illustrated in Table 4 and
      Figure 5.  The  majority  of wells have a  relatively short monitoring record of
      quarterly  samples between May  2005 and May 2006.   Among the 12 wells
      recently  installed in the shallow zone,  roughly half show a stable concentration
      trend.   One well,  MW-306, shows a decreasing trend, while  the others show
      variation in VC concentrations over the recent time frame.  Older wells  300-A,
      300-B and 300-C show increasing concentration trends.
   •   The  total dissolved   mass  estimate  (zeroth  moment) for  VC  showed a
      "Decreasing" trend between 1999 and 2006 for the shallow groundwater zone.
      Recent estimates of total  dissolved mass in the shallow zone range between 0.3
      kilograms  (Kg) in  2005 dropping to 0.2 Kg in 2006.  First moments (center of
      mass) in the PRB area are very stable over the 2005 to 2006 time-frame, as mass
      stays centered on higher concentration wells  near 300A.  However, this time-
      frame is very short. Moments should be reevaluated after a longer data set has
      been collected (4 years  of data).  Moments  for the deep zone could not be
      evaluated due to the small number of monitoring locations.
   •   Spatial analysis  of the VC  plume  using Delaunay triangulation  and slope factor
      calculations indicate that the interior of the plume is well characterized  by the
      existing well  network  and no new wells are  recommended inside the network.
      However, a qualitative evaluation of the plume shows that the downgradient area
      to the south is not delineated to the CUO.  Redundancy analysis indicates that
      locations  MW-301, MW-304 and  MW-305 may be removed from the network
      without loss of information.  The results of the spatial analysis were considered in
      a final qualitative review, and wells MW-304 and MW-305 were  retained in the
      program at a reduced sample frequency.
   •   Results of the MAROS well sampling frequency tool (the Modified  Cost Effective
      Sampling [MCES]  method)  indicate that sampling  frequency for the majority of
      wells in the PRB area can maintained at semiannual.  Results  of the MCES are
      shown in Table  5.  Most of the monitoring well  network was sampled quarterly
      from  May 2005 to May  2006;  since  then, the sampling frequency has been
      decreased to semiannual.
      Based on current trends,  the MCES results for the majority of wells indicate that
      Annual sampling would be adequate to monitor changes in the plume.  Wells
      300A and 300B were recommended for Quarterly sampling  based on a recent
      increasing concentration  trend;  however,  due  to the length of  the monitoring
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      record  and the location of these  wells,  a semiannual monitoring  frequency  is
      recommended after the qualitative  evaluation.   A  Quarterly result was also
      returned for well MW-305, based on an order of magnitude concentration increase
      between  November 2005 and  March 2006.  The increase may be a  transient
      phenomenon, but after the qualitative evaluation, the well is recommended for
      retention  in the monitoring program at a semiannual frequency.
      Final recommendations for  sampling frequency were determined after a review  of
      both qualitative and quantitative information.
4.3     Recommendations for the PRB Area
Recommendations for the PRB Area are summarized in Table 6 and described below.
   •   Continued sampling of 15  monitoring wells at the PRB Area is  recommended.
      Continuation of a semiannual  monitoring frequency for most wells is  deemed
      appropriate assuming  that future  monitoring results do not  indicate  increasing
      trends that should be monitored more closely.  Continued sampling  of two lower-
      priority wells (MW-313  and MW-312) at  an annual  frequency is  recommended.
      MW-313  is located cross-gradient of  the VOC plume and MW-312 is screened  in
      a relatively deep interval.
   •   Exclusion of  four wells from  the  monitoring program  at  the PRB  Area  is
      recommended for the  reasons  identified in Tables 3 and 6.  In general, these
      wells are  not providing data of sufficient usefulness to justify continued sampling.
   •   The potential  data gaps identified  in  Section 4.1  should be carefully considered,
      and additional sampling/characterization  should  be performed if appropriate  to
      ensure that  1) the plume  is  adequately  characterized  to  determine  risks  to
      potential  receptors, 2)  potential receptors are not being impacted by site-related
      contamination  to  an unacceptable  degree,  and 3) the appropriate  data are
      collected  to evaluate the effectiveness of MNA and properly estimate the  time and
      cost required to achieve CUOs.  Detailed site characterization information for the
      PRB area is not currently  available  in site documents provided  to the authors.
      The lack  of clarity in determining the  depth  of the drainage ditch near the PRB  is
      indicative of challenges in  information management associated with this area  of
      concern.  The majority of wells  in the PRB area were drilled after the RODs were
      issued  (1990, 1992, and 1997)  and current information on the specific source  of
      contamination and area hydrogeology are not included in these documents. The
      recommendation for the PRB area includes development of a Site Conceptual
      Model document to guide management decisions for this area of concern.
   •   Development of a comprehensive  site-wide database should continue.  Current
      and future analytical results should  be available  from laboratories in electronic
      data deliverable  (EDO)  format,  which  should  simplify  the  validation and
      importation process.  Results  of  historical analyses should be added to the
      database  where possible,   particularly when these  data  are  used to support
      management decisions.  The site-wide database  should be made available to all
      stakeholders.
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5.0    Soil Remedy Area Results
5.1     Qualitative Review for the Soil Remedy Area
   •   Details of the qualitative evaluation for the Soil Remedy Area are summarized in
      Table 7 and depicted on Figure 7. All wells that are part of the current monitoring
      program for this site are recommended for retention. However, a reduction in the
      sampling frequency is recommended for at least seven of the  nine monitoring
      wells listed in Table 7. In general, the frequency reductions were recommended
      because 1) existing monitoring wells have been sampled at least 16 times over a
      period  of at  least 7 years, and, with few  exceptions,  increasing trends are not
      evident (based  on statistical trend analysis results through  May 2006); 2) the
      reported low groundwater flow velocity and presence of a slurry wall surrounding
      the soil remedy cell  should prevent  rapid  changes  in dissolved contaminant
      concentrations and preclude the need for more frequent monitoring; 3) operation
      of the  DPE system within/beneath the soil remedy cell is apparently removing
      VOC mass and  reducing VOC concentrations in the vadose and  saturated zones
      over time;  and  4) available  information  indicates that  there  are  no nearby
      receptors.  Continued semi-annual monitoring  of two wells DMW-3S  and DMW-
      3D is recommended due the magnitude  of recent COC detections.  Continuation
      of this frequency is contingent on future analytical results.
   •   The TAL for the Soil Remedy Area includes VOCs (SW8260B) and selected field
      parameters (pH, conductivity, temperature, turbidity, DO, and ORP). This TAL is
      reasonably optimized.    However, discussion with  the  analytical   laboratory
      regarding optimization of the target VOC  list to a  short-list of key COCs (e.g.,
      chlorinated ethenes)  is  recommended.   Potential advantages include  lower
      laboratory analytical costs and lower data management/validation/reporting costs.
   •   The hydraulic monitoring recommendations made for the PRB Area (Section 4.1)
      are also applicable to the Soil Remedy Area.
   •   The following potential data gaps were noted during  performance of the MNO
      evaluation for the Soil Remedy Area.  They should be reviewed with the objective
      of verifying whether or not the current level of plume  definition  is  acceptable in
      terms of 1) risks posed to potential receptors and 2) estimating the  time and cost
      to achieve CUOs in groundwater.
      o  The downgradient extent of the VOC plume in the shallow zone is  not well
         defined.  The TCE concentration measured  in well DMW-3S in May 2006 was
         23 ug/L compared to a CUO of 5 ug/L, and there are no shallow wells  installed
         farther downgradient.   The DO and ORP values  measured at  this well in
         November 2005 (8.8  mg/L and 94  millivolts, respectively)  indicate  that the
         shallow saturated zone is aerobic and oxidizing  in this area, and the TCE will
         not readily  degrade.   This  observation is  supported by the relative lack of
         reductive dechlorination daughter products at DMW-3S (i.e., DCE and VC).
         However, information  obtained from  Progressive indicates that there are no
         receptors in the vicinity of the Soil Remedy Area  (Personal communication
         from Bridget Morello, 26 October 2006).  The northern boundary of the Clare
         Water Supply Superfund Site appears to be located approximately 200 feet
         north  of the  Soil  Remedy Area,  and  institutional controls that preclude
         exposure to groundwater may not be  in place  north of this  boundary.  The

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         stakeholders should  verify that the current level  of plume  definition  is
         acceptable in terms of characterizing risks posed to potential receptors.
      o  The intermediate zone is the first water-bearing zone below the bottom of the
         slurry wall.  There is  only one  well screened in this  zone (215), and  it  is
         located approximately  165 feet north of the soil remedy cell.  Therefore, the
         existing monitoring network would likely not detect contaminant migration from
         beneath the  soil   cell in the  intermediate  zone.    Installation of three
         intermediate-zone wells along the northern (presumed downgradient) edge  of
         the soil cell (at or near shallow wells DMW-1S, -2S, and -3S, Figure 7) should
         be considered.  The intermediate-zone well control in this area appears to be
         sparse, and inferred groundwater flow directions in the intermediate zone are
         therefore somewhat speculative.  Installation of new wells in this zone would
         help establish the groundwater flow direction in the intermediate zone (i.e., via
         triangulation between well 215 and the  new wells).   If the groundwater flow
         direction in the intermediate  zone  is  actually  more  directly  eastward  as
         suggested  by  a more recent potentiometric surface map transmitted  by
         Progressive (that was  contoured without using anomalous data from well
         300B),  then consideration should be given to focusing  installation of new
         intermediate wells  on  the east side of the soil remedy cell as indicated in the
         response to Progressive comment #16 (Attachment F).   Two intermediate
         wells could be  installed along  the east side and a third on the  north side  to
         determine the vertical extent of identified contamination given the presence  of
         a continuing source in that area.
      o  Groundwater  elevation  data  collected  in  2005 indicate a  northerly  to
         northwesterly  groundwater flow direction in  the shallow zone at  the  Soil
         Remedy Area.   Well  DMW-1S is located approximately  70 feet east  of the
         northwestern corner  of the soil cell.   Therefore,  dissolved  contaminants
         migrating  from  beneath the western portion of the soil  cell  may  not  be
         detected by the existing shallow well network.  Installation of an additional
         shallow well along the southern edge of US Highway 10 approximately 70 feet
         west of DMW-1S  should  be  considered (Figure 7).   It appears  that the
         contouring of shallow groundwater elevation data for the Soil Remedy Area on
         Figures 7 and 10 of the 2005 Annual Monitoring Report may not be completely
         correct.  For example, the elevation for  DMW-2S  measured  in May 2005
         (838.23) is incorrectly  located between the 836 and 838 elevation contours.
      o  Groundwater elevation data collected in 2005 indicate groundwater flow in the
         deep zone toward the east to east-northeast.  However, it appears that the
         well control in this area is sparse, and inferred flow directions in the deep zone
         are somewhat speculative. Given the potential for migration toward the east-
         northeast, installation  of one additional deep zone well northwest of DMW-3S
         (Figure 7) should be  considered to detect any contaminant migration  in the
         deep zone from beneath the northern portion of the soil cell. Installing a deep
         zone well   near  DMW-3S would   have  the added benefit   of  allowing
         assessment of vertical hydraulic gradients between the shallow,  intermediate,
         and deep zones (assuming an  intermediate well is also installed as discussed
         above), and also would help determine the groundwater flow direction  with a
         higher  degree  of  certainty  (via  triangulation with  existing  deep wells).
         Installation of  one additional deep zone well could be made conditional on
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         sampling results for new intermediate zone wells.   If the intermediate zone
         wells do not contain COCs at concentrations of concern, indicating a lack of
         significant vertical migration  of COCs, then installation of a new  deep well
         would not be necessary or recommended.
      o  As  described  in Section 2.2, it appears  that the  estimated groundwater
         velocity for the native materials at the Soil Remedy Area may be based on a
         single  hydraulic conductivity  measurement made  elsewhere on  the  Clare
         Superfund  Site.   Therefore,  there appears to be  a fairly high  degree  of
         uncertainty regarding the groundwater seepage velocity at the Soil Remedy
         Area.    Refinement/confirmation  of  the  magnitude of this  variable  via
         performance of slug and/or pumping tests in selected site wells  should  be
         considered given that it is an  important variable in assessing contaminant fate
         and transport and determining optimal monitoring locations and frequencies.
      o  The  contaminant conditions  required  to  trigger  a reexamination of the
         monitoring  program (i.e. monitoring objectives)  do  not appear to be well
         defined.  Currently there is a  CUO exceedance at well DMW-3S.  However,
         this TCE detection does not appear to be of concern given the reported lack of
         nearby receptors.  Is there a threshold  value above which  additional plume
         characterization would be determined to  be advisable? Some thought should
         be given to articulating what contaminant concentrations are considered to  be
         significant.
      o  There are  13 DPE wells at the Soil Remedy Area, all of which are assumed to
         be operating on at least an intermittent  basis.  However, these wells are not
         sampled (or at least sample results are  not reported in the database) so it is
         not possible to determine if  one  or more of  the wells can be shut  down
         because it is no longer removing significant VOC  mass.   This situation  is
         economical from a monitoring perspective,  but may not  be  economical from
         the standpoint of energy usage, costs for treatment of extracted water, and
         system  operation  and  maintenance.   Consideration  should  be  given  to
         whether the economic benefits of occasional sampling of the DPE wells would
         outweigh the added cost.
5.2     MAROS Statistical Review for the Soil Remedy Area
The Soil Remedy Area has a limited number of wells screened in both the shallow and
deep intervals. Because fewer that six locations are monitored in each zone, the spatial
statistical evaluation of the Soil Remedy area was limited in scope.
   •   The  COC Assessment module  in  MAROS identified VC as  the only priority
      constituent in  the Soil  Remedy area,  based on  its  low MCL and historic
      concentrations at some locations; however the data set did not  have a complete
      record for VC.  TCE  was  chosen  as the  guiding constituent for the network
      evaluation based on its more extensive record.
   •   The majority of wells in the Soil  Remedy Area have limited detections of TCE.
      Mann-Kendall concentration trend results are illustrated on  Figure 9.  Locations
      UMW-1S,  DMW-2D, and UMW-1D had non-detect results for all sample events,
      while  locations  DMW-1D,  and  DMW-3D had single detections that  were not
      confirmed  in later sampling. The deep zone of the aquifer to the east of the Soil
      Remedy area is largely unaffected by COCs.
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      Concentrations  for shallow zone wells DMW 1 through 3 all showed strongly
      decreasing trends for  TCE,  while  location 215  showed sporadic detections
      resulting  in No  Trend (NT), or high variability for TCE.   Strongly decreasing
      trends at downgradient shallow zone locations  indicate that the combined slurry
      wall and  DPE remediation systems  are functioning to reduce concentrations in
      this area.
   •   Preliminary sample frequency results from the MCES tool  indicate  that  the
      frequency of well  sampling could be reduced from semiannual to largely annual
      without loss of significant information.  For the deep zone wells,  preliminary
      results indicate  that a biennial (every two  year) sampling frequency would be
      adequate to characterize the change in concentration at these locations. In order
      to  determine the final sampling frequency, the results of both the qualitative and
      statistical analyses were combined.   Final  recommendations are presented in
      Table 9 and are illustrated on Figure 10.
   •   The number of  wells in  the Soil Remedy Area in each groundwater zone  (<6)
      were insufficient to perform moment analysis and formal spatial analysis for well
      redundancy and sufficiency.  Well redundancy and sufficiency recommendations
      are based on the qualitative evaluation detailed above.
5.3     Recommendations for the Soil Remedy Area
Recommendations for  the Soil Remedy Area  are summarized in Table 9 and described
below.
   •   Nine monitoring wells currently included  in the monitoring  program should be
      retained  for continued sampling  as described in  Tables 7  and 9; however,
      sampling frequencies for at least seven of the wells could be reduced to annual
      (five wells) or biennial (every other  year) (two wells). The current semiannual
      frequency for the remaining two wells  (DMW-3S  and  DMW-3D)  should be
      retained due to  potentially increasing concentrations.  Concentration trends can
      be evaluated  at these locations after another one to two additional  semi-annual
      monitoring events  are performed, and the sample frequency adjusted to annual if
      concentrations are stable to decreasing.
   •   Shallow well  SW-5 can  be excluded  from the Soil Remedy Area monitoring
      program  as described in Tables 7 and 9.  However, if this well is considered
      useful for site-wide monitoring or for monitoring another nearby site, then it should
      be retained for those purposes.
   •   The potential  data gaps  identified  in Section 5.1 should be carefully considered,
      and additional sampling/characterization should be performed as appropriate to
      ensure that 1)  the plume is  adequately  characterized to determine risks  to
      potential  receptors, 2) potential receptors are not being impacted by site-related
      contamination to  an unacceptable  degree, and 2)  the  appropriate data  are
      collected to properly estimate the time and cost required to achieve CUOs for
      groundwater.  As with the PRB area, a Site Conceptual Model document including
      detailed descriptions of area  hydrogeology  may be  valuable in organizing site
      information and  providing management decision support.
   •   At a minimum, installation of one shallow well and three intermediate-depth wells
      is  recommended to  more fully characterize  the quality of groundwater migrating

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      downgradient from beneath the soil remedy cell and to better define groundwater
      flow directions in the intermediate zones. In addition, installation of one deep well
      should be considered if sampling results for new intermediate-depth wells indicate
      the presence of COCs at concentrations of concern in intermediate groundwater
      as described in Section 5.1.
   •   Development of a comprehensive site-wide database should continue. Current
      and future analytical  results should be available from laboratories in electronic
      data   deliverable  (EDO)  format,  which  should  simplify the  validation  and
      importation  process.   Results of historical analyses should  be added  to the
      database where possible,  particularly when  these data are used  to support
      management decisions.  The site-wide database should be made available to all
      stakeholders.
6.0    Long-Term Monitoring Program Flexibility
The long-term monitoring (LTM) program recommendations described above are based
on available data regarding current (and expected future) site conditions. Changing site
conditions, such as changes in hydraulic (pumping-related) stresses or remedial system
operation, could affect contaminant fate and transport.  Therefore, the LTM program
should be reviewed if site conditions change significantly, and revised as necessary to
adequately  track changes in the magnitude and extent of COCs in groundwater over
time.
7.0    References Cited
AFCEE.  (1997). Air Force Center for  Environmental  Excellence, AFCEE  Long-Term
       Monitoring Optimization Guide, http://www.afcee.brooks.af.mil.
AFCEE.  (2003). Monitoring  and  Remediation  Optimization  System (MAROS) 2.1
       Software  Users  Guide. Air  Force  Center for  Environmental  Excellence.
       http://www.gsi-net.com/software/MAROS V2  1Manual.pdf
Aziz, J. A.,  C. J. Newell, M. Ling, H. S.  Rifai and J.  R.  Gonzales (2003). "MAROS:  A
       Decision Support System for Optimizing Monitoring Plans." Ground Water 41(3):
       355-367.
Progressive Environmental  and Construction,  Inc.  (2006). 2005 Annual  Monitoring
       Report, Clare Water Supply Superfund Site, Clare Michigan.  Prepared for Clare
       PRP Group.  February 21. Tampa, Florida.
USEPA (1992).  EPA Superfund Record  of Decision:   Clare Water Supply, EPA ID
       MID980002273, OU 02, Clare, Ml.  EPA/ROD/R05-92/209.  September 16.
USEPA (1998).  Technical  Protocol  for Evaluating Natural  Attenuation of Chlorinated
       Solvents in  Ground  Water.   EPA/600/R-98/128.   Office  of Research  and
       Development. September.
USEPA (2006).  Draft Second Five-Year Review  Report for Clare Water Supply,  City of
       Clare, Clare County,  Michigan. Prepared  by USEPA Region 5, Chicago,  Illinois.
       September.
Long-Term Groundwater Monitoring Network Optimization                             Page 16
PRB and Soil Remedy Areas
Clare Water Supply Superfund Site

-------
Tables

-------
                                                               TABLE 1
                                                      Summary of Site-Wide Long
                                                  Term Groundwater Monitoring Plan
                                              Clare Water Supply Superfund Site, Michigan
Well
PRB Monitoring
220
300A
300B
300C
MW-301
MW-302
MW-303
MW-304
MW-305
MW-306
MW-307
MW-308
MW-309
MW-310
MW-31 1
MW-312
MW-31 3
SW-11
SW-12
General Well
Depth

Deep
Shallow
Intermediate
Deep
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Deep
Shallow
Shallow
Shallow
Soil Remedy Monitoring
DMW-1 D
DMW-1S
DMW-2D
DMW-2S
DMW-3D
DMW-3S
EW-1
EW-2
EW-3
EW-4
EW-5
EW-6
EW-7
EW-8
EW-9
EW-10
EW-11
EW-1 2
EW-1 3
SW-5
UMW-1D
UMW-1S
Deep
Shallow
Deep
Shallow
Deep
Shallow
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Shallow
Deep
Shallow
Well Depth
(BGS)

60.5
17
30
80
17
15
15
15
12
17
17
12
17
17
10
70
17
5.5
11.5

75
17
75
11
75
10
30
30
30
30
30
30
30
30
30
30
30
30
30
6
55
9
Top of
Screen
(BGS)

55.5
12
20
60
12
10
10
10
7
12
12
7
12
12
5
65
12
2
8

70
12
70
6
70
5
25
25
25
25
25
25
25
25
25
25
25
25
25
3
50
4
Screen
Length

5
5
10
20
5
5
5
5
5
5
5
5
5
5
5
5
5
3
3

5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
3
5
5
Hydraulic Monitoring
Current Frequency

Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly

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
Water Quality Monitoring
Current Frequency

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
Not Sampled
Semi Annual

Semi Annual
Semi Annual
Semi Annual
Semi Annual
Semi Annual
Semi Annual
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
Semi Annual
Semi Annual
Semi Annual
Method

VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B, Ml 10 Metals
VOCs - 8260B, Ml 10 Metals
VOCs - 8260B, Ml 10 Metals
VOCs - 8260B, Ml 10 Metals
VOCs - 8260B, Ml 10 Metals
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B, Ml 10 Metals
VOCs - 8260B
VOCs - 8260B
-
VOCs - 8260B

VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
VOCs - 8260B













VOCs - 8260B
VOCs - 8260B
VOCs - 8260B
Notes:
Monthly hydraulic monitoring ended in May 2006; next hydraulic monitoring event was November 2006.
BGS = feet below ground surface.
        \proj\clare\EPA GIS\files to Parsons\PRB & Soil Remedy Tables_rev2.xls

-------
GSI Job No. G-3138-105
Issued 03/22/2007
Page 1 of 1
                                                                                             GROUNDWATER
                                                                                             SERVICES, INC.
                                                  TABLE 2
                                AQUIFER INPUT PARAMETERS FOR MAROS

                                  LONG-TERM MONITORING OPTIMIZATION
                           CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
Parameter
Current Plume Length
Maximum Plume Length
PlumeWidth
SeepageVelocity Intermediate (ft/yr)*
Distance to Receptors (Source to MW-5)
GWFIuctuations
SourceTreatment
PlumeType
NAPL Present
Vinyl Chloride
Cleanup Objective
MCL
Parameter
Groundwater flow direction
Porosity
Source Location near Well
Source X-Coordinate
Source Y-Coordinate
Saturated Thickness
PRB
Value
380
380
380
98
1200
No
Permeable Reactive Barrier
Chlorinated Solvent
No
Screening Levels
0.015
0.002
Value
South
0.38
300A*
13014379.33
845654.49
30
Soil Remedy
Value
350
350
350
0.005
2000
No
Cap, slurry wall and DPE
Chlorinated Solvent
No
Trichloroethene
0.005
Value
North
0.39
Soil Remedy Cell
13014044.21
846239.92
15 (Shallow)

Units
ft
ft
ft
ft/yr
ft
-

mg/L
mg/L


ft
ft
ft
Notes:
1. Aquifer data from Progressive database (2006).
2. Priority COCs defined by prevalence, toxicty and mobility.
3. Saturated thickness represents the span of the shallow to intermediate aquifer.
5. ft = Coordinates in NAD 1983 State Plane Michigan Central feet.
6. Cleanup Objective from Michigan Part 201  Ground Water /Surface Water Interface standard for PRB area.
   MCL = USEPA Maximum Contaminant Level for drinking water.
7. * = For the purpose  of the spatial analysis, a point north of the
  barrier wall was chosen as the 'source' area.

-------
                                  TABLE 3
QUALITATIVE EVALUATION OF PRB AREA GROUNDWATER MONITORING NETWORK
                      LONG-TERM MONITORING OPTIMIZATION
                  CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
                                                                                                               PARSONS
Well Name
220
300A
300B
300C
MW-301
MW-302
MW-303
MW-304
MW-305
MW-306
MW-307
MW-308
MW-309
Hydrologic Unit
Deep
Shallow
Intermediate
Deep
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Shallow
Current
Sampling
Frequency
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
Qualitative Analysis
Exclude
X



X



X




Retain

X
X
X

X
X
X

X
X
X
X
Monitoring Frequency
Recommendation
NA
Semi-Annual
Semi-Annual
Semi-Annual*
NA
Semi-Annual
Semi-Annual
Semi-Annual
NA
Semi-Annual
Semi-Annual
Semi-Annual
Semi-Annual
Rationale
VOCs trace-level to non-detect during 43 sampling events over 12 years (1994-2006) with no cleanup objective (CUO) exceedances. No reason to believe
that this will change in the future. Continued monitoring of this deep zone well that is screened below the primary contaminated interval would not provide
useful information.
Provides upgradient data to evaluate VOC removal effectiveness of southern PRB. 17 sampling events from Dec '99 to Nov '06 provide sufficient baseline
data to evaluate seasonal removal effectiveness; semiannual monitoring frequency should allow sufficient data to be collected to permit evaluation of PRB
performance over time.
Screened in Gray Till below bottom of PRBs that is not well-monitored; contains elevated VC levels that appear to be increasing with time; results indicative
of underflow of VOCs beneath PRB; retain to continue monitoring groundwater quality in deeper zone.
Screened approx 44 to 64 ft below bottom of PRBs; only 3 deep wells present at site. Increasing VC trend between April '03 and Nov '05. Retain at
moderate frequency to monitor trend. Consider reducing frequency to annual if increasing trend ceases.
Results of 5 sampling events in 2005-2006 indicate occasional presence of very low VOC levels < CUO; no apparent increasing or decreasing trends.
However, this well does not serve to bound plume on west side or accurately indicate VOC mass migrating around PRBs given higher COC detections in
MW3 10, which is screened in same interval and located futher west. Therefore, MW30 1 not providing useful data.
Measures water quality upgradient of PRBs in MW302-303 -304/3 1 1 transect. COC concentrations over 5 quarterly events ending in May 06 consistently
increased from MW302 to MW303; therefore, contrast between MW3 02 andMW303 did not appear to be a good indicator of PRB removal efficiency.
Potential explanations include: 1) PRB is not effective at this location, 2) MW302 is not screened in primary contaminant flowpath, 3) groundwater does not
migrate from MW302 to MW303, or 4) there is a source of VOCs between MW302 and MW303 . However, trend reversed in Nov 06 (VC higher at
MW302 than at MW303), potentially indicating PRB effects. Maintain semiannual monitoring frequency to assess future trends and PRB impacts. Note that
COC concentrations in MW302 are much lower than detected in adjacent vertical profiling samples from VAS-301, indicating that data for MW302 are not
representative of maximum COC concentrations in groundwater at this location.
Measures elevated COC levels in this area, and provides useful upgradient data to evaluate VOC removal efficiency of southern PRB. Concentration
decrease from Aug to Nov 05 appears to indicate effect of northern PRB installation. Semi-annual monitoring frequency should yield sufficient data over
time regarding PRB effectiveness.
Provides useful data regarding VOC removal efficiency of southern PRB near base of shallow zone. Semiannual monitoring frequency should yield
sufficient data over time regarding PRB effectiveness. Note that vertical profiling data for adjacent VAS-304 indicate that MW-304 may be screened beneath
highest VOC concentrations present in aquifer at this location.
Measures water quality upgradient of PRBs in MW305-300A-307/308 transect. COC concentrations over 5 quarterly events consistently increased from
MW305 to MW300A; therefore, contrast between these two wells does not appear to be a good indicator of northern PRB removal efficiency. Same trend
observed in Nov 06. Potential explanations include: 1) PRB is not effective at this location, 2) MW305 is not screened in primary contaminant flowpath, 3)
groundwater does not migrate from MW305 to MW300A, or 4) there is a source of VOCs between MW305 and MW300A. Note that COC concentrations
in MW305 are much lower than detected in adjacent vertical profiling samples from VAS-302, indicating that data for MW305 are not representative of
maximum COC concentrations in groundwater at this location. Continued monitoring of MW305 does not provide useful information regarding COC
concentrations entering northern PRB and PRB effectiveness.
Provides useful data regarding combined VOC removal efficiency of northern and southern PRBs and concentrations exiting PRB area. Semi-annual
monitoring frequency should yield sufficient data over time regarding PRB effectiveness.
Provides useful data regarding VOC removal efficiency of southern PRB and concentrations exiting PRB area near base of shallow zone. Semi-annual
monitoring frequency should yield sufficient data over time regarding PRB effectiveness.
Provides useful data regarding VOC removal efficiency of southern PRB and concentrations exiting PRB area in middle portion of shallow zone. Semi-
annual monitoring frequency should yield sufficient data over time regarding PRB effectiveness.
Monitors untreated VOC concentrations migrating past east end of PRBs. Data suggest possible increasing trend from Aug '05 to May '06, with lower VC
concentration in Nov 06. Semi-annual monitoring frequency should yield sufficient data over time regarding PRB effectiveness unless increasing trend
continues in the future.

-------
                                                                                   TABLE 3
                                             QUALITATIVE EVALUATION OF PRB AREA GROUNDWATER MONITORING NETWORK
                                                                     LONG-TERM MONITORING OPTIMIZATION
                                                                 CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
                                                                                                                                                                        PARSONS
Well Name
MW-310
MW-311
MW-312
MW-313
SW-11
SW-12
Hydrologic Unit
Shallow
Shallow
Deep
Shallow
Shallow
Shallow
Current
Sampling
Frequency
Semi-Annual
Semi-Annual
Semi-Annual
Semi-Annual
Not Sampled
Semi-Annual
Qualitative Analysis
Exclude




X
X
Retain
X
X
X
X


Monitoring Frequency
Recommendation
Semi-Annual
Semi-Annual
Annual
Every other year
NA
NA
Rationale
Monitors untreated VOC concentrations migrating past west end of PRBs. Stable VC trend indicated as of Nov 06; semi-annual monitoring frequency should
yield sufficient data over time regarding COC concentrations in this area.
Provides useful data regarding VOC removal efficiency of southern PRB and concentations exiting PRB area in middle to upper portion of shallow zone.
COC concentrations generally similar to slightly higher than in paired well MW304, consistent with vertical profiling results from VAS-305 (maximum
concentrations at 8.5' bis). Semi-annual monitoring frequency should yield sufficient data over time regarding PRB effectiveness.
Retain as deep zone sentry well in downgradient direction due to increasing trends in well 300C, which is screened at similar depth interval. Relatively low
frequency justified by lack of COC detections through Nov 06 and reported lack of receptors. If rapid plume expansion at this depth was going to occur it
would likely have already impacted this well.
Well appears to be cross-gradient of VOC plume; only 2 trace-level chlorinated ethene detections in 6 monitoring events (up to Nov 06). Retain at low
frequency to monitor eastern extent of plume over time.
Nov 06 sampling event first since 1999. No COC detections over 1 1 events from 1994 to 1999, and only 1 trace-level toluene detection in Nov 06 (possible
lab contaminant). Distant and upgradient from PRBs. Other wells installed closer to PRBs provide better site-specific upgradient data.
Well is cross-gradient of VOC plume; only 1 trace-level chlorinated ethene detection in 14 monitoring events. Continued low-frequency monitoring of
MW3 13 would facilitate assessment of eastern plume extent over time.
NA = not applicable.
* = conditional recommendation; see comments.

-------
GSI Job No. G-3138-105
Issued 03/22/2007
Page 1 of 1
                                                                                                                                     GROUNDWATER
                                                                                                                                     SERVICES, INC
                                                                     TABLE 4
                                          WELL TREND SUMMARY RESULTS FOR PRB AREA: 1999-2006

                                                     LONG-TERM MONITORING OPTIMIZATION
                                               CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN


WellName

Number of
Samples

Number of
Detects

Maximum
Result [mg/L]

Max Result
Above CUO?

Average
Result [mg/L]
Average
Result Above
MCL?

Mann Kendall
Trend
Linear
Regression
Trend

Overall Trend
Result
Vinyl Chloride Shallow and Intermediate Zone
300A
300B
MW-301
MW-302
MW-303
MW-304
MW-305
MW-306
MW-307
MW-308
MW-309
MW-31 0
MW-31 1
MW-31 3
SW-12
15
13
5
5
5
5
5
5
5
5
5
5
5
5
12
15
13
4
5
5
5
5
5
4
5
5
5
5
1
1
5.2
0.2
0.0015
0.099
1.6
0.041
0.24
0.015
0.033
0.058
0.048
0.027
0.069
0.00073
0.0016
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
0.925
0.0546
0.0013
0.059
0.604
0.0231
0.152
0.00518
0.012
0.0414
0.0242
0.0167
0.0312
0.000946
0.00105
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
I
I
S
S
NT
S
S
D
NT
NT
NT
NT
S
ND*
ND*
I
I
S
D
D
S
NT
D
NT
NT
S
NT
S
ND*
ND*
I
I
S
PD
S
S
S
D
NT
NT
S
NT
S
ND*
ND*
Vinyl Chloride Deep Zone
220
300C
MW-31 2
15
13
5
1
8
0
0.00031
0.027
0.001
No
Yes
No
0.000954
0.0076
0.001
No
Yes
No
S
I
-
S
I
-
S
I
ND
Wofes
1.  Trends were evaluated for data collected between 1/1/1999 and 5/30/2006. Trends including new data from 11/2006 are shown in Attachment C.
2. Shallow and Intermediate zone is approximately between 7 and 40ftbgs (847 and 817ft AMSL). Deep zone is below 40 ft bgs (below 817 ft AMSL).
3.  Number of Samples is the number of samples for the compound at this location.
   Number of Detects is the number of times the compound has been detected at this location.
4.  Maximum Result is the maximum concentration for the COC indicated between 1999 and 2006.
5.  CUO = Clean-up Objective, 0.015 mg/L. MCL = 0.002 mg/L for vinyl chloride.  'Above MCL' indicates that the result value is above the screening level'.
6.  D = Decreasing; PD = Probably Decreasing; S = Stable; PI = Probably Increasing; I = Increasing; N/A = Insufficient Data to determine trend;
  NT = No Trend; ND = well has all non-detect results for COC; ND* = Non-detect except for one trace value.
7.  Mann-Kendall trend results are illustrated on Figure 4.

-------
GSIJobNo. G-3138-105
Issued 03/22/2007
Page 1 of 1
                                                                                                   GROUND WATER
                                                                                                   SERVICES, INC.
                                                   TABLE 5
                     WELL REDUNDANCY ANALYSIS SUMMARY RESULTS FOR PRB AREA
                                   LONG-TERM MONITORING OPTIMIZATION
                             CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
WellName
Vinyl Chloride
Average Slope
Factor
Vinyl Chloride
Minimum Slope
Factor
Vinyl Chloride
Maximum Slope
Factor
Preliminary
Statistical Result
Preliminary Sample
Frequency
Shallow and Intermediate Zone Wells
300A
300B
MW-301
MW-302
MW-303
MW-304
MW-305
MW-306
Mw-307
MW-308
MW-309
MW-310
MW-311
MW-313
SW-12
0.47
0.39
0.87
0.11
0.35
0.13
0.19
0.60
0.54
0.24
0.20
0.32
0.13
0.90
0.88
0.28
0.15
0.59
0.02
0.30
0.00
0.00
0.20
0.16
0.00
0.13
0.03
0.01
0.55
0.65
0.72
0.54
1.00
0.28
0.50
0.27
0.49
0.80
1.00
0.53
0.31
0.70
0.25
1.00
1.00
Retain
Retain
Retain
Exclude
Retain
Exclude
Exclude
Retain
Retain
Retain
Retain
Retain
Retain
Retain
Retain
Quarterly
Quarterly
Biennial
Annual
Annual
Annual
Quarterly
Annual
Annual
Annual
Annual
SemiAnnual
Annual
Biennial
Annual
Deep Zone Wells
220
300C
MW-312
Insufficient well locations in deep zone for spatial analysis
Biennial
Biennial
Biennial
Notes:
1.  Slope Factor is the difference between the actual concentration and the concentration estimated from nearest
   neighbors normalized by the actual concentration.  Slope factors close to 1 show the concentrations cannot be
   estimated from the nearest neighbors, and the well is important in the network.
2.  Slope factors were calculated using data between January 2002 and May 2006.
3.  Locations with slope factors below 0.3 were considered for elimination.
4.  Preliminary Sample Frequency is the result from the MCES analysis, 1999-2006.

-------
                                                                                      TABLE 6
                                                 FINAL RECOMMENDED GROUNDWATER MONITORING NETWORK FOR PRB AREA
                                                                     LONG-TERM MONITORING OPTIMIZATION
                                                               CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
WellName
Number of
Samples
Number of
Detects
Average
Result [mg/L]
Average
Result Above
CUO?
VC Mann
Kendall
Trend
VC Linear
Regression
Trend
VC Overall
Trend Result
Recommendation /
Quantitat
Sample Locations
Mter Qualitative and
ve Review
Sample Frequency
Rationale
Shallow and Intermediate Zone
300A
300B
MW-301
MW-302
MW-303
MW-304
MW-305
MW-306
MW-307
MW-308
MW-309
MW-310
MW-311
MW-313
SW-12
SW-11
15
13
5
5
5
5
5
5
5
5
5
5
5
5
12
2
15
13
4
5
5
5
5
5
4
5
5
5
5
1
1
0
0.925
0.055
0.001
0.059
0.604
0.023
0.152
0.005
0.012
0.041
0.024
0.017
0.031
0.001
0.001
0.001
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
No
No
No
I
I
S
S
NT
S
S
D
NT
NT
NT
NT
S
ND*
ND*
ND
I
I
S
D
D
S
NT
D
NT
NT
S
NT
S
ND*
ND*
ND
I
I
S
PD
S
S
S
D
NT
NT
S
NT
S
ND*
ND*
ND
Retain
Retain
Exclude
Retain
Retain
Retain*
Retain*
Retain
Retain
Retain
Retain
Retain
Retain
Retain
Exclude
Exclude
Semiannual
Semiannual

Semiannual
Semiannual
Semiannual
Semiannual
Semiannual
Semiannual
Semiannual
Semiannual
Semiannual
Semiannual
Annual


Monitors high concentrations
between PRB, efficacy of
southern PRB.
Monitors Intermediate
groundwater zone, not
treated by PRB
Low concentration to non-
detect, redundant with MW-
310.
Upgradient, low
concentrations, outside of
main plume
Monitors efficacy of PRB
Monitors efficacy of PRB in
ower Shallow Zone,
companion well to MW311
Monitors upgradientof PRB
n Shallow Zone
Monitors immediately
downgradient of eastern
PRB in Shallow Zone
Monitors efficacy of PRB in
ower Shallow Zone,
companion well to MW-308
Monitors efficacy of PRB in
mid-upper Shallow Zone
Monitors eastern edge of
PRB for possible routing of
plume around PRB
Monitors western Shallow
Zone, outside of PRB
remedy.
Monitors efficacy of PRB in
mid-upper Shallow Zone
Sentry well cross-gradient
shallow eastern edge of
plume
Cross-gradient, not in main
plume.
Upgradient, not in plume
Deep Zone
220
300C
MW-312
15
13
5
1
8
0
0.000954
0.0076
0.001
No
No
No
S
I
-
S
I
-
S
I
ND
Exclude
Retain
Retain

Semiannual
Annual
Largely non-detect, not
representative of plume or
source.
Monitors Upgradient Deep
Zone
Deep Zone sentry well
Wofes
1.  Shallow and Intermediate zone is approximately between 7 to 37 ft bgs (847 and 817ft AMSL). Deep zone is below 40 ft bgs (below 817ft AMSL).
2.  Number of Samples is the number of samples during the recent time-frame for the compound at this location.
   Number of Detects is the number of times the compound has been detected for data consolidated by quarter at this location.
3. Average Result is the average concentration for TCE between 1999 and 2006.
4.  CUO = Clean-up Objective, 0.005 mg/L. 'Above CUO' indicates that the result value is above the objective standard.
5.  D = Decreasing; PD = Probably Decreasing; S = Stable; PI = Probably Increasing; I  = Increasing; N/A = Insufficient Data to determine trend;
  NT = No Trend; ND = well has all non-detect results for COC; ND* = Non-detect except for one trace value.
6.  All recommendations are contingent upon stable plume status under current conditions.
   Changes in groundwater flow velocity or head may require increasing or decreasing sample locations and frequency.
7.  Sample locations are illustrated on Figure 7.
8.  * = Recommended for exclusion by either qualitative or quantitative analysis, but retained after final evaluation.

-------
                                                                                                                                                                                PARSONS
                                                                                        TABLE 7
                                         QUALITATIVE EVALUATION OF SOIL REMEDY AREA GROUNDWATER MONITORING NETWORK
                                                                         LONG-TERM MONITORING OPTIMIZATION
                                                                     CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
Well Name
DMW-1D
DMW-1S
DMW-2D
DMW-2S
DMW-3D
DMW-3S
SW-5
UMW-1D
UMW-1S
EW-1
EW-2
EW-3
EW-4
EW-5
EW-6
EW-7
EW-8
EW-9
EW-10
EW-11
EW-1 2
EW-1 3
215
Hydrologic Unit
Deep
Shallow
Deep
Shallow
Deep
Shallow
Shallow
Deep
Shallow
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Current
Sampling
Frequency
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
Qualitative Analysis
Exclude






X
















Retain
X
X
X
X
X
X

X
X













X
Monitoring Frequency
Recommendation
Annual
Annual
Annual
Annual
Semi-Annual*
Semi-Annual*
--
every other year
every other year













Annual
Rationale
1 6 sampling events from 3/99 to 1 1/06. Missing PCE and VC data from 3/99 to 5/04. COCs non-detect in almost every case but increased cis-DCE in
1 1/06 (unvali dated data). Retain as deep sentry well downgradient of soil remedy cell. Frequency reduction justified based on historical monitoring
results (primarily non-detect), assumed low groundwater flow velocity, presence of low-permeability sediments below soil cell and slurry wall around it,
and deep screen interval (significant impacts at 70 ft bgs less likely).
1 6 sampling events from 3/99 to 1 1/06. Missing PCE and VC data from 3/99 to 5/04. Retain as downgradient shallow sentry well. TCE exhibits
decreasing trend while cis-DCE exhibits no trend and variable concentrations with occasional cleanup goal exceedances. Reduce frequency to annual
given assumed low groundwater flow velocity, lack of receptors, and lack of recent CUO exceedances (only 2 in previous 8 events up to 11/06) unless
risks to potential receptors are perceived, justifying additional remedial action and/or sampling.
SameasDMW-lD.
No CUO exceedances since 1 999. Retain as downgradient shallow sentry well. Frequency reduction justified based on historical monitoring results (trace-
level to non-detect), assumed low groundwater flow velocity, lack of receptors, and presence of slurry wall restricting migration of contaminants from soil
cell into downgradient shallow zone groundwater.
Same as DMW-1D. However, data for 2005-2006 suggest possible increasing trend in chlorinated VOC concentrations; therefore, retain current sampling
frequency to assess temporal trend. Consider frequency reduction to annual if future data demonstrate that concentrations are not increasing.
1 6 sampling events from 3/99 to 1 1/06. Missing PCE and VC data from 3/99 to 5/04. TCE exceeded cleanup goals in most recent events. Overall
decreasing trend, but November 05 and May 06 data suggest possible rebound. Retain as downgradient shallow sentry well. If results of one additional
semi-annual event indicates resumption of either stable or decreasing trend, then reduce frequency to annual.
30 sampling events since 12/94; no cleanup goal exceedances since 1998. Upgradientto cross-gradient from Soil Remedy Cell; additional sampling would
not provide useful data regarding Soil Remedy Area.
Retain as upgradient deep zone well; low monitoring frequency justified by upgradient location and lack of historical COC detections over 16 monitoring
events since 1999.
Retain as upgradient shallow zone well; frequency reduction justified by upgradient location and lack of historical COC detections over 1 6 monitoring
events since 1999.
No Data
No Data
No Data
No Data
No Data
No Data
No Data
No Data
No Data
No Data
No Data
No Data
No Data
Sampled 36 times from 3/94 to 1 1 706 with only scattered low-level detections and no CUO exceedances. Retain as downgradient intermediate- zone sentry
well. Frequency reduction justified by monitoring history, distance from source area, assumed low groundwater flow velocity, lack of receptors, potential
for DMW-1S/2S/3S to provide early warning of contaminant migration toward 21 5.
* = conditional recommendation; see comments.

-------
GSIJobNo. G-3138-105
Issued 03/22/2007
Page 1 of 1
                                                                                                                                                      GROUNDWATER
                                                                                                                                                      SERVICES, INC,
                                                                              TABLE 8
                                                WELL TREND SUMMARY RESULTS SOIL REMEDY AREA:  1999-2006

                                                             LONG-TERM MONITORING OPTIMIZATION
                                                       CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN


WellName

Number of
Samples

Number of
Detects

Maximum
Result [mg/L]

Max Result
Above MCL?

Average
Result [mg/L]
Average
Result Above
MCL?

Mann Kendall
Trend
Linear
Regression
Trend

Overall Trend
Result
Preliminary
Sample
Frequency
Trichloroethene Shallow Zone
DMW-1S
DMW-2S
DMW-3S
UMW-1S
SW-5
15
14
15
15
13
Trichloroethene Chloride Dee
DMW-1D
DMW-2D
DMW-3D
UMW-1D
15
15
15
15
15
7
15
0
0
0.099
0.048
0.007
0.001
0.001
Yes
Yes
Yes
No
No
0.017
0.0019
0.021
0.001
0.001
Yes
No
Yes
No
No
D
D
D
—
—
D
D
D
—
—
D
D
D
ND
ND
Annual
Annual
Annual
Biennial
Biennial
p Zone
1
0
1
0
0.001
0.001
0.0016
0.001
No
No
No
No
0.001
0.001
0.00104
0.001
No
No
No
No
—
—
NT
-
—
—
NT
-
ND*
ND
NT
ND
Biennial
Biennial
Biennial
Biennial
Notes
1.  Trends were evaluated for data collected between 1/1/1999 and 5/30/2006.
2.  Shallow and Intermediate zone is approximately between 0 and 17 ft bgs. Deep zone is below 50 ft bgs.
3.  Number of Samples is the number of samples for the compound at this location.
   Number of Detects is the number of times the compound has been detected at this location.
4.  Maximum Result is the maximum concentration for the COC indicated between 1999 and 2006.
5.  CUO = Clean-up Objective, 0.015 mg/L. MCL = 0.005 mg/L for TCE. 'Above MCL' indicates that the result value is above the screening level'.
6.  D = Decreasing; PD = Probably Decreasing; S = Stable; PI = Probably Increasing; I = Increasing; N/A = Insufficient Data to determine trend;
  NT = No Trend; ND = well has all non-detect results for COC; ND* = Non-detect except for one trace value.
7.  Mann-Kendall trend results are illustrated on Figure 4.
8.  LOE = Lines of Evidence. The LOE trend is a combination of the Mann-Kendall and Linear Regression trends.
9.  Average Result is the average concentration at the monitoring location for all samples between 1999 and 2006.
10.  The Sampling Frequency is a preliminary result from the software algorithm. A final frequency should be determined after a qualitative evaluation of all site data.
11* Location DMW-1D had only one detection of TCE and DCE in June 2000. The detection was not repeated in subsequent sample events.

-------
                                                                                       TABLE 9
                                                        FINAL RECOMMENDED MONITORING NETWORK SOIL REMEDY AREA
                                                                      LONG-TERM MONITORING OPTIMIZATION
                                                                CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
WellName
Number of
Samples
Number of
Detects
Average
Result [mg/L]
Average
Result Above
CUO?
TCE Mann
Kendall
Trend
TCE Linear
Regression
Trend
TCE Overall
Trend Result
Recommendation 1
Quantltat
Sample Locations
\fter Qualitative and
ve Review
Sample Frequency
Rationale
Shallow and Intermediate Zone
DMW-1S
DMW-2S
DMW-3S
UMW-1S
215
SW-5
15
14
15
15
15
13
15
7
15
0
3
0
0.017
0.002
0.021
0.001
0.001
0.001
Yes
No
Yes
No
No
No
D
D
D

NT
ND
D
D
D

NT
ND
D
D
D
ND
NT
ND
Retain
Retain
Retain
Retain
Retain
Exclude
Annual
Annual
Semiannual*
Biennial
Annual

Downgradient shallow sentry
well
Downgradient shallow sentry
well
Consider changing frequency
to Annual if concentrations
stable to decreasing over 2-3
sample events
Monitors shallow zone
upgradientof soil remedy.
Sentry well for downgradient
intermediate groundwater
zone.
Cross-gradient of Soil Remedy
Cell and not providing useful
data.
Deep Zone
DMW-1D
DMW-2D
DMW-3D
UMW-1D
15
15
15
15
1
0
1
0
0.001
0.001
0.001
0.001
No
No
No
No


NT



NT

ND*
ND
NT
ND
Retain
Retain
Retain
Retain
Annual
Annual
Semiannual*
Biennial
Monitors for contaminant
migration in deep zone
Monitors for contaminant
migration in deep zone
Consider changing frequency
to Annual if concentrations
stable to decreasing over 2-3
sample events
Monitors deep groundwater
zone upgradient of soil remedy
Notes
1.  Shallow and Intermediate zone is approximately between 7 to 37 ft bgs (847 and 817ft AMSL). Deep zone is below 40 ft bgs (below 817 ft AMSL).
2.  Number of Samples is the number of samples during the recent time-frame for the compound at this location.
   Number of Detects is the number of times the compound has been detected for data consolidated by quarter at this location.
3. Average Result is the average concentration for TCE between 1999 and 2006.
4.  CUO = Clean-up Objective is equal to MCL, 0.005 mg/L. 'Above CUO' indicates that the result value is above the objective standard.
5.  D = Decreasing; PD = Probably Decreasing; S = Stable; PI = Probably Increasing; I = Increasing; N/A = Insufficient Data to determine trend;
  NT = No Trend; ND = well has all non-detect results for COC; ND* = Non-detect except for one trace value.
6.  All recommendations are contingent upon stable plume status under current conditions.
   Changes in groundwater flow velocity or head may require increasing or decreasing sample locations and frequency.
7.  Sample locations are illustrated on Figure 9.
8.  * = Consider reducing frequency to Annual if concentration trends stable to decreasing.
9.  SW-5 may provide useful information for the Site-Wide groundwater monitoring network, which was not evaluated here.

-------
Figures

-------
Permeable Reative
Barrier Area (PRB)
   220
—| MW-303

    i—| MW-305

      300A
          MW-301
          . MW-311

           MW-304
                               MW-307

                             MW-308
          • MW-306
                                                                                                    Legend
                                                                                                       Soil Remedy
                                                                                                 H    Area Wells

                                                                                                 H    PRB Area Wells

                                                                                              Well Depth

                                                                                                 0    Deep

                                                                                                 A    Intermediate

                                                                                                 H    Shallow

                                                                                             	 Permeable
                                                                                             ^^^~ Reactive Barrier
                                                                                           Notes:
                                                                                           1. Shallow zone is between 5 and
                                                                                             20 FT bgs. Intermediate zone is
                                                                                             between 20 and 50 FT bgs. Deep
                                                                                             zone is between 50 and 80 FT bgs.
                                                                                           2. Data source Progressive Environmental
                                                                                             and Construction, August 2006.
                                                                                                               140
GROUNDWATER MONITORING
    LOCATIONS: PRB AND
    SOIL REMEDY AREAS

    Clare \Afeter Treatment Site
         Clare, Michigan
                                                                                                G-3138-105
                                                                    03/22/2007
                                                                                               Figure 1
                                                                                                                  MV
                                                                                      MV
                                                                                                                  MV

-------
Draft
                                                                                           PARSONS
                                        FIGURE 2A
                 APPROXIMATE WELL SCREEN INTERVALS FOR PRB AREA
                      LONG-TERM MONITORING OPTIMIZATION EVALUATION
                        CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
                                                                           Approx Water Table
                                                                           Bottom of PRBs (826-827)
                                                                           Approx Top of Intermediate Zone
                     823
                     821
                     819
                     817
                     815
                     813
                     811
                     809
                     807
                     805
                     803
                     801
                     799
                     797
                     795
                                                                           Approx Top of Deep Zone
                Shallow
                Intermediate
                Deep
•

-------
Draft
                                          FIGURE 2B
                PROXIMATE WELL SCREEN INTERVALS FOR SOIL REMEDY AREA
                       LONG-TERM MONITORING OPTIMIZATION EVALUATION
                         CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
                                                                                               PARSONS
  0>
  I
  o'


Zone
                 845
                 843
                 841
                 839
                                                         °9
                                                                                Approx Water Table (836-844)
                                                                                Base of Slurry Wall
                                                                                Approx Top of Intermediate Zone
                 827
                 825
                 823
                 821
                 819
                 817
                 815
                 813
                 811
                 809
                 807
                 805
                 789
                 787
                 785
                 783
                 781
                 779
                 777
                 775
                 773
                 771
                 769
                 767
                 765
                 763
                 761
                 759
                 757
                 755
                 753
                 751
                 749
                 747
                                                                                Approx Top of Deep Zone
                Shallow
                Intermediate
                Deep

-------
                                                                                                   © ND
                                                                                                     (1999)
               220
                ND
                                                    VAS-301
                                                    1700
                                VAS-ETI-1
                                14
                                VAS-ETI-3
                                  .....  „_
                                  MW-310
                                       27
                                         MW-311
                                             96
                                             26
            MW-308
                58
                   /   \  X
                   /    \   X
                   /           \
                   18
                                                                             -306
                                                2.1

                                                            MW-307
                                                            10
             VAS-305
             119
                                                                                            o
                                                                                            °
                                                                                              ND
                                                                                  .MW-312
                                                                                  ND
LEGEND
RECOMMENDED SAMPLE FREQUENCY
MW-302 O SHALLOW MONITORING WELL
   300B D INTERMEDIATE  MONITORING WELL
    220-^- DEEP MONITORING WELL
VAS-302 A VERTICAL PROFILING  BOREHOLE
     ND = NOT DETECTED
       * = CONDITIONAL RECOMMENDATION,
          SEE COMMENTS IN TABLE 3
  -^—  INFERRED  GROUNDWATER
          FLOW DIRECTION
                                     r-,
    SEMIANNUAL
    ANNUAL
EVERY OTHER  YEAR
EXCLUDE
                                     NOTE:
                                     VINYL CHLORIDE (VC) CONCENTRATIONS
                                     POSTED FOR MONITORING WELLS ARE FOR
                                          Q6_ yc CONCENTRAT|QNS pQSTED
                                     FOR  VAS~  SERIES BOREHOLES ARE
                                     MAXIMUM DETECTED IN JANUARY 05.
                                                                           SCALE:  1"=60'
             FIGURE 3
   QUALITATIVE  EVALUATION
    RESULTS  FOR PRB  AREA
Long-Term Monitoring  Network Optimization
    Clare Water Supply Superfund Site
                                                              PARSONS
                                                                                                   Denver, Colorado

-------
         Legend
   	 Permeable
   ^^^^ Reactive Barrier

           Groundwater Flow
           Direction

 MannKendall Trend Vinyl Chloride

      ®   Decreasing

      O   Probably Decreasing
      O   Stable

      •   Increasing

      •   No Trend

      •   Non Detect
Notes:
1. Concentration trends were determined
   for vinyl chloride data between 1999
   and November 2006.
2. All wells screened in shallow zone
  of aquifer except locations indicated.
3. Data source Progressive Environmental
  and Construction, August 2006.


            Scale (ft)
           ^•=
        0      30      60
     TEMPORAL TREND
RESULTS:  VINYL CHLORIDE
          PRB AREA
   Clare Water Treatment Site
        Clare, Michigan
    Figure 4

-------
    \
Area South of PRB
Not Delineated to CUO
for Shallow GW
                                                 MW-312
                                                  (Deep)
                                                                                                                Legend
                                                                                                          Average Concentration
                                                                                                               Vinyl Chloride

                                                                                                           +   0.000946-0.001 mg/L

                                                                                                           O   0.001-0.002 mg/L

                                                                                                           O   0.002-0.01 mg/L

                                                                                                           •   0.01-0.015 mg/L

                                                                                                           •   0.015-0.925 mg/L


                                                                                                         	 Permeable
                                                                                                         ^^^^ Reactive Barrier

                                                                                                       Notes:
                                                                                                       1. Average concentrations for wells
                                                                                                         1999-2006.
                                                                                                       2. CUO = 0.015 mg/L;
                                                                                                         MCL = 0.002 mg/L.
                                                                                                       3. All wells screened in shallow zone
                                                                                                         of aquifer except locations indicated.
                                                                                                       4. Data source Progressive Environmental
                                                                                                         and Construction, August 2006.
                                                                                                                  (IIKH'NOWAIFR
                                                                                                           WELL SUFFICIENCY
                                                                                                            VINYL CHLORIDE
                                                                                                                PRB AREA
                                                                                                          Clare Water Treatment Site
                                                                                                               Clare, Michigan
                                                                                                           Figure 5

-------
         Legend


   Recommended Sample
          Frequency

      D   Semiannual

      •   Annual

      D   Biennial
      @   Exclude

  	  Permeable
  ^~^~  Reactive Barrier
Notes:
1. Analysis was conducted for vinyl
  chloride data between 1999 and 2006.
2. All wells screened in shallow zone
  of aquifer except locations indicated.
3. Data source Progressive Environmental
  and Construction, August 2006.
           Scale (ft)

       0     30     60
  FINAL RECOMMENDED
  MONITORING NETWORK
         PRB AREA
   Clare Water Treatment Site
        Clare, Michigan
      G-3138-105
      03/22/2007
    Figure 6
                       MV
                       MV

-------
                                                                                                                                    215
                                                                                                                                  D ND
                                                                           O
                                                                                       Do DMW-1S
                                                                                           2.9
                                 UMW-1D
                                      ND
        O SW-2
          NO DATA
                                                                                 NX/
                                                                               V
                                                                               SHALLOW ®
                                                                                                 ®
                                                                                             ®
                                                                                                         O
                                                                                                          DMW-2S
                                                                                                          0.79
                                                                           DMW-3S*
                                                                          O  23
                                                                               D
                                                                                                           ®
                                                                                                                                              216
                                                                                                                                           NO DATA
                                                                                                                  INTERMEDIATE
                                                                                                 DMW-1D
                                                                                                     ND
                                                                                                       ®
                                                                                                                                     DEEP
                                                                                                                                          DMW-2D
                                                                                                                                              ND
I


5
Q_

O
ro
     LEGEND
     DMW-1SO SHALLOW MONITORING WELL

        215 n INTERMEDIATE  MONITORING  WELL

     DMW-1D-^- DEEP MONITORING WELL

            ® PASSIVE SOIL  VENT

            © DUAL PHASE EXTRACTION WELL

         ND = NOT DETECTED
           * = CONDITIONAL RECOMMENDATION,
              SEE COMMENTS IN TABLE 7
 LEGEND
 O POTENTIAL NEW SHALLOW  MONITORING WELL

 D POTENTIAL NEW INTERMEDIATE MONITORING WELL

-^- POTENTIAL NEW DEEP MONITORING  WELL

-^—   INFERRED GROUNDWATER
        FLOW DIRECTION
NOTE:
VALUES  POSTED AT EACH WELL  LOCATION
ARE MAY 2006 TCE CONCENTRATIONS  (pg/L)
                                                                                          UMW-1S
                                                                                        O ND
RECOMMENDED SAMPLE FREQUENCY

fj SEMIANNUAL
Ll ANNUAL

D EVERY OTHER  YEAR

D EXCLUDE
T
                                                                                                                                                      DMW-3D'
                                                                                                         SW-5
                                                                                                         ND
                                        0'     30'    60'

                                         SCALE:  1"=60'
                 FIGURE 7

QUALITATIVE  EVALUATION RESULTS
       FOR  SOIL  REMEDY AREA

    Long-Term Monitoring Network Optimization
        Clare Water Supply Superfund Site
                                                                                                                                                                   Denver, Colorado

-------
      104
 (Intermediate)
(Insufficient Data)
                                         Legend
   Mann-Kendall Trend
   Trichloroethene

     •   Decreasing

     O   Probably Decreasing

     O   Stable

     O   Probably Increasing

     •   Increasing

     •   No Trend

     •   Non detect

Notes:
1. Trends were determined for
  trichloroethene data between 1999
   and 2006.
2. All wells screened in shallow zone
  of aquifer except locations indicated.
3. Data source Progressive Environmental
  and Construction, August 2006.
4. 'Well DMW-1D had one detection of
   TCE that was not reproduced - well
   may be non-detect for TCE.
                                             60
                                                    120
                                    TEMPORAL TREND
                                       RESULTS: TCE
                                   SOIL REMEDY AREA
                                      Clare Water Supply
                                        Clare, Michigan
                                    03/22/2007
                                   Figure 8
                                                       MV
                                                       MV

-------
               Area of potential
               new shallow well
                                                                             215
UMW-1D
 (Deep)  ;
                                  Shallow Flow
                                  SOU Remedy Cell    Intermediate Flow
                                                                   Deep Flow
                               UMW-1S
                                                                               t
                                                                                I—|
Area of potential
news Intermediate wells
(nested with shallow wells)
                                                                                  Area of potential
                                                                                  new Deep well
     DMW-1D
      (Deep)


     DMW-2D
   L,  (Deep)

     DMW-3D
      (Deep)
  SW-5
      /"""•.„
                                   "If
                                 104
                            (Intermediate)
                          (Insufficient Data)

                                                                                                                     SW-9 -
                                                                                                                                                    Legend
   Recommended
   Sampling Frequency


     D   Semiannual

     •   Annual

     D   Biennial

     •   Not Analyzed

     ®   Exclude

Notes:
1. Results represent a combination
  of qualitative and quantitative
  methods. See text for details.
2. Analysis was conducted for
  trichloroethene data between 1999
   and 2006.
3. Data source Progressive Environmental
  and Construction, August 2006.
                                                                                                                                                                120
                                                           FINAL RECOMMENDED
                                                           MONITORING NETWORK
                                                             SOIL REMEDY AREA
                                                               Clare Water Supply
                                                                 Clare, Michigan
                                                                                                                                                G-3138-105
                                                                                                                                               Figure 9
                                                                                                                                                                   MV
                                                                                                                                                                   MV
                                                                                                                                                                  MV

-------
     Attachment A
Geologic Cross-Sections

-------
                                                                                                                                                                                                                 O
                                                                                                                                                                                                                 m
                                                                                                                                                                                                                 O
                                                                                                                                                                                                                  I
                                                                                                                                                                                                                 r-o
                                                                                                                                 PRB WALL
                                                                                                                          K-2.3E-2GM/SEC
                                      LEGEND

                                           20     TCE (UG/L)
                                          1950   CIS-1.2-DCE (UG/L)
                                           200    VC (UG/L)
                                                                                        SCALE: HORIZONTAL: 1" =  10'
                                                                                               VERTICAL :    1" = 5'
NOTE:  ALL LOCATIONS AND THICKNESSES
      ARE APPROXIMATE.
    SURFACE ELEVATION


BORING/SAMPLE LOCATION
                                                                                                                                                        SAND (BACKFILL)
                                                                                                                                                                                 NATIVE MATERIAL
      NOTES:
1.
2.
3.
4.
          GEO  DATA FROM  JULY/AUGUST 2000
          VAS  DATA  FROM JANUARY  2005.
          SW SAMPLE FROM MAY  2000.
          BORING/SAMPLE LOCATIONS ARE
          APPROXIMATE, NOT  SURVEYED.
/Tfcf* /^Vx~^ T"» T"l O (~1 ~I"¥ 7T~l

-------
                        0
 I
GJ
CD
                                                                          0
                                                                                               °§
                                                                                               OO >•
5>
CO
 I
OJ
o
en
                                                                                                                                                o
                                                                                                                                                m
                                                                                                                                                0
                                                                                               o
                                                                                               m
                                                                                               0

                                                                                               — '
                                                                                               (D
              850
                                                                                                      850
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                      VERTICAL :   1" = 5'


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                      ARE APPROXIMATE.
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                                                                                                          APPROVED:	

                                                                                                          DATE:
                                                                                                                      2/7/05
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                                    FIGURE 6
    SOIL REMEDY
GROUNDWATER LEVEL
 CROSS-SECTION A-A'

-------
                                                                                     OCTOBER, 2004
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                                                                                                             APPROVED:	

                                                                                                             DATE:
                                                                                                                         2/7/05
                                                                                                             JOB No.:    24UN.20015.0002
                                                                                                             CAD FILE:     PRBBASE
                                                                                                                                   PREPARED BY:
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     OKEMOS, MICHIGAN
                       PREPARED FOR:
                            CLARE PRP GROUP
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                                    FIGURE 7
    SOIL REMEDY
GROUNDWATER LEVEL
 CROSS-SECTION B-B'

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    Attachment B
MAROS 2.2 Methodology

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                          ATTACHMENT B
                  MAROS 2.2 METHODOLOGY


                               Contents

1.0 MAROS Conceptual Model	1

2.0 Data Management	2

3.0 Site Details	2

4.0 Constituent Selection	3

5.0 Data Consolidation	3

6.0 Overview Statistics: Plume Trend Analysis	3
      6.1 Mann-Kendall Analysis	4
      6.2 Linear Regression Analysis	4
      6.3 Overall Plume Analysis	5
      6.4 Moment Analysis	6

7.0 Detailed Statistics: Optimization Analysis	8
      7.1 Well Redundancy Analysis- Delaunay Method	8
      7.2 Well Sufficiency Analysis - Delaunay Method	9
      7.3 Sampling Frequency - Modified CES Method	10
      7.4 Data Sufficiency- Power Analysis	11

Cited References

Tables

      Table 1 Mann-Kendall Analysis Decision Matrix
      Table 2 Linear Regression Analysis Decision Matrix
Figures
      Figure 1 MAROS Decision Support Tool Flowchart
      Figure 2 MAROS Overview Statistics Trend Analysis Methodology
      Figure 3 Decision Matrix for Determining Provisional Frequency

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GSIJobNo. G-3138-105
November 8, 2006
MAROS METHODOLOGY

MAROS is a collection of tools in one software package that is used in an explanatory,
non-linear but linked fashion. The tool includes models, statistics,  heuristic rules, and
empirical relationships to assist the user in optimizing a groundwater monitoring network
system.  The  final optimized network maintains adequate  delineation while providing
information on plume dynamics over time. Results generated from the software tool can
be used to develop lines of evidence, which, in combination  with expert opinion, can be
used to inform regulatory decisions  for  safe  and economical  long-term monitoring of
groundwater plumes.  For a detailed description of the structure of the software and
further utilities,  refer  to  the  MAROS  2.2   Manual  (AFCEE, 2003;  http://www.gsi-
net.com/software/MAROS V2 1Manual.pdf) and Aziz et al., 2003.

1.0 MAROS Conceptual  Model

In MAROS 2.2, two levels of analysis are used for optimizing  long-term monitoring plans:
1) an overview statistical  evaluation with interpretive trend analysis based on temporal
trend  analysis and  plume  stability  information;  and 2) a more detailed  statistical
optimization based on spatial and temporal redundancy reduction methods (see Figures
A.1 and A.2 for further details). In general, the MAROS method applies to 2-D aquifers
that have relatively simple site hydrogeology. However, for a multi-aquifer (3-D) system,
the user has the option to apply the statistical analysis layer-by-layer.

The overview  statistics or interpretive trend analysis  assesses the general  monitoring
system  category  by considering  individual well  concentration trends, overall  plume
stability, hydrogeologic factors (e.g.,  seepage velocity, and  current plume length), and
the location of potential receptors (e.g., property boundaries or drinking water wells). The
method relies on temporal trend analysis to assess plume stability, which is then used to
determine the general monitoring  system category.   Since  the  monitoring system
category is evaluated for both source and tail regions of the plume, the site wells are
divided into two different zones: the source zone and the tail zone.

Source  zone  monitoring  wells could include  areas  with non-aqueous  phase  liquids
(NAPLs), contaminated vadose zone soils, and areas where  aqueous-phase releases
have been introduced into ground water. The  source zone generally contains locations
with historical high ground water concentrations of the COCs. The tail zone is usually the
area downgradient of  the contaminant source zone.  Although this classification  is a
simplification of the plume conceptual model,  this  broadness makes the user aware on
an  individual   well basis  that the concentration  trend results can  have a different
interpretation depending on the well location in and around the  plume.  The location and
type of the individual wells allows further interpretation of the  trend results, depending on
what type of well  is being analyzed (e.g., remediation well, leading plume edge well, or
monitoring well).  General recommendations for the monitoring network frequency and
density are suggested based on heuristic rules applied  to the source and tail  trend
results.
Attachment B                              f                       MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
The  detailed statistics  level of analysis  or sampling  optimization  consists  of  well
redundancy and well sufficiency analyses using the Delaunay method,  a sampling
frequency analysis using the Modified Cost Effective Sampling (MCES) method and a
data sufficiency analysis  including statistical  power  analysis.  The  well  redundancy
analysis is designed  to minimize monitoring locations and the Modified CES method is
designed to minimize the frequency  of sampling.  The data sufficiency analysis uses
simple statistical methods to assess  the sampling  record to determine if groundwater
concentrations are statistically below target levels and  if the current monitoring network
and record is sufficient in terms of evaluating concentrations at downgradient locations.

2.0 Data Management

In MAROS, ground water monitoring data can be imported from simple database-format
Microsoft® Excel spreadsheets, Microsoft Access  tables,  previously created  MAROS
database archive files, or entered manually. Monitoring data interpretation in MAROS is
based  on historical  analytical data from  a  consistent set of wells  over  a series of
sampling events. The analytical  data is composed of the well name, coordinate location,
constituent, result, detection limit and associated data qualifiers. Statistical validity of the
concentration trend analysis requires  constraints on the minimum data input of at least
four  wells  (ASTM 1998)  in  which COCs have been  detected. Individual sampling
locations need to include data from at least six most-recent sampling events. To ensure
a meaningful comparison of COC concentrations over time and space, both data quality
and  data  quantity  need to be considered.  Prior to statistical analysis, the user can
consolidate  irregularly sampled data  or smooth data  that might result from seasonal
fluctuations or a change in site conditions.  Because MAROS is a terminal analytical tool
designed for long-term  planning,  impacts  of seasonal variation  in the water unit are
treated on a broad scale, as they relate to multi-year trends.

Imported ground water monitoring data and the  site-specific information entered in Site
Details can be archived and exported as MAROS archive files. These archive  files can
be appended as new monitoring data becomes available, resulting in a dynamic long-
term  monitoring  database  that  reflects  the  changing  conditions  at the site  (i.e.
biodegradation, compliance  attainment, completion  of remediation  phase,  etc.).   For
wells with a limited monitoring history,  addition  of information as it becomes available
can change the frequency or identity of wells in the network.

3.0 Site Details

Information needed for the MAROS analysis includes  site-specific parameters such as
seepage velocity and current plume  length and width. Information on the  location of
potential receptors relative to the source and tail regions of the plume is entered at this
point.  Part of the trend  analysis methodology applied in MAROS focuses on where the
monitoring well  is located, therefore the user needs  to divide site wells into two different
zones: the source zone or the tail zone. Although this classification is a simplification of
the well function, this broadness makes the user aware on an individual well basis that
the concentration trend results can have a  different  interpretation depending on the well
location in and around the plume. It is up to the user to make further interpretation of the
Attachment B                             2                       MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
trend results, depending on what type of well is being analyzed (e.g.,  remediation well,
leading  plume edge  well,  or  monitoring well).   The Site Details section  of MAROS
contains a preliminary map of well locations to confirm well coordinates.

4.0 Constituent Selection

A database  with multiple COCs can be entered into the MAROS software.  MAROS
allows the analysis of up to 5 COCs concurrently and users can pick COCs from a list of
compounds  existing in  the monitoring  data.  MAROS runs separate  optimizations for
each compound.  For sites with a single source, the suggested strategy is to choose one
to  three priority COCs for the optimization.  If, for example, the  site  contains multiple
chlorinated volatile organic compounds (VOCs), the standard sample chemical analysis
will evaluate all VOCs, so the sample  locations and frequency  should based  on the
concentration trends  of the most  prevalent,  toxic or mobile  compounds.  If different
chemical classes are present,  such  as metals and chlorinated VOCs, choose and
evaluate the priority constituent in each chemical class.

MAROS includes  a short module that provides recommendations on prioritizing COCs
based on  toxicity, prevalence, and  mobility of the compound.  The toxicity ranking is
determined  by examining  a representative concentration for each compound  for the
entire site.  The  representative concentration is then compared to the screening level
(PRG or  MCL)  for  that  compound  and  the  COCs  are  ranked according  to the
representative concentrations  percent exceedence of  the  screening  level.   The
evaluation of prevalence is performed by determining a representative concentration for
each well location and evaluating the total exceedences (values above screening levels)
compared to the total number of wells.  Compounds found over screening levels are
ranked  for mobility based on  Kd  (sorption  partition coefficient).  The MAROS  COC
assessment provides  the relative ranking of each COC, but the user must choose which
COCs are included in the analysis.

5.0 Data Consolidation

Typically, raw data from long-term monitoring have been measured irregularly in  time or
contain  many non-detects, trace level results, and duplicates. Therefore, before the data
can be further analyzed, raw data are filtered, consolidated, transformed, and possibly
smoothed to allow for a consistent dataset meeting the minimum  data requirements for
statistical analysis mentioned previously.

MAROS allows users to specify the period of interest in which data will be consolidated
(i.e., monthly, bi-monthly, quarterly,  semi-annual,  yearly,  or  a biennial  basis).  In
computing the representative  value when consolidating, one of  four  statistics can be
used:  median, geometric mean, mean,  and maximum. Non-detects can be transformed
to  one half the reporting or method detection  limit (DL), the DL, or a fraction of the DL.
Trace level results can be represented by their actual values, one half of the  DL, the DL,
or  a fraction of their actual values.  Duplicates are reduced in MAROS by one of three
ways: assigning the average, maximum, or first value. The reduced data for each  COC
Attachment B                             3                      MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
and each well can be viewed as a time series in a graphical form on a linear or semi-log
plot generated by the software.

6.0 Overview Statistics: Plume Trend Analysis

Within the MAROS software there are historical data analyses that support a conclusion
about plume stability (e.g., increasing plume, etc.) through  statistical trend analysis of
historical  monitoring data.   Plume  stability results  are  assessed from time-series
concentration data with the application  of three statistical  tools:  Mann-Kendall Trend
analysis, linear regression trend analysis and moment analysis. The two trend methods
are used to estimate the concentration trend for each well and each COC based on a
statistical  trend  analysis of concentrations  versus time at each well.  These trend
analyses are then consolidated to give the user a general plume stability estimate and
general  monitoring frequency and density recommendations (see Figures  A.1  through
A.3 for further step-by-step details).  Both qualitative and quantitative plume information
can be  gained by these evaluations of  monitoring network historical data trends both
spatially and temporally.  The  MAROS Overview Statistics are the foundation the user
needs to make informed optimization decisions at the site.  The Overview Statistics  are
designed  to  allow site personnel to develop  a better understanding of the plume
behavior over time  and  understand  how the individual well concentration trends  are
spatially distributed within the plume. This step allows the user to gain  information that
will support a more informed decision to be made in the next level or detailed statistics
optimization analysis.

6.1 Mann-Kendall Analysis

The Mann-Kendall test  is a statistical procedure that is well suited for analyzing trends in
data over time.  The Mann-Kendall test can be viewed as a non-parametric test for zero
slope of the first-order  regression of time-ordered concentration data versus time. One
advantage of the Mann-Kendall test is that it does not require any assumptions as to the
statistical distribution of the data (e.g.  normal, lognormal, etc.) and can be used with data
sets which include irregular sampling intervals and missing data.  The Mann-Kendall test
is designed for analyzing a single groundwater constituent, multiple constituents  are
analyzed separately.   The Mann-Kendall  S statistic measures  the  trend  in the data:
positive values indicate an increase in  concentrations over time  and negative values
indicate a decrease in concentrations over time. The strength of the trend is proportional
to the magnitude of the Mann-Kendall  statistic (i.e., a large  value  indicates  a strong
trend). The confidence in the trend is determined by consulting the  S statistic and  the
sample  size, n, in a Kendall probability table  such as the one reported in Hollander and
Wolfe (1973).

The concentration trend is determined for each well and each COC based on results of
the S statistic, the confidence  in  the trend, and the Coefficient of Variation (COV). The
decision matrix for this evaluation is shown in Table 3. A Mann-Kendall statistic that is
greater  than 0 combined with  a  confidence  of greater than 95%  is categorized as an
Increasing  trend while a Mann-Kendall statistic of less than 0 with a confidence between
90% and 95% is defined as a probably Increasing trend, and  so on.
Attachment B                              4                      MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
Depending  on  statistical  indicators,  the  concentration  trend is classified into six
categories:

       Decreasing (D),
       Probably Decreasing (PD),
       Stable (S),
       No Trend (NT),
       Probably Increasing (PI)
       Increasing (I).

These trend  estimates are then analyzed to identify the source and tail region  overall
stability category (see Figure 2 for further details).

6.2 Linear Regression Analysis

Linear  Regression is a  parametric statistical  procedure  that  is typically  used for
analyzing trends in data  over  time.  Using  this type  of analysis,  a  higher degree of
scatter simply corresponds to a wider confidence interval about the average log-slope.
Assuming the sign (i.e., positive or negative) of the estimated log-slope is correct, a level
of confidence that the slope is not zero can be easily determined.   Thus, despite a poor
goodness of fit, the overall trend in the data may still be ascertained, where low levels of
confidence correspond to  "Stable" or "No Trend"  conditions (depending on  the degree of
scatter) and higher levels  of confidence indicate the stronger likelihood of a  trend. The
linear regression analysis is based on the first-order  linear regression  of the log-
transformed  concentration  data versus time.   The  slope  obtained  from  this log-
transformed  regression, the  confidence level for this  log-slope, and the COV of the
untransformed data are used to determine the concentration trend.  The decision matrix
for this evaluation is shown in Table 4.

To estimate  the confidence in the log-slope,  the  standard error of the log-slope is
calculated. The coefficient of variation, defined as the standard deviation divided by the
average, is used as a secondary measure  of scatter to distinguish between "Stable" or
"No Trend" conditions for  negative slopes.  The Linear  Regression Analysis  is designed
for analyzing a single groundwater constituent;  multiple  constituents are  analyzed
separately, (up  to five COCs simultaneously).  For this evaluation, a  decision matrix
developed by Groundwater Services, Inc. is also used to determine the "Concentration
Trend" category (plume stability) for each well.

Depending  on  statistical  indicators,  the  concentration  trend is classified into six
categories:

       Decreasing (D),
       Probably Decreasing (PD),
       Stable (S),
       No Trend (NT),
       Probably Increasing (PI)
       Increasing (I).
Attachment B                              5                       MAROS 2.2 Methodology

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 GSIJobNo. G-3138-105
 November 8, 2006
 The resulting confidence in the trend, together with the log-slope and the COV of the
 untransformed data,  are  used  in the  linear  regression analysis decision  matrix to
 determine the concentration trend. For example,  a positive log-slope with a confidence
 of less than 90%  is categorized as having No Trend whereas a negative log-slope is
 considered Stable if the COV is less than 1 and categorized as No Trend if the COV is
 greater than 1.

 6.3 Overall Plume  Analysis

 General  recommendations  for  the  monitoring  network frequency  and  density  are
 suggested  based  on  heuristic  rules  applied to  the  source  and  tail trend  results.
 Individual well trend results are consolidated and weighted by the MAROS according to
 user input, and the direction and strength  of contaminant concentration trends in the
 source zone and tail zone for each COC are determined.  Based on
    i)      the consolidated trend analysis,
    ii)     hydrogeologic factors (e.g.,  seepage velocity), and
    iii)     location of  potential  receptors  (e.g.,  wells,  discharge points, or  property
           boundaries),
the software suggests a general  optimization plan for the current monitoring system in
order to efficiently but effectively monitor groundwater in  the future.  A flow chart utilizing
the trend analysis results and other site-specific parameters to form a general sampling
frequency and well density recommendation is outlined in Figure 2.   For example,  a
generic  plan  for  a  shrinking  petroleum  hydrocarbon plume  (BTEX)  in  a  slow
hydrogeologic environment (silt)  with  no nearby  receptors would entail minimal,  low
frequency sampling of just a few indicators.  On the other hand, the  generic plan for a
chlorinated solvent  plume in a fast hydrogeologic environment that is expanding but has
very  erratic concentrations over time  would entail more extensive,  higher frequency
sampling. The generic  plan is based on a heuristically derived  algorithm for assessing
future  sampling  duration,  location and density  that takes into consideration  plume
stability.  For a detailed description of  the heuristic rules used  in the  MAROS software,
refer to the MAROS 2.2Manual (AFCEE, 2003).

 6.4 Moment Analysis

 An analysis of moments can help resolve plume trends, where the zeroth moment shows
 change  in dissolved mass vs. time, the first moment shows the center of mass location
 vs. time, and the  second moment shows the spread of the plume  vs. time. Moment
 calculations can predict how the plume will change in the future if further statistical
 analysis is applied to the moments to  identify a trend (in this case, Mann Kendall Trend
 Analysis is applied). The trend analysis of moments can be summarized as:

    •  Zeroth Moment: An estimate of the total mass of the constituent for each sample
       event
    •  First Moment: An estimate of the center  of mass for each sample event
    •  Second Moment: An estimate  of the spread of the plume around the center of
       mass
 Attachment B                              6                      MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
The  role of moment analysis in  MAROS is  to provide a relative estimate of plume
stability and condition within the context of results from other MAROS modules.  The
Moment  analysis  algorithms in  MAROS are  simple approximations  of  complex
calculations  and are meant to estimate changes in  total  mass,  center of mass and
spread of mass for complex well networks.  The Moment Analysis module is sensitive to
the number and arrangement of wells in each  sampling event, so, changes in the
number and identity of wells during monitoring events, and the parameters chosen for
data consolidation can cause changes in the estimated moments.

Plume stability may vary by constituent, therefore the MAROS Moment analysis can be
used to evaluate multiple COCs simultaneously which can be used to provide a quick
way of comparing individual plume parameters to determine the size  and movement of
constituents relative to one another. Moment analysis in the MAROS software can also
be used to  assist the  user in evaluating the impact on plume  delineation  in future
sampling events by removing  identified "redundant" wells from a  long-term monitoring
program (this analysis was not performed as part of this study, for more details on this
application of moment analysis refer to the MAROS Users Manual (AFCEE, 2003)).

The zeroth moment  is the sum of concentrations for all monitoring wells and is a mass
estimate. The zeroth moment calculation can show high variability over time, largely due
to the fluctuating concentrations  at the most contaminated  wells as well as varying
monitoring  well network.  Plume analysis   and  delineation  based  exclusively  on
concentration can exhibit fluctuating temporal  and  spatial values. The mass estimate is
also  sensitive to the  extent of the site monitoring well  network over time. The zeroth
moment trend over time is determined by using the Mann-Kendall Trend Methodology.
The zeroth  Moment trend test allows the user to understand  how the plume  mass has
changed over time.  Results for the trend include: Increasing, probably Increasing, no
trend, stable, probably decreasing, decreasing  or not applicable (N/A) (Insufficient Data).
When considering the results of the zeroth moment trend, the following factors should be
considered  which could  effect the calculation and interpretation of the plume mass over
time:  1) Change in the  spatial distribution of the wells sampled historically 2) Different
wells sampled within  the well network over time (addition and subtraction of well within
the network). 3) Adequate versus inadequate delineation of the plume over time

The first moment estimates  the center of mass, coordinates (Xc and Yc)  for each
sample event and COC. The changing center  of mass locations indicate the movement
of the center of mass over time. Whereas, the  distance from the original source location
to the center of mass locations indicate the movement of the center of mass over time
relative to the original source.  Calculation of the first moment normalizes the spread by
the concentration indicating the center of mass. The first moment trend of the distance to
the center of mass over time shows  movement of the plume in relation to the original
source location over  time.  Analysis of the movement of mass should be viewed as it
relates to 1) the original  source location of contamination 2) the direction of groundwater
flow and/or 3) source removal or remediation.  Spatial and temporal trends in the center
of mass can indicate spreading or shrinking or transient movement  based on season
variation in rainfall or other hydraulic considerations.   No appreciable movement or a
neutral trend in  the center of mass would indicate  plume stability. However, changes in
Attachment B                             7                      MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
the first moment over time do not necessarily completely characterize the changes in the
concentration distribution (and  the  mass)  over time.  Therefore,  in order to  fully
characterize the plume  the  First  Moment trend  should  be compared  to  the zeroth
moment trend (mass change over time).

The second moment indicates the spread of the contaminant about the center of mass
(Sxx and Syy), or the distance of contamination from the center of mass for a particular
COC and sample event.  The Second Moment represents the spread of the plume over
time  in both the x and y  directions.  The Second Moment trend indicates the spread of
the plume about the center of mass. Analysis of the  spread  of the plume should be
viewed as it relates to the direction  of groundwater flow.  An Increasing trend in the
second moment indicates an expanding plume, whereas a declining trend in the second
moment indicates a shrinking plume. No appreciable movement or a neutral trend in the
center of mass would indicate plume stability.  The second moment provides a measure
of the  spread of the concentration distribution about the plume's center of  mass.
However, changes in the second moment over  time do not necessarily  completely
characterize the  changes in  the concentration distribution (and  the mass) over  time.
Therefore, in order to fully characterize the plume  the Second Moment trend should be
compared to the zeroth moment trend (mass change over time).

7.0 Detailed Statistics: Optimization Analysis

Although the overall  plume  analysis  shows a  general  recommendation  regarding
sampling frequency reduction and a general sampling density, a more detailed analysis
is also available with the  MAROS 2.2 software in order to allow for further reductions on
a well-by-well  basis  for  frequency,  well  redundancy, well sufficiency and sampling
sufficiency.  The  MAROS Detailed Statistics allows for a quantitative analysis for spatial
and temporal optimization of the well network on a well-by-well basis. The results from
the Overview Statistics  should  be considered along with the  MAROS optimization
recommendations gained from the Detailed Statistical Analysis  described  previously.
The MAROS Detailed Statistics results should be reassessed in view of site knowledge
and  regulatory requirements as well as  in consideration of  the Overview Statistics
(Figure 2).

The  Detailed  Statistics or Sampling Optimization MAROS modules can  be used to
determine the minimal number  of sampling locations and the  lowest frequency of
sampling that can still meet the requirements of sampling spatially and temporally for an
existing monitoring program.  It also  provides an analysis of the  sufficiency of data for
the monitoring program.

Sampling optimization in MAROS consists of four parts:

   •   Well redundancy analysis using the Delaunay method
   •   Well sufficiency analysis using the Delaunay method
   •   Sampling frequency determination using the Modified CES  method
   •   Data sufficiency analysis using statistical power analysis.
Attachment B                             g                      MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
The  well redundancy analysis using the Delaunay  method  identifies  and eliminates
redundant locations from the monitoring network.  The  well sufficiency  analysis can
determine the areas where new sampling locations might be needed.  The Modified CES
method determines the optimal sampling frequency for a sampling location  based on the
direction, magnitude, and uncertainty in  its concentration trend.  The data sufficiency
analysis examines the risk-based site cleanup status and power and expected sample
size associated with the cleanup status evaluation.

7.1 Well Redundancy Analysis - Delaunay Method

The  well redundancy analysis using the Delaunay method  is designed  to select the
minimum number of sampling locations  based on the spatial analysis of the relative
importance of each sampling location in the monitoring network.  The approach allows
elimination of sampling locations that have little impact on the historical characterization
of a  contaminant  plume.  An extended method or wells sufficiency analysis, based on
the  Delaunay method, can also  be used for  recommending new sampling locations.
Details about the Delaunay method can be found in Appendix A.2 of the MAROS Manual
(AFCEE, 2003).

Sampling Location determination  uses the Delaunay triangulation method to determine
the  significance  of the current sampling locations relative  to the  overall  monitoring
network.  The Delaunay method calculates the  network Area and Average concentration
of the plume using data from multiple monitoring wells. A  slope factor (SF) is calculated
for each well to indicate the significance of this well in the system (i.e. how removing a
well changes the average concentration.)

The Sampling  Location optimization process is performed in  a stepwise fashion.  Step
one involves assessing the significance of the well in the system, if a well has a small SF
(little significance to the network),  the well may  be removed from the monitoring network.
Step two involves evaluating the information loss of removing  a well from the network.  If
one well has a small SF, it may or may not be eliminated depending on whether the
information loss is significant. If the information  loss is not significant, the well can be
eliminated from the monitoring network and the process of optimization continues with
fewer wells.  However if the well information  loss is significant then the optimization
terminates. This  sampling optimization  process allows the user to assess "redundant"
wells that will not incur significant information loss on a constituent-by-constituent  basis
for individual sampling events.

7.2 Well Sufficiency Analysis - Delaunay Method

The well sufficiency analysis, using the Delaunay method, is designed to recommend
new  sampling locations in areas within the existing monitoring network where there is a
high  level of uncertainty in contaminant concentration.  Details about the well sufficiency
analysis can be found in Appendix A.2 of the MAROS Manual  (AFCEE, 2003).

In many cases, new sampling locations need to be  added  to the existing  network to
enhance the spatial  plume characterization.  If the MAROS algorithm calculates a high
Attachment B                             g                      MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
level of uncertainty in predicting the constituent concentration for a particular area, a new
sampling location is recommended.  The Slope Factor (SF) values obtained from the
redundancy  evaluation  described  above  are  used  to  calculate  the  concentration
estimation error for each triangle  area  formed in the Delaunay  triangulation.  The
estimated SF value for each area is then classified into four levels: Small,  Moderate,
Large, or Extremely large (S, M,  L, E)  because the larger the estimated SF value, the
higher  the estimation error  at this area.   Therefore, the  triangular areas with the
estimated SF value at the Extremely large or Large level can be candidate regions for
new sampling locations.

The results from the Delaunay method and the method for determining  new sampling
locations are derived solely from the spatial configuration of the monitoring network and
the spatial pattern of the contaminant plume.  No parameters  such as the hydrogeologic
conditions are  considered  in  the  analysis.  Therefore,  professional  judgment and
regulatory considerations must be used to make final decisions.

7.3 Sampling Frequency Determination  - Modified CES Method

The Modified CES method optimizes  sampling frequency for each sampling location
based on the magnitude, direction, and  uncertainty of its  concentration trend derived
from its  recent and historical monitoring records. The Modified Cost Effective Sampling
(MCES)  estimates a  conservative lowest-frequency  sampling  schedule for a given
groundwater monitoring location that still provides needed information for regulatory and
remedial decision-making.  The MCES  method was developed on the basis of the Cost
Effective Sampling (CES) method developed by Ridley et al  (1995). Details  about the
MCES method can be found in Appendix A.9 of the MAROS Manual (AFCEE,  2003).

In order to estimate the  least frequent  sampling schedule for a monitoring location that
still provides enough information for regulatory and remedial decision-making, MCES
employs three  steps to determine the sampling frequency.   The first step involves
analyzing frequency based on recent trends. A preliminary location  sampling frequency
(PLSF) is developed  based on the rate of change  of well concentrations calculated  by
linear regression along with the Mann-Kendall  trend  analysis of the  most  recent
monitoring data (see Figure 3).  The variability within the sequential sampling data  is
accounted for by the Mann-Kendall analysis.  The rate of change vs. trend result matrix
categorizes wells as requiring annual, semi-annual  or quarterly sampling.  The PLSF  is
then reevaluated  and adjusted based  on overall  trends.   If the long-term  history of
change  is significantly greater than the recent trend, the frequency  may be reduced  by
one level.

The final step  in the analysis involves reducing frequency based on risk, site-specific
conditions, regulatory requirements or other external issues.  Since not all compounds  in
the target being assessed are equally harmful, frequency  is reduced by one level  if
recent  maximum  concentration for a compound of high risk is less than  1/2  of the
Maximum Concentration Limit (MCL). The result of applying this method is a suggested
sampling frequency based on recent sampling  data trends and overall sampling data
trends and expert judgment.
Attachment B                             fQ                     MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
The  final sampling  frequency  determined from the MCES method  can be Quarterly,
Semiannual, Annual, or Biennial.  Users can further reduce the sampling frequency to,
for example, once every three years, if the trend estimated from Biennial data (i.e., data
drawn once every two years from the original data) is the same as that estimated from
the original data.

7.4 Data Sufficiency Analysis - Power Analysis

The  MAROS Data Sufficiency module  employs simple statistical methods to evaluate
whether the collected data are adequate  both in quantity and in quality  for revealing
changes in constituent concentrations.   The first section of the  module evaluates
individual  well  concentrations to determine  if they are  statistically  below a  target
screening  level.  The  second section includes  a simple calculation for estimating
projected groundwater concentrations at a specified point downgradient of the plume.  A
statistical Power analysis is then applied to the projected concentrations to determine if
the downgradient concentrations  are statistically below the cleanup standard.  If the
number of  projected concentrations is below the level to provide statistical significance,
then the number of sample events required to statistically confirm concentrations below
standards is estimated from the Power analysis.

Before testing  the  cleanup status for individual wells, the stability  or  trend of the
contaminant plume should be evaluated. Only after the plume has reached stability or is
reliably  diminishing  can we conduct a test to examine the cleanup  status of wells.
Applying the analysis to wells  in an expanding plume may cause incorrect conclusions
and is less meaningful.

Statistical power analysis  is a technique  for interpreting the results  of statistical tests.
The  Power of a statistical  test  is a measure of the  ability of the test  to detect an effect
given that the effect actually exists. The method provides additional information about a
statistical  test:  1) the  power  of  the statistical test, i.e.,  the probability  of finding a
difference in the variable of interest when a difference truly exists; and 2) the expected
sample  size of a future sampling plan given the minimum detectable difference  it is
supposed to detect.  For example, if the mean concentration is lower than the cleanup
goal  but a statistical test cannot prove this, the power and expected sample size can tell
the reason and how many more samples  are needed to result in a significant test.  The
additional samples can be obtained  by a longer period of sampling or an increased
sampling frequency.   Details  about the  data sufficiency  analysis  can  be found  in
Appendix A.6 of the  MAROS Manual (AFCEE,  2003).

When applying the MAROS power analysis method, a hypothetical statistical compliance
boundary (HSCB)  is  assigned to be  a line  perpendicular to  the  groundwater  flow
direction (see  figure below).  Monitoring well concentrations are projected onto the
HSCB using the distance from  each well to the compliance boundary along with a decay
coefficient.  The projected concentrations from each well and each sampling event are
then used in the risk-based power analysis. Since there may be more  than one sampling
event selected by the user, the risk-based power analysis results are given on an event-
Attachment B                              77                      MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
by-event basis. This power analysis can then indicate if target are statistically achieved
at the HSCB.  For instance, at a site where the historical monitoring record is short with
few wells,  the HSCB  would be  distant;  whereas, at a site with longer duration of
sampling with many wells, the HSCB would be close.  Ultimately,  at a site the goal would
be to  have the  HSCB coincide  with  or  be within  the  actual  compliance boundary
(typically the site property line).
                                "HSCB"
   Concentrations
   projected to this
-"line
           e>
                                                            The nearest
                                                            downgradient
                                                            receptor
                Groundwater flow direction
In order to perform a risk-based cleanup status evaluation for the whole site, a strategy
was developed as follows.

    •   Estimate  concentration versus distance decay coefficient from plume centerline
       wells.
    •   Extrapolate  concentration versus  distance for each  well  using  this  decay
       coefficient.
    •   Comparing  the extrapolated concentrations with the compliance concentration
       using power analysis.

Results from  this  analysis  can be  Attained or  Not Attained, providing  a statistical
interpretation of whether the cleanup goal has been met on  the site-scale from the risk-
based  point of view.  The results as a function of time can be used to evaluate if the
monitoring system has enough power at each step in  the  sampling record to indicate
certainty of compliance by the plume location and condition relative to the  compliance
boundary.  For example, if results are Not Attained at early sampling events but are
Attained in recent sampling events, it indicates that the  recent sampling record provides
a powerful enough result to indicate compliance of the  plume relative to the location of
the receptor or compliance boundary.
Attachment B
                                       12
                                                              MAROS 2.2 Methodology

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GSIJobNo. G-3138-105
November 8, 2006
CITED REFERENCES

AFCEE 2003. Monitoring and Remediation Optimization System (MAROS) 2.1 Software
Users  Guide.  Air  Force  Center  for  Environmental  Excellence,  http://www.gsi-
net.com/software/MAROS  V2 1Manual.pdf

AFCEE. 1997.  Air Force Center for Environmental  Excellence,  AFCEE Long-Term
Monitoring Optimization Guide, http://www.afcee.brooks.af.mil.

Aziz, J. A., C. J. Newell, M.  Ling, H.  S. Rifai and J. R. Gonzales (2003). "MAROS:  A
Decision Support System  for Optimizing Monitoring Plans."  Ground Water 41(3): 355-
367.

Gilbert, R. O., 1987,  Statistical Methods  for Environmental Pollution Monitoring, Van
Nostrand Reinhold, New York, NY, ISBN 0-442-23050-8.

Hollander,  M. and Wolfe, D.  A. (1973).  Nonparametric Statistical Methods, Wiley, New
York, NY.

Ridley, M.N.  et al., 1995. Cost-Effective Sampling of Groundwater Monitoring Wells, the
Regents of UC/LLNL, Lawrence Livermore National Laboratory.

U.S. Environmental Protection Agency, 1992. Methods for Evaluating the Attainment  of
Cleanup Standards Volume 2: Ground Water.

Weight, W. D. and J. L. Sonderegger (2001). Manual of Applied Field Hydrogeology.
New York,  NY, McGraw-Hill.
Attachment B                             73                     MAROS 2.2 Methodology

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 If
GROUNDWATER
SERVICES, INC.
Mann-Kendall
Mann-Kendall
Statistic
S>0
S>0
S>0
S<0
S<0
S<0
S<0
TABLE 1
Analysis Decision Matrix
Confidence in the
Trend
> 95%
90 - 95%
< 90%
< 90% and COV > 1
< 90% and COV < 1
90 - 95%
> 95%
(Aziz, et. al., 2003)
Concentration Trend
Increasing
Probably Increasing
No Trend
No Trend
Stable
Probably Decreasing
Decreasing
Linear Regression
Confidence in the
Trend
< 90%
90 - 95%
> 95%
TABLE 2
Analysis Decision Matrix (Aziz, et. al., 2003)
Log-slope
Positive Negative
COV < 1 Stable
No Trend
COV > 1 No Trend
Probably Increasing Probably Decreasing
Increasing Decreasing

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                                                                                             If
                                                                                           GROUNDWATER
                                                                                           SERVICES, INC.
                                   MAROS: Decision Support Tool
    MAROS is a collection of tools in one software package that is used in an explanatory, non-linear fashion.  The tool
    includes  models,  geostatistics, heuristic rules, and empirical  relationships  to  assist  the  user  in  optimizing  a
    groundwater monitoring network system while maintaining adequate delineation of the plume as well as knowledge
    of the plume state over time. Different users utilize the tool in different ways and interpret the results from a different
    viewpoint.
                                                   T
                                          Overview Statistics
    What it is: Simple, qualitative and quantitative plume information can be gained through evaluation of monitoring
    network historical data trends both spatially and temporally. The MAROS Overview Statistics are the foundation the
    user needs to make informed optimization decisions at the site.

    What it does: The Overview Statistics are designed to allow site personnel to develop a better understanding of the
    plume behavior over time and understand how the individual well concentration trends are spatially distributed within
    the plume. This step allows the user to gain information that will support a more informed decision to be made in the
    next level of optimization analysis.

    What are the tools: Overview Statistics includes two analytical tools:

         1)  Trend Analysis: includes Mann-Kendall and Linear Regression statistics for individual wells and results in
             general  heuristically-derived monitoring categories with  a suggested sampling  density and monitoring
             frequency.

         2)   Moment Analysis: includes dissolved mass  estimation (0th Moment), center of mass (1st Moment), and
             plume spread (2nd  Moment) over  time.  Trends of these moments show  the  user another piece of
             information about the plume stability overtime.

    What is the  product: A first-cut blueprint for a  future long-term  monitoring program that  is intended to be a
    foundation for more detailed statistical analysis.
                                                   T
                                          Detailed Statistics
    What it is: The MAROS Detailed Statistics allows for a quantitative analysis for spatial and temporal optimization of
    the well network on a well-by-well basis.

    What it does: The results from the Overview Statistics should be considered along side the MAROS optimization
    recommendations gained from the  Detailed Statistical Analysis.  The MAROS Detailed Statistics results should be
    reassessed in view of site knowledge and regulatory requirements as well as the Overview Statistics.

    What are the tools: Detailed Statistics includes four analytical tools:

         1)   Sampling Frequency Optimization: uses the Modified CES method to establish a recommended future
             sampling frequency.

         2)   Well Redundancy Analysis: uses the Delaunay Method to evaluate if any wells within the monitoring
             network are redundant and can be eliminated without any significant loss of plume information.

         3)   Well  Sufficiency Analysis: uses  the Delaunay  Method  to  evaluate areas  where new  wells  are
             recommended within the monitoring network due to high levels of concentration uncertainty.

         4)  Data Sufficiency Analysis: uses Power Analysis to assess if the historical monitoring data record  has
             sufficient power to  accurately  reflect the location of the plume  relative  to the  nearest receptor or
             compliance point.

    What is the product:  List of wells to remove from the monitoring program, locations where monitoring wells may
    need to be added, recommended frequency of sampling for each well, analysis if the  overall system is statistically
    powerful to monitor the plume.	
Figure 1.  MAROS Decision Support Tool Flow Chart

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                                                                                       GROUNDWATER
                                                                                       SERVICES, INC.
                           Select Representative Wells in "Source" and "Plume" Zone
                                           Source Zone   i Tail Zone

                           Identify Site Constituents of Concern (COCs).
                           (Assistance provided by software.)


                           Analyze Lines of Evidence (LOEs)
                           for Plume Stability (by well and by COC)
                           Categorize concentrations of COC in each well as:

                                    • Increasing (I)   	
                                    • Probably Increasing (PI)    	
                                    • No Trend (NT)
                                    • Stable (S)
                                    • Probably Decreasing (PD)    	
                                    • Decreasing (D)  	
                            Determine General Trend
                            for Each Well Based On All
                            LOE's
SOURCE   PLUME
                           "Lump Lines of Evidence"
                            Determine General Trend for Source and
                            Tail Zones

                                  Increasing (I)
                                  Probably Increasing (PI)
                                  No Trend (NT)
                                  Stable  (S)
                                  Probably Decreasing (PD)
                                  Decreasing (D)

                             "Lump Wells" in Source and Tail Zone
                           Determine
                           LTMP
                           Monitoring
                           Category
                           for COC By
                           Source / Tail
                           
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                                                                GROUNDWATER
                                                                SERVICES, INC.
       Sampling
       Frequency
       Q: Quarterly
       S: SemiAimual
       A: Annual
0>
CE3
T3

I
    PI
        Rate of Change (Linear Regression)
          High  MH  Medium  LM   Low
Figure 3.  Decision Matrix for Determining Provisional Frequency (Figure A.3.1 of the
         MAROS Manual (AFCEE 2003)

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 Attachment C
MAROS Reports

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March 22, 2007
ATTACHMENT C:
                              LONG-TERM
                  MONITORING NETWORK OPTIMIZATION
                     PRB AND SOIL REMEDY AREAS

                     Clare Water Supply Superfund Site
                             Clare, Michigan
MAROS Reports

PRB Area:
      COC Assessment Report
      Mann-Kendall Reports Selected Wells
      (Including data from November 2006 monitoring event)
So/7 Remedy Area:
      COC Assessment Report
      Mann-Kendall Reports Selected Wells

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 MAROS   COC Assessment
 Project:   Clare Water Supply

 Location:  Clare

 Toxicitv:
   User Name:  MV

   State:   Michigan
Contaminant of Concern
VINYL CHLORIDE
cis-1 ,2-DICHLOROETHYLENE
Representative
Concentration
(mg/L)
1.2E-01
6.9E-02
PRG
(mg/L)
1.5E-02
6.1E-02
Percent
Above
PRG
713.2%
12.9%
  Note: Top COCs by toxicity were determined by examining a representative concentration for each compound over the entire site. The
  compound representative concentrations are then compared with the chosen PRG for that compound, with the percentage excedence from
  the PRG determining the compound's toxicity. All compounds above exceed the PRG.


 Prevalence:
Contaminant of Concern
VINYL CHLORIDE
cis-1 ,2-DICHLOROETHYLENE
Class
ORG
ORG
Total
Wells
16
16
Total
Excedences
10
3
Percent
Excedences
62.5%
18.8%
Total
detects
15
13
  Note: Top COCs by prevalence were determined by examining a representative concentration for each well location at the site. The
  total excedences (values above the chosen PRGs) are compared to the total number of wells to determine the prevalence of the
  compound.
 Mobility:

 Contaminant of Concern
                                            Kd
 VINYL CHLORIDE

 cis-1,2-DICHLOROETHYLENE
 0.042

0.0724
   Note: Top COCs by mobility were determined by examining each detected compound in the dataset and comparing their
   mobilities (Koc's for organics, assume foe = 0.001, and Kd's for metals).
 Contaminants of Concern (COC's)


        VINYL CHLORIDE

        cis-1,2-DICHLOROETHYLENE
MAROS Version 2.2, 2006, AFCEE
                                                 Tuesday, November 07, 2006
                                                                                                     Page 1 of 1

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 MAROS  Statistical  Trend Analysis  Summary
Project:   Clare
Location:  Clare
                   User Name:  MV
                   State:  Michigan
Time Period:  3/23/1994  to 11/10/2006
 Consolidation Period: No Time Consolidation
 Consolidation Type: Median
 Duplicate Consolidation:  Average
 ND Values: Specified Detection Limit
 J Flag Values :  Actual Value
Well
Source/
Tail
Number Number
of of
Samples Detects
Average Median
Cone. Cone.
(mg/L) (mg/L)
All
Samples
"ND" ?
Mann-
Kendall
Trend
Linear
Regression
Trend
cis-1 ,2-DICHLOROETHYLENE
220
300A
300B
300C
MW-301
MW-302
MW-303
MW-304
MW-305
MW-306
Mw-307
MW-308
Mw-309
MW-310
MW-311
MW-312
MW-313
SW-11
SW-12
VINYL CHLORIDE
220
300A
300B
300C
MW-301
MW-302
MW-303
MW-304
MW-305
MW-306
Mw-307
MW-308
Mw-309
MW-310
T
S
s
S
T
S
T
T
S
T
T
T
T
T
T
T
T
T
T

T
S
S
S
T
S
T
T
S
T
T
T
T
T
31
15
13
13
5
5
5
5
5
5
5
5
5
5
5
5
5
10
12

35
16
14
14
6
6
6
6
6
6
6
6
6
6
6
15
13
2
3
4
5
5
5
2
0
5
5
1
5
1
1
0
0

1
16
14
9
5
6
6
6
6
6
5
6
6
6
1.3E-03
4.1E-01
5.6E-03
5.8E-04
8.8E-04
4.0E-02
4.9E-01
4.8E-03
1.2E-01
1.2E-03
5.0E-04
8.4E-03
3.3E-03
6.6E-04
2.0E-02
5.4E-04
6.0E-04
5.0E-04
5.0E-04

9.8E-04
8.8E-01
6.1E-02
8.0E-03
1.2E-03
6.8E-02
5.2E-01
2.0E-02
1.5E-01
4.5E-03
1.1E-02
3.8E-02
2.1E-02
1.7E-02
5.0E-04
2.7E-01
5.5E-03
5.0E-04
7.3E-04
3.1E-02
6.1E-02
4.6E-03
1.1E-01
5.0E-04
5.0E-04
5.8E-03
2.4E-03
5.0E-04
8.9E-03
5.0E-04
5.0E-04
5.0E-04
5.0E-04

1 .OE-03
7.2E-01
3.6E-02
1 .3E-03
1 .3E-03
5.7E-02
1.2E-01
1 .9E-02
1.5E-01
2.3E-03
9.1E-03
3.6E-02
1 JE-02
2.0E-02
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
Yes
Yes

No
No
No
No
No
No
No
No
No
No
No
No
No
No
NT
S
I
S
S
D
NT
S
S
NT
S
S
NT
S
NT
S
NT
S
S

S
I
I
I
S
S
D
PD
S
D
S
S
S
NT
NT
NT
I
S
S
PD
D
S
S
NT
I
S
S
S
NT
S
NT
D
D

PD
PI
I
I
D
NT
D
D
NT
D
S
S
D
NT
MAROS Version 2.2, 2006, AFCEE
Monday, December 18, 2006
                                                                               Page 1 of 2

-------
 MAROS  Statistical  Trend Analysis Summary

Source/
Well Tai,
Number
of
Samples
Number
of
Detects
Average
Cone.
(mg/L)
Median
Cone.
(mg/L)
All
Samples
"ND" ?
Mann-
Kendall
Trend
Linear
Regression
Trend
VINYL CHLORIDE
MW-311
MW-312
MW-313
SW-11
SW-12
T
T
T
T
T
6
6
6
12
14
6
0
1
0
1
2.8E-02
1.0E-03
9.6E-04
1.0E-03
1.0E-03
2.2E-02
1.0E-03
1 .OE-03
1.0E-03
1 .OE-03
No
Yes
No
Yes
No
S
S
NT
S
S
PD
S
NT
S
D
Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable
(N/A); Not Applicable (N/A) - Due to insufficient Data (< 4 sampling events); No Detectable Concentration (NDC)

    The Number of Samples and Number of Detects shown above are post-consolidation values.
MAROS Version 2.2, 2006, AFCEE
Monday, December 18, 2006
Page 2 of 2

-------
 MAROS Mann-Kendall Statistics Summary
Well: 300A
Well Type: s
COC: VINYL CHLORIDE
Time Period:          to
Consolidation Period: Other
Consolidation Type: Maximum
Duplicate Consolidation: First
ND Values: Specified Detection Limit
J Flag Values : Fraction of Actual Value

3.0E+00 •
|) 2.5E+00 •
§ 2.0E+00 -
S 1.5E+00 -
c
01
c 1.0E+00 -
o
O
5.0E-01 •
Data Table:

^> ^ <^


• • *
* * *


Effective
Well Well Type Date
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
12/12/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/29/2002
4/22/2003
10/21/2003
4/27/2004
10/27/2004
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/15/2006
11/15/2006
Date
^f ^f ^ ^P4 ^
•
^ *
* * * *
• »
•



0 Mann Kendall S Statistic:
I 41
Confidence in
Trend:
1 96.5%
Coefficient of Variation:
I °75
Mann Kendall
Concentration Trend:
(See Note)
I '

Number of Number of
Constituent Result (mg/L) Flag Samples Detects
VINYL CHLORIDE 2.9E-01
VINYL CHLORIDE 3.3E-01
VINYL CHLORIDE 6.6E-01
VINYL CHLORIDE 3.9E-01
VINYL CHLORIDE 7.0E-01
VINYL CHLORIDE 7.3E-01
VINYL CHLORIDE 9.8E-01
VINYL CHLORIDE 9.0E-01
VINYL CHLORIDE 9.4E-01
VINYL CHLORIDE 9.4E-01
VINYL CHLORIDE 1.4E+00
VINYL CHLORIDE 1.5E+00
VINYL CHLORIDE 3.0E+00
VINYL CHLORIDE 5.5E-01
VINYL CHLORIDE 6.1E-01
VINYL CHLORIDE 2.2E-01
2 2
1 1
1 1
1 1
2 2
1 1
1 1
1 1
1 1
1 1
1 1
1 1
2 2
1 1
1 1
1 1
Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                              3/19/2007
                     Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics  Summary
Well: 300B
Well Type: s
COC: VINYL CHLORIDE
Time Period:          to
Consolidation Period: Other
Consolidation Type: Maximum
Duplicate Consolidation: First
ND Values:  Specified Detection Limit
J Flag Values : Fraction of Actual Value


2tF 01
.%)C~U 1
^ 2.0E-01 -
E
c 1.5E-01 •
o
1
•£ 1.0E-01 •
8
c
0 5.0E-02 •
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
300B S
300B S
300B S
300B S
300B S
300B S
300B S
300B S
300B S
300B S
300B S
300B S
300B S
300B S
Date
0°° v^ oo& eft" «$?^ eft" $ r&" $ eft"
^ ^ ^




•
.•...'••'*


Effective
pe Date Constituent
12/12/1999 VINYL CHLORIDE
6/28/2000 VINYL CHLORIDE
12/6/2000 VINYL CHLORIDE
10/30/2001 VINYL CHLORIDE
5/1/2002 VINYL CHLORIDE
10/29/2002 VINYL CHLORIDE
4/22/2003 VINYL CHLORIDE
10/21/2003 VINYL CHLORIDE
4/27/2004 VINYL CHLORIDE
10/27/2004 VINYL CHLORIDE
5/24/2005 VINYL CHLORIDE
11/9/2005 VINYL CHLORIDE
5/15/2006 VINYL CHLORIDE
11/15/2006 VINYL CHLORIDE

^ .o4 ^j& .vj*
*• «• ^

•

• *




Result (mg/L) Flag
1.4E-02
2.0E-02
7.2E-03
3.6E-03
1.0E-02
2.4E-02
3.4E-02
3.7E-02
6.2E-02
4.8E-02
1.1E-01
1.4E-01
2.0E-01
1.4E-01
Mann Kendall S Statistic:

I 71
Confidence in
Trend:
1 100.0%
Coefficient of Variation:
I 1'02
Mann Kendall
Concentration Trend:
(See Note)
I '

Number of Number of
Samples Detects
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     3/19/2007
                        Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics  Summary
Well: 300C
Well Type: T
COC: VINYL CHLORIDE
Time Period:          to
Consolidation Period: Other
Consolidation Type: Maximum
Duplicate Consolidation: First
ND Values:  Specified Detection Limit
J Flag Values : Fraction of Actual Value
3.0E-02 -
__ 2.5E-02 -
_j
,§ 2.0E-02 •
c
| 1.5E-02-
§ 1.0E-02-
o
0 5.0E-03 -
O.OE+00 •
Data Table:
Date

-------
 MAROS Mann-Kendall Statistics  Summary
Well: MW-303
Well Type:  s
COC: VINYL CHLORIDE
                                                  Time Period:           to
                                                  Consolidation Period: Other
                                                  Consolidation Type:  Maximum
                                                  Duplicate Consolidation: First
                                                  ND Values: Specified Detection Limit

                                                  J Flag Values : Fraction of Actual Value
                                       Date
o
1
I
o
o

1.6E+00 -
1.4E+00 -
1.2E+00 •
1.0E+00 •
8.0E-01 •
6.0E-01 -
4.0E-01 -
2.0E-01 -
n np4-nn .
/ / / / / /
»


*




* * * •
                                                                               Mann Kendall S Statistic:
                                                                               Confidence in
                                                                               Trend:
                                                                                    I   97.2%

                                                                               Coefficient of Variation:
                                                                                        1.29
                                                                               Mann Kendall
                                                                               Concentration Trend:
                                                                               (See Note)
 Data Table:
Well
MW-303
MW-303
MW-303
MW-303
MW-303
MW-303
Well Type
s
s
s
s
s
s
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/15/2006
11/15/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
1.6E+00
1.1E+00
9.1E-02
1.2E-01
1.1E-01
7.6E-02
Number of
Samples
1
1
1
1
1
1
Number of
Detects
1
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       3/19/2007
                                                                           Page 1 of 1

-------
 MAROS Mann-Kendall Statistics  Summary
Well: MW-304
Well Type:  T
COC: VINYL CHLORIDE
Time Period:           to
Consolidation Period:  Other
Consolidation Type: Maximum
Duplicate Consolidation: First
ND Values: Specified Detection Limit
J Flag Values :  Fraction of Actual Value
                                       Date

_j
1
o
1
Concen

4.0E-02 -
3.5E-02 -
3.0E-02 •
2.5E-02 •
2.0E-02 •
1.5E-02-
1.0E-02-
5.0E-03 -
n np4-nn .
•


*
•

*
                                                                               Mann Kendall S Statistic:
                                                                               Confidence in
                                                                               Trend:
                                                                                    I   93.2%

                                                                               Coefficient of Variation:
                                                                                        0.68
                                                                               Mann Kendall
                                                                               Concentration Trend:
                                                                               (See Note)

                                                                                   [    PD
 Data Table:
Well
MW-304
MW-304
MW-304
MW-304
MW-304
MW-304
Well Type
T
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/15/2006
11/15/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
4.1E-02
2.8E-02
8.5E-03
1.8E-02
2.0E-02
3.7E-03
Number of
Samples
1
1
1
1
1
1
Number of
Detects
1
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       3/19/2007
                         Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: MW-305
Well Type: s
COC: VINYL CHLORIDE
Time Period:  1/1/1999    to 11/15/2006
Consolidation Period: No Time Consolidation
Consolidation Type:  Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit

J Flag Values : Actual Value
                                 Date
    O)


    o
    2   0.1 -
    o
    O
       0.01
                                                                                Mann Kendall S Statistic:
                                                                                Confidence in
                                                                                Trend:
                          I   57.0%

                     Coefficient of Variation:
                                                                                         0.63
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
 Data Table:
Well
MW-305
MW-305
MW-305
MW-305
MW-305
MW-305
Well Type
s
s
s
s
s
s
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/15/2006
11/15/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
2.4E-01
6.8E-02
2.3E-02
2.4E-01
1.9E-01
1.1E-01
Number of
Samples
1
1
1
1
1
1
Number of
Detects
1
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        3/19/2007
                          Page 1 of 1

-------
 MAROS Mann-Kendall Statistics  Summary
Well: MW-306
Well Type:  T
COC: VINYL CHLORIDE
                                                  Time Period:           to
                                                  Consolidation Period: Other
                                                  Consolidation Type:  Maximum
                                                  Duplicate Consolidation: First
                                                  ND Values: Specified Detection Limit

                                                  J Flag Values : Fraction of Actual Value
                                       Date
         o
         1
I
o
o

1.4E-02-
1.2E-02-
1.0E-02-
8.0E-03 •
6.0E-03 -
4.0E-03 •
2.0E-03 -
n np4-nn .
/ / / / / /
*




*
* * *

                                                                               Mann Kendall S Statistic:
                                                                               Confidence in
                                                                               Trend:
                                                                                    I   99.2%

                                                                               Coefficient of Variation:
                                                                                        1.17
                                                                               Mann Kendall
                                                                               Concentration Trend:
                                                                               (See Note)
 Data Table:
Well
MW-306
MW-306
MW-306
MW-306
MW-306
MW-306
Well Type
T
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/15/2006
11/15/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
1.5E-02
4.4E-03
2.4E-03
2.0E-03
2.1E-03
1.1E-03
Number of
Samples
1
1
1
1
1
1
Number of
Detects
1
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       3/19/2007
                                                                           Page 1 of 1

-------
 MAROS Mann-Kendall Statistics  Summary
Well: Mw-307
Well Type:  T
COC: VINYL CHLORIDE
    Time Period:           to
    Consolidation Period:  Other
    Consolidation Type: Maximum
    Duplicate Consolidation: First
    ND Values: Specified Detection Limit

    J Flag Values :  Fraction of Actual Value
                                       Date
                        A'
.<*'

_J
E
itration
Concer
3.0E-02 •
2.5E-02 •
2.0E-02 -
1.5E-02-
1.0E-02-
5.0E-03 •
n np4-nn .
*


* *
                                                                               Mann Kendall S Statistic:
                                                                                Confidence in
                                                                                Trend:
                                                                                    I   76.5%

                                                                               Coefficient of Variation:
                                                                                        0.99
                                                                               Mann Kendall
                                                                               Concentration Trend:
                                                                               (See Note)
 Data Table:
Well
Mw-307
Mw-307
Mw-307
Mw-307
Mw-307
Mw-307
Well Type
T
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/15/2006
11/15/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
3.3E-02
1.1E-02
1.0E-03 ND
5.0E-03
1.0E-02
8.1E-03
Number of
Samples
1
1
1
1
1
1
Number of
Detects
1
1
0
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       3/19/2007
                             Page 1 of 1

-------
 MAROS Mann-Kendall Statistics  Summary
Well: MW-308
Well Type:  T
COC: VINYL CHLORIDE
           Time Period:           to
           Consolidation Period:  Other
           Consolidation Type: Maximum
           Duplicate Consolidation:  First
           ND Values: Specified Detection Limit

           J Flag Values :  Fraction of Actual Value
                                       Date
^

_J
E
itration
Concer
6.0E-02 •
5.0E-02 •
4.0E-02 -
3.0E-02 -
2.0E-02 -
1.0E-02-
n np4-nn .



* *
                                                                               Mann Kendall S Statistic:
                                                                               Confidence in
                                                                               Trend:
                                                                                    I   64.0%

                                                                               Coefficient of Variation:
                                                                                        0.45
                                                                               Mann Kendall
                                                                               Concentration Trend:
                                                                               (See Note)
 Data Table:
Well
MW-308
MW-308
MW-308
MW-308
MW-308
MW-308
Well Type
T
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/15/2006
11/15/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
5.5E-02
2.6E-02
2.3E-02
4.5E-02
5.8E-02
2.0E-02
Number of
Samples
1
1
1
1
1
1
Number of
Detects
1
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       3/19/2007
                                    Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: Mw-309
Well Type: T
COC: VINYL CHLORIDE
                                                   Time Period:           to
                                                   Consolidation Period: Other
                                                   Consolidation Type:  Maximum
                                                   Duplicate Consolidation: First
                                                   ND Values: Specified Detection Limit

                                                   J Flag Values : Fraction of Actual Value
                                       Date
    6.0E-02


_   5.0E-02
_j

,§   4.0E-02


|   3.0E-02
g   2.0E-02
o
0   1.0E-02-

    0.
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                                                                                      I   64.0%

                                                                                Coefficient of Variation:
                                                                                         0.75
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
 Data Table:
Well
Mw-309
Mw-309
Mw-309
Mw-309
Mw-309
Mw-309
Well Type
T
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/15/2006
11/15/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
4.8E-02
1.4E-02
1.6E-02
1.8E-02
2.5E-02
2.2E-03
Number of
Samples
1
1
1
1
1
1
Number of
Detects
1
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        3/19/2007
                                                                             Page 1 of 1

-------
 MAROS   COC Assessment
 Project:   Soil Remedy

 Location:  Clare

 Toxicitv:


 Contaminant of Concern
           User Name:  MV

           State:   Michigan
Representative
Concentration
    (mg/L)
 PRG
(mg/L)
Percent
Above
 PRG
 TRICHLOROETHYLENE (TCE)
                                       5.3E-03
                                                       5.0E-03
                                                                      6.9%
  Note: Top COCs by toxicity were determined by examining a representative concentration for each compound over the entire site. The
  compound representative concentrations are then compared with the chosen PRG for that compound, with the percentage excedence from
  the PRG determining the compound's toxicity. All compounds above exceed the PRG.


 Prevalence:
Contaminant of Concern
Class
Total
Wells
Total
Excedences
Percent
Excedences
Total
detects
 TRICHLOROETHYLENE (TCE)
                                         ORG
                                                       8
                                                                                 25.0%
  Note: Top COCs by prevalence were determined by examining a representative concentration for each well location at the site. The
  total excedences (values above the chosen PRGs) are compared to the total number of wells to determine the prevalence of the
  compound.
 Mobility:

 Contaminant of Concern
                                            Kd
 TRICHLOROETHYLENE (TCE)
                                              0.297
   Note: Top COCs by mobility were determined by examining each detected compound in the dataset and comparing their
   mobilities (Koc's for organics, assume foe = 0.001, and Kd's for metals).
 Contaminants of Concern (COC's)


        VINYL CHLORIDE

        TRICHLOROETHYLENE (TCE)

        cis-1,2-DICHLOROETHYLENE
MAROS Version 2.2, 2006, AFCEE
                                                  Saturday, October 28, 2006
                                                                                                     Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: UMW-1S
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T

«S?^ v^o^'v^o^
^ >   ^r ^3>










Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I °
Confidence in
Trend"

I 48.0%
Coefficient of Variation:
1 0.00

Mann Kendall
Concentration Trend:
(See Note)
I S

Number of Number of
Samples Detects
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-1S
Well Type:  s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/24/1999   to 5/16/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op m
I .^C-U I •
_ 1.0E-01 -
£ 8.0E-02 -
c
s 6.0E-02 •

§ 4.0E-02 -
o
0 2.0E-02 -
O.OE+00 •
Data Table:
Well Well Ty
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S

«S?^ ^^o^'^^o12
^ > V > V

•

•


* * *


Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
/*s£' Wv^ XX^' ^f XX^' ^f S^*1
^ 7* V*









Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

.J^jvO ^j^
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Result (mg/L) Flag
9.9E-02
6.7E-02
1.4E-02
1.3E-02
1.0E-02
9.0E-03
7.0E-03
7.0E-03
9.0E-03
4.0E-03
4.0E-03
4.0E-03
4.0E-03
3.2E-03
2.9E-03
Mann Kendall S Statistic:
_

Confidence in
Trend:
1 100.0%
Coefficient of Variation:
I 1'61

Mann Kendall
Concentration Trend:
(See Note)
I °

Number of Number of
Samples Detects
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/28/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: DMW-1S
Well Type:  s
COC: cis-1,2-DICHLOROETHYLENE
Time Period: 3/24/1999   to 5/16/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


2nc ni
.UE-U I •
1.8E-01 -
;;[• 1.6E-01 -
|" 1.4E-01 -
r 1.2E-01 •
o
s 1.0E-01 •
i 8.0E-02 •
| 6.0E-02 •
0 4.0E-02 •
2.0E-02 •

Data Table:
Well Well Ty
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S

«S?^ v^o^'v^o^
^ >  
•


Constituent
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE

.J^jvO ^j^
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Result (mg/L) Flag
2.4E-02
8.0E-03
4.0E-03
3.0E-03
2.3E-02
6.7E-02
6.0E-03
1.8E-01
2.0E-02
9.0E-03
5.0E-03
9.3E-02
5.9E-03
5.5E-03
2.9E-03
Mann Kendall S Statistic:

I ^?9
Confidence in
Trend:
1 81 .0%
Coefficient of Variation:
I 1'62
Mann Kendall
Concentration Trend:
(See Note)
I NT

Number of Number of
Samples Detects
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/28/2006
                         Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-2S
Well Type:  s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/24/1999   to 5/16/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
8.0E-03 •
7.0E-03 -
? 6.0E-03 -
~ 5.0E-03 -
| 4.0E-03 •
g 3.0E-03 -
o
o 2.0E-03 •
O
1.0E-03-
Data Table:
Date
^ ^ ^ ^ o* o* ^ 0* / 0* / 0* ^ 4
*

* * *



^ Mann Kendall S Statistic:

Confidence in
Trend:
1 99.3%
Coefficient of Variation:
1 0.95
Mann Kendall
Concentration Trend:
(See Note)
_


Effective Number of Number of
Well Well Type Date Constituent Result (mg/L) Flag Samples Detects
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
3/24/1999 TRICHLOROETHYLENE (TCE) 5.0E-03 1 1
6/23/1999 TRICHLOROETHYLENE (TCE) 7.0E-03 1 1
12/21/1999 TRICHLOROETHYLENE (TCE) 2.0E-03 1 1
6/28/2000 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
12/6/2000 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
10/30/2001 TRICHLOROETHYLENE (TCE) 2.0E-03 1 1
5/1/2002 TRICHLOROETHYLENE (TCE) 1.0E-03 1 1
10/28/2002 TRICHLOROETHYLENE (TCE) 2.0E-03 1 1
4/22/2003 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
10/21/2003 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
4/27/2004 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
10/26/2004 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
5/20/2005 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
5/16/2006 TRICHLOROETHYLENE (TCE) 7.9E-04 1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/28/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-3S
Well Type:  s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/24/1999   to 5/16/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


6nc n9
.UE-U^ •
_ 5.0E-02 -
^j
£ 4.0E-02 -
c
s 3.0E-02 •

§ 2.0E-02 -
o
0 1.0E-02-

Data Table:
Well Well Ty
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S

«S?^ v^o^'v^o
^ >   ^r ^3>





* *



Result (mg/L) Flag
3.1E-02
4.8E-02
1.5E-02
3.0E-02
2.1E-02
3.1E-02
3.6E-02
6.0E-03
2.3E-02
8.0E-03
1.2E-02
1.0E-02
4.5E-03
2.2E-02
2.3E-02
Mann Kendall S Statistic:
_

Confidence in
Trend:
1 95.4%
Coefficient of Variation:
1 0.58

Mann Kendall
Concentration Trend:
(See Note)
I °

Number of Number of
Samples Detects
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/28/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-1D
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T

«S?^ ^^o^'^^o12
^ > V > V










Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
/*s£' Wv^ XX^' ^f /*s£' ^f S^*1
^ 7* V*










Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

.J^jvO ^j^
^3> ^r ^3>










Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I 8
Confidence in
Trend"

I 63.3%
Coefficient of Variation:
1 0.00

Mann Kendall
Concentration Trend:
(See Note)
I NT

Number of Number of
Samples Detects
1 0
1 0
1 0
1 1
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: UMW-1D
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T

«S?^ ^^o^'^^o12
^ > V > V










Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
/*s£' Wv^ XX^' ^f /*s£' ^f S^*1
^ 7* V*










Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

.J^jvO ^j^
^3> ^r ^3>










Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I °
Confidence in
Trend"

I 48.0%
Coefficient of Variation:
1 0.00

Mann Kendall
Concentration Trend:
(See Note)
I S

Number of Number of
Samples Detects
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-2D
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T

«S?^ ^^o^'^^o12
^ > V > V










Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
/*s£' Wv^ XX^' ^f /*s£' ^f S^*1
^ 7* V*










Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

.J^jvO ^j^
^3> ^r ^3>










Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I °
Confidence in
Trend"

I 48.0%
Coefficient of Variation:
1 0.00

Mann Kendall
Concentration Trend:
(See Note)
I S

Number of Number of
Samples Detects
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-3D
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value



1 op ni
1 .OC-UO •
1.6E-03-

U 1.4E-03 -

,§ 1.2E-03-
5 1 OF ni .
O 1 .UC~UO
2 8.0E-04 •
c
g 6.0E-04 -
c
2 4.0E-04 -
2.0E-04 -


Data Table:

Well Well Ty
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T

£> j£> <£> 5^
«S?^ ^^o^'^^o12
^ > V > V
















Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
<£ (^ & & <£ <£ (^
XX^' W^^ XX^' ^f XX^' ^f XX^'
^ 7* V*
4
















Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

5,*- <£ <£ <£>
.J^jvO ^j^
^y \* \y

















Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.6E-03
1.0E-03 ND
1.0E-03 ND

Mann Kendall S Statistic:

I 10
Confidence in
Trend:

I 66.9%
1
Coefficient of Variation:

I 0.15
9


Mann Kendall
Concentration Trend:
(See Note)
I NT

Number of Number of
Samples Detects
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 1
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS Mann-Kendall  Statistics Summary
Well: 215
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 6/1/1988   to  5/16/2006
Consolidation Period:  No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


2K.C ni
.Ot-Uo -
^ 2.0E-03 -
E
c 1.5E-03-
o
1
•£ 1.0E-03-
c
0 5.0E-04 •

Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T

«$^ OO&' 6$*' ^^
^ O

•

^ ^
» » ••••• •
•




Effective
Pe Date
3/21/1994
6/28/1994
9/21/1994
12/19/1994
3/21/1995
6/27/1995
9/19/1995
12/19/1995
3/26/1996
6/19/1996
9/17/1996
12/17/1996
3/25/1997
6/24/1997
9/23/1997
12/16/1997
3/24/1998
6/17/1998
10/1/1998
3/24/1999
6/23/1999
12/21/1999
Date
*^ .o.®0 rt<^ .o.®0 rt<^ •Q
x^ ^5 O ^? O i^




	
^
•
•


Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

^ rt<^ *^
O x^




>••••





Result (mg/L) Flag
1.0E-03
2.1E-03
1.0E-03 ND
1.3E-03
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.3E-03
7.4E-04
1.0E-03 ND
5.5E-04
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
4.0E-04
4.4E-04
3.8E-04
2.9E-04
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I ^61
P
Confidence in
Trend:
I 81 .2%
Coefficient of Variation:
I °'37
Mann Kendall
Concentration Trend:
(See Note)
I S

Number of Number of
Samples Detects
1 1
2 2
1 0
1 1
1 0
1 0
1 0
1 0
1 0
1 1
1 1
1 0
1 1
1 0
1 0
1 0
2 2
1 1
2 2
1 1
1 0
1 0
MAROS Version 2.2, 2006, AFCEE
                                               10/30/2006
                      Page 1 of 2

-------
 MAROS Mann-Kendall Statistics Summary
Well Well Type
215
215
215
215
215
215
215
215
215
215
215
215
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Constituent Result (mg/L)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
1.0E-03
6.5E-04
1.0E-03
1.4E-04
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
Number of
Flag Samples
ND 1
2
ND 1
1
ND 1
ND 1
ND 1
ND 1
ND 1
ND 1
ND 1
ND 1
Number of
Detects
0
1
0
1
0
0
0
0
0
0
0
0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                             10/30/2006
Page 2 of 2

-------
 MAROS Mann-Kendall  Statistics Summary
Well: SW-9
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 6/1/1988   to  5/16/2006
Consolidation Period:  No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


IA c no
.4t-Uz -
1.2E-02-
^j
|> 1.0E-02-
§ 8.0E-03 -
£ 6.0E-03 -
c
01
c 4.0E-03 -
o
O
2.0E-03 •

Data Table:
Well Well Ty
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T

^ ^ <>5> o
V^ V^ «&sr ^\®
i i X' ^^




* »*
* *
* * »<


Effective
Pe Date
6/1/1988
6/1/1989
3/21/1994
6/28/1994
9/21/1994
12/19/1994
3/21/1995
6/27/1995
9/19/1995
12/19/1995
3/26/1996
6/19/1996
9/17/1996
12/17/1996
3/25/1997
6/24/1997
9/23/1997
12/16/1997
3/24/1998
6/17/1998
10/1/1998
3/24/1999
Date
** o//^ / //* -/ 
-------
 MAROS Mann-Kendall Statistics Summary
Well Well Type
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
T
T
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Number of Number of
Constituent Result (mg/L) Flag Samples Detects
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
9.2E-03
1.2E-02
1.1E-02
7.0E-03
4.4E-03
4.8E-03
6.1E-03
6.4E-03
2.0E-03
1.5E-03
2.7E-03
1.8E-03
1.7E-03
1.3E-03
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
2 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                             10/30/2006
Page 2 of 2

-------
November 7. 2006
                             LONG-TERM
                  MONITORING NETWORK OPTIMIZATION
                     PRB AND SOIL REMEDY AREAS

                     Clare Water Supply Superfund Site
                             Clare, Michigan
APPENDIX B:	

MAROS Reports

PRB Area:

      COC Assessment Report
      Mann-Kendall Reports Selected Wells

So/7 Remedy Area:

      COC Assessment Report
      Mann-Kendall Reports Selected Wells

-------
 MAROS   COC Assessment
 Project:   Clare Water Supply

 Location:  Clare

 Toxicitv:
   User Name:  MV

   State:   Michigan
Contaminant of Concern
VINYL CHLORIDE
cis-1 ,2-DICHLOROETHYLENE
Representative
Concentration
(mg/L)
1.2E-01
6.9E-02
PRG
(mg/L)
1.5E-02
6.1E-02
Percent
Above
PRG
713.2%
12.9%
  Note: Top COCs by toxicity were determined by examining a representative concentration for each compound over the entire site. The
  compound representative concentrations are then compared with the chosen PRG for that compound, with the percentage excedence from
  the PRG determining the compound's toxicity. All compounds above exceed the PRG.


 Prevalence:
Contaminant of Concern
VINYL CHLORIDE
cis-1 ,2-DICHLOROETHYLENE
Class
ORG
ORG
Total
Wells
16
16
Total
Excedences
10
3
Percent
Excedences
62.5%
18.8%
Total
detects
15
13
  Note: Top COCs by prevalence were determined by examining a representative concentration for each well location at the site. The
  total excedences (values above the chosen PRGs) are compared to the total number of wells to determine the prevalence of the
  compound.
 Mobility:

 Contaminant of Concern
                                            Kd
 VINYL CHLORIDE

 cis-1,2-DICHLOROETHYLENE
 0.042

0.0724
   Note: Top COCs by mobility were determined by examining each detected compound in the dataset and comparing their
   mobilities (Koc's for organics, assume foe = 0.001, and Kd's for metals).
 Contaminants of Concern (COC's)


        VINYL CHLORIDE

        cis-1,2-DICHLOROETHYLENE
MAROS Version 2.2, 2006, AFCEE
                                                 Tuesday, November 07, 2006
                                                                                                     Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: MW-301
Well Type: T
COC: VINYL CHLORIDE
Time Period:  1/1/1999    to 5/17/2006
Consolidation Period: No Time Consolidation
Consolidation Type:  Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit

J Flag Values : Actual Value
                                   Date
1 .UUCTTUU '
•§- 1.00E-01 -
c
O
c
Ol
c 1.00E-02-
o
O
1 nnp.n.i .






*
                                                                                Mann Kendall S Statistic:
                                                                                Confidence in
                                                                                Trend:
                                                                                     I   67.5%

                                                                                Coefficient of Variation:
                                                                                         0.18
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
 Data Table:
Well
MW-301
MW-301
MW-301
MW-301
MW-301
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
1.5E-03
1.5E-03
1.0E-03 ND
1.1E-03
1.4E-03
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
0
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       10/24/2006
                          Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: MW-302
Well Type: s
COC: VINYL CHLORIDE
Time Period:  1/1/1999    to 5/17/2006
Consolidation Period: No Time Consolidation
Consolidation Type:  Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit

J Flag Values : Actual Value
                                   Date
       1.00B-00
    O)


    o
    £  1.00E-01 -


    I
    o
    O
       1.00E-02
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                          I   88.3%

                     Coefficient of Variation:
                              0.41
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
 Data Table:
Well
MW-302
MW-302
MW-302
MW-302
MW-302
Well Type
s
s
s
s
s
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
9.9E-02
5.0E-02
5.9E-02
5.4E-02
3.3E-02
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        10/24/2006
                          Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: MW-303
Well Type: s
COC: VINYL CHLORIDE
                                                       Time Period:  1/1/1999    to 5/17/2006
                                                       Consolidation Period: No Time Consolidation
                                                       Consolidation Type: Median
                                                       Duplicate Consolidation: Average
                                                       ND Values: Specified Detection Limit
                                                       J Flag Values : Actual Value
                                  Date
        10
I    1
o
    1   0.1
    o
    O
   0.01
                                                                                Mann Kendall S Statistic:
                                                                                Confidence in
                                                                                Trend:
                                                                                     I   88.3%

                                                                                Coefficient of Variation:
                                                                                         1.16
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
                                                                                    [    NT
 Data Table:
Well
MW-303
MW-303
MW-303
MW-303
MW-303
Well Type
s
s
s
s
s
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
1.6E+00
1.1E+00
9.1E-02
1.2E-01
1.1E-01
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       10/24/2006
                                                                                 Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: MW-304
Well Type: T
COC: VINYL CHLORIDE
                                                        Time Period: 1/1/1999    to  5/17/2006
                                                        Consolidation Period:  No Time Consolidation
                                                        Consolidation Type: Median
                                                        Duplicate Consolidation:  Average
                                                        ND Values: Specified Detection Limit

                                                        J Flag Values : Actual Value
                                   Date
       1.00E+00
•=-  1.00E-01
o
    c  1.00E-02
    o
    O
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                                                                                      I   75.8%

                                                                                Coefficient of Variation:
                                                                                         0.53
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
 Data Table:
Well
MW-304
MW-304
MW-304
MW-304
MW-304
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
4.1E-02
2.8E-02
8.5E-03
1.8E-02
2.0E-02
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        10/24/2006
                                                                                 Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: MW-305
Well Type: s
COC: VINYL CHLORIDE
Time Period:  1/1/1999    to 5/17/2006
Consolidation Period: No Time Consolidation
Consolidation Type:  Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit

J Flag Values : Actual Value
                                  Date
    O)


    o
    2   0.1 -
    o
    O
       0.01
                                                                                Mann Kendall S Statistic:
                                                                                Confidence in
                                                                                Trend:
                          I   50.0%

                     Coefficient of Variation:
                                                                                         0.66
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
 Data Table:
Well
MW-305
MW-305
MW-305
MW-305
MW-305
Well Type
s
s
s
s
s
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
2.4E-01
6.8E-02
2.3E-02
2.4E-01
1.9E-01
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       10/24/2006
                          Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics  Summary
Well: MW-306
Well Type: T
COC: VINYL CHLORIDE
                                                        Time Period: 1/1/1999    to 5/17/2006
                                                        Consolidation Period: No Time Consolidation
                                                        Consolidation Type:  Median
                                                        Duplicate Consolidation: Average
                                                        ND Values: Specified Detection Limit

                                                        J Flag Values :  Actual Value
                                   Date
       1.00E+00
•=-  1.00E-01
o
    c  1.00E-02
    o
    O
                                                           ,i'
                                                           **&*
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                                                                                      I   95.8%

                                                                                Coefficient of Variation:
                                                                                          1.08
                                                                                 Mann Kendall
                                                                                 Concentration Trend:
                                                                                 (See Note)
 Data Table:
Well
MW-306
MW-306
MW-306
MW-306
MW-306
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
1.5E-02
4.4E-03
2.4E-03
2.0E-03
2.1E-03
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        10/24/2006
                                                                                  Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics Summary
Well: Mw-307
Well Type: T
COC: VINYL CHLORIDE
Time Period:  1/1/1999    to 5/17/2006
Consolidation Period: No Time Consolidation
Consolidation Type:  Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
                                   Date
1.00E+00-
•§- 1.00E-01 -
o
c
Ol
c 1.00E-02-
o
O
1 nnp.n.i .
^ 6C -A < ^
*.^l O>^ vO tk^r ^fff^
^ ^ ^ ^ ^

* •
                                                                                Mann Kendall S Statistic:
                                                                                Confidence in
                                                                                Trend:
                                                                                     I   75.8%

                                                                                Coefficient of Variation:
                                                                                         1.03
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
                                                                                    [     NT
 Data Table:
Well
Mw-307
Mw-307
Mw-307
Mw-307
Mw-307
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
3.3E-02
1.1E-02
1.0E-03 ND
5.0E-03
1.0E-02
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
0
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       10/24/2006
                          Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: MW-308
Well Type: T
COC: VINYL CHLORIDE
Time Period:  1/1/1999    to 5/17/2006
Consolidation Period: No Time Consolidation
Consolidation Type:  Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
                                   Date
       1.00B-00
    O)

    o
    £  1.00E-01 -

    I
    o
    O
       1.00E-02
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                          I   59.2%

                     Coefficient of Variation:
                              0.39
                     Mann Kendall
                     Concentration Trend:
                     (See Note)
                         [    NT
 Data Table:
Well
MW-308
MW-308
MW-308
MW-308
MW-308
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
5.5E-02
2.6E-02
2.3E-02
4.5E-02
5.8E-02
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        10/24/2006
                          Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: Mw-309
Well Type: T
COC: VINYL CHLORIDE
Time Period:  1/1/1999    to 5/17/2006
Consolidation Period: No Time Consolidation
Consolidation Type:  Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
                                   Date
       1.00B-00
    O)

    o
    £  1.00E-01 -

    I
    o
    O
       1.00E-02
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                          I   59.2%

                     Coefficient of Variation:
                              0.58
                     Mann Kendall
                     Concentration Trend:
                     (See Note)
                         [    NT
 Data Table:
Well
Mw-309
Mw-309
Mw-309
Mw-309
Mw-309
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
4.8E-02
1.4E-02
1.6E-02
1.8E-02
2.5E-02
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        10/24/2006
                          Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics  Summary
Well: MW-310
Well Type: T
COC: VINYL CHLORIDE
                                                        Time Period: 1/1/1999    to 5/17/2006
                                                        Consolidation Period: No Time Consolidation
                                                        Consolidation Type:  Median
                                                        Duplicate Consolidation: Average
                                                        ND Values: Specified Detection Limit
                                                        J Flag Values :  Actual Value
                                   Date
       1.00E+00
•=-  1.00E-01 H
o
    c  1.00E-02H
    o
    O
   1.00E-03
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                                                                                      I   88.3%

                                                                                Coefficient of Variation:
                                                                                          0.60
                                                                                 Mann Kendall
                                                                                 Concentration Trend:
                                                                                 (See Note)
                                                                                     [    NT
 Data Table:
Well
MW-310
MW-310
MW-310
MW-310
MW-310
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
7.1E-03
1.9E-02
5.2E-03
2.5E-02
2.7E-02
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        10/24/2006
                                                                                  Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: MW-311
Well Type: T
COC: VINYL CHLORIDE
Time Period:  1/1/1999    to 5/17/2006
Consolidation Period: No Time Consolidation
Consolidation Type:  Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit

J Flag Values : Actual Value
                                   Date
       1.00B-00
    O)


    o
    £  1.00E-01 -


    I
    o
    O
       1.00E-02
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                          I   59.2%

                     Coefficient of Variation:
                              0.70
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
 Data Table:
Well
MW-31 1
MW-31 1
MW-31 1
MW-31 1
MW-31 1
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
2.9E-02
6.9E-02
1.5E-02
1.7E-02
2.6E-02
Number of
Samples
1
1
1
1
1
Number of
Detects
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        10/24/2006
                          Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics  Summary
Well: MW-312
Well Type: T
COC: VINYL CHLORIDE
                                                   Time Period: 1/1/1999    to  5/18/2006
                                                   Consolidation Period:  No Time Consolidation
                                                   Consolidation Type: Median
                                                   Duplicate Consolidation: Average
                                                   ND Values:  Specified Detection Limit

                                                   J Flag Values : Actual Value
                                        Date
    1.2E-03


_   1.0E-03
_j

£   8.0E-04


|   6.0E-04

§   4.0E-04
o
0   2.0E-04 -

    0.
                  &
>
&
#
                                                                                 Mann Kendall S Statistic:
                                                                                 Confidence in
                                                                                 Trend:
                                                                                      I   40.8%

                                                                                 Coefficient of Variation:
                                                                                          0.00
                                                                                 Mann Kendall
                                                                                 Concentration Trend:
                                                                                 (See Note)
 Data Table:
Well
MW-312
MW-312
MW-312
MW-312
MW-312
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L)
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
Flag
ND
ND
ND
ND
ND
Number of
Samples
1
1
1
1
1
Number of
Detects
0
0
0
0
0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        11/6/2006
                                                                             Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics  Summary
Well: MW-313
Well Type: T
COC: VINYL CHLORIDE
                            Time Period: 1/1/1999    to  5/18/2006
                            Consolidation Period:  No Time Consolidation
                            Consolidation Type: Median
                            Duplicate Consolidation:  Average
                            ND Values: Specified Detection Limit
                            J Flag Values : Actual Value
                                   Date
                      &
.&
&
1 .UUCTTUU '
o) 1.00E-01 •
E.
c
o
2 1.00E-02-
§
c
0 1.00E-03-
1 nnp.n/i .







^ » • • »
                                                                                Mann Kendall S Statistic:
                                                                                Confidence in
                                                                                Trend:
                                                                                     I   75.8%

                                                                               Coefficient of Variation:
                                                                                        0.13
                                                                                Mann Kendall
                                                                                Concentration Trend:
                                                                                (See Note)
                                                                                    [     NT
 Data Table:
Well
MW-313
MW-313
MW-313
MW-313
MW-313
Well Type
T
T
T
T
T
Effective
Date
5/24/2005
8/11/2005
11/9/2005
3/15/2006
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L)
7.3E-04
1.0E-03
1.0E-03
1.0E-03
1.0E-03
Flag

ND
ND
ND
ND
Number of
Samples
1
1
1
1
1
Number of
Detects
1
0
0
0
0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                       11/6/2006
                                                     Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: 300A
Well Type:  s
COC: VINYL CHLORIDE
Time Period: 1/1/1999   to 5/17/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value

10 .ii

j"
B)
o
!
§ * *
0 «, »

01

Data Table:
Well Well Type
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
300A S
Date
>V>V>V>V>V>1

•
* » » »
* *




Effective
Date Constituent
12/12/1999 VINYL CHLORIDE
6/28/2000 VINYL CHLORIDE
12/6/2000 VINYL CHLORIDE
10/30/2001 VINYL CHLORIDE
5/1/2002 VINYL CHLORIDE
10/29/2002 VINYL CHLORIDE
4/22/2003 VINYL CHLORIDE
10/21/2003 VINYL CHLORIDE
4/27/2004 VINYL CHLORIDE
10/27/2004 VINYL CHLORIDE
5/24/2005 VINYL CHLORIDE
8/11/2005 VINYL CHLORIDE
11/9/2005 VINYL CHLORIDE
3/15/2006 VINYL CHLORIDE
5/17/2006 VINYL CHLORIDE

6)
j^ Mann Kendall S Statistic:
_
Confidence in
Trend:
1 99.8%
Coefficient of Variation:
I °72
Mann Kendall
Concentration Trend:
(See Note)
I '

Number of Number of
Result (mg/L) Flag Samples Detects
2.9E-01 2 2
3.3E-01 1 1
6.6E-01 1 1
3.9E-01 1 1
7.0E-01 2 2
7.3E-01 1 1
9.8E-01 1 1
9.0E-01 1 1
9.4E-01 1 1
9.4E-01 1 1
1.4E+00 1 1
1.5E+00 1 1
3.0E+00 2 2
5.5E-01 1 1
6.1E-01 1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/24/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics  Summary
Well: 300B
Well Type: s
COC: VINYL CHLORIDE
                                                        Time Period:  1/1/1999    to 5/17/2006
                                                        Consolidation Period: No Time Consolidation
                                                        Consolidation Type:  Median
                                                        Duplicate Consolidation: Average
                                                        ND Values: Specified Detection Limit

                                                        J Flag Values : Actual Value
                                  Date
       1.00B-00
O)
•§-  1.00E-01 H
o
    c  1.00E-02H
    o
    O
       1.00E-03
                                                                                 Mann Kendall S Statistic:
                                                                                  I    62
                                                                             Confidence in
                                                                             Trend:
                                                                                      I   100.0%

                                                                                 Coefficient of Variation:
                                                                                          1.10
                                                                             Mann Kendall
                                                                             Concentration Trend:
                                                                             (See Note)

                                                                                 [     I
 Data Table:
Well
300B
300B
300B
300B
300B
300B
300B
300B
300B
300B
300B
300B
300B
Well Type
s
s
s
s
s
s
s
s
s
s
s
s
s
Effective
Date
12/12/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/29/2002
4/22/2003
10/21/2003
4/27/2004
10/27/2004
5/24/2005
11/9/2005
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L) Flag
1.4E-02
2.0E-02
7.2E-03
3.6E-03
1.0E-02
2.4E-02
3.4E-02
3.7E-02
6.2E-02
4.8E-02
1.1E-01
1.4E-01
2.0E-01
Number of
Samples
1
1
1
1
1
1
1
1
1
1
1
1
1
Number of
Detects
1
1
1
1
1
1
1
1
1
1
1
1
1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                        10/24/2006
                                                                                  Page 1 of 1

-------
 MAROS  Mann-Kendall Statistics Summary
Well: 300C
Well Type: T
COC: VINYL CHLORIDE
                                                   Time Period: 1/1/1999    to  5/18/2006
                                                   Consolidation Period:  No Time Consolidation
                                                   Consolidation Type: Median
                                                   Duplicate Consolidation:  Average
                                                   ND Values:  Specified Detection Limit

                                                   J Flag Values : Actual Value
                                       Date
             3.0E-02
__   2.5E-02 -
_j
B)
_§   2.0E-02
c
|   1.5E-02

§   1.0E-02
o
0   5.0E-03 -

    O.OE+00
»  »      »
                                                                                 Mann Kendall S Statistic:
                                                                             I    43
                                                                         Confidence in
                                                                         Trend:
                                                                                      I   99.6%

                                                                                 Coefficient of Variation:
                                                                                          1.38
                                                                                 Mann Kendall
                                                                                 Concentration Trend:
                                                                                 (See Note)
                                                                                      [     I
 Data Table:
Well
300C
300C
300C
300C
300C
300C
300C
300C
300C
300C
300C
300C
300C
Well Type
T
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
12/12/1999
7/21/2000
12/6/2000
10/30/2001
5/1/2002
10/29/2002
4/22/2003
10/21/2003
4/27/2004
10/27/2004
5/24/2005
11/9/2005
5/1 7/2006
Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
Result (mg/L)
1.0E-03
7.3E-04
2.9E-04
1.0E-03
1.0E-03
3.2E-03
1.0E-03
1.3E-02
1.6E-03
2.4E-02
2.4E-02
2.7E-02
1.0E-03
Flag
ND


ND
ND

ND





ND
Number of
Samples
1
1
1
1
1
1
1
1
1
1
1
1
1
Number of
Detects
0
1
1
0
0
1
0
1
1
1
1
1
0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                         11/6/2006
                                                                             Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: 220
Well Type:  T
COC: VINYL CHLORIDE
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
220 T
220 T
220 T
220 T
220 T
220 T
220 T
220 T
220 T
220 T
220 T
220 T
220 T
220 T
220 T

«S?^ ^^o^'^^o12
^ > V > V










Effective
Pe Date
3/24/1999
6/23/1999
12/12/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/29/2002
4/22/2003
10/21/2003
4/27/2004
10/27/2004
5/24/2005
11/9/2005
5/1 7/2006
Date
•> <$• ^j& fr <$• <$• ^ 
^ 7* V*






•



Constituent
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE
VINYL CHLORIDE

^^ .Q4^^
^ •
-------
 MAROS   COC Assessment
 Project:   Soil Remedy

 Location:  Clare

 Toxicitv:


 Contaminant of Concern
           User Name:  MV

           State:   Michigan
Representative
Concentration
    (mg/L)
 PRG
(mg/L)
Percent
Above
 PRG
 TRICHLOROETHYLENE (TCE)
                                       5.3E-03
                                                       5.0E-03
                                                                      6.9%
  Note: Top COCs by toxicity were determined by examining a representative concentration for each compound over the entire site. The
  compound representative concentrations are then compared with the chosen PRG for that compound, with the percentage excedence from
  the PRG determining the compound's toxicity. All compounds above exceed the PRG.


 Prevalence:
Contaminant of Concern
Class
Total
Wells
Total
Excedences
Percent
Excedences
Total
detects
 TRICHLOROETHYLENE (TCE)
                                         ORG
                                                       8
                                                                                 25.0%
  Note: Top COCs by prevalence were determined by examining a representative concentration for each well location at the site. The
  total excedences (values above the chosen PRGs) are compared to the total number of wells to determine the prevalence of the
  compound.
 Mobility:

 Contaminant of Concern
                                            Kd
 TRICHLOROETHYLENE (TCE)
                                              0.297
   Note: Top COCs by mobility were determined by examining each detected compound in the dataset and comparing their
   mobilities (Koc's for organics, assume foe = 0.001, and Kd's for metals).
 Contaminants of Concern (COC's)


        VINYL CHLORIDE

        TRICHLOROETHYLENE (TCE)

        cis-1,2-DICHLOROETHYLENE
MAROS Version 2.2, 2006, AFCEE
                                                  Saturday, October 28, 2006
                                                                                                     Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: UMW-1S
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T
UMW-1S T

«S?^ v^o^'v^o^
^ >   ^r ^3>










Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I °
Confidence in
Trend"

I 48.0%
Coefficient of Variation:
1 0.00

Mann Kendall
Concentration Trend:
(See Note)
I S

Number of Number of
Samples Detects
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-1S
Well Type:  s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/24/1999   to 5/16/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op m
I .^C-U I •
_ 1.0E-01 -
£ 8.0E-02 -
c
s 6.0E-02 •

§ 4.0E-02 -
o
0 2.0E-02 -
O.OE+00 •
Data Table:
Well Well Ty
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S

«S?^ ^^o^'^^o12
^ > V > V

•

•


* * *


Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
/*s£' Wv^ XX^' ^f XX^' ^f S^*1
^ 7* V*









Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

.J^jvO ^j^
^3> ^r ^3>









Result (mg/L) Flag
9.9E-02
6.7E-02
1.4E-02
1.3E-02
1.0E-02
9.0E-03
7.0E-03
7.0E-03
9.0E-03
4.0E-03
4.0E-03
4.0E-03
4.0E-03
3.2E-03
2.9E-03
Mann Kendall S Statistic:
_

Confidence in
Trend:
1 100.0%
Coefficient of Variation:
I 1'61

Mann Kendall
Concentration Trend:
(See Note)
I °

Number of Number of
Samples Detects
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/28/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics  Summary
Well: DMW-1S
Well Type:  s
COC: cis-1,2-DICHLOROETHYLENE
Time Period: 3/24/1999   to 5/16/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


2nc ni
.UE-U I •
1.8E-01 -
;;[• 1.6E-01 -
|" 1.4E-01 -
r 1.2E-01 •
o
s 1.0E-01 •
i 8.0E-02 •
| 6.0E-02 •
0 4.0E-02 •
2.0E-02 •

Data Table:
Well Well Ty
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S
DMW-1S S

«S?^ v^o^'v^o^
^ >  
•


Constituent
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE
cis-1 ,2-DICHLOROETHYLENE

.J^jvO ^j^
^3> ^r ^3>









Result (mg/L) Flag
2.4E-02
8.0E-03
4.0E-03
3.0E-03
2.3E-02
6.7E-02
6.0E-03
1.8E-01
2.0E-02
9.0E-03
5.0E-03
9.3E-02
5.9E-03
5.5E-03
2.9E-03
Mann Kendall S Statistic:

I ^?9
Confidence in
Trend:
1 81 .0%
Coefficient of Variation:
I 1'62
Mann Kendall
Concentration Trend:
(See Note)
I NT

Number of Number of
Samples Detects
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/28/2006
                         Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-2S
Well Type:  s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/24/1999   to 5/16/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
8.0E-03 •
7.0E-03 -
? 6.0E-03 -
~ 5.0E-03 -
| 4.0E-03 •
g 3.0E-03 -
o
o 2.0E-03 •
O
1.0E-03-
Data Table:
Date
^ ^ ^ ^ o* o* ^ 0* / 0* / 0* ^ 4
*

* * *



^ Mann Kendall S Statistic:

Confidence in
Trend:
1 99.3%
Coefficient of Variation:
1 0.95
Mann Kendall
Concentration Trend:
(See Note)
_


Effective Number of Number of
Well Well Type Date Constituent Result (mg/L) Flag Samples Detects
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
DMW-2S S
3/24/1999 TRICHLOROETHYLENE (TCE) 5.0E-03 1 1
6/23/1999 TRICHLOROETHYLENE (TCE) 7.0E-03 1 1
12/21/1999 TRICHLOROETHYLENE (TCE) 2.0E-03 1 1
6/28/2000 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
12/6/2000 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
10/30/2001 TRICHLOROETHYLENE (TCE) 2.0E-03 1 1
5/1/2002 TRICHLOROETHYLENE (TCE) 1.0E-03 1 1
10/28/2002 TRICHLOROETHYLENE (TCE) 2.0E-03 1 1
4/22/2003 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
10/21/2003 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
4/27/2004 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
10/26/2004 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
5/20/2005 TRICHLOROETHYLENE (TCE) 1.0E-03 ND 1 0
5/16/2006 TRICHLOROETHYLENE (TCE) 7.9E-04 1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/28/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-3S
Well Type:  s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/24/1999   to 5/16/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


6nc n9
.UE-U^ •
_ 5.0E-02 -
^j
£ 4.0E-02 -
c
s 3.0E-02 •

§ 2.0E-02 -
o
0 1.0E-02-

Data Table:
Well Well Ty
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S
DMW-3S S

«S?^ v^o^'v^o
^ >   ^r ^3>





* *



Result (mg/L) Flag
3.1E-02
4.8E-02
1.5E-02
3.0E-02
2.1E-02
3.1E-02
3.6E-02
6.0E-03
2.3E-02
8.0E-03
1.2E-02
1.0E-02
4.5E-03
2.2E-02
2.3E-02
Mann Kendall S Statistic:
_

Confidence in
Trend:
1 95.4%
Coefficient of Variation:
1 0.58

Mann Kendall
Concentration Trend:
(See Note)
I °

Number of Number of
Samples Detects
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     10/28/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-1D
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T
DMW-1D T

«S?^ ^^o^'^^o12
^ > V > V










Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
/*s£' Wv^ XX^' ^f /*s£' ^f S^*1
^ 7* V*










Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

.J^jvO ^j^
^3> ^r ^3>










Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I 8
Confidence in
Trend"

I 63.3%
Coefficient of Variation:
1 0.00

Mann Kendall
Concentration Trend:
(See Note)
I NT

Number of Number of
Samples Detects
1 0
1 0
1 0
1 1
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: UMW-1D
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T
UMW-1D T

«S?^ ^^o^'^^o12
^ > V > V










Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
/*s£' Wv^ XX^' ^f /*s£' ^f S^*1
^ 7* V*










Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

.J^jvO ^j^
^3> ^r ^3>










Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I °
Confidence in
Trend"

I 48.0%
Coefficient of Variation:
1 0.00

Mann Kendall
Concentration Trend:
(See Note)
I S

Number of Number of
Samples Detects
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-2D
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


1 op ni
1 .^C-UO •
Inc ni
.Ut-Uo -
£ 8.0E-04 -
c
s 6.0E-04 •

§ 4.0E-04 -
o
0 2.0E-04 -
Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T
DMW-2D T

«S?^ ^^o^'^^o12
^ > V > V










Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
/*s£' Wv^ XX^' ^f /*s£' ^f S^*1
^ 7* V*










Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

.J^jvO ^j^
^3> ^r ^3>










Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I °
Confidence in
Trend"

I 48.0%
Coefficient of Variation:
1 0.00

Mann Kendall
Concentration Trend:
(See Note)
I S

Number of Number of
Samples Detects
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS  Mann-Kendall  Statistics Summary
Well: DMW-3D
Well Type:  T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999   to 5/18/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value



1 op ni
1 .OC-UO •
1.6E-03-

U 1.4E-03 -

,§ 1.2E-03-
5 1 OF ni .
O 1 .UC~UO
2 8.0E-04 •
c
g 6.0E-04 -
c
2 4.0E-04 -
2.0E-04 -


Data Table:

Well Well Ty
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T
DMW-3D T

£> j£> <£> 5^
«S?^ ^^o^'^^o12
^ > V > V
















Effective
Pe Date
3/24/1999
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Date
<£ (^ & & <£ <£ (^
XX^' W^^ XX^' ^f XX^' ^f XX^'
^ 7* V*
4
















Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

5,*- <£ <£ <£>
.J^jvO ^j^
^y \* \y

















Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.6E-03
1.0E-03 ND
1.0E-03 ND

Mann Kendall S Statistic:

I 10
Confidence in
Trend:

I 66.9%
1
Coefficient of Variation:

I 0.15
9


Mann Kendall
Concentration Trend:
(See Note)
I NT

Number of Number of
Samples Detects
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 0
1 1
1 0
1 0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                                     11/6/2006
                        Page 1 of 1

-------
 MAROS Mann-Kendall  Statistics Summary
Well: 215
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 6/1/1988   to  5/16/2006
Consolidation Period:  No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


2K.C ni
.Ot-Uo -
^ 2.0E-03 -
E
c 1.5E-03-
o
1
•£ 1.0E-03-
c
0 5.0E-04 •

Oncu-nn
m\ICr\I\I
Data Table:
Well Well Ty
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T
215 T

«$^ OO&' 6$*' ^^
^ O

•

^ ^
» » ••••• •
•




Effective
Pe Date
3/21/1994
6/28/1994
9/21/1994
12/19/1994
3/21/1995
6/27/1995
9/19/1995
12/19/1995
3/26/1996
6/19/1996
9/17/1996
12/17/1996
3/25/1997
6/24/1997
9/23/1997
12/16/1997
3/24/1998
6/17/1998
10/1/1998
3/24/1999
6/23/1999
12/21/1999
Date
*^ .o.®0 rt<^ .o.®0 rt<^ •Q
x^ ^5 O ^? O i^




	
^
•
•


Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)

^ rt<^ *^
O x^




>••••





Result (mg/L) Flag
1.0E-03
2.1E-03
1.0E-03 ND
1.3E-03
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.3E-03
7.4E-04
1.0E-03 ND
5.5E-04
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
4.0E-04
4.4E-04
3.8E-04
2.9E-04
1.0E-03 ND
1.0E-03 ND
Mann Kendall S Statistic:

I ^61
P
Confidence in
Trend:
I 81 .2%
Coefficient of Variation:
I °'37
Mann Kendall
Concentration Trend:
(See Note)
I S

Number of Number of
Samples Detects
1 1
2 2
1 0
1 1
1 0
1 0
1 0
1 0
1 0
1 1
1 1
1 0
1 1
1 0
1 0
1 0
2 2
1 1
2 2
1 1
1 0
1 0
MAROS Version 2.2, 2006, AFCEE
                                               10/30/2006
                      Page 1 of 2

-------
 MAROS Mann-Kendall Statistics Summary
Well Well Type
215
215
215
215
215
215
215
215
215
215
215
215
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Constituent Result (mg/L)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
1.0E-03
6.5E-04
1.0E-03
1.4E-04
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E-03
Number of
Flag Samples
ND 1
2
ND 1
1
ND 1
ND 1
ND 1
ND 1
ND 1
ND 1
ND 1
ND 1
Number of
Detects
0
1
0
1
0
0
0
0
0
0
0
0
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                             10/30/2006
Page 2 of 2

-------
 MAROS Mann-Kendall  Statistics Summary
Well: SW-9
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 6/1/1988   to  5/16/2006
Consolidation Period:  No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value


IA c no
.4t-Uz -
1.2E-02-
^j
|> 1.0E-02-
§ 8.0E-03 -
£ 6.0E-03 -
c
01
c 4.0E-03 -
o
O
2.0E-03 •

Data Table:
Well Well Ty
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T
SW-9 T

^ ^ <>5> o
V^ V^ «&sr ^\®
i i X' ^^




* »*
* *
* * »<


Effective
Pe Date
6/1/1988
6/1/1989
3/21/1994
6/28/1994
9/21/1994
12/19/1994
3/21/1995
6/27/1995
9/19/1995
12/19/1995
3/26/1996
6/19/1996
9/17/1996
12/17/1996
3/25/1997
6/24/1997
9/23/1997
12/16/1997
3/24/1998
6/17/1998
10/1/1998
3/24/1999
Date
** o//^ / //* -/ 
-------
 MAROS Mann-Kendall Statistics Summary
Well Well Type
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
SW-9
T
T
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
6/23/1999
12/21/1999
6/28/2000
12/6/2000
10/30/2001
5/1/2002
10/28/2002
4/22/2003
10/21/2003
4/27/2004
10/26/2004
5/20/2005
11/8/2005
5/16/2006
Number of Number of
Constituent Result (mg/L) Flag Samples Detects
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
9.2E-03
1.2E-02
1.1E-02
7.0E-03
4.4E-03
4.8E-03
6.1E-03
6.4E-03
2.0E-03
1.5E-03
2.7E-03
1.8E-03
1.7E-03
1.3E-03
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
2 1
1 1
1 1
1 1
1 1
 Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A) -
 Due to insufficient Data (< 4 sampling events); ND = Non-detect
MAROS Version 2.2, 2006, AFCEE
                                             10/30/2006
Page 2 of 2

-------
          Attachment D
       Electronic Database

(provided on CD in hardcopy report)

-------
       Attachment E
Selected November 2006 Data

-------
  FILCON  FACILITY

(FORMERLY MITCHELL)
/
MW-3C
PCE
TCE
CIS-1,2
-ye
1,1^00

5/05
1.8
0.9J
1.9
1.5
- ^0.98J

8/05
<1

<1
1.5
<1

11/05
<1

<1
<1
<1

3/06
<1

0.77J
1.1
0.36J

5/06


0.73J
1.4
<1

11/06
<1

0.5J
0.5J
0.55J
MW-302
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
1.0
110D
99D
88D
8/05
<1
<1
31
50
97
11/05
<1
<1
33
59
85
3/06
<1
0.52J
27
54
120D
5/06
<1
<1
<1
33
92
11/06
<1
0.46J
44
110
190

MW-310
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
<1
1.3
7.1
<1
8/05
<1
<1
<1
19
<1
11/05
<1
<1
<1
5.2
<1
\
3/06
<1
<1
<1
\2b
V1
5/06
<1
<1
<1
27
<1
11/06
<1
<1
<1
21
<1
300C
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
<1
<1
24
4.9
11/05
<1
<1
<1
27
7.5
5/06
<1
<1
<1
<1
<1
11/06
<1
<1
<1
13
2.7
MW-303
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
0.68J
20
1,4000
1,6000
500D
8/06
<1N
20 /
8801?
1.1QOJZ
35pj2
11/05
<1
8.4
410
9TD-—
130D
3/06
<1
2.2
61
-1200
J95D
5/06
<1
2.2
52
1100
93D
11/06
<1
0.86J
16
76
91
                                                               V-301
                                                                          QMW-302
                                                                          V-303
MW-305
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
0.73J
33
240D
240D
80
8/05
<1
7.4
69
68
33
11/05,
<1 /
1.7 /
17 ^
23
ie ,
3/06
<10
<10
^l 40
/240
78
5/06
<1
1.5
110D
190D
96
11/06
<1
0.58J
34
110
73
300B
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
<1
6.8
110
1.2
11/05
<1
<1
7.7
1400
1.4
5/06
<1
<1
10
200D
2.7
11/0>
<1
<1
8.7
140
2.3
                                                                                                                                        o
                                                                                                                                         300B
  QMW-305


Q300A
MW-309
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
0.63J

6.8
48
1
8/05
<1

1.7
14
<1
11/05
<1

1.7
16
<1
3/06
<1

2.4
18
0.54J
5/06
<1

3.7
25
0.88J
11/06
<1

0.44J
2.2
<1
                                                                                                                  PRB
                                                                                                                  PRB
                                                                                                                                             -JO
                                                                                                                                               MW-309I
                                                                                                                                                                             ^SW-12

LEGEND
MW-308 O MONITORING
^





PCE-
TCE-
CIS-1
^M^^M PRB
SW-12
PCE
TCE
CIS-1,2
VC
1,1 -DCA
GSI
45
200
620
15
740
5/05
<1
<1
<1
<1
<1
TETRACHLOROETHYLENE
TRICHLOROETHYLENE

WELL








2 - CIS-1.2-DICHLOROETHYLENE
VC - VINYL CHLORIDE
1.1-DCA-1.1 DICHLOROETHANE
GSI - GROUNDWATER SURFACE WATER
INTERFACE CRITERIA & RBSLS
MW-304
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
<1
6.8
41
7.2
8/05
<1
<1
4.6
28
5.3
11/05
<1
<1
2.7
8.5
4.7
3/06
<1
<1
3
18
5.5
5/06
<1
<1
6.9
20
22
11/06
<1
<1
<1
3.7
7.1
                                                                                           rfW-307
                                                                                                                                  MW-
SW-12
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
<1
<1
<1
<1
11/05
<1
<1
<1
<1
<1
5/06
<1
<1
<1
<1
<1
11/06
<1
<1
<1
<1
<1
                                           306
MW-311
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
8.8
20
29
13
8/05
<1
10
58
69
20
11/05
<1
2.4
6.9
15
11
3/06
<1
2.9
6.3
17
7.6
5/06
<1
4.9
8.9
26
10
11/06
<1
0.53J
3.1
10
5.3
                                                                                                                                                           MW-313

                                                                                                                                                             O
MW-313
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
<1
<1
0.73J

8/05
<1
<1
<1


11/05
<1
<1
<1


3/06
<1
<1
<1


5/06
<1
<1
1


11/06
<1
<1
<1


MW-308
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
8.6
19
55
18
8/05
<1
2.0
5.8
26
8.4
11/05
<1
1.7
5.2
23
9.6
3/06
<1
1.6
5.7
45
13
5/06
<1
2.1
6.5
58
15
11/06
<1
1.4
3.5
20
9.7
MW-307
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
<1
<1
33
6
8/05
<1
<1
<1
11
2.2
11/05
<1
<1
<1
<1
1.2
3/06
<1
<1
<1
5
1.5
5/06
<1
<1
<1
10
7.4
11/06
<1
<1
<1
8.1
8.1
300A
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
0.72J
430D
1,4000
1.300D
8/05
<1
<1
5100
1,5000
1.500D
12/05
<1
<1
190D
7200
950D
3/06
<1
<1
210D
5500
890D
5/06
<1
<1
190D
6100
890D
11/06
<1
<1
89
220
590

MW-306
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
<1
<1
3.8
15
1.8
8/05
<1
<1
<1
4.4
<1
11/05
<1
<1
<1
2.4
<1
3/06
<1
<1
<1
2
<1
5/06
<1
<1
0.81J
2.1
<1
11/06
<1
<1
<1
1.1
<1
MW-312
PCE
TCE
CIS-1,2
VC
1,1 -DCA
5/05
0.81J
<1
0.70J
<1
<1
8/05
<1
<1
<1
<1
<1
11/05
<1
<1
<1
<1
<1
3/06
1
1
1
1
1
5/06
1
1
1
1
1
11/06





                                                                                                                                     O
                                                                                                                                     MW-312
                              NOTES:
1. NOVEMBER 2005 SAMPLE RESULTS FOR 300A UNUSABLE PER DATA
VALIDATION; LOCATION WAS RESAMPLED IN DECEMBER 2005.
0 , 3? 6? 2- NOVEMBER 2006 SAMPLE RESULTS ARE CONSIDERED PRELIMINARY
^ — — ^^^H^^^^ AS DATA VALIDATION HAS NOT BEEN COMPLETED AS OF THE ISSUANCE OF
SCALE' 1' - 30'

PROGRESSIVE
^\ / ENGINEERING & CONSTRUCTION, INC.
\/ Phone:(813)930-0669 Fax:(813)930-9809
3912 W. Humphrey Street Tampa, Florida 33614
E-mail: infb@progressiveec.com
Website: http://www.progressiveec.com
NO.
A
/?\
A
A
A
REVISION DETAILS
ADDED 1,1-DCA RESULTS
ADD NOV 2006 DATA



DATE
8/2/06
12/6/06



FILE PATH: PROJECTS\CLARE\Drawings\2005\Annual Report Figs\22 - Summary of VOCs In PRB GW.dwg | SCALE: 1" = 30'
SUMMARY OF VOCS IN
PRB AREA GROUNDWATER
CLARE WATER SUPPLY SUPERFUND SITE
CLARE, MICHIGAN
DATE: 12/14/05
DRAWN: BER
APPROVED: GJR
DRAWING NUMBER:
FIGURE 22
SHEET 22 OF 25

-------
Summary of Groundwater Quality Data for November 2006
Clare Water Supply Site
Clare, Michigan
Page 1 of 7
CONSTrrUENTT:
COCs
Benzene
1,1-Dichloroethane
1 ,2-Dichloroethane
cis-1 ,2-Dichloroethene
trans-1 ,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1 ,1 ,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes (total)

TDL
1
1
1
1
1
1
2
1
1
1
1
1
1
1
3
SFTE:
LAB ID:
DATE:
CUO
5
880
5
70
100
700
5
100
5
1000
200
5
5
2
100000
103 104
A751880 A752317
11/7/2006 11/8/2006
109
A751893
11/8/2006
110
A751892
11/8/2006
111
A752288
11/8/2006
210D 210S
A752291 A752293
11/8/2006 11/8/2006
211
A751895
11/8/2006

<1 <1 <1 <1 <1 <1 <1 <1
<1 <1
<1 <1
4.1 <1
<1 <1
<1
0.45J
200
3
<1
0.6J
<1
<1
<1
<1
4.2
1.1
<1 14
<1 <1
<1 0.48J
<1 <1
2.1
<1
3.7
<1
<1 <1 <1 <1 <1 <1 <1 <1
<2 <2
<2
<2
<2
<2 <2
<2
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
0.81J 0.64J
1.1
2
<1
0.6J 0.65J
0.53J
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
3.2 <1
2.2
<1
3.1
<1 <1
<1
<1 <1 100 <1 <1 <1 <1 <1
<3 <3
<3
<3
<3
<3 <3
<3
                                       Notes on last page.
Clare\EPAGISData\FilestoParsons\Nov2006 GWQual.xls

-------
Summary of Groundwater Quality Data for November 2006
Clare Water Supply Site
Clare, Michigan
Page 2 of 7
CONSTITUENT:
COCs
Benzene
1,1-Dichloroethane
1 ,2-Dichloroethane
cis-1 ,2-Dichloroethene
trans-1 ,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
1 ,1 ,1 -Trichloroethane
1 ,1 ,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes (total)

TDL
1
1
1
1
1
1
2
1
1
1
1
1
1
1
3
SITE:
LAB ID:
DATE:
CUO
5
880
5
70
100
700
5
100
5
1000
200
5
5
2
100000
215 220
A751874 A752297
11/7/2006 11/9/2006
300A
A752313
11/10/2006
300B
A752311
11/10/2006
300C
A752310
11/10/2006
D-106
A752292
11/8/2006
D-107 DMW-1D
A751894 A751876
11/8/2006 11/7/2006

<1 <1 <1 <1 <1 <1 <1 <1
<1 3.1
590
2.3
2.7
<1
<1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1
89
8.7
<1
1.9
<1 20
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<2 <2
<2
<2
<2
<2
<2 <2
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
1.5 1.5
<1
0.89J
1.3
<1
1.3 0.95J
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 2.5 <1 <1
<1 <1
<3 <3
220
<3
140
<3
13
<3
<1
<3
<1 <1
<3 <3
                                       Notes on last page.
Clare\EPAGISData\FilestoParsons\Nov2006 GWQual.xls

-------
Summary of Groundwater Quality Data for November 2006
Clare Water Supply Site
Clare, Michigan
Page 3 of 7
CONSTITUENT:
COCs
Benzene
1,1-Dichloroethane
1 ,2-Dichloroethane
cis-1 ,2-Dichloroethene
trans-1 ,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1 ,1 ,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes (total)

TDL
1
1
1
1
1
1
2
1
1
1
1
1
1
1
3
SFTE:
LAB ID:
DATE:
CUO
5
880
5
70
100
700
5
100
5
1000
200
5
5
2
100000
DMW-1S
A751873
11/7/2006
DMW-2D
A751882
11/7/2006
DMW-2S DMW-3D DMW-3S
A751872 A751877 A751879
11/7/2006 11/7/2006 11/7/2006
MW-301
A752299
11/9/2006
MW-302
A752305
11/9/2006
MW-303
A752306
11/9/2006

<1 <1 <1 <1 <1 <1 <1 <1
<1
<1
<1 <1 <1
0.55J
190
91
<1 <1 <1 <1 <1 <1 <1 <1
49
1.2
<1 <1 0.52J
0.5J
44
16
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<2
<2
<2 <2 <2
<2
<2
<2
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
2.1
1.2
<1 1.4 1.3
0.42J
0.98J
0.89J
<1 <1 <1 <1 <1 <1 1.9 <1
<1 <1 <1 <1 <1 <1 <1 <1
5.1
<1
<3
<1
<1
<3
1 <1 13
<1 <1 <1
<3 <3 <3
<1
0.5J
<3
0.46J
110
<3
0.86J
76
<3
                                       Notes on last page.
Clare\EPAGISData\FilestoParsons\Nov2006 GWQual.xls

-------
Summary of Groundwater Quality Data for November 2006
Clare Water Supply Site
Clare, Michigan
Page 4 of 7
CONSTITUENT:
COCs
Benzene
1,1-Dichloroethane
1 ,2-Dichloroethane
cis-1 ,2-Dichloroethene
trans-1 ,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1 ,1 ,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes (total)

TDL
1
1
1
1
1
1
2
1
1
1
1
1
1
1
3
SITE:
LAB ID:
DATE:
CUO
5
880
5
70
100
700
5
100
5
1000
200
5
5
2
100000
MW-304
A752300
11/9/2006
MW-305
A752314
11/10/2006
MW-306 MW-307
A752312 A752307
11/10/2006 11/10/2006
MW-308
A752308
11/10/2006
MW-309
A752309
11/10/2006
MW-310
A752304
11/9/2006
MW-31 1
A752303
11/9/2006

<1 <1 <1 <1 <1 <1 <1 <1
7.1
73
<1 8.1
9.7
<1
<1
5.3
<1 <1 <1 <1 <1 <1 <1 <1
<1
34
<1 <1
3.5
0.44J
<1
3.1
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<2
<2
<2 <2
<2
<2
<2
<2
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<1
<1
<1 <1
0.54J
<1
1.2
0.44J
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<1
3.7
<3
0.58J
110
<3
<1 <1
1.1 8.1
<3 <3
1.4
20
<3
<1
2.2
<3
<1
21
<3
0.53J
10
<3
                                       Notes on last page.
Clare\EPAGISData\FilestoParsons\Nov2006 GWQual.xls

-------
Summary of Groundwater Quality Data for November 2006
Clare Water Supply Site
Clare, Michigan
Page 5 of 7
CONSTITUENT:
COCs
Benzene
1 , 1 -Dichloroethane
1 ,2-Dichloroethane
cis-1 ,2-Dichloroethene
trans-1 ,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
1 ,1 ,1-Trichloroethane
1 ,1 ,2-Trichloroetnane
Trichloroethene
Vinyl Chloride
Xylenes (total)

TDL
1
1
1
1
1
1
2
1
1
1
1
1
1
1
3
SITE:
LAB ID:
DATE:
CUO
5
880
5
70
100
700
5
100
5
1000
200
5
5
2
100000
MW-312 MW-313 MW-5
A752296 A752301 A751889
11/9/2006 11/9/2006 11/7/2006
MW-6 MW-7 MW-8
A751871 A751870 A751890
1 1 17/2006 1 1 /7/2006 1 1 /8/2006
P-202
A752294
11/8/2006
SW-11
A752298
11/9/2006

<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 0.63J
<1 <1 0.43J
<1
<1
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 6.9
<1 <1 0.47J
<1 <1 29
<1 <1 1.3
1.5
<1
<1
<1
<1 <1 <1 <1 <1 <1 <1 <1
<2 <2 <2
<2 <2 <2
<2
<2
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<1 0.9J 1.2
1.2 1.2 1.2
1.3
1.2
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 5.7
<1 <1 0.56J
9.4
<1
<1 <1 <1 <1 <1 0.79J <1 <1
<3 <3 <3
<3 <3 <3
<3
<3
                                       Notes on last page.
Clare\EPAGISData\FilestoParsons\Nov2006 GWQual.xls

-------
Summary of Groundwater Quality Data for November 2006
Clare Water Supply Site
Clare, Michigan
Page 6 of 7
CONSTITUENT:
COCs
Benzene
1,1-Dichloroethane
1 ,2-Dichloroethane
cis-1 ,2-Dichloroethene
trans-1 ,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
1 ,1 ,1-Trichloroethane
1 ,1 ,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes (total)

TDL
1
1
1
1
1
1
2
1
1
1
1
1
1
1
3
SFTE:
LAB ID:
DATE:
CUO
5
880
5
70
100
700
5
100
5
1000
200
5
5
2
100000
SW-12 SW-5
A752302 A751886
11/9/2006 11/7/2006
SW-9 UMW-1D
A751878 A751875
11/7/2006 11/7/2006
UMW-1S W-6 W-9
A751887 A751891 A752318
11/7/2006 11/8/2006 11/8/2006
WD-10
A751881
11/7/2006

<1 8.4 <1 <1 <1 <1 <1 <1
<1 <1 1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<1 1.5
1.8 <1
<1 <1 <1
<1
<1 <1 <1 <1 <1 <1 <1 <1
<1 21 <1 <1 <1 <1 <1 <1
<2 <2
<2 <2
<2 <2 <2
<2
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 7.7 <1
0.66J 2.6
1.4 1.1
1.8 1.1 0.74J
1.5
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 <1 <1 <1 <1 <1 <1
<1 <1 1.1 <1 <1 <1 <1 <1
<1 1.2
<3 <3
5.7 <1
<3 <3
<1 <1 <1
<3 <3 <3
<1
<3
                                       Notes on last page.
Clare\EPAGISData\FilestoParsons\Nov2006 GWQual.xls

-------
Summary of Groundwater Quality Data for November 2006
Clare Water Supply Site
Clare, Michigan
Page 7 of 7
CONSTITUENT:
COCs
Benzene
1,1-Dichloroethane
1 ,2-Dichloroethane
cis-1 ,2-Dichloroethene
trans-1 ,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
1,1,1 -Trichloroethane
1 ,1 ,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes (total)

TDL
1
1
1
1
1
1
2
1
1
1
1
1
1
1
3
SITE:
LAB ID:
DATE:
CUO
5
880
5
70
100
700
5
100
5
1000
200
5
5
2
100000
WD-8
A751888
11/7/2006
WS-10
A751883
11/7/2006
WS-5
A751902
11/8/2006

<1 <1 <1
<1 <1 11
<1 <1 <1
130
9.7
1.3
<1
150
4.6
<1 <1 <1
<2
<2
<2
<1 <1 <1
<1 <1 <1
1.5
1.7
0.5J
<1 <1 <1
<1 <1 <1
8.7
0.84J
<3
5
<1
<3
14
0.95J
<3
                                                     Not analyzed.
                                                NA  Not applicable.
                                                J    Estimated value; analyte was observed at a value less than the detection limit.
                                                <    Analyte was not detected; result is reported as less than the detection limit.
                                                CUO - Clean up objective as specified in ROD.
                                                BOLD indicates detected value is above the CUO.
                                                Known Contaminant of Concern - as listed  in ROD.
                                                ug/L  Micrograms  per liter.

                                                Note: Toluene results are a laboratory artifact (for most samples).
                                                Toluene was present in all samples, trip blanks and equipment blanks.
                                                Data validation has not yet been completed.
Clare\EPAGISData\FilestoParsons\Nov2006 GWQual.xls

-------
         Attachment F
Review Comments and Responses

-------
              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
  Item
  No.
Section
Page/Line/
  Para
                     Comment
                   Response
   1
Section
  2.1
 Pg2,4
paragraph
Report references the drainage swale in the vicinity of the
PRB as having a depth of 7-8 feet below land surface (ft
bis). Survey data for the swale ranges from 840.49 to
840.15 feet above mean sea level (ft amsl) from west to
east along the proximity of the PRB remedy compared to
the top-of-ground data for the monitor wells nearest the
swale (MW-308 and MW-311) of 843.3 and 842.4 ft
amsl, respectively. Therefore, survey data indicate that
the swale, in the vicinity of the PRB, is approximately 2-
3 ft. deep.
The depth of 7-8 feet was taken from Lithologic
Cross Section A-A' obtained from Progressive.  If
the cross section is incorrect, then the text will be
revised to indicate a 2-3 foot depth. This shallow
depth may explain why there is so little flow in the
swale—it may receive very little to no groundwater
discharge.
         Section
           2.2
          Pg3,4
         paragraph
           Text should clarify who's professional judgment is being
           referenced here. Also, Progressive offers the following
           additional information regarding seepage velocities in the
           proximity of the soil remedy which may/may not impact
           the implication made in this paragraph: laboratory
           permeameter tests conducted by Dames and Moore (in
           1990) on cores from borings SW-12 (4'-6'), SW-28 (8'-
           10') and B-29  (6'-8') yielded an average-hydraulic
           conductivity for the clay layer of 4. 3x 10 cm/sec;
           laboratory tests on cores from borings 208, 212 and B-29
           yielded an average hydraulic conductivity Jbr the
           underlying glacial till in the range of 1x10  cm/sec; and
           based upon the November 2006 hydraulic data, this
           would put groundwater seepage velocity in the range  of
           2.3E-5 ft/day and 3.5E-5 ft/day  for the clay and
           underlying glacial till layers, respectively.
                                                     Text regarding professional judgment will be
                                                     clarified. Laboratory permeability tests on discrete
                                                     soil samples may not provide an accurate
                                                     representation of the hydraulic conductivity of the
                                                     larger in situ water-bearing zone. For example, flow
                                                     may occur through fracture networks that are not
                                                     well-represented in the tested soil samples.
                                                     Groundwater velocity estimates should be derived
                                                     using hydraulic conductivity data from site-specific
                                                     field tests (i.e., slug tests, pumping tests, tracer
                                                     tests).
         Section
           3.3
          Pg5, 1
         paragraph
           Recommend that the final sentence of this paragraph be
           moved (and reworded as appropriate) to after the third
           sentence of same paragraph.
                                                                                   Change will be made.
Progressive comments_responses final, doc
                                                                                                         Page 1 of 12

-------
              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
  Para
Comment
Response
         Section
           4.0
                    Groundwater quality data collected in November 2006
                    are available and attached for inclusion in the evaluation.
                    The November data demonstrate significant
                    concentration decreases for the overwhelming majority
                    of the monitoring network.
                                                                The November 2006 data can be used by interested
                                                                parties to evaluate the conclusions and
                                                                recommendations made in the LTMO report. There
                                                                is insufficient budget remaining to fully incorporate
                                                                the new data into the evaluation and revise the report
                                                                accordingly. However, the data will be reviewed
                                                                qualitatively to determine the impact, if any, on the
                                                                recommendations made. In addition, the data will
                                                                be included in the final report as an attachment.
         Section
           4.1
          Pg7, 1
           bullet
            It should be noted that quarterly data were collected for a
           duration of 1 year, not two years as indicated, the
           frequency was then changed to semiannual.
                                                                                  Text and tables will be revised.
                         nd
         Section
           4.1
          Pg7,2
           bullet
            Progressive would like to clarify that vertical aquifer
           sampling (VAS) was performed just subsequent to the
           PRB installation by Secor. The resultant data was used
           by Progressive prior to installation of the new PRB
           monitor wells (MW-301 to MW-313) to identify which
           borings should undergo VAS during monitor well
           installation for purposes of selecting the proper screened
           intervals.  During the installation of MW-301 to MW-
           313, Progressive performed VAS at select locations and
           placed well screens within the vertical zone exhibiting
           the highest concentrations of contaminants of concern.
           Due to the VAS performed during the monitor well
           installation activities and given that the water table in this
           area has exhibited seasonal fluctuations of up to 5 ft at
           some locations, the 5-ft screens used are of an
           appropriate length to best monitor water quality in this
           area.
                                Comment noted. The referenced text in the 2n
                                bullet still appears to be accurate and appropriate
                                and no changes are proposed.
Progressive comments_responses final, doc
                                                                                                        Page 2 of 12

-------
              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
  Para
Comment
Response
         Section
           4.1
          Pg7,5
         bullet aijd
          Pg8,l
           bullet
           Progressive agrees with elimination of monitoring for MI
           10 metals and reducing the frequency of monitoring for
           ferrous iron.
                                                                                  Comment noted.
         Section
           4.1
          pg 8, 3h
          and 4
          bullets
           As stated above, the reference to the drainage swale
           depth being 7-8 ft is erroneous; actual depth is 2-3 ft
           based upon survey data. In addition, the swale is
           typically dry, and has only been observed to contain
           flowing water immediately subsequent to precipitation
           events and during periods of snow melt. Regarding the
           extent of definition of downgradient VOCs, Progressive
           asserts that as long as the concentrations exhibited in the
           monitor wells located south of the PRB continue to
           decline, monitoring further downgradient is unnecessary.
           Also, there is no need to monitor the area south of the
           swale due to existing MW-312 and SW-23. As of
           November 2006 analytical data for all wells south of the
           PRB exhibited VC concentrations less than the GSI
           criteria, with one exception, MW-3 08 which had a VC
           concentration of 20 ug/L, just 5 parts per billion above
           the GSI criteria. For these reasons, Progressive continues
           to maintain that the PRB area shallow groundwater
           monitor well network, installed pursuant to the Final
           PRB Monitoring Work Plan (dated 5/2/05) as approved
           with comments by USEPA (letter dated 5/11/05), is
           sufficient to provide the data necessary to monitor the
           performance of the  PRB remedy. As decreasing
           concentrations have been the norm at all downgradient
           monitor locations, and there are  no possible receptors in
           the near vicinity, there is no basis to support expansion of
           the shallow monitor network at this time.
                               Depth of swale will be corrected if necessary as
                               described in response to comment #1.

                               The report did not contain definite recommendations
                               for downgradient monitoring. The extent of
                               definition of downgradient VOCs was presented as a
                               potential data gap for stakeholder consideration. We
                               agree that the November 2006 results are promising.
                               However, some VC that exceeds the cleanup goal is
                               bypassing the PRBs in the shallow zone, especially
                               at MW-310 (21  to 27 (ig/L in May and November
                               2006). There are no wells installed that could be
                               used to define the downgradient extent of this
                               contamination based on inferred groundwater flow
                               directions for the shallow zone.  It is likely that
                               concentrations of concern are not migrating to the
                               Clare site boundary to the south given the low
                               magnitude of the concentrations and the fact the VC
                               can degrade under a variety of geochemical
                               conditions.

                               Typically, the downgradient extent of contaminant
                               concentrations exceeding cleanup goals is defined
                               upfront during the site characterization stage, so that
                               informed remedial decisions can be made based on
                               knowledge of the plume extent and plume dynamics
                               (i.e., is plume expanding, stable, or decreasing?).
Progressive comments_responses final, doc
                                                                                                        Page 3 of 12

-------
              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
  Para
Comment
Response
         Section
           4.1
          Pg8,5
           bullet
           The PRB was not designed to treat water in the
           intermediate and/or deep aquifers; references to the
           likeliness of the PRB treating these deeper aquifers are,
           therefore, not applicable. With regard to the extent of
           delineation of the intermediate and deep aquifers, it
           should be noted that historical data provides additional
           useful information  for these aquifers. Monitor well 207
           (located in the source area upgradient of the PRB and
           screened from 57-62 ft bis) exhibited non-detect results
           when it was last sampled in March 1994.  Also, well W-4
           (located approximately 400 ft downgradient of the PRB
           area and screened from 45-50 ft bis) exhibited
           concentrations all below 1 ppb when it was last sampled
           in June 1998. For your use, the coordinates of wells W-4
           and 207 were 678713.39, 4854167.96 and 678562.58,
           4854213.37, respectively. If installation of any additional
           wells were to be considered in this area, they would be
           installed for MNA  use only.
                                Whether or not the PRB was designed to treat water
                                in the intermediate or deep aquifers is not the point
                                of this text. The text simply presents an observation
                                that is relevant to the LTMO evaluation—namely
                                that contaminants detected in the intermediate zone
                                at 300B are not treated.

                                Regarding the extent of delineation in the
                                intermediate and deep zones, here are some relevant
                                observations:
                                -200 (ig/L of VC was detected in well 300B in May
                                2006 (140 (ig/L in November 2006),  in groundwater
                                that is not treated by the PRB. VC concentrations at
                                this well were found to be statistically increasing
                                based on data collected through November 2006.
                                —Potentiometric maps in the 2005 Annual Report
                                show this well to be located near the  center of a
                                potentiometric high, with flow occurring radially
                                outwards in all directions from this area. Therefore,
                                the flow direction in the intermediate zone at well
                                300B is not known with certainty.  These maps
                                indicate that there is not sufficient well control to
                                confidently delineate the groundwater flow direction
                                in the intermediate zone in this  area.
                                —There is not sufficient well control to confidently
                                delineate the migration direction and extent of VC in
                                the intermediate zone in this area.
                                --VC is a relatively volatile and toxic compound that
                                can pose an inhalation risk to occupants of overlying
                                structures in some situations.
                                -Therefore, the situation is that there is a VC plume
                                containing concentrations that substantially exceed
                                the CUO that is of unknown extent and migration
Progressive comments_responses final, doc
                                                                                                         Page 4 of 12

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              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
  Para
                     Comment
                   Response
                                                                                   direction. Whether these information gaps are
                                                                                   significant is a question for the stakeholders to
                                                                                   determine based on risk analysis. Could these
                                                                                   concentrations pose an inhalation risk to any
                                                                                   potential indoor air receptors?  Can this question be
                                                                                   answered given the current level of characterization?
                                                                                   These are the types of questions that need to be
                                                                                   considered. It is our opinion that the historical data
                                                                                   for wells 207 and W-4 do not provide definitive
                                                                                   answers to these questions.	
   10
Section
  4.2
 pg 9 aad
  10,4
  bullet
Progressive maintains that there is no need to delineate
south of the PRB pefthe afeove comments regarding
Section 4.1, pg 8, 3  and 4  bullets. Progressive also
reiterates that monitoring of the PRB area was performed
on a quarterly basis for only one year, not two.
See responses to comments 5 and 8. The sampling
frequency was corrected in the text and tables.
   11
Section
  4.3
 pg 10, J,
  and 2
  bullets
Progressive agrees with the proposed semiannual
sampling frequency, and we are also willing to perform
semi-annual sampling at the wells (MW-312 and MW-
313) where an annual frequency was recommended.
Progressive agrees with the recommendations to
eliminate MI  10 metals sampling and reduce the ferrous
iron sampling frequency. The recent data (attached
hereto) continue to demonstrate decreasing concentration
trends at most PRB area wells; the inclusion of this data
in your evaluation should alleviate the concern you
identified of possible increasing concentration trends at
MW-309 and MW-310. Progressive believes that
performing hydraulic monitoring on a semi-annual basis
should be sufficient for this area, and is interested to see
the  results of the GSI/Parsons evaluation of the hydraulic
data (sent on 12/6/06 and attached to this memo for
reference) to see which, if any, locations are identified
Evaluation of the hydraulic data submitted by
Progressive is beyond the scope of what Parsons and
GSI are budgeted to perform. In general, hydraulic
monitoring for all wells located within the area of
interest and screened within the depth zones of
interest is recommended to maximize the accuracy
of potentiometric surface maps. This
recommendation is based on the observation that
measurement of water levels in monitoring wells is
generally relatively fast and inexpensive relative to
water quality monitoring, and provides very
important site characterization information.
However, if multiple wells screened at similar
depths  are clustered in a small area and have similar
groundwater elevations, one or more could be
considered for removal from the hydraulic
monitoring program unless more detailed	
Progressive comments_responses final, doc
                                                                                                          Page 5 of 12

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             RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
       Section
         Page/Line/
           Para
                                Comment
                                                                       Response
                             for omission from the current hydraulic monitoring list
                             due to redundancy.
                                                                               delineation of local groundwater flow patterns is
                                                                               desired. At least two years of quarterly hydraulic
                                                                               monitoring is recommended to determine seasonal
                                                                               impacts on the potentiometric surface. After that,
                                                                               semiannual hydraulic monitoring during relatively
                                                                               wet and dry times (e.g., spring and fall) should be
                                                                               sufficient unless the quarterly monitoring results
                                                                               indicate significant seasonal variability that needs to
                                                                               be monitored more frequently.   Hydraulic
                                                                               monitoring of all wells at the PRB  and Soil Remedy
                                                                               areas is recommended. Text regarding hydraulic
                                                                               monitoring recommendations will be added to the
                                                                               LTMO report.
                                                                                  See responses to previous comments that pertain
                                                                                  this issue.
12
Section
  4.3
                          rd
pg 10, 3
  bullet
Again, for the reasons stated above (see comments
regarding: Section 3^3, pg 5, 1  paragraph; Section 4.0;th
Section 4.1, pg 7, 2  bullet; Secjion 4.1, pg 8, 3  and 4
bullets; and Section 4.1, pg 8, 5  bullet) Progressive
disagrees that any further action is needed at the PRB
area. However, we are prepared to reassess the adequacy
of the program after two additional years (4 semi-annual
events) of monitoring are performed in this area.
to
   13
       Section
         5.0
                    As previously mentioned, the groundwater analytical data
                    generated from November 2006 sampling are now
                    available and are attached for your use and/or inclusion
                    in your evaluation.
                                                               See response to comment #4.
   14
       Section
         5.1
         pg 10 api
           11,1
           bullet
           Progressive agrees that a reduction in the monitoring
           frequency at the identified locations is prudent.
                                                    Comment noted.
   15
       Section
                          rd
                    It should be noted that residual impacts were left in place
                    outside of the slurry wall/cap when it was installed.	
                                                               The report did not contain definite recommendations
                                                               for additional monitoring downgradient of the	
Progressive comments_responses final, doc
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             RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
  Para
Comment
Response
           5.1
           bullet
           Placement of the slurry wall was restricted due to the
           presence of existing utilities and, therefore, containment
           of impacted soil and groundwater north of the remedy
           wasn't possible. Due to the lack of receptors in the
           vicinity, and the results of the most recent groundwater
           sampling event (November 2006) which exhibit stable to
           decreasing concentrations within the shallow aquifer,
           Progressive asserts that the monitor wells immediately
           outside the containment cell are sufficient to evaluate the
           performance of the remedy; and, if groundwater
           concentrations at these wells do not remain stable to
           decreasing further sampling/wells may be considered.
                               existing shallow well network. The extent of
                               definition of downgradient VOCs was presented as a
                               potential data gap for stakeholder consideration.
                               The proximity of the Soil Remedy Area to the site
                               boundary to the north makes it more important to
                               confirm that TCE concentrations of concern are not
                               migrating out of the area of institutional controls. In
                               addition, there appear to be buildings across
                               Highway 10 to the north; could there be vapor
                               intrusion concerns that need to be considered given
                               the presence of TCE north of the slurry wall?  Stable
                               TCE concentrations could indicate the presence of a
                               continuing source that could potentially be feeding
                               an expanding TCE plume. This is all conjecture of
                               course but there are no downgradient data to either
                               support or refute this observation.
Progressive comments_responses final, doc
                                                                                                        Page 7 of 12

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              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
   Para
                     Comment
                    Response
   16
Section
  5.1
pgll,4
  bullet
Progressive agrees with the contention that the current
number of intermediate wells in this vicinity lends to
somewhat speculative hydraulic data evaluation.
However, based upon the non-detect concentrations in
downgradient intermediate wells 104 and 215 indicating
no significant impacts in the intermediate aquifer, the
deeps wells DMW-1D, DMW-2D, DMW-3D and UMW-
1D all exhibiting concentrations below cleanup
objectives, the lack of risk to receptors from possible
impacts to the intermediate aquifer and the fact that
additional water quality data from this area would not
change the operation of the remedy,  Progressive does not
believe that additional characterization is necessary in
this aquifer. Progressive would also  like to note that the
interpretation of the regional groundwater flow direction
in this area may be  skewed by the seemingly anomalous
hydraulic data from 300B located at the PRB area. A
depiction of the intermediate aquifer potentiometric
surface that was generated with omission of data from
300B is attached  for your consideration (we also attached
a map depicting the potentiometric surface with 300B
included for reference). This interpretation suggests that
installation of three intermediate monitor wells along the
north side of the containment cell (where the aquifer is
currently monitored by intermediate wells 215 and to
some extent 104) would not be helpful.  However,
Progressive is willing to install one intermediate well for
hydraulic monitoring purposes in the area adjacent to the
southeast corner of the soil remedy building.
Parsons does not agree that data for wells 104 and
215 lead to the conclusion that there are no
significant impacts to the intermediate aquifer.
These wells are approximately 440 ft apart, and they
are screened at differing elevations (25 to 30 feet
bgs for 215 and 42.6 to 47.6 ft bgs for 104).  If a
CAH plume in the intermediate zone was emanating
from the soil remedy area it would not necessarily
be detected in these wells.

The alternate interpretation of the intermediate
groundwater potentiometric surface provided by
Progressive suggests that wells 215 and 104 may not
be useful in determining impacts to intermediate
zone groundwater quality.  If this alternate
interpretation is correct, then installation of two
intermediate wells east (downgradient) of the soil
remedy cell should be considered.  In addition,
installation of at least one intermediate well on the
north side still seems reasonable to determine the
vertical extent of identified contamination given the
presence of a continuing source in that area.

The reason for recommending one additional deep
well was to allow monitoring of groundwater quality
in the full range of potential groundwater flow
directions from the soil remedy cell and to help
confirm groundwater flow directions in the deep
zone. Any additional wells could potentially be
installed as temporary wells to allow collection of a
groundwater sample and a water level elevation;
they could then be abandoned if the results did not
indicate cause for concern.
Progressive comments_responses final, doc
                                                                                                          Page 8 of 12

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              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
  Para
                     Comment
                   Response
   17
Section
  5.1
 Pg 12, 1
  bullet
This bullet discusses shallow groundwater migration out
of the soil cell based on 2005 groundwater level data.
Please note that Progressive has since identified a flaw in
the collection process of the hydraulic data within the
containment cell that renders the soil remedy area
shallow aquifer potentiometric contours suspect; i.e.,
field personnel were not allowing proper time for water
levels to stabilize after breaking the vacuum seal of the
extraction wells.  Progressive has included the most
recent (properly collected) hydraulic data contours for
your use/information, and that map depicts a significant
inward hydraulic gradient around the entire containment
cell. Therefore, based upon the historically consistent
operation of the soil remedy (lack of [unplanned]
downtime), historical groundwater level data, the most
recently collected shallow groundwater data, and the fact
that the slurry wall is keyed into the clay, Progressive
believes that this  inward gradient has likely been
maintained since  installation of the remedy and seepage
out of the cell in the shallow aquifer is unlikely. As such,
there is no need to install another shallow well NW of the
containment cell, and continued monitoring of existing
wells DMW-1S, DMW-2S and DMW-3S will provide
sufficient detail regarding the fate of residual impacts
outside the cell.
Given the current operational schedule of 1 month
on/5 months off and the inferred regional shallow
groundwater flow direction toward the north-
northwest, installation of one additional shallow
well as indicated in the LTMO report does not
appear unreasonable or excessive to confirm that the
remedy is remaining protective overtime.
Progressive comments_responses final, doc
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              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
   Para
                     Comment
                   Response
                          nod
   18
Section
  5.1
Pgl2,2
  bullet
Progressive agrees that the current number of deep wells
in this vicinity lends to somewhat speculative hydraulic
data evaluation, however, since there is no evidence that
any significant impacts (above cleanup objectives) have
migrated into the deep aquifer as exemplified by the
historic concentrations exhibited at wells BMW-ID,
DMW-2D, DMW-3D, UMW-1D, and the same can be
said for the intermediate aquifer in this vicinity given the
historic results for 104 and 215, there does not appear to
be any justification for additional characterization of this
aquifer.
Data for wells 104 and 215 may not be relevant for
determining impacts to the intermediate zone given
the alternate potentiometric surface map prepared by
Progressive (showing a hydraulic gradient to the
east). See also response to comment #16. The
objective of the additional well installations
recommended for consideration was simply to more
fully cover the range of potential flow directions
indicated by the available data.  The justifications
for addition of another deep well are stated in the
report and include:  1) more accurate and site-
specific determination of groundwater flow direction
and vertical hydraulic gradient, and 2) obtaining
groundwater quality data along a potential flowline
from the soil remedy cell that is not currently
monitored. How can we be sure that the existing
deep wells are properly positioned if the hydraulic
data are sparse and the potentiometric surface
interpretation is somewhat speculative as a result?
   19
Section
  5.1
pg 12, 3
  bullet
Based upon the most recent groundwater elevation data
showing an inward hydraulic gradient around the
containment cell in the shallow aquifer, it is likely that
seepage out of the containment cell in the shallow aquifer
is insignificant. Per the additional information provided
above (see comment on Section 2.2), the  groundwater
seepage velocity is likely in the range of 2.3E-5 ft/day
and 3.5E-5 ft/day for the clay and underlying glacial till
layers, respectively. Impacts detected in  groundwater
outside of the containment cell are likely from residual
source material that was left in place as previously
discussed.
See response to comment #2.
Progressive comments_responses final, doc
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              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
  Para
                     Comment
                   Response
  20
Section
  5.1
pg 12, 4
  bullet
There is no threshold value or trigger concentration for
additional assessment. So long as routine monitoring
results continue to exhibit stable or non-increasing trends
(below the pre-startup levels), there is no reason for
additional assessment.
Comment noted.
  21
Section
  5.1
 Pg 13, 1
  bullet
It should be noted that the operating frequency of the soil
remedy has been reduced to 1-month on / 5-months off
(as of November 2006, per EPA approval). Should
sample results indicate that influent concentrations have
significantly rebounded when the system is restarted in
May 2007, Progressive will sample the individual
extraction wells to assist with further optimization of the
remedy.
Comment noted.
  22
Section
  5.3
 pg 14, 1
  bullet
Progressive agrees with the recommended sampling
frequencies. Progressive believes that performing
hydraulic monitoring on a semiannual basis should
provide sufficient hydraulic information for this area, and
is interested to see the results of the GSI/Parsons
evaluation of the hydraulic data (sent on 12/6/06 and
attached to this memo for reference) to  see which, if any,
locations are identified for omission from the current
hydraulic monitoring list due to redundancy.
See response to comment #11.  Given the already
sparse density of water level measurements in this
area and resulting uncertainty regarding
groundwater flow directions, particularly in deeper
zones, periodic collection of water level
measurements in all wells associated with the soil
remedy area and all nearby wells is recommended.
Progressive comments_responses final, doc
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              RESPONSE TO PROGRESSIVE ENGINEERING & CONSTRUCTION, INC.'s COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
     CLARE WATER SUPPLY SUPERFUND SITE PRB AND SOIL REMEDY AREAS, DATED NOVEMBER 8, 2006
     	(Continued)	
  Item
  No.
Section
Page/Line/
   Para
                     Comment
                   Response
                          nd
  23
Section
  5.3
pg 14, 2,
  and 3
  bullet
Progressive does not agree that further characterization of
the shallow aquifer is warranted based upon the hydraulic
performance of the remedy (as demonstrated for
November 2006 in the attached figure), the stable to
decreasing concentrations exhibited by the shallow
aquifer monitoring and the lack of risk to receptors.
Progressive does not agree that further characterization of
the intermediate aquifer is necessary based upon the non-
detect concentrations in downgradient intermediate wells
104 and 215 indicating no significant impacts in the
intermediate aquifer, the concentrations all below
cleanup objectives exhibited by deep wells BMW-ID,
DMW-2D, DMW-3D and UMW-1D, the lack of risk to
receptors from possible impacts to the intermediate
aquifer and the fact that additional water quality data
from this area would not change the operation of the
remedy. However, Progressive will agree to install one
new intermediate monitor well for hydraulic monitoring
purposes, and suggests locating that well adjacent to the
southeast side of the  soil remedy building to improve the
hydraulic monitoring network in that area.
See above responses to comments pertaining to
these issues.
  24
General
Progressive does not agree that further characterization of the deep
aquifer is necessary since there is no evidence that any significant
impacts (above cleanup objectives) have migrated into the deep
aquifer as exemplified by the historic concentrations exhibited at wells
DMW-1D, DMW-2D, DMW-3D, UMW-1D, and the same can be said
for the intermediate aquifer in this vicinity given the historic results
for 104 and 215.
                                                     See above responses to comments pertaining to
                                                     these issues.
Progressive comments_responses final, doc
                                                                                                         Page 12 of 12

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                                           RESPONSE TO MDEQ COMMENTS ON
                          THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                         CLARE WATER SUPPLY SUPERFUND SITE

Comments on the preliminary Long-Term Monitoring Optimization memoranda for the Stageright, PRB and Soil Remedy areas of the
Clare Water Supply Superfund site were received from three parties at  MDEQ: Barbara Vetort, Mark Henry and John Spielberg.
The comments are addressed below, with comments grouped according to similar topic areas.
Commenter
 Area
Page/Lin
 e/Para
Comment
Response
    JS
Comment 1a

BV
Comment 4
(page 2
paragraph 3)
General
          (JS) The agencies and the PRPs would really benefit from
          having data in electronic format all in one place. The data
          should include all the source areas:  Mitchell, Ex-Cell-O,
          StageRight, American Dry Cleaners, Stanley Oil, Standard
          Oil, MOOT bulk storage, etc. The data should be raw data
          as reported by the laboratories,  including detection limits
          and  qualifiers. CAS numbers for the parameters tested is
          also a good idea.  Most laboratories  can provide data in
          electronic, database format.

           (BV) The recommendation to combine groundwater
           elevation data collected from Stageright wells with data
           collected from the rest of the site wells to facilitate a more
           complete picture of groundwater hydraulics east of
           Stageright should be implemented. The  current level of
           plume definition is not acceptable in the Stageright area.
                               The authors agree that all site analytical data should
                               be maintained in an electronic database, accessible
                               to all stakeholders.  Proper data management is
                               central to all site optimization efforts. Progressive
                               Engineering is maintaining a site-wide electronic
                               database, and they  have done an excellent job
                               under the circumstances. The Progressive
                               database contains both analytical and hydraulic
                               monitoring data for the entire site. The authors
                               suggest that the site database be made available to
                               all stakeholders. An updated database should be
                               distributed to stakeholders after the results of each
                               sample event are added.

                               Inclusion  of validated data in the  database as
                               opposed to raw data (assuming that data validation
                               is performed) is recommended.

                               The database used  for the LTMO efforts will be
                               included on CD in the final report.

                               As a general observation, the addition of current and
                               future monitoring data to the database is a fairly
                               simple matter as data are now delivered in
                               electronic format from most labs.

                               The addition of historic information to the electronic
                               database is more problematic. Often, these data
                               are only available in hard-copy and must be added
MDEQcomments_responses final.doc
                                                                                                 Page 1 of21

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                                          RESPONSE TO MDEQ's COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
                                                                                          manually. Frequently, data are missing detection
                                                                                          limits, method names or data flags. Manual addition
                                                                                          of data is an expensive process and the opportunity
                                                                                          for introducing transcription errors is extremely high.
                                                                                          Specific elements of the historic data set should be
                                                                                          prioritized and added to the database as time and
                                                                                          budgets permit. Priority data include concentrations
                                                                                          of constituents that exceed screening levels and
                                                                                          detected compounds.

                                                                                          The authors would also suggest that a sample
                                                                                          location table be maintained in the site database.
                                                                                          Sample locations tables generally include
                                                                                          information such as the well name (and any historic
                                                                                          names), the depth, top of casing, screened intervals,
                                                                                          geographic coordinates, and date of installation.  A
                                                                                          location table can be useful for documenting details
                                                                                          such as VAS. A table with groundwater parameters
                                                                                          such as K values would be extremely helpful for a
                                                                                          site this complex.
     JS

Comment 2a
Stage right
           The MDEQ believes this area is the highest priority area
           at the site to be dealt with
                                                                                          The authors agree.
     JS

Comment 2b
Stage right
           The MDEQ supports the objective of determining whether
           this area was characterized sufficiently.  One way this
           can be evaluated is by finding out which wells were
           vertically sampled prior to setting the well screens. If
           vertical aquifer sampling (VAS) was insufficient, then this
           may need to be completed prior to implementing an
           LTMO in this area, or in conjunction with the LTMO.
                                Generally speaking, characterization of the vertical
                                extent of contamination is desirable.  Vertical
                                sampling is generally part of site characterization.
                                The authors were not provided with VAS
                                information.

                                Some sites benefit from a formal conceptual site
                                model document detailing well installation details,
                                groundwater parameters, source areas, transport
                                mechanisms, geotechnical evaluations, receptors
                                etc. It can be very useful to put all of the site data in
                                one location for all stakeholders.
MDEQcomments_responses final.doc
                                                                                                    Page 2 of21

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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                       CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
                                                                                         In most cases, consensus on site characterization
                                                                                         and site conceptual model should be largely
                                                                                         complete before monitoring networks are optimized.
                                                                                         As a general rule, the LTMO scope of work is limited
                                                                                         to determining if a sufficient number of wells exist
                                                                                         spatially to achieve monitoring objectives. The
                                                                                         authors are not funded or scoped to performed a
                                                                                         detailed review of the site investigation as part of the
                                                                                         LTMO evaluation.
     JS

Comment 2c
Stage right
           The MDEQ agrees that the shallow zone has not been
           well characterized. This zone needs better definition.
           The shallow water-bearing zone and the vadose zone
           above it may potentially contain a smear zone containing
           a continuing source of TCE and other contaminants.
           Past contamination near the water table could have
           moved up and down with rising and falling  water levels,
           thus causing the vertical smearing of contamination in
           this zone.
                               See comment 2b above.  A 'smear zone' is typically
                               present at sites that have had floating free product
                               (e.g., petroleum product), whereas TCE does not
                               float on the groundwater surface. Continuing
                               sources of contamination would be an element
                               included in a conceptual site model.
     JS

Comment 2d
Stage right
           Any new wells installed should be completed with the benefit of
           VAS to determine the zones of highest contamination
                               Comment noted. The authors agree that long-term
                               monitoring wells should be screened within the zone
                               containing the highest dissolved contaminant
                               concentrations to the extent practical.
     JS

Comment 2e
Stage right
           MDEQ agrees that chloride, alkalinity and TDS sampling
           and analysis can be reduced
                                                                                         Comment noted.
     JS

Comment 2f
  and BV
Stage right
           (JS) Would be best to have the complete data set for this
           area rather than just summaries that show exceedances
           of cleanup objectives.  Electronic format data in
           spreadsheets would be better than hard copy.
                                                                                         See comment 1a, above.
MDEQcomments_responses final.doc
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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
  Comment
  (page 1
paragraph 3)
                       (BV) The MDEQ Superfund staff has not received the
                       majority of the necessary TCRA data to include the
                       boring logs and analytical data. Therefore, the MDEQ
                       Superfund staff cannot verify the technical information
                       used for the optimization.
     JS

Comment 2f

And BV
Comment 2
(page 2,
paragraph 1)
Stage right
           (JS) An assumption was made by the optimizers that
           missing data meant that concentrations were non-detect.
           MDEQ agrees that evaluating this assumption with more
           complete historical data is a good idea.

           (BV) This report states that Progressive Engineering
           provided the data for optimization.  Progressive
           Engineering is not the Stageright TCRA consultant. This
           report states that not all the data collected by the
           Stageright consultant, MACTEC, was included, therefore
           the Optimizers assumed the results were non-detect.
           The Optimizers state that historical constituent
           concentrations should be confirmed before the Long-
           Term Monitoring Program is finalized.  The Agencies
           need to confirm that all the Stageright data and well logs
           are comprehensive and accurate.
                                Many times it is difficult to track historic data from
                                former or uncooperative consultants and to translate
                                it from hard-copy to electronic data. (See comment
                                1a above).

                                The authors were told by Progressive that 'missing
                                data' were assumed to be non-detect results.  The
                                authors did not have access to hard-copy data from
                                previous site investigations to verify concentrations
                                and detection limits, so, had to accept the dataset as
                                delivered.

                                As a general note, most LTM networks are
                                optimized for one to two major contaminants of
                                concern (COCs), when the  less prevalent
                                contaminants are contained within the plume of the
                                priority COCs. In the case of Stageright, TCE is the
                                parent compound, and appears to be most
                                widespread with the most exceedances.  Data for
                                TCE in the Stageright area  are recorded in the site
                                database, and include non-detect results.  For this
                                reason, the authors proceeded with the analysis.
                                The optimization was performed for TCE with  other
                                compounds considered qualitatively to evaluate  and
                                confirm recommendations.
MDEQcomments_responses final.doc
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                                          RESPONSE TO MDEQ's COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
     JS

Comment 2g

AndBV
Comment 3
(page 2,
paragraph 2)
Stage right
           (JS): Exclusion of site-wide monitoring wells in this area
           (e.g., 211, D-106, D-107, WD-10) should not be assumed
           to mean they should be excluded from site-wide
           monitoring.

           (BV): I  agree with the majority of recommendations that
           are outlined on pages eight and nine.  One exception, the
           recommendations include excluding wells that are not
           associated with the  Stageright TCRA.  Therefore,
           excluding wells 211,0106, D107, and WD10 is not
           appropriate for the well field remedial action.
                                One of the central activities of LTMO is to determine
                                to what extent an individual monitoring location
                                provides unique information in support of site
                                monitoring objectives.

                                A major issue of the Clare Water Supply ROD and
                                associated documents is that groundwater
                                monitoring objectives are not explicitly defined.
                                Without explicit monitoring objectives the goal and
                                significance of monitoring any individual location can
                                be interpreted differently by each stakeholder.

                                Based on qualitative and statistical evaluation, the
                                deep wells recommended for removal from routine
                                monitoring did not provide unique information
                                significant to Stageright site management decisions.
                                However, as MDEQ has expressed concern over
                                removal of these locations, their contribution and
                                suggested sample frequency will be revisited and
                                any recommendations will be better explained in the
                                final report. Even if these wells are not
                                recommended for further sampling connected to the
                                Stageright site, they could be retained for the site-
                                wide monitoring program, which was not evaluated.
     JS

Comment 2h
Stageright
           Deep zone well P-202 is too close to municipal well MW-
           5 to be useful as a sentinel well. The optimizers say this
           area is not well monitored. Therefore, better
           characterization of this zone is needed. Another deep
           zone well should be installed near the  east edge of the
           StageRight parking lot, just south of MW-8-97.
                                Given an estimated deep aquifer seepage velocity of
                                approximately 18 ft/d, all current wells are too close
                                to MW-5 to function as sentinel wells in the short
                                term.  Well MW-10-97 is approximately 2 weeks
                                travel time to MW-5. Most analytical samples
                                require at least 2 weeks to process. Data review is
                                usually much slower than analysis, and action,
                                slower, yet.

                                With these limitations, sampling P-202 provides a
MDEQcomments_responses final.doc
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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
                     Comment
                  Response
                                                                                          long-term, well-documented metric of plume
                                                                                          stability.  The well shows decreasing trends.
                                                                                          Installation of another deep zone well should be
                                                                                          accompanied by an explicit monitoring objective the
                                                                                          well will fulfill and, if necessary, expedited chemical
                                                                                          analysis to achieve the objective.
     JS

Comment 2i
                       MDEQ would like an explanation of how the average
                       TCE concentration reported in Tables 4 and 7 is used. Is
                       it used in any other calculation or statistic? Or,  is it just a
                       benchmark to compare against the CUO and MCL?
                                                               Average TCE concentration is a simple statistical
                                                               benchmark used in a general way to identify high,
                                                               medium and  low concentration wells relative to the
                                                               regulatory screening levels.

                                                               Taken together with the maximum concentration,
                                                               sample size,  and concentration trend, the average
                                                               concentration provides a summary of information
                                                               relevant to defining the area of regulatory concern
                                                               and the function of the location in the monitoring
                                                               network.
     JS

Comment 2j
   and 3a
                       The new municipal well, MW-8, was not mentioned. It
                       should be noted on the site maps, and considered in the
                       LTMO evaluation. Even though this well is outside the
                       StageRight area, it is a potential receptor of contaminants
                       from StageRight. Because of this, it should be
                       considered in the evaluation.
                                                               The new municipal well was installed as we finished
                                                               the draft report.  The authors were not informed of
                                                               its construction until after the analysis was
                                                               performed.

                                                               We do not have the coordinates for the well or any
                                                               information on its screened interval, pumping rate or
                                                               preliminary concentrations of priority COCs.
                                                               Because this well was installed near an existing
                                                               contaminant plume, it should be sampled
                                                               periodically same as other nearby active water
                                                               supply wells.
    BV
 Comment 1
  (page 1,
Stage right
 General
There is no site conceptual model presented to provide
the basis for the optimization effort.  Were the  remedial
design MODFLOW files used for this project?  Since they
As far as the authors know, there is no single
document describing a consensus site conceptual
model for the areas of concern. (For further
discussion of site conceptual model and site	
MDEQcomments_responses final.doc
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                                        RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                       CLARE WATER SUPPLY SUPERFUND SITE
                    	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
paragraph 2)
                      were not cited, we assume these files were not used.
                                                              characterization, see Comment 2b)

                                                              The site conceptual model was not detailed in the
                                                              draft memorandum for the Stageright Area (or
                                                              PRB/Soil Remedy). A brief summary of relevant
                                                              conceptual model information provided to the
                                                              authors will be included in the final memorandum.

                                                              The authors reviewed the data received, which
                                                              included the RODs, 5-year review, potentiometric
                                                              surface maps, cross-sections and analytical
                                                              database. Supplemental data on seepage velocity,
                                                              porosity, groundwaterflow direction, etc. were
                                                              supplied by Progressive.

                                                              LTMO is not generally a groundwater flow modeling
                                                              effort.  MODFLOW files were neither requested nor
                                                              made available to us, nor were the results of site
                                                              modeling made available.
    BV
 Comment 4
  (page 2,
paragraph 4)
Stageright
           The Long-Term Monitoring Optimization (LTMO) states
           that 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. A
           contingency plan specifying this should be a part of any
           changes to the groundwater monitoring program. In
           addition, every five years a complete round of analytical
           sampling for all wells should be performed to verify that
           the LTMO remains effective.  This comprehensive
           monitoring was stated as a requirement by the former
           Potentially Responsible Party's consultant in the 1994
           Remedial Design Remedial Action Work Plan.
                               The authors agree.

                               Contingency plans should be related to the stated
                               monitoring objectives.  Both should be published in
                               a site management document.
    BV
 Comment 5
PRB Area
           I am concerned that the MDEQ technical support staff
           was not given adequate input on the site conceptual
                               CSM information was provided to the authors by
                               Progressive and the USEPA, and is summarized in
MDEQcomments_responses final.doc
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                                         RESPONSE TO MDEQ's COMMENTS ON
                      THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
  (page 2
paragraph 5)
                       model used as the basis for the LTMO.
                                                               Section 2 of the LTMO report. Groundwater input
                                                               parameters are listed in Table 2 of the LTMO report.
    BV
 Comment 6
  (page 2
paragraph 6)
PRB Area
           For example, in Section 2.1 PRB area, it states that the
           shallow groundwaterflow direction is south-to-southeast
           across the PRBs. This has not been verified by existing
           site data. The remedial investigation reports the shallow
           aquifer permeabilities range from 10~3 to 10~5, rather than
           10'7.
                                Existing potentiometric surface data indicate that the
                                groundwater flow direction is roughly S/SE in the
                                vicinity of the PRB; however, the authors concur that
                                the site is not fully characterized as detailed  in
                                Section 4.1 of the LTMO report.  The hydraulic
                                gradient information derived from water level
                                measurements was used to infer the groundwater
                                flow direction; this is the standard practice at a
                                majority of contaminated sites.

                                It appears that a range of aquifer hydraulic
                                conductivities have been reported for various
                                geologic units; consensus values should be
                                determined as part of the CSM review.  At least
                                some of the K values reported in the Rl report
                                appear to have been derived from laboratory tests of
                                soil samples, and may not accurately represent
                                field-scale K values. The range of 1E-07 to 5E-07
                                cm/sec given in the text of the report was derived
                                from lithologic cross-sections provided by
                                Progressive and contained in Attachment A of the
                                report.  The Dames & Moore Rl report  states that
                                the till has a hydraulic conductivity on the order of
                                10"7 cm/sec.
    BV
 Comment 7
  (page 3
paragraph 1)
PRB Area
           The PRB remedial action area is still completing the first
           two years of remedial action monitoring.  The MDEQ
           Superfund staff has stated that the PRB should not be
           optimized until the remedy is demonstrated to be
           operating effectively.  It is premature to optimize the
           monitoring program at the PRB area. The current level of
           plume definition is not acceptable in this area.
                                Comment noted. The authors concur, for the most
                                part. Concrete metrics should be developed for
                                determining if the remedy is operating effectively.

                                As a general note, given a sufficiently long sample
                                record, recommendations for current sampling
                                locations and frequency can be made while site
                                characterization efforts are on-going. While areas of
                                site characterization uncertainty can be identified
                                during LTMO, specific actions to address site	
MDEQcomments_responses final.doc
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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                       CLARE WATER SUPPLY SUPERFUND SITE
                    	(Continued)	
Commenter
 Area
Page/Lin
 e/Para
Comment
Response
                                                                                        characterization must be based on stakeholder
                                                                                        consensus. The authors believe that the LTMO
                                                                                        recommendations made in the report are
                                                                                        reasonable; however, they should be reassessed as
                                                                                        noew data are obtained.
    BV
 Comment 8
  (page 3
 paragraph 3
  Soil
Remedy
           The last sentence in the second paragraph states that
           the groundwater monitoring wells DMW1S, DMW2S, and
           DMW3S, in May and November 2005 ranged from 8 to
           13 feet bgs.  The report states this is a few feet below the
           bottom of the emplaced soils and near the top of the till.
           The emplaced soils (soil from Mitchell area) are
           essentially at the former ground surface, the till is below
           the upper aquifer. Please clarify this sentence.
                               A reference to cross-sections drawn by Secor and
                               contained in Appendix A will be added to this text.
                               These cross-sections show the water table being
                               present a few feet below the bottom of the emplaced
                               'Mitchell' soils.
    BV
 Comment 9
  (page 3
paragraph 4)
  Soil
Remedy
           The receptors for the upper aquifer are the municipal well
           field. The seepage velocities for this area are too low.
           The Dames & Moore Remedial Investigation (Rl) reports
           the upper aquifer to be 10~5.
                               Seepage velocities appear to vary across the site.
                               Consensus representative velocities are needed for
                               LTMO, and should be supplied by the stakeholders.
                               As stated in Section 2.2 of the report, we agree that
                               the seepage velocity obtained from Progressive for
                               the area outside the soil treatment cell is too low.
    BV
Comment 10
  (page 3
paragraph 5)
  Soil
Remedy
           The Optimizers state that they did not have a complete
           data set for Vinyl Chloride for this area. The soil remedy
           area should have a complete data set for the wells
           discussed, back to their installation date, which is the
           same as the soil  remedy completion date, circa 1999.  Rl
           wells are present around the soil remedy area, were their
           data sets complete? Some of the issues with the data
           set are related to Quality Assurance/Quality Control
           problems that were experienced during the groundwater
           monitoring sampling events.	
                               For wells DMW1S-3S and 1D-3D, the site database
                               contains vinyl chloride results from 2005 - 2006.
                               TCE data are recorded from 1999 -2006.  (See
                               Comment 1a). Other wells in the area have a more
                               complete data set for vinyl chloride, with results for
                               SW-9 extending to 1988.  These wells are not
                               closely associated with the soil remedy area.
    BV
Comment 11
  (page 3
paragraph 6)
  Soil
Remedy
           I agree with the recommendations for the Soil Remedy
           Area.  However, I recommend annual rather than biennial
           sampling forUMWID and UMW1S.

           This evaluation does not look at any data older than
           1999.  There is data for many of the existing wells that
                               Annual sampling for UMW1D and UMW1S to
                               address 'background' water quality or to determine if
                               constituents from outside the soil remedy area are
                               migrating toward it is potentially reasonable.
                               However, if the groundwater flow velocity in this
                               area is indeed very low, then annual sampling may
MDEQcomments_responses final.doc
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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
   Area
Page/Lin
 e/Para
Comment
Response
                                     goes back to the 1980s. Why isn't this data evaluated for
                                     at least some key wells?  The current level of plume
                                     definition seems adequate in this area.
                                                                            be overkill because abrupt changes in upgradient
                                                                            groundwater quality that could impact the soil
                                                                            remedy area would be unlikely.

                                                                            For LTMO, 'recent' analytical data are given higher
                                                                            priority as historic data may have been collected
                                                                            under different sampling or analysis protocols.
                                                                            Often historic data have higher detection limits, and
                                                                            outliers that can skew statistics. Recent data are
                                                                            more likely to be comparable. Of the wells
                                                                            evaluated, only well 215 had  data collected prior to
                                                                            1999; these data were used  in the qualitative
                                                                            evaluation of this well.
    MH
 Comment 1
 Stage right

General
Comment
           1)  From the information provided is seems that there
              are very few shallow monitoring wells associated with
              the part of the site. Has the shallow of the aquifer
              been shown to be clean? The data indicates that a
              rather substantial source of contamination exists at
              the site. If this source material is in the vadose zone,
              then there would be substantial contamination in the
              shallow portion of the aquifer which could discharge
              to the nearby wetlands.
                                Comment noted, see Comment 2b on site
                                characterization.
    MH
 Comment 2
 Stage right

  General
 Comment
           2)  Since this document deals with optimization of the
              monitoring well network, it would be best if the
              Agencies took into account whether or not the
              individual monitoring well locations had been
              characterized using vertical aquifer sampling (VAS)
              techniques. More weight should placed on the value
              of the data from a particular part of the sight where
              VAS has been used to define the vertical and
              horizontal extent of contamination. MACTEC should
              be able to provide this information.
                                Comment noted, see Comment 2b on site
                                characterization.

                                Well weighting is possible for both qualitative and
                                MAROS evaluations.
    MH
 Comment 3
 Stage right
           3)  There is a column in Table 4 that indicates the
              average concentrations found in the individual wells.
              I'm not sure that the average concentrations are very
                                                                                         Comment noted. See comment response 2i above.
MDEQcomments_responses final.doc
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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                       CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
               General
              Comment
                          appropriate for decision making purposes unless the
                          geochemistry at that location is at steady-state.
    MH
 Comment 4
Stage right

 General
Comment
           4)  The documentation for the MAROS software
              package (Appendix B) that was used for the
              evaluation does not speak to the basic assumption
              that the site is well characterized and that the
              existing monitoring well network actually represents
              the plume. This presumed assumption has been
              violated at each of the 3 source areas (Stageright,
              Mitchell and ExCello). At each of these areas there
              exists groundwater contamination that has not been
              delineated in magnitude or area. Integral to a
              "moment analysis" would be a thorough
              understanding of the distribution of that mass. The
              MAROS evaluations of these areas identified these
              deficiencies. The MAROS evaluations reinforce the
              fact that these sources are not fully defined -
              especially  in the deeper portions of the aquifer. The
              lack of definition of the individual sources  precludes
              an understanding of the  interactions between them,
              or the cumulative effects of the three.
                                Comment noted, see Comment 2b on site
                                characterization and BV Comment 7.
                                                                                         While the extent of all identified groundwater
                                                                                         contamination has not been fully delineated (based
                                                                                         on data supplied to the authors) sufficient data are
                                                                                         available for a subset of wells to optimize the
                                                                                         monitoring approach in limited areas.

                                                                                         Collecting more data than is needed in one area
                                                                                         does not help the lack of data in another. The
                                                                                         authors maintain that some current locations can be
                                                                                         monitored at  a reduced frequency while the site
                                                                                         undergoes further characterization.
    MH
 Comment 5
Stageright

 General
Comment
           5)  There has been no discussion of the capture zone of
              the municipal wells in the vicinity of the site. I suspect
              that all parts of the site are within the capture zone of
              the municipal system.
                                No data were provided on the pumping rate and
                                capture zone of the public supply wells.  The authors
                                assumed (based on gw flow velocity and
                                potentiometric surface) that the capture zone
                                extended across the entire Stageright area. It was
                                also assumed that the Stageright plume does not
                                extend east of the municipal well MW-2.
    MH
 Comment 6
Stageright

 General
Comment
           6)  This optimization process should be repeated once
              the site-wide data gaps have been filled and we have
              a better understanding of the contaminant
              distributions and transport pathways.
                                Comment noted; the authors concur with this
                                comment. Optimization should be a dynamic
                                process and LTMO conclusions and
                                recommendations should be reassessed as new
                                data are obtained.
MDEQcomments_responses final.doc
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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
 MH Specific
 Comment 1
Stage right

 Specific
Comment
           1)  Page 4, pp 1; The documents states that there was
              an assumption made that all the missing data are
              non-detect. This should be checked into, and if found
              not to be true, the entire process should be
              re evaluated.
                                Comment noted.  The authors do not have access
                                to the missing data, which may be in hard copy
                                form.
 MH Specific
 Comment 2
Stage right

 Specific
Comment
           2)  Page 4, pp 3; The end of the paragraph states that
              the number of wells screened in the shallow zone
              was insufficient to perform a statistical analysis. From
              this one could conclude that the contamination in the
              shallow zones cannot be statistically evaluated using
              the software employed.
                                The number of wells screened in the shallow zone
                                was insufficient to perform a spatial statistical
                                analysis using MAROS. Concentration trends at
                                individual well locations could be evaluated if there
                                were sufficient sample events, but these wells have
                                not been sampled regularly.

                                Is there a reason these wells are not sampled? Dry?
 MH Specific
 Comment 3
Stage right

 Specific
Comment
           3)  Page 5, pp 1; This paragraph discusses the
              recommendations being based on the assumption
              that the "relatively rapid [groundwater] velocity will
              continue in the future". I also suggest that the In this
              part of the facility, the groundwater velocity is high
              because of its proximity to municipal production
              wells. A new production well has been installed in a
              near proximity to the Stageright facility. If the new
              well is not pumping at the same rate or from the
              same vertical interval as the pumping parameters
              used in the assumptions of the optimization model,
              the model may have to be reevaluated.
                                The authors agree. The new well was added,
                                unknown to the authors, near the end of the
                                analysis.

                                However, the groundwater velocity in this area most
                                likely will not decrease significantly due to
                                installation  of a new extraction well.
 MH Specific
 Comment 4
Stageright

 Specific
Comment
           4)  Page 5, pp 3; This paragraph suggests that the site
              characterization should be performed and suggests
              an additional monitoring well pair be installed. Any
              site wells should be installed using VAS techniques.
              Beyond just installing two additional wells additional
              characterization should be undertaken to determine
              the distribution and magnitude of the source.
                                                                                         Comment noted.
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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
 MH Specific
 Comment 5
Stage right

 Specific
Comment
           5)  Page 5, last paragraph; The document suggests that
              fewer contaminants could be analyzed during
              sampling events. If the Agencies agree that this is
              the best approach, then I suggest that periodically
              the entire list of contaminants included in an EPA
              Method 8260B analysis be evaluated
                                The rationale for this approach should be clearly
                                identified. Once COCs are identified, analysis for
                                other contaminants should not be necessary unless
                                new releases occur or hydraulic conditions change.
                                However, given that the cost of a full 8260 analysis
                                is not likely to be substantially more expensive than
                                an abbreviated analysis, periodic analysis for a full
                                analyte list should not have significant cost impacts.
 MH Specific
 Comment 6
Stage right

 Specific
Comment
           6)  Page 6, pp 2; I would agree, continuing to monitor
              the groundwater for chloride, TDS and alkalinity on a
              regular basis is not providing information that cannot
              be gained on a much less frequent basis.
                                                                                         Comment noted.
 MH Specific
 Comment 7
Stage right

 Specific
Comment
           7)  Page 7, pp 3; The recommendation is made to
              exclude MW-2-99 and MW-6-97 from the monitoring
              program, yet in the first paragraph of the following
              page the statement is made that near MW-6-97 the
              aquifer is "not well defined". This is counterintuitive.
                                Groundwater flow and contaminant transport in the
                                Stageright area appears to be heterogeneous and
                                channelized, with high concentrations (MW-1-02)
                                adjacent to low concentrations (MW-6-97).  The
                                nature of the hydrogeology at and between the six
                                points identified in Figure 6 should be clarified as
                                part of a consensus conceptual site model.

                                This said, MW-2-99 and MW-6-97 do not help
                                characterize the contaminated part of the aquifer.
                                They probably identify an area with lower flow
                                velocity or some sort of hydrogeological
                                discontinuity. Because  they do not characterize the
                                contaminated zone very well, they do not provide
                                significant information to support management
                                decisions.  Routine monitoring of these wells is not
                                particularly efficient.
 MH Specific
 Comment 8
Stageright

 Specific
Comment
           8)  Page 8, pp 1; The document states the intermediate
              groundwater zone to the east of MW1 -02 and MW-6-
              97 is not well defined. I suggest that VAS be
              performed and/or a monitoring well cluster be
              installed in this area.
                                The groundwater quality is not delineated to the east
                                of wells MW-1-02, MW-6-97 and MW-8-97. Plume
                                delineation efforts are recommended for this area.
MDEQcomments_responses final.doc
                                                                                                   Page 13 of 21

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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                       CLARE WATER SUPPLY SUPERFUND SITE
                    	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
 MH Specific
 Comment 9
Stage right

 Specific
Comment
           9)  Page 8, pp 2; The document points out that the
              groundwater velocity near MW-5 is extremely rapid
              and that concentrations are largely stable or
              decreasing. This indicates to me that that there is a
              moderately large source of parent contaminant at the
              site that may exist as a non-aqueous phase liquid.
                               Decisions on source area treatment can be
                               complicated. The reference in footnote 4 below may
                               be of help.

                               This is outside the scope of LTMO. All we can say
                               now is that under current conditions, the plume
                               appears to be stable. The magnitudes of dissolved
                               contaminant concentrations are not indicative of the
                               presence of significant NAPL.  It is possible that
                               sorbed contaminants are continually 'bleeding' into
                               the groundwater in the source area.
 MH Specific
Comment 10
Stage right

 Specific
Comment
           10) Page 8, pp 5; This paragraph in the
              recommendations suggests additional monitoring is
              needed east of MW-6-97. This should include VAS.
                                                                                        See response to Comment 8
  MHPRB
 Comment 1
  PRB
 General
Comment
           1)  The document does not discuss any data gaps
              surrounding the permeable reactive barrier (PRB)
              wall.
                               Data gaps for the PRB area are discussed in
                               Section 4.1 of the report.
  MHPRB
 Comment 2
  PRB
 General
Comment
           2)  Are there institutional controls in place for all parts of
              the site to which contamination exists or could
              migrate to?
                               We have been told that institutional controls cover
                               the entire Clare Water Supply site.  However, the
                               exact nature and extent of the institutional controls
                               are unknown to us.
  MH PRB
 Comment 3
  PRB
 General
Comment
           3)  How much sensitivity analysis was performed for the
              models and statistical software packages to bracket
              the range of values used in their assumptions?
                               None. We requested values for the input
                               parameters from Progressive, and received, what
                               should be, the consensus values established after a
                               thorough site investigation. The LTMO analysis was
                               not a modeling effort.

                               However, as part of the qualitative evaluation,
                               groundwater potentiometric surface maps, reports
                               and analytical data were reviewed. The memoranda
                               indicate  cases where the data reviewed did not
                               mesh with input parameters supplied.
MDEQcomments_responses final.doc
                                                                                                 Page 14 of 21

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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                        CLARE WATER SUPPLY SUPERFUND SITE
                     	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
  MH PRB
 Comment 4
  PRB
 General
Comment
           4)  The hydrogeology of the entire site should be looked
              at as a whole. Isopotential maps should include all
              parts of the site and should be updated following
              each monitoring event.
                                                                                         Comment noted.
  MH PRB
 Comment 1
  PRB
 Specific
Comment
           1)  Page 2, pp 1; The document describes the surficial
              unconfined aquifer as perched water. "Perched"
              suggests that the aquifer rests above some dry
              vadose soils. This is not the case. This unconfined
              portion of the aquifer becomes continuous with the
              main (deeper) aquifer to the east of the PRB.
                                Perched aquifers are aquifers that have a relatively
                                low-permeability confining layer (aquiclude) below
                                the groundwater, and sit above the main water table.
                                Information supplied to the authors suggests that the
                                surficial aquifer is perched above a relatively low-
                                permeability till unit in the area of the PRB.

                                Perched water is usually more susceptible to
                                fluctuations caused by seasonal influences. While
                                the perched water may discharge to the main
                                aquifer to the east or to the ditch to the south, in the
                                area of the PRB, the surficial unit is technically
                                perched.
  MHPRB
 Comment 2
  PRB
 Specific
Comment
           2)  Page 2 bullet 1; To the best of my knowledge,
              monitored natural attenuation (MNA) is not part of the
              ROD remedy. In this bulleted section, one of the
              goals should be to effect reliable source control
              measures.
                                In order to collect data in support of monitoring
                                objectives, it is good to have monitoring objectives.

                                As there are no explicitly defined monitoring goals
                                for the PRB area, the authors created some. The
                                first bullet includes evaluating the effectiveness of
                                source control measures, which is essential in
                                implementing 'reliable source control measures' as
                                stated in the comment.

                                Under monitoring goals for the PRB, the authors do
                                not mention monitored natural attenuation (MNA) as
                                a remedy strategy.  However, the authors do
                                acknowledge the existence of natural  attenuation
                                processes. Vinyl chloride is biodegraded aerobically
                                (see reference Note 5), and physical processes
                                such as dilution and dispersion contribute to
                                reduced  concentrations downgradient from a
                                source.  Collectively, these processes are known as
                                'natural attenuation', and this  is what was meant in
MDEQcomments_responses final.doc
                                                                                                   Page 15 of 21

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                                 RESPONSE TO MDEQ's COMMENTS ON
                 THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                CLARE WATER SUPPLY SUPERFUND SITE
                                              (Continued)
Commenter











MH PRB
Area











PRB
Page/Lin
e/Para












Comment











3) Page 2, Section 2.1 , pp 2; The statement is made
that the shallow groundwater direction is south to
Response
the statement.
Although MNA is not a formal part of the remedy
identified in the ROD, in reality it is part of the
remedy that is being relied upon because there are
VOC concentrations that exceed cleanup goals that
are not being treated by the PRB. This should not
be ignored, regardless of whether or not MNA is
included in the ROD.
The combined influence of the PRB and natural
attenuation processes limit the extent of
groundwater affected with constituents above
regulatory limits. The goal of the monitoring
program should be to evaluate the extent of
groundwater above regulatory screening levels.
Later in the report, the authors point out that MNA
appears to be a tacit remedy for intermediate and
deep groundwater in the PRB area, as the PRB's do
not extend to deeper areas of contamination. This
comment will be edited, as it is misleading.
The authors did not include confirmation of source
control as a monitoring objective, as no source of
constituents was identified to us. However, the
authors would support monitoring of the source
area, once it is identified. The ROD (1992) states
that "a source removal action was undertaken by
one of the PRPs in this area under an order from the
MDNR", but it is not clear if this was the source of
vinyl chloride in the PRB area.
In the future, identification of the source of vinyl
chloride and a complete statement of monitoring
objectives may be included as part of a Site
Conceptual Model.
Comment noted. The groundwater flow direction
was inferred from the measured hydraulic potentials,
MDEQcomments_responses final.doc
Page 16 of 21

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                                         RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                       CLARE WATER SUPPLY SUPERFUND SITE
                    	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
 Comment 3
 Specific
Comment
              southeast, across the PRB. Simply demonstrating a
              hydraulic potential across the PRB (4 times per year)
              is not equivalent to demonstrating flow through the
              PRB.
                               which is a typical practice. The authors agree that
                               the flow direction is inferred, and not specifically
                               demonstrated. The text will be revised to better
                               indicate this.
  MH PRB
 Comment 4
  PRB
 Specific
Comment
           4)  Page 2, Section 2.1, pp 4; The document states that
              the wetlands area directly recharges the aquifer. Is
              this known or assumed?
                               The ROD (1992) states "The drainage ditch empties
                               into a small wetlands area which directly recharges
                               the aquifer in the vicinity of the two contaminated
                               wells."  Both the ROD and the maps received are
                               not clear in distinguishing the various ditches across
                               the site. The ROD statement was assumed to apply
                               to the ditch south of the PRB which appears to flow
                               to the east.

                               Clarifying the interaction between area surface
                               water and groundwater may be a goal of a site
                               conceptual model.
  MHPRB
 Comment 5
  PRB
 Specific
Comment
           5)  Page 3, Section 2.2, pp 3; The authors state that at
              the ExCello site, that some impacts" remained in
              place near DMW1S, 2S, and 3S. This area should  be
              defined and the impacts monitored.
                                                                                        Comment noted.
  MHPRB
 Comment 6
  PRB
 Specific
Comment
           6)  Page 3, Section 2.2, pp 4; I would like to know how
              much water PRP-1 is pumping and at what rate in a
              10~7 cm/sec formation. Does PRP-1 even pump
              water? If the MAROS software(s) used this hydraulic
              conductivity, then a sensitivity analysis should be
              performed or pneumatic slug testing of the existing
              site monitoring wells.
                               PRP-1 is approximately 400 ft W/SWof the Ex-Cello
                               area. The PRP-1 area was not analyzed as part of
                               the LTMO evaluation, and the authors do not have
                               any details about this well.  Hydraulic conductivity in
                               this area may be different from the soil cell as the
                               clay/till unit disappears to the east.

                               For the Ex-Cello/Soil Remedy area, seepage
                               velocity was used as a qualitative metric of the
                               propensity for the groundwater plume to expand.
                               The combination of low groundwater velocity and
                               decreasing to non-detect concentrations indicates
                               the plume does not require an extensive monitoring
                               effort. The authors do recommend further
                               groundwater testing to delineate the groundwater
                               quality north and east of the soil cell as described in
MDEQcomments_responses final.doc
                                                                                                 Page 17 of 21

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                                 RESPONSE TO MDEQ's COMMENTS ON
                 THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                CLARE WATER SUPPLY SUPERFUND SITE
                                              (Continued)
Commenter

MH PRB
Comment 7
MHPRB
Comment 8
MHPRB
Comment 9
MH PRB
Comment 10
MH PRB
Comment 11
MH PRB
Comment 12
Area

PRB
Specific
Comment
PRB
Specific
Comment
PRB
Specific
Comment
PRB
Specific
Comment
PRB
Specific
Comment
PRB
Specific
Page/Lin
e/Para







Comment

7) Page 5, Section 3.3; The statement is made that the
"Dataset transmitted by Progressive was not
complete...". This should be looked into. If the
MAROS evaluation can be influenced by data that
was omitted, that data should be provided and
reevaluated. I would like to know why "data for vinyl
chloride and tetrachloroethylene collected prior to
2005 were not included for most wells
8) Page 6, Section 3.3, pp 3; The dynamics of the
groundwaterflow at the site should be evaluated and
should include the entire range of groundwater
directions that would result from seasonal variation.
9) Page 8, pp 3; The last sentence in this bullet
indicates that surface water exposure pathway is not
a concern. This should be discussed among the
agencies. If this result influences the MAROS data
evaluation, the site should be reevaluated.
10) Page 8, pp 4; The contamination in the intermediate
and deeper portions of the aquifer should be defined
and monitored.
1 1) Page 8, last paragraph; MNA is not part of the ROD
remedy.
12) Page 9, Section 4.2, bullet 3; I have to raise the
question of how can one reliably estimate the center
of mass if that mass has not been defined and is not
monitored?
Response
Section 5.1 of the report.
This statement will be corrected. The data set for
the PRB provides what appears to be a full set of
data for PCE, TCE, cDCE and VC.
The soil remedy data set does not have results for
PCE and VC prior to 2005 for many wells.
See Comment 1a on historic data.
Comment noted.
The potential for groundwater to discharge to the
ditch is of concern to the authors.
The LTMO analysis indicates that the southerly
(inferred downgradient) extent of the VOC plume is
not well defined. south of the PRBs.
Unless additional sample data are available for
shallow groundwater and the groundwater/surface
water interface, the LTMO evaluation will not
change.
Comment noted.
Comment noted. MNA was not considered as a
remedial alternative in the ROD (1992). This will be
edited.
The center of mass is calculated only for the area
covered by the wells. Mass outside of the well
network is not considered.
MDEQcomments_responses final.doc
Page 18 of 21

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                                 RESPONSE TO MDEQ's COMMENTS ON
                 THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                CLARE WATER SUPPLY SUPERFUND SITE
                                              (Continued)
Commenter


MH PRB
Comment 13
















MHPRB
Comment 14


MH PRB
Comment 15



MH PRB

Area
Comment

PRB
Specific
Comment















PRB
Specific
Comment

Soil
Remedy
Specific
Comment

Soil
Remedy
Page/Lin
e/Para





























Comment

13) Page 10, pp 2; This paragraph describes an order of
magnitude change in concentration over the course
of the past year yet earlier in this document the
authors recommend that this well no longer be
monitored due to its redundancy. This would seem to
be a valuable well, why would we not monitor it?













14) Page 10, Section 4.3, bullet 3; Once again, MNA is
not part of the ROD remedy.


15) Page 1 1 , pp 3; Before the "risks to receptors" is
evaluated, shouldn't we define the limits of the
groundwater and soil contamination?


1 6) Page 1 1 , pp 4; As Parsons points out, the
institutional controls should be evaluated in light of
where contamination is and can potentially migrate
Response

The authors state that well MW-305 "is
recommended tor retention in the monitoring
program at a semiannual frequency".

The initial statistical evaluation found this well to be
redundant because, over the length of the
monitoring record, the concentration at MW-305
could be estimated from surrounding wells.
Statistically, the well was not unique. However, the
well was retained in the network after the qualitative
evaluation (see Table 6) because of reasons laid out
in Table 3.
The preliminary frequency analysis indicated that
MW-305 should be sampled Quarterly, because of
the jump in concentration. However, after the
qualitative evaluation the recommendation was
made for semi-annual sampling.
MW-305 is a good example of why all statistical
evaluations should be reviewed qualitatively.
Comment noted. See response to MH PRB
comment 2.


Comment noted. Definition of extent of
contamination is typically performed prior to
completion of risk analysis.


Comment noted.


MDEQcomments_responses final.doc
Page 19 of 21

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                                        RESPONSE TO MDEQ's COMMENTS ON
                     THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                      CLARE WATER SUPPLY SUPERFUND SITE
                    	(Continued)	
Commenter
  Area
Page/Lin
 e/Para
Comment
Response
Comment 16
 Specific
Comment
              to.
  MH PRB
Comment 17
   Soil
 Remedy
 Specific
Comment
           17) Page 11, Last paragraph; This paragraph details a
              data gap in the current monitoring well network. This
              data gap should be filled with a VAS investigation
              and an appropriate monitoring well or two.
                                                                                       Comment noted.
  MH PRB
Comment 18
   Soil
 Remedy
 Specific
Comment
           18) Page 12, pp 2; This paragraph correctly reiterates
              the need for additional characterization and some
              additional monitoring to demonstrate that the ExCello
              remedy is working effectively.
                                                                                       Comment noted.
  MH PRB
Comment 19
   Soil
 Remedy
 Specific
Comment
           19) Page 12, pp 4; Hydraulic conductivity measurements
              in a distribution of site monitoring wells should be
              measured to resolve this data gap. I suggest
              pneumatic slug testing as it is fairly inexpensive and
              easy to perform.
                                                                                       Comment noted.
  MH PRB
Comment 20
   Soil
 Remedy
 Specific
Comment
          20) Page 12, last paragraph; The statement is made that
              "this TCE detection does not appear to be of concern
              given the lack of nearby receptors." This should be
              looked at in light of the 10-year capture zone for the
              municipal well system, ARAR's, and the availability of
              adequate institutional controls.	
                               A formal site conceptual model may be a good place
                               to evaluate these issues.
  MHPRB
Comment 21
   Soil
 Remedy
 Specific
Comment
          21) Page 13, pp 1; Perhaps the ExCello remedy needs to
              be reevaluated. Since water is being pumped from
              within the enclosure, even after years of operation, it
              may be that the cap, sidewalls or floor may be
              leaking. Is it time to sample the soil within the
              enclosure (I did not see any soil gas probes) to
              determine if the treatment objectives have been met?
              How do the soil/groundwater concentrations outside
              the cell compare to those media within the cell?	
                               The authors do not have access to sampling data
                               within the cell.
MDEQcomments_responses final.doc
                                                                                                Page 20 of 21

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                                      RESPONSE TO MDEQ's COMMENTS ON
                    THE DRAFT LONG-TERM GROUNDWATER MONITORING OPTIMIZATION
                                     CLARE WATER SUPPLY SUPERFUND SITE
                                                     (Continued)
Notes:
   1.   JS = Comment received from John Spielberg MDEQ
   2.   BV = Comment received from Barbara Vetorts MDEQ.
   3.   MH = Comment received from Mark Henry.
   4.   DNAPL References: Kavanaugh et al. (2003) The DNAPL Remediation Challenge:  Is there a case for source depletion.  USEPA
       EPA/600/R-03/143.
   5.   Bradley, P.M. and F.H. Chapelle, Effect of Contaminant Concentration on Aerobic Microbial Mineralization of DCE and VC in Stream-Bed
       Sediments. Environmental Science and Technology, 1998. 32(5): p. 553-557.
MDEQcomments_responsesfinal.doc                                                                                Page 21 of 21

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