Long-Term Groundwater
Monitoring Optimization
Clare Water Supply Superfimd Site
StageRight Area
Clare, Michigan
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Solid Waste and EPA 542-R-07-009
Emergency Response August 2007
(5203P) www.epa.gov
Long-Term Groundwater
Monitoring Optimization
Clare Water Supply Superfund Site
StageRight Area
Clare, Michigan
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Notice and Disclaimer
Work described herein was performed by GSI Environmental, Inc. for the U.S.
Environmental Protection Agency (U.S. EPA) and has undergone technical review by
EPA. 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. 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 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 1
3.0 Methods 2
3.1 Qualitative Evaluation 2
3.2 MAROS Statistical Evaluation 4
3.3 Data Input, consolidation and Site Assumptions 4
4.0 Results 5
4.1 Qualitative Review 5
4.2 MAROS Statistical Review 7
5.0 Recommendations 10
6.0 Long-Term Monitoring Program Flexibility 11
7.0 References Cited 12
Tables
Table 1 Groundwater Monitoring Locations StageRight Area
Table 2 Aquifer Input Parameters: StageRight Area
Table 3 Qualitative Evaluation of StageRight Groundwater Monitoring Network
Table 4 Well Trend Summary Results: 1999-2006
Table 5 Well Redundancy Analysis Summary Results
Table 6 MCES Sampling Frequency Analysis Results
Table 7 Final Recommended Groundwater Monitoring Network StageRight Area
Figures
Figure 1 StageRight Area Well Locations and Average TCE Concentrations
Figure 2 Qualitative Evaluation Results for StageRight Facility
Figure 3 Approximate Well Screen Intervals for StageRight Vicinity
Figure 4 StageRight Area TCE Temporal Trend Results
Figure 5 StageRight Area TCE First Moments Intermediate Zone
Figure 6 StageRight Area Well Redundancy and Sufficiency TCE
Figure 7 Final Recommended Monitoring Network StageRight Area
Attachments
Attachment A: Groundwater Seepage Velocity Calculations
Attachment B: MAROS 2.2 Methodology
Attachment C: MAROS Reports
Attachment D: MDEQ Comment Response
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Clare Water Supply
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Monitoring Network Optimization
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ABBREVIATIONS
AOC Area of Concern
BGS Below Ground Surface
CES Cost Effective Sampling
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
COC Constituent of Concern
CUO Clean-up Objective
DCE c/s-1,2-Dichloroethene
EDO Electronic Data Deliverable
GIS Geographic Information System
GSI Groundwater Services, Inc.
HSCB Hypothetical Statistical Compliance Boundary
LTM Long-Term Monitoring
LTMO Long-Term Monitoring Optimization
MAROS Monitoring and Remediation Optimization Software
MCES Modified Cost Effective Sampling
MCL Maximum Contaminant Level
MSL Mean Sea Level
NAPL Non-Aqueous Phase Liquid
NPL National Priorities List
PCE Tetrachloroethene (Perchloroethene)
PLSF Preliminary Location Sampling Frequency
PRG Preliminary Remediation Goal
PRP Potentially-Responsible Party
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Rl Remedial Investigation
SF Slope Factor
TCE Trichloroethene
IDS Total Dissolved Solids
USEPA United States Environmental Protection Agency
VOC Volatile Organic Compound
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GROUNDWATER MONITORING NETWORK OPTIMIZATION
STAGERIGHT AREA
CLARE WATER SUPPLY SUPERFUND SITE
The following memorandum contains a review of the long-term groundwater monitoring
network for the StageRight (former Welltronics) Facility area near the Clare Public Water
Supply, Clare Michigan. The current monitoring network was evaluated using a formal
qualitative approach and statistical tools found in the Monitoring and Remediation
Optimization System software (MAROS). (The network evaluation was conducted in
September 2006 prior to activation of the new municipal well, MW-8). The goal of the
groundwater monitoring program is to track changes in concentrations of priority
chlorinated constituents that may affect the drinking water remediation system used to
treat the public water supply. Recommendations are made for groundwater sample
frequency and location based on current hydrogeologic, pumping, and contaminant
conditions. The report evaluates the monitoring network west of Maple St. to the
StageRight Facility on the west using analytical and hydrogeologic data from sampling
events conducted between June 1988 and May 2006.
1.0 Project Objectives
The goal of the StageRight monitoring network optimization is to design a monitoring
program that is 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 of the monitoring program 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 site-specific sampling location and frequency recommendations based
on both qualitative and quantitative statistical analysis results.
2.0 Site Background
The StageRight Area of Concern (StageRight AOC) is part of the Clare Water Supply
Superfund site (EPA ID# MID980002273) located in the southwest section of the City of
Clare, Clare County, Michigan. The StageRight facility (former Weltronics facility) is
part of a larger industrial complex located immediately upgradient of the municipal well
field for the City of Clare, Michigan. Shallow public water supply wells in Clare are
chronically affected by low levels of chlorinated solvents and hydrocarbons emanating
from multiple sources in the industrial park. Affected groundwater is currently treated
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with air strippers and blended with uncontaminated groundwater prior to distribution to
the public.
A Remedial Investigation (Rl) report was completed by Dames and Moore on behalf of
the potentially responsible parties (PRPs) in 1990. Based on soil sample results, the
source area associated with the StageRight AOC is located under the main building just
west of well MW-1-97 (see Figure 1). Contaminants from other source areas in the
industrial park may migrate to the StageRight area by means of a remnant tile drain
system from previous agricultural activity and under the influence of strong pumping in
the area of the municipal wells.
The StageRight subsurface is characterized by 10-12 feet of layered sand, clay and silt
in the upper soil column underlain by a sand and gravel unit with varying amounts of silt
to a depth of 60 to 80 feet below ground surface (bgs). The municipal wells are drilled
into the sand/gravel unit. A layer of low-permeability glacial till exists west of the
StageRight area, but pinches out west of the current StageRight monitoring wells.
The groundwater system is unconfined in the StageRight area with a flow direction to the
east/southeast influenced by pumping at the municipal well MW-5 (and currently MW-8
operational as of September 2006). The water table is present at a depth of
approximately 20 to 25 feet bgs. Pumping increases the groundwater gradients in the
area resulting in high groundwater velocities (see Table 2).
As part of a Time Critical Removal Action (ES&E, 2000), an ozone sparging system has
been installed in the vicinities of wells MW-1-97 and MW3-99. The full ozone system has
been operating since 2002. Additional monitoring wells were installed as part of the
Removal Action. Monitoring data from the StageRight network was used to evaluate the
efficacy of the Time Critical Removal Action.
3.0 Methods
Evaluation of the groundwater monitoring network in the vicinity of the StageRight
Facility 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
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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
REASONS FOR REMOVING A WELL
FROM MONITORING NETWORK
Well is needed to further characterize the
site or monitor changes in contaminant
concentrations through time
Well provides spatially redundant
information with a neighboring well (e.g.,
same constituents, and/or short distance
between wells).
Well is important for defining the lateral or
vertical extent of contaminants
Well has been dry for more than two
years
a/
Well is needed to monitor water quality at a
compliance or receptor exposure point
(e.g., water supply well)
Contaminant concentrations are
consistently below laboratory detection
limits or cleanup goals
Well is important for defining background
water quality
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.
Once the decision has been made to retain a well in the network, data are reviewed to
determine a sample 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
REASONS FOR DECREASING
SAMPLING FREQUENCY
Groundwater velocity is low
Change in contaminant concentration
would not significantly alter a decision or
course of action
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REASONS FOR INCREASING
SAMPLING FREQUENCY
REASONS FOR DECREASING
SAMPLING FREQUENCY
Well is necessary to monitor source area
or operating remedial system
Well is distal from source area and
remedial system
Cannot predict if concentrations will
change significantly over time, or recent
significant increasing trend in contaminant
concentrations at a monitoring location
resulting in concentrations approaching or
exceeding a cleanup goal, possibly
indicating plume expansion
Concentrations are not expected to change
significantly over time, 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, plume stability and spatial
uncertainty in the StageRight area. 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 StageRight area. 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 from the StageRight area were supplied by Progressive Engineering and
Construction, Inc (Progressive, 2006), supplemented with information from historic site
reports. Progressive is in the process of assembling analytical data from the various
areas of concern into a site-wide database. Chemical analytical data were organized in
a database, from which summary statistics were calculated. It should be noted that the
electronic dataset transmitted by Progressive was not complete in that many non-detect
analytical results from StageRight wells (collected by MACTEC) have not been entered
into the site database at this time. For example, analytical results for vinyl chloride or
c/s-1,2-dichloroethene (DCE) were not included for some wells with trichloroethene
(TCE) detections. The following evaluation assumed that the missing data were non-
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detect for these constituents. Complete validated historic constituent concentrations
should be entered into a site-wide electronic database available to all stakeholders.
Wells and sample frequencies in the current StageRight groundwater monitoring
program are shown on Table 1. The qualitative evaluation included both current and
historic monitoring locations in an area bounded by Maple St. to the east and the
StageRight building to the west. In all, 34 locations were considered in the qualitative
evaluation. Details of the qualitative evaluation are shown on Table 3 and on Figure 2.
Data from the current monitoring network (21 wells) were used in the quantitative
(MAROS) analysis.
Well screened intervals were used to group locations into shallow, intermediate, and
deep groundwater zone monitoring points. Screened intervals for wells are illustrated in
Figure 3. Fourteen locations were considered part of the intermediate groundwater zone
(approximately 30-50 ft bgs), and seven locations were assigned to the deep zone
(approximately 50- 80 ft bgs.). The two groundwater zones were considered separately
as two-dimensional slices for the quantitative evaluation and as largely independent
zones for the qualitative evaluation. The number of wells screened in the shallow zone
was insufficient to perform spatial statistical analyses.
A list of aquifer physical parameters assumed for the analysis is shown in Table 2. Two
screening levels were identified for concentrations of TCE in groundwater. A cleanup
objective (CUO) of 0.3 mg/L was established as a remediation goal under the Time
Critical Removal Action for the StageRight Facility. The USEPA Maximum Contaminant
Level (MCL) of 0.005 mg/L was used as a general screening level and long-term goal for
water quality in the aquifer. A consensus groundwater seepage velocity was not
available from the stakeholder group, so a seepage velocity was estimated for the area
(see Attachment A below).
4.0 Results
Results from the, qualitative evaluation, analytical program review, stability analysis,
temporal trend analyses, moment analysis, and sampling frequency determination for
the StageRight facility are summarized below.
4.1 Qualitative Review
• The qualitative review included an estimation of the groundwater velocity in the
StageRight area. The seepage velocity was estimated to be approximately 13
ft/day for the intermediate zone and 18 ft/day for the deep zone (see Attachment
A). Recommendations for future monitoring in the StageRight area were
influenced by the large magnitude of the estimated seepage velocity and are
contingent on the future stability and magnitude of the seepage velocity (i.e.,
recommendations are based on the assumption that the estimated seepage
velocity is reasonably accurate and that this relatively rapid velocity will continue
in the future).
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Details of the qualitative evaluation are shown on Figures 2 and 3 and Table 3.
The potentially rapid groundwater velocity and the proximity of the public water
supply well (MW-5) result in the recommendation to sample several locations
along the centerline of the plume monthly. However, several wells were
recommended for reduction in sample frequency or elimination from the
monitoring program. Three intermediate zone wells (MW-2-99, MW-6-97 and
WS-10) and four deep zone wells (211, MW-106D, MW-107D and WD-10) are
recommended for exclusion from the program.
The plume in the intermediate groundwater zone to the east of MW-1-02 and
MW-6-97 is not well bounded. With the addition of the new municipal water
supply well in the area of MW-2 but closer to the plume (MW-8), there is concern
that groundwater and dissolved contaminants could be migrating into the
uncharacterized area north of MW-5. For this reason, installation of a new well
pair screened in the intermediate and deep groundwater zones should be
considered for the area north of MW-5 and east of MW-6-97.
Available information indicates that groundwater samples collected from
StageRight wells by MACTEC are analyzed for volatile organic compounds
(VOCs) using Method SW8260B, chloride using Method E300.0, total alkalinity
using Method E310.1, and total dissolved solids (TDS) using Method E160.1.
Information presented in the 2005 Annual Monitoring Report prepared by
Progressive Environmental (February 2006) indicates that other area wells
sampled by Progressive are analyzed for VOCs (method not known but assumed
to be SW8260B), and the field parameters pH, conductivity, turbidity,
temperature, dissolved oxygen, and oxidation-reduction potential.
Information presented in the Monthly Progress Report submitted to the USEPA
by MACTEC on September 7, 2005 indicates that, as of July 2005, the inorganic
parameters had been targeted for analysis up to 67 times beginning in May 2001
(actual number of analyses varies by well). The basis for performing these
inorganic analyses is not clear. Chloride can be used as a natural attenuation
indicator parameter but this is not a monitored natural attenuation site and other
important natural attenuation indicator parameters are not targeted for analysis.
If the purpose is to support the suitability of the water for human use then
samples from the production wells can be analyzed for these parameters; it
should not be necessary to analyze samples from all monitoring wells for these
inorganic parameters every sampling event. The following recommendations
pertaining to the groundwater analytical program should be considered:
Discuss optimizing the target VOC list to a short-list of key contaminants of
concern (e.g., chlorinated ethenes) with the analytical laboratories. Potential
advantages include lower laboratory analytical costs and lower data
management/validation/reporting costs.
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Review the basis for collecting samples for chloride, alkalinity, and IDS in
StageRight monitoring wells. Concentrations of these analytes in site
groundwater have been thoroughly documented, and it appears that significant
optimization/reduction of the inorganic constituent sampling program should be
possible.
4.2 MAROS Statistical Review
• The MAROS Constituent of Concern (COC) Assessment ranked TCE as the
highest priority constituent in terms of toxicity and prevalence. Tetrachloroethene
(PCE) ranked lower than TCE in terms of prevalence and toxicity; however, the
data set supplied for the evaluation did not include analytical results for PCE and
DCE for many locations. The qualitative and quantitative evaluation centered on
characterizing distribution of TCE, with other constituents considered as
secondary drivers for the monitoring program.
• Individual well trend analyses for priority constituents were determined in
MAROS using analytical data collected between 1999 and 2006. For some
locations, more recent trends were determined and compared to the long-term
trends. Results indicate that the majority of sample locations have Decreasing
long-term concentration trends for TCE using both Mann-Kendall and Linear
Regression techniques (see Table 4). Results for the Mann-Kendall trend
evaluation are illustrated on Figure 4.
Source wells MW-1-97 and MW-5-97 and high concentration well MW-3-99 show
Decreasing to Probably Decreasing trends for TCE. Only two locations in the
intermediate zone showed Increasing trends for TCE. Upgradient location MW-
1-01 shows an Increasing trend from 1999-2006, but has an average
concentration below the screening levels (MCL = 0.005 mg/L). The recent trend
(2004-2006) at MW-1-01 is Stable, indicating MW-1-01 may have been
influenced by remediation activities during the 2000-2001 timeframe. An
Increasing trend was found at location MW-6-97 from 1999-2006; however, as
with MW-1-01, the average concentration is below the screening levels. The
recent trend at MW-6-97 (2004-2006) is Decreasing. With the initiation of
pumping at new municipal well MW-8, concentration trends in the StageRight
area should be evaluated after each sample event.
Individual wells in the deep groundwater zone have largely Decreasing trends for
TCE or show non-detect results. Average concentrations in this zone are below
the screening levels. Results of the well trend analysis are shown in Table 4 and
on Figure 4.
• The total dissolved mass estimate (zeroth moment) for TCE showed a
"Decreasing" trend between 1999 and 2006 for the intermediate groundwater
zone. Recent estimates of total dissolved mass in the intermediate zone plume
show approximately 0.4 Kg in 2001 dropping to 0.20 Kg in 2006. Decreasing
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total mass along with Decreasing trends at individual wells indicate that
remediation efforts in the area appear to be effective. (Moments for the deep
zone could not be evaluated due to the small number of monitoring locations.)
The movement of the center of mass (first moment) of the plume relative to the
source area shows a Decreasing trend, indicating a stable to shrinking plume.
First moments are illustrated on Figure 5, and indicate very little change in the
center of mass of the plume over the time-frame analyzed. Plume stability is
most likely enhanced by the continuous pumping at the municipal wells, which
dramatically reduces the opportunity for the plume to expand.. Evaluation of
plume spread about the center of mass (second moment) indicates Increasing
trends both parallel and perpendicular to groundwater flow. Increasing second
moments indicate reduced mass in the center of the plume relative to the edges,
which supports the conclusion that the sparging system is effectively removing
contaminant mass from the plume.
• Spatial analysis of the plume suggests that preferential flow paths exist in the
StageRight area. Intermediate zone wells MW-3-99, MW-1-02, MW-8-97, and
MW-7-97 show higher TCE concentrations than adjacent wells MW-1-99, MW-2-
99 and MW-6-97. For this reason, the MAROS statistical evaluation indicates a
moderately high degree of uncertainty in the center of the plume (see Figure 6).
Installation of a new well pair is recommended for the area just east of the
current network, as the area of high concentration at MW1-02 is not bounded
immediately to the east. Channelization within the sand/gravel matrix could
provide a flow path for constituents to the east before turning south to the
pumping wells. A recommendation is made to exclude wells MW-2-99 and MW-
6-97 from the monitoring program, as they do not contribute information to
support characterization of the movement of plume mass (see also Table 3 for
additional details on rationale for exclusion of these wells). Well WS-10 is also
recommended for exclusion as it is north of the plume and shows low levels of
constituents.
Deep zone wells 211, D-106 (MW-106D), D-107 (MW-107D) and well WD-10 are
also recommended for exclusion from the StageRight monitoring program, based
on their low levels of TCE and their position outside the main plume flow path.
These wells may be retained for hydrogeologic monitoring and/or as part of a
regional groundwater quality assessment.
While no areas within the current network were identified by MAROS as requiring
additional sampling locations, areas of concentration uncertainty were identified.
The deep groundwater zone beneath the plume core between MW-10-97 and P-
202 is not monitored. However, as this area of the plume is decreasing in
concentration for both the intermediate and deep zones, a new deep well is not
recommended in this area under current conditions.
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Upgradient well MW-1-01 has an average concentration below the screening
levels; however, the well exhibits a long-term Increasing concentration trend for
TCE. Concentrations at this well may have been influenced by a combination of
pumping intensity at municipal wells mobilizing affected groundwater to the north
and by recent activity associated with remedy installation. No new well is
recommended for the area north of MW-1-01 at this time as concentration trends
have been Stable for the past two years. However, wells on the northern edge of
the StageRight Facility should be monitored periodically for any changes in
dissolved contaminant concentrations in the future.
An area of higher concentration uncertainty was identified during the qualitative
evaluation. The groundwater quality in the intermediate groundwater zone to the
east of MW-1-02 and MW-6-97 is not well characterized. This area is outside of
the current network and could not be evaluated using MAROS spatial statistical
tools.
Results from the qualitative evaluation and the MAROS well sampling frequency
tool (the Modified CES method) were used to develop a sample frequency for
groundwater using conservative assumptions. An overall sample schedule was
developed after considering site hydrogeology, the location of each well in
relation to the plume and the water supply wells, individual well trends, non-
detect values, and recent sample frequency. (Note: the sample frequency
recommendations are based on the assumption that the groundwater flow
velocity in the MW-5 area is extremely rapid but that plume conditions at the site
are largely stable to decreasing. Deviations from these assumptions should
result in reevaluation of the sample frequency and modification of the monitoring
program.)
The final well sampling recommendation developed using both qualitative and
quantitative methods is illustrated on Figure 7 and detailed in Tables 3, 6, and 7.
The optimized sampling program recommends:
o Monthly sampling for flow path wells MW-1-02, MW-8-97, MW-7-97, P-
202, and MW-5.
o Semiannual sampling (every 6 months) for source area wells MW-1-97,
MW-3-99, MW-5-97.
o Annual sampling for wells MW-1-01, MW-3-01, MW-2-01, MW-1-99, WS-
5 and deep well MW-10-97. Wells WS-5 and MW-5-97 may be reduced
in frequency or excluded from the monitoring program if further sampling
indicates consistent Decreasing trends (see Table 3 for details).
The total recommended program results in 71 groundwater samples annually.
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5.0 Recommendations
• Monthly chemical sampling and water level measurements are recommended for
five wells along the flow path of constituents to public supply well MW-5
(illustrated on Figures 2 and 7). Data from these monitoring events should be
reviewed promptly after each sample event and evaluated for increasing
concentration trends.
• Installation of a new monitoring well pair is recommended for the intermediate
and deep groundwater zones east of MW-6-97. Two additional areas of
concentration uncertainty should be monitored for increasing trends using the
proposed network and sample frequency: Continue monitoring the intermediate
zone north near MW-1-01 and the area around MW-1-02 and MW-8-97. Monitor
deep zone wells MW-10-97 and P-202 for any increasing concentration trends.
• Exclude intermediate zone wells WS-10, MW-2-99 and MW-6-97 from the routine
analytical monitoring program for the StageRight area. These wells should be
maintained for water-level measurement and may be included in periodic (e.g.,
every 5 years) confirmation sampling to ensure plume stability
Exclude deep zone wells 211, D-106 (MW-106D), D-107 (MW-107D) and well
WD-10 from routine analytical monitoring at the StageRight area. As with the
intermediate zone wells, these locations should be maintained for water-level
monitoring and periodic confirmation sampling. As the Site-Wide groundwater
monitoring plan was not evaluated in this report, the deep wells listed above may
provide useful information on groundwater quality for broader regional
groundwater quality evaluations. If wells 211, D-106 and D-107 are included in
the Site-Wide monitoring network, they may be sampled at a frequency
appropriate for regional groundwater management decisions.
• Semiannual monitoring is recommended for three high concentration 'source'
wells: MW-1-97, MW-5-97 and MW-3-99.
• Annual sampling is recommended for six locations that support plume
delineation: MW-1-01, MW-2-01, MW-3-01, MW1-99, MW-10-97, and WS-5.
Annual sampling is recommended due to the stability of the plume under the
current pumping regime, as demonstrated by the stationary position of the first
moments.
• If current trends continue at locations MW-5-97 and WS-5, these wells may be
considered for removal from the program in the future as described more fully in
Table 3.
• Cost and data management benefits may be gained from optimizing the chemical
analytical program to a short list of target VOCs that include key contaminants of
concern (e.g., chlorinated ethenes). Review the basis for collecting samples for
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chloride, alkalinity, and IDS in StageRight monitoring wells. Concentrations of
these analytes in site groundwater have been thoroughly documented, and it
appears that significant optimization/reduction of the inorganics sampling
program should be possible.
• Combine groundwater elevation data collected from StageRight wells by
MACTEC with data collected from area wells by Progressive and other
stakeholders to facilitate a more complete evaluation of groundwater flow
directions and hydraulic gradients. Neither data set, by itself, provides a
sufficiently complete picture of groundwater hydraulics east of the StageRight
facility.
• 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 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 brought on by installation of the new
municipal well 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.
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March 22, 2007
7.0 Reference Cited
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/Maros.htm.
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.
Progressive (2006). Progressive Environmental and Construction, Inc. Clare Water
Supply Database.
ES&E. (2000). Time Critical Removal Action Work Plan, StageRight Facility, Clare Water
Supply Site, Clare, Michigan.
StageRight Area 12 Long-Term Groundwater
Clare Water Supply Superfund Site Monitoring Network Optimization
-------
Tables
-------
GSI Job No. G-3138-105
Issued 03/22/2007
Page 1 of 1
V
GROUNinVATIiR
SERVICES, INC
TABLE 1
GROUNDWATER MONITORING LOCATIONS STAGERIGHT AREA
LONG-TERM MONITORING OPTIMIZATION
CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
Well Type
Well Name
Top of Screen
[ft bgs]
Bottom of
Screen
[ft bgs]
Recent Sampling
Frequency
Intermediate Zone Wells
T
T
S
T
T
T
T
S
S
T
T
T
T
T
MW-1-01
MW-1-02
MW-1-97
MW-1-99
MW-2-01
MW-2-99
MW-3-01
MW-3-99
MW-5-97
MW-6-97
MW-7-97
MW-8-97
WS-5
WS-10
38
39.1
32
35
40
35
37
30
35
39
40
35
35
44.5
43
44.1
42
45
45
45
42
40
45
49
50
45
40
49.5
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Semi-annual
Semi-annual
Deep Zone Wells
T
T
T
S
T
T
T
211
D-106
D-107
MW-10-97
MW-5
P-202
WD-10
50
57.25
58
55
53
65
64
55
62.25
63
65
80
85
69
Semi-annual
Semi-annual
Semi-annual
Monthly
Quarterly
Monthly
Semi-annual
Wofes:
1. S = Source area; T = Tail area (designations for MAROS software).
2. Wells listed above had sufficient data to be included in both quantitative and qualitative evaluations.
Well locations are shown on Figure 1.
3. Screened intervals from Progressive, 2006.
4. ft bgs = feet below ground surface.
5. Deep wells P-201, P-203, P-204, P-205, and WD-5 have insufficient data for quantitative analysis.
6. Intermediate zone wells MW-4-97, S-107, WD-21 and 108 had insufficient data for quantitative analysis.
7. Shallow zone wells were not evaluated.
-------
GSIJobNo. G-3138-105
Issued 03/22/2007
Page 1 of 1
GROUNIWATER
SERVICES, INC.
TABLE 2
AQUIFER INPUT PARAMETERS: STAGERIGHT AREA
LONG-TERM MONITORING OPTIMIZATION
CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
Parameter
Current Plume Length
Maximum Plume Length
PlumeWidth
SeepageVelocity Intermediate (ft/yr)*
SeepageVelocity Deep (ft/yr)*
Distance to Receptors (Source to MW-5)
GWFIuctuations
SourceTreatment
PlumeType
NAPLPresent
Trichloroethene (TCE)
Cleanup Objective (Removal Action)
MCL
Parameter
Groundwater flow direction
Porosity
Source Location near Well
Source X-Coordinate
Source Y-Coordinate
Saturated Thickness Intermediate Zone
Saturated Thickness Deep Zone
Parameter
Shallow Zone Aquifer
Intermediate Zone Aquifer
Deep Zone Aquifer
Value
300
700
200
4600
6700
300
No
Ozone Sparge (Air stripping at well
head)
Chlorinated Solvent
No
Screening Levels
0.3
0.005
Value
E/SE
0.31
MW-1-97
13015427.53
845280.636
20
40
Value
<22
30-50
50-85
Units
ft
ft
ft
ft/yr
ft/yr
ft
~
~
~
~
mg/L
mg/L
345
~
~
ft
ft
ft
ft
ft bgs
ft bgs
ft bgs
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 Objectives for removal action - StageRight property (Progressive, 2006).
7. * = Seepage velocity estimated from site data. See Attachment A.
-------
Issued: 3/22/2007
Page 1 of 2
TABLE 3
QUALITATIVE EVALUATION OF STAGERIGHT GROUNDWATER MONITORING NETWORK
LONG-TERM MONITORING OPTIMIZATION
CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
Well Name
Hydrologlc Unit
Current
Sampling
Frequency
Qualitative Analvsis
Exclude
Retain
Monitoring
Frequency
Recommendation
Rationale
StageRight Wells
MW-1-01
MW-1-02
MW-1-97
MW-1-99
MW-2-01
MW-2-99
MW-3-01
MW-3-99
MW-5-97
MW-6-97
MW-7-97
MW-8-97
WS-5
WS-10
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Semiannual
Semiannual
X
X
X
X
X
X
X
X
X
X
X*
X
X
X*
Annual
Monthly
Semiannual
Annual
Annual
NA
Annual
Semiannual
Semiannual
NA
Monthly
Monthly
Annual
NA
Upgradient to cross-gradient from plume; TCE varied from ND to 5.7 ug/L during 58 sampling events over 4.8 yr from 8/01 to 4/06; maximum
change of only 3. 1 ug/L over last 45 sampling events since 8/02, increasing trend prior to 2004. 1 ,2-DCE exhibits slow increasing trend but well
below MCL. Retain at relatively low frequency to provide upgradient/background groundwater quality data.
Located along approximate longitudinal axis of TCE plume immediately downgradient of 'hotspot' well MW3-99; decreasing TCE levels but
becoming asymptotic; relatively stable PCE levels; good indication of remediation effectiveness; retain at high frequency given potential high
groundwater flow velocity to provide early warning of hotspot migration toward production well MW-5 in the event that subsurface conditions
change and plume expansion occurs. Note that estimated groundwater flow velocity is based on very limited data; if actual velocity is lower,
then lower sampling frequency (e.g., quarterly) may be appropriate.
Measures effectiveness of ozone sparging system at reducing relatively elevated TCE levels at east edge of StageRight building; well contains
2nd-highest levels of TCE at site.
No MCL exceedances in 54 events since 10/01 ; no evidence of increasing trend. Retain at relatively low frequency to monitor southern (cross-
gradient) boundary of plume overtime.
Retain to monitor potentially increasing 1 ,2-DCE concentrations (TCE stable since late 2002); low magnitude of COG concentrations and lack of
substantial changes from event to event justify relatively low frequency.
TCE non-detect during 20 events from 9/04 to 4/06; redundant with MW-1-99 which is screened in same zone and can be sampled to monitor
southern extent of plume over time in this area.
Retain to monitor northern (cross-gradient) plume boundary over time. Relatively low frequency justified by decreasing 1 ,2 DCE levels over
time and consistent non-detect for other COCs.
Retain to monitor highest TCE concentrations detected in site groundwater and effectiveness of ozone sparge system; relatively stable
concentrations over past few years following early decreasing trend from 2000 to 2001 .
Retain only if data from this well are needed to make decisions regarding continued operation of sparge system in this area. Otherwise, this
well is redundant with MW-1-97, which has consistently higher COG concentrations and will be the limiting factor on achieving compliance with
cleanup goals in this area.
umy i siignt cleanup goal exceedance ( njh = 3.6 ug/L in iviarcn U4) over 4 yrs and 40 sampling events; I u= staple since apout Jan U4; i ,A-
DCE historically less than 10 ug/L and ND last 5 events ending 4/06. Stable to decreasing trends since 2004, low magnitude of concentrations,
and proximity of well MW-1-02 which has higher COG levels and is recommended for retention support exclusion of this well from LTM
program. This well does not appear to be in the primary flowpath of groundwater and dissolved contamination emanating from StageRight
Facility
Retain as sentry well at high frequency given potential for high groundwater flow velocity for early warning of COG concentrations migrating
toward production well MW-5. Note that estimated groundwater flow velocity is based on very limited data; if actual velocity is lower, then lower
sampling frequency (e.g., quarterly) may be appropriate.
Retain at high frequency given potential for high groundwater flow velocity to monitor concentrations along approximate plume axis and
flowpath between source area and production well MW-5; apparent increasing trend in PCE levels. Note that estimated groundwater flow
velocity is based on very limited data; if actual velocity is lower, then lower sampling frequency (e.g., quarterly) may be appropriate.
Decreasing trend for TCE, cross-gradient location, and distance from main plume area support relatively infrequent monitoring; discontinue
monitoring or decrease to every other year if concentrations remain at low levels through 2007 unless hydraulic regime changes or remediation
system is shut down.
Stable trends for COCs since 2002, low-magnitude concentrations (at or below cleanup goals), cross-gradient location, and distance from main
plume all support exclusion of this well from continued regular LTM. TCE below 10 ug/L for 19 events from Sept 98 to May 06.
NA = not applicable.
* = conditional recommendation; see comments
Parsons
-------
Issued: 3/22/2007
Page 2 of 2
TABLE 3
QUALITATIVE EVALUATION OF STAGERIGHT GROUNDWATER MONITORING NETWORK
LONG-TERM MONITORING OPTIMIZATION
CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
Well Name
Hydrologlc Unit
Current
Sampling
Frequency
Qualitative Analvsis
Exclude
Retain
Monitoring
Frequency
Recommendation
Rationale
StageRight Wells
StageRight Area Deep Wells
211
MW-106D
(D-106)
MW-107D
(D-107)
MW-10-97
MW-5
P-202
WD-10
Deep
Deep
Deep
Deep
Deep
Deep
Deep
Semiannual
Semiannual
Semiannual
Monthly
Semiannual
Monthly
Semiannual
Groundwater Remedy Wells
MW-105S
MW-106S
MW-2
Wells Not t
MW4-97
MW-107S
WD-5
WD-21
WS-21
P-201
P-203
P-204
P-205
219
Shallow
Shallow
Deep
Currently Sampled
Intermediate
Deep
Intermediate
Shallow
Deep
Deep
Deep
Deep
Deep
Semiannual
Semiannual
Semiannual
X
X
X
X
X
X
X
X
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
X
X
X
X
X*
X
X
X*
NA
NA
NA
Annual
Monthly
Monthly
NA
Semiannual
Consistently low-magnitude concentrations below cleanup goals; no need to continue obtaining deep zone data for this plume-periphery area
Consistently similar or lower concentrations than in production wells MW-2 and MW-5; no discernible temporal trends; historical data indicate
that continued sampling would not add significantly useful information.
Mostly non-detect for COCs with a few trace-level detections below cleanup goals; no evidence of increasing trends; distant from main plume
area and production wells; no need to continue regular groundwater quality monitoring in this outlying area.
Only 9 TCE detections in 76 sampling events; only 1 detection since 2/01 (4 ug/L in 1/04). More consistent 1,2-DCE detections well below
MCL. Retain as vertical sentry well to monitor vertical plume extent over time at east edge of StageRight building and potentially increasing 1,2-
DCE concentrations.
Production well used for drinking water purposes. Stable to decreasing, low-magnitude COG concentrations. Increase sampling frequency due
to presence of high COG concentrations potentially within 1 month's travel time of well.
Retain as deep sentry well at high frequency given potential for high groundwater flow velocity to monitor TCE concentrations exceeding
cleanup goal near production well MW-5 (also screened in deep zone). Note that estimated groundwater flow velocity is based on very limited
data; if actual velocity is lower, then lower sampling frequency (e.g. , quarterly) may be appropriate.
Mostly non-detect for COCs with a few trace-level detections below cleanup goals; no evidence of increasing trends; distant from main plume
area and production wells; no need to continue regular groundwater quality monitoring in this outlying, relatively uncontaminated zone.
No Data
No Data
Production well used for drinking water purposes. Low-magnitude COG concentrations support maintaining current sampling frequency; overall
increasing in cis-1,2-DCE concentrations up to approx May 05 should be watched carefully.
NA
NA
NA
NA
NA
NA
NA
NA
NA
No Data
1 data point for March 04; all non-detect; no need to monitor groundwater quality in this outlying area; conclusion supported by data for well D-
107.
1 data point for June 1989; all non-detect; no need for continued monitoring based on data for 211, which is screened higher in deep zone.
3 data points from 1988 to 1994; TCE evidenced decreasing trend to non-detect in 1994. Distant and cross-gradient from main plume; no need
to continue monitoring in this relatively uncontaminated area.
1 data point for March 04; all non-detect; no need to monitor groundwater quality in this outlying area; conclusion supported by data for well WD-
21.
1 data point for March 04; all non-detect except for 8.5 ug/L 1 ,2-DCE. Available data indicate that deep zone cross-gradient from plume is not
significantly contaminated and does not merit additional monitoring. However, recommend one update sampling of P-201 to confirm this
conclusion, followed by continued exclusion of well from LTM program unless results of update sampling indicate otherwise.
1 data point for March 04; all non-detect; no need to monitor groundwater quality in this outlying area.
1 data point for March 04; all non-detect except for 10 ug/L 1,2-DCE; no need to monitor groundwater quality in this outlying area; well is not
located between StageRight plume and receptors such as production wells so provides no value in assessing contaminant migration from
source area to production wells.
1 data point for March 04; comparison of P-205 data and MW-2 data indicates MW-2 is pulling in contaminated groundwater from an interval
not intercepted by P-205, making data for P-205 of little use. Recommend one update sampling of P-205 to confirm this conclusion, followed by
continued exclusion of well from LTM program unless results of update sampling indicate otherwise.
No Data. However, top of screen is 100 ft bgs; well is probably too deep to provide useful information.
NA = not applicable.
* = conditional recommendation; see comments
Parsons
-------
GSIJobNo. G-3138-105
Issued 03/22/2007
Page 1 of 1
TABLE 4
WELL TREND SUMMARY RESULTS: 1999-2006
l.KOL'NinVAIFR
SI KVICVS, INC .
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
Trichloroethene — Intermediate Zone
MW-1-01
MW-1-02
MW-1-97
MW-1-99
MW-2-01
MW-2-99
MW-3-01
MW-3-99
MW-5-97
MW-6-97
MW-7-97
MW-8-97
WS-5
WS-10
20
16
25
25
20
25
20
25
25
17
25
25
15
15
16
16
25
22
20
10
0
25
25
17
25
25
15
14
0.049
0.75
3.3
0.024
0.012
0.026
<0.002
2.8
0.68
0.021
0.018
0.59
0.26
0.084
No
Yes
Yes
No
No
No
No
Yes
Yes
No
No
Yes
No
No
0.004
0.218
0.535
0.003
0.008
0.002
0.001
1.626
0.175
0.003
0.012
0.238
0.024
0.005
No
Yes
Yes
No
Yes
No
No
Yes
Yes
No
Yes
Yes
Yes
Yes
I
D
PD
D
NT
S
-
D
D
I
D
D
D
NT
I
D
D
D
I
S
-
D
D
I
D
D
D
NT
I
D
D
D
PI
S
ND
D
D
I
D
D
D
NT
Trichloroethene — Deep Zone
211
D-106
D-107
MW-10-97
MW-5
P-202
WD-10
15
15
15
25
24
26
15
7
15
1
4
24
26
1
0.002
0.008
<0.001
0.030
0.012
0.017
<0.001
No
No
No
No
No
No
No
0.001
0.003
0.001
0.002
0.007
0.011
0.001
No
No
No
No
Yes
Yes
No
S
NT
—
PD
D
D
-
S
D
_
D
D
D
-
S
S
ND*
D
D
D
ND*
Notes
1 . Trends were evaluated for data collected between 1/1/1999 and 5/30/2006.
2. Intermediate zone is approximately between 30 and 50 ft bgs (809 and 793 ft AMSL). Deep zone is between 50 and 85 ft bgs (below 793 ft AMSL).
3. Number of Samples is the number of samples consolidated by quarter for the compound at this location.
fra^ quarter at this location.
5. CUO = Clean-up Objective, 0.3 mg/L. MCL = 0.005 mg/L '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;
°* = Non-detect exceP'for one trace value'
-------
GSI Job No. G-3138-105
Issued 03/22/2007
Page 1 of 1
V
UROIIMWATKR
SF.RVICf.S, INC.
TABLE 5
WELL REDUNDANCY ANALYSIS SUMMARY RESULTS
LONG-TERM MONITORING OPTIMIZATION
CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
WellName
TCE Average
Slope Factor
TCE Minimum
Slope Factor
TCE Maximum
Slope Factor
Preliminary
Statistical Result
Recommendation After
Qualitative Review
Intermediate Zone Wells
MW-1-01
MW-1-02
MW-1-97
MW-1-99
MW-2-01
MW-2-99
MW-3-01
MW-3-99
MW-5-97
MW-6-97
MW-7-97
MW-8-97
WS-10
WS-5
0.57
0.56
0.36
0.87
0.29
0.83
1.00
0.76
0.90
0.70
0.27
0.75
0.19
0.22
0.21
0.46
0.16
0.65
0.19
0.09
1.00
0.69
0.62
0.58
0.14
0.55
0.01
0.05
1.00
0.73
0.50
1.00
0.81
1.00
1.00
0.89
1.00
1.00
0.42
0.87
0.91
0.71
Retain
Retain
Retain
Retain
Exclude
Exclude (based on
minimum slope
factor)
Retain
Retain
Retain
Retain
Exclude
Retain
Exclude
Exclude
Retain
Retain
Retain
Retain
Retain at reduced
frequency
Exclude
Retain
Retain
Retain
Exclude
Retain, eliminate MW-6-97
Retain
Exclude
Retain, eliminate after
confirmation sampling
Deep Zone Wells
211
D-106
D-107
MW-10-97
MW-5
P-202
WD-10
1.00
0.09
1.00
1.00
0.10
0.53
1.00
1.00
0.02
1.00
1.00
0.10
0.49
1.00
1.00
0.13
1.00
1.00
0.10
0.55
1.00
Retain
Exclude
Retain
Retain
Exclude
Retain
Retain
Exclude
Exclude
Exclude
Retain
Retain
Retain
Exclude
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.
-------
GSI Job No. G-3138-105
Issued 03/22/2007
Page 1 of 1
SLRVICKS. INC.
TABLE 6
MCES SAMPLING FREQUENCY ANALYSIS RESULTS
LONG-TERM MONITORING OPTIMIZATION
CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
Well Type
T
T
S
T
T
T
T
S
S
T
T
T
T
T
Well Name
MW-1-01
MW-1-02
MW-1-97
MW-1-99
MW-2-01
MW-2-99
MW-3-01
MW-3-99
MW-5-97
MW-6-97
MW-7-97
MW-8-97
WS-5
WS-10
Number of
Samples
20
16
25
25
20
25
20
25
25
17
25
25
15
15
Original
Frequency2
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Semi-annual
Semi-annual
TCE
Preliminary Sample
Frequency
Recommendation
Annual
Annual
Quarterly
Annual
Annual
Annual
Biennial
Annual
Annual
Annual
Annual
Annual
Annual
Annual
Final
Recommendation
After Qualitative
Evaluation*
Annual
Monthly
Semiannual
Annual
Annual
Exclude
Annual
Semiannual
Semiannual
Exclude
Monthly
Monthly
Annual
Exclude
Rationale
Upgradient location, below MCL
Retain to monitor Increasing TCE
trend.
High GW velocity, downgradient from
high concentration area, upgradient
from public supply well.
Monitors source area, Probably
Decreasing trend supports reduced
frequency.
Decreasing trend, located in low
concentration area
Increasing overall trend, but Stable
recent trends, reduce frequency
Stable trend, TCE below screening
levels, redundant with MW-1-99.
Monitors northern edge, largely non-
detect. Continued low concentration,
may result in lowered sample
frequency in future.
Area of highest concentration, monitor
with source area wells.
Monitors source area, Decreasing
trend supports reduced frequency,
possible removal from routine
monitoring if continued Decreasing
trends.
In area ot low concentrations,
redundant with MW-1-02 and MW-8-
97.
Retain at monthly frequency to signal
movement of constituents toward
supply well MW-5.
Retain at monthly frequency to signal
movement of constituents toward
supply well MW-5.
Monitors souther edge of plume.
Upgradient location, low concentration.
Deep Zone
T
T
T
S
T
T
T
211
D-106
D-107
MW-10-97
MW-5
P-202
WD-10
15
15
15
25
24
26
15
Semi-annual
Semi-annual
Semi-annual
Monthly
Quarterly
Monthly
Semi-annual
Biennial
Annual
Biennial
Annual
Annual
Annual
Biennial
Exclude
Exclude
Exclude
Semi-annual
Monthly
Monthly
Exclude
Stable, low concentrations south of
plume, below MCL
Stable, low concentrations, below MCL
Stable, largely non-detect
concentrations south of plume, below
MCL
Deep source area, continue monitoring
source
Monitor water supply well to prevent
failure of treatment system.
Sentry well for MW-5 supply well.
Largely non-detect, upgradient of
plume.
Notes:
1. S = Source well; T = Tail well. MCES- Modified Cost Effective Sampling.
2. Number of Samples is the number of quarterly results found by averaging monthly sampling 1999-2006.
3. The Preliminary Sample Frequency is the sampling frequency recommended by the MCES algorithm in the MAROS software.
4. * See details of Qualitative evaluation Table 3. The Qualitative evaluation includes other COCs and hydraulic parameters.
Final Recommendation is the sampling frequency suggested after both qualitative and quantitative review of the well condition and function.
5. Exclude = Do not sample during routine monitoring. Does not indicate well should be abandoned.
-------
GSI Job No. G-3138-105
Issued 03/22/2007
Page 1 of 1
TABLE 7
FINAL RECOMMENDED MONITORING NETWORK STAGERIGHT AREA
LONG-TERM MONITORING OPTIMIZATION
CLARE WATER SUPPLY SUPERFUND SITE, MICHIGAN
liKOl'NinVATPR
SI RVK ( S, INC..
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
After Qualitative and
Quantitative Review
Preliminary Sample
Frequency
Recommendation
Final Recommended
Sample Frequency
Intermediate Zone
MW-1-01
MW-1-02
MW-1-97
MW-1-99
MW-2-01
MW-2-99
MW-3-01
MW-3-99
MW-5-97
MW-6-97
MW-7-97
MW-8-97
WS-10
WS-5
Deep Zone
211
D-106
D-107
MW-10-97
MW-5
P-202
WD-10
20
16
25
25
20
25
20
25
25
17
25
25
15
15
15
15
15
25
24
26
15
16
16
25
22
20
10
0
25
25
17
25
25
14
15
7
15
1
4
24
26
1
0.004
0.218
0.535
0.003
0.008
0.002
0.001
1.626
0.175
0.003
0.012
0.238
0.005
0.024
0.001
0.003
0.001
0.002
0.007
0.011
0.001
No
Yes
Yes
No
Yes
No
No
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
I
D
PD
D
NT
S
-
D
D
I
D
D
NT
D
S
NT
—
PD
D
D
—
I
D
D
D
I
S
-
D
D
I
D
D
NT
D
S
D
—
D
D
D
—
I
D
D
D
PI
S
ND
D
D
I
D
D
NT
D
S
S
ND*
D
D
D
ND*
Retain
Retain
Retain
Retain
Retain at reduced
frequency
Exclude
Retain
Retain
Retain
Exclude
Retain, eliminate MW
6-97
Retain
Exclude
Retain, eliminate after
confirmation sampling
Exclude
Exclude
Exclude
Retain
Retain
Retain
Exclude
Annual
Annual
Quarterly
Annual
Annual
Annual
Biennial
Annual
Annual
Annual
Annual
Annual
Annual
Annual
Biennial
Annual
Biennial
Annual
Annual
Annual
Biennial
Annual
Monthly
Semiannual
Annual
Annual
Exclude
Annual
Semiannual
Semiannual
Exclude
Monthly
Monthly
Exclude
Annual, sample to
confirm trend
Exclude*
Exclude*
Exclude*
Annual
Monthly
Monthly
Exclude*
Notes
1 . Intermediate zone is approximately between 30 and 50 ft bgs (809 and 793 ft AMSL). Deep zone is between 50 and 85 ft bgs (below 793 ft AMSL).
2. Number of Samples is the number of samples consolidated by quarter for the compound at this location.
rfrtteefr*8rota|^ consolidated by quarter at this location.
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;
Changes in groundwaterflow velocity or head in response to the new municipal well may require increasing or decreasing sample locations and frequency.
7. Sample locations are illustrated on Figure 7.
8. Exclude* = While these wells do not provide unique information for StageRight management decisions, they may be retained
for Site -Wide groundwater monitoring, which was not evaluated.
-------
Figures
-------
Stageright Facility
(Former Welltronics)
MW-1-97
MW-10-97
(Deep)
MW-5-97
MW-1-02
^L. 1 MW-6-97
'' ^—[ MW-8-97
y—| MV\A7-97
General Groundwater
Flow Direction
Legend
Active Well Locations
Average Concentration
TCE 1999-2006
A ND - 0.0025 mg/L
A 0.0025-0.005 mg/L
A 0.005-0.100000 mg/L
A 0.100-0.300 mg/L
A 0.300 -1 6 2 mg/L
0 Inactive Locations or
Locations with No Data
Notes:
1. Average concentrations were
d etermined for trichloroethene (TCE)
between 1999 and 2006.
2. Clean-up Objective (CUO) for
TCE = 0.3 mg/L; MCL= 0.005 mg/L.
3. vve"s screened in intermediate zone
0 f aquifer except where indicated.
4. Data source Progressive Environmental
ancl Construction, August 2006.
Scale (ft)
^•=
0 60 120
STAGERIGHT AREA
WELL LOCATIONS
AND AVERAGE TCE
CONCENTRATIONS
Clare Water Supply
Clare, Michigan
G-3138-105
03/22/2007
Figure 1
MV
MV
MV
-------
P-203\\
Vf WS-21
LEGEND
WS-21 O SHALLOW MONITORING WELL
MW3-01 D INTERMEDIATE MONITORING WELL
WD-5 El DEEP MONITORING WELL
MW-5 9 DEEP PRODUCTION WELL
A AIR SPARGE WELL
© DUAL PHASE EXTRACTION WELL
ND NOT DETECTED
* = CONDITIONAL RECOMMENDATION.
SEE COMMENTS IN TABLE 3
-10 - INFERRED LINE OF EQUAL
TCE CONCENTRATION.
APRIL-MAY 2006
INFERRED GROUNDWATER
FLOW DIRECTION
RECOMMENDED
SAMPLE FREQUENCY
Q MONTHLY
Q SEMIANNUAL
Q ANNUAL
PI EXCLUDE
SCALE: 1"=100'
FIGURE 2
QUALITATIVE EVALUATION RESULTS
FOR STAGERIGHT FACILITY
Long-Term Monitoring Network Optimization
Clare Water Supply Superfund Site
Denver, Colorado
-------
FIGURE 3
APPROXIMATE WELL SCREEN INTERVALS FOR STAGERIGHT VICINITY
LONG-TERM MONITORING OPTIMIZATION EVALUATION
CLARE WATER SUPPLY SUPEREUND SITE, MICHIGAN
Approx Water Table
Approx Top of Intermediate Zone
Approx Top of Deep Zone
Shallow
Intermediate
Deep
Note: Well 219 is screened from approximately 729 to 734 feet above mean sea level, below the bottom of this figure.
PARSONS
-------
StageRight Facility
(Former Welltronics)
MW-1-97
MW-10-97
(Deep)
MW-5-97
H 16-
General Groundwater
Flow Direction
Legend
0 Deep Zone Wells
O Intermediate Zone
Wells
Mann-Kendall Trend
Trichloroethene
O Decreasing
O Probably Decreasing
O Stable
O Probably Increasing
O Increasing
• No Trend
• Non detect
Notes:
1. Trends were determined for
trichloroethene data between 1999
an d 2006.
2. Vifells screened in intermediate zone
of aquifer except where indicated.
3. Data source Progressive Environmental
and Construction, August 2006.
140
l.KOt M'UMl K
MRVICES. INC.
STAGERIGHT AREA
TCE TEMPORAL
TREND RESULTS
Clare Water Supply
Clare, Michigan
G-3138-105
03/22/2007
Figure 4
MV
MV
MV
-------
General Groundwater
Flow Direction
WS-5
MW-7-97
0
•\
MW-5
(Deep Pumping Well)
Legend
Plume Center of Mass
(First Moments)
Effective Date of
Center of Mass Calculation
Water Supply Well
Mann-Kendall Trends
Intermediate Zone
© D
O PD
O s
O PI
• I
• NT
• ND
Notes:
1. Trends were determined for
TCE data between 1999 and 2006.
2. All wells screened in Intermediate zone
of aquifer except pumping well MW-5.
3. Data source Progressive Environmental
and Construction, August 2006.
Scale (ft)
••±±
0 30 60
i,HOI snuum
SERVICES, INC.
STAGERIGHTAREA
TCE FIRST MOMENTS
INTERMEDIATE ZONE
Clare Water Supply
Clare, Michigan
G-3138-105
03/22/2007
Figure 5
MV
MV
MV
-------
NORTH
845450.0 -
845400.0 -
845350.0 -
845300.0 -
845250.0 -
845200.0 -
845150.0-
Q-ic'i nn n -
FIGURES STAGERIGHT AREA WELL
REDUNDANCY AND SUFFICIENCY TCE
| \ >•„, — :* WS-10
I \ ^^ --""'" ''''' /
I \ ^-x -,^-"" // /
\ \ --'" // /
M \r™wr0r-~~ — """ 7\MW'^ M // I
| / \vv i \ / // Areas of high concentration
/ . x I \ / / j indicate possible preferentia
1 / \ N>x 1 \ ^ ^ (/•• — ~^ff^ i flow paths.
k^MWj-97 ^ ' ~""~~~-~ ^f*l^^/f Areas of low concentration close
\ ~ t^L — — S^^w-i-Q2 to higher concentrations create
Whmps-97 " ,? ^^~~~~~ — ' ^•v'' ^^^^*^^^^i greater uncertainty, but do not
C""~--^^_ L /' ^^^ ^^KfTSS? / trigger recommendation for new
^^ ^^""~x ' X\ ' samP'e location.
X\ ^\ ~~~~~~ Jj^>-^ / Xvx /
\ \ "~"~-lK:'jMW-8-97 M \ .
/ ^-N /
\ * / ^
\ \ / 2* MW-7-97
\ \ S W „-"
N\ \ ' --"""
\ ^ / ***""*
New Location
Analysis for Intermediate Zo
TRICHLOROETHYLENE (TC
Existing
Locations
Potential areas for
new locations are
indicated by triangles
with a high SF level.
Estimated SF Level:
S - Small
M - Moderate
L - Large
E- Extremely large
High SF -> high
estimation error ->
possible need for
new locations
Low SF-> low
estimation error ->
no need for new
locations
Back to
Access
^ J
8451 00.0 H : EAST
13015400.0 13015450.0 13015500.0 13015550.0 13015600.0 13015650.0 13015700.0
-------
WD-10
(Deep) ^k
Stageright Facility
(Former Welltronics) wiw-i-9?
MW-10-97 '
(Deep)
MW-5-97
MW-1-02
1 MW-6-97
MW-8-97
Clare Public Works
MW-5
(Deep Pumping Well)
General Groundwater
Flow Direction
MW-2 Pumping Well
(Deep)
Legend
Recommended
Sample Frequency
D Monthly
D Semiannual
D Annual
»Z« Exclude
Notes:
"I-Sample locations and recommended
f requencies based on combined
a''ve anc' quan'''at've approach.
Os screened in intermediate zone
f aquifer except where indicated.
3. MO nthly sampling triggered by high
oundwater velocity in the area of MW-5.
4. Data source Progressive Environmental
and Constru <*i°n. August 2006.
140
FINAL RECOMMENDED
MONITORING NETWORK
STAGERIGHT AREA
Clare Water Supply
Clare, Michigan
G-3138-105
03/22/2007
Figure 7
MV
MV
MV
-------
March 22, 2007
ATTACHMENT A
GROUNDWATER SEEPAGE VELOCITY CALCULATIONS
StageRight Area
V = Ki/ne where:
V = groundwater seepage velocity (ft/day)
K = hydraulic conductivity (ft/day)
i = hydraulic gradient (ft/ft)
ne = effective porosity (unitless)
Zone
K (ft/day) i (ft/ft)
V (ft/day)
intermediate
deep
425
425
0.009
0.013
0.3
0.3
13
18
Notes:
1. K based on average 0.15 cm/sec for MW-5 and MW-2 vicinities as obtained from
Dames and Moore Rl and transmitted by Progressive.
2. i for intermediate zone based on calculations using equipotential lines for May
and Nov 05 on potentiometric surface maps provided by Progressive.
3. i for deep zone based on average of calculated gradients between WD-10 and
P 202 for May and Nov 05 and calculated gradient between WD-5 and P-202 for May 05.
4. ne is based on estimate for permeable, well-sorted sand or sand and gravel.
StageRight Area
Clare Water Supply Superfund Site
Long-Term Groundwater
Monitoring Network Optimization
-------
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 Flow Chart
Figure 2 MAROS Overview Statistics Trend Analysis Methodology
Figure 3 Decision Matrix for Determining Provisional Frequency
-------
March 22, 2007
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
-------
March 22, 2007
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
-------
March 22, 2007
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
-------
March 22, 2007
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
-------
March 22, 2007
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
-------
March 22, 2007
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 Q MAROS 2.2 Methodology
-------
March 22, 2007
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
-------
March 22, 2007
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
-------
March 22, 2007
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
-------
March 22, 2007
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 70 MAROS 2.2 Methodology
-------
March 22, 2007
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-
AttachmentB n MAROS 2.2 Methodology
-------
March 22, 2007
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).
Concentrations
projected to this
line
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
-------
March 22, 2007
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
-------
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
-------
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
-------
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
(e.g., E)
Monitoring Categories
E: Extensive
M: Moderate
L: Limited
Spec
system uptirniZtiuon Results D3seci on
Monitoring category and site-specific
parameters.
• Well Density
• Sampling Frequency
* Sampling Duration
Site Classification
Design Category
Fuel
Big Small
van net -LI" iv
E
11
Solvent
Big Small
inn tor inn «T
Figure 2:
MAROS Overview Statistics Trend Analysis Methodology
-------
GROUNDWATER
SERVICES, INC.
Sampling
Frequency
Q: Quarterly
S: SeiniAnnual
A: Annual
TJ
C
0>
ra
T3
E
0>
^
c
ro
PI
D
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)
-------
March 22, 2007
LONG-TERM
MONITORING NETWORK OPTIMIZATION
STAGERIGHT AREA
Clare Water Supply Superfund Site
Clare, Michigan
ATTACHMENT C:
MAROS Reports
Stage Right Area
COC Assessment Report
Mann-Kendall Reports Selected Wells
Zeroth Moment Report (Estimate of Total Dissolved Mass in Plume)
-------
MAROS COC Assessment
Project: Clare Water Supply
Location: Stageright
Toxicitv:
User Name: MV
State: Michigan
Contaminant of Concern
TRICHLOROETHYLENE (TCE)
TETRACHLOROETHYLENE(PCE)
Representative
Concentration
(mg/L)
2.1E-01
2.3E-02
PRG
(mg/L)
5.0E-03
5.0E-03
Percent
Above
PRG
4078.5%
355.2%
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
TRICHLOROETHYLENE (TCE)
TETRACHLOROETHYLENE(PCE)
Class
ORG
ORG
Total
Wells
14
4
Total
Excedences
9
2
Percent
Excedences
64.3%
50.0%
Total
detects
13
2
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)
TETRACHLOROETHYLENE(PCE)
0.297
0.923
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)
TRICHLOROETHYLENE (TCE)
MAROS Version 1.2, 2006, AFCEE
Tuesday, September 12, 2006
Page 1 of 1
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-1-01
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 4/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
6.0E-03 •
_ 5.0E-03 -
_j
£ 4.0E-03 -
| 3.0E-03 •
c
g 2.0E-03 -
o
0 1.0E-03-
o.o&ooJ
Data Table:
//"/
Date
//
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-1-02
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 4/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1 -
Concentration (mg/L)
o
0.01 •
Date
&w
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-1-97
Well Type: s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 4/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
10-
1
Concentration
0.1 •
y>V>
*
***»
Date
•\ *4
v^ x1^
^
• *
^VVVVV'
* * * *
»
• *
/
Mann Kendall S Statistic:
I -71
Confidence in
Trend:
1 94.9%
Coefficient of Variation:
I 1'21
Mann Kendall
Concentration Trend:
(See Note)
1 PD
Data Table:
Well
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
MW-1-97
Well Type
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
Effective
Date
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
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)
Result (mg/L) Flag
3.3E+00
1.3E+00
1.2E+00
7.5E-01
4.7E-01
3.3E-01
3.5E-01
3.0E-01
2.5E-01
3.8E-01
2.5E-01
1.3E-01
1.5E-01
1.2E-01
1.6E-01
1.2E-01
3.2E-01
5.3E-01
2.8E-01
3.8E-01
5.7E-01
7.1E-01
Number of Number of
Samples Detects
1 1
3 3
2 2
1 1
1 1
2 2
1 1
1 1
1 1
2 2
1 1
3 3
2 2
2 2
1 1
1 1
3 3
1 1
3 3
2 2
3 3
3 3
MAROS Version 2.2, 2006, AFCEE
9/11/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well
MW-1-97
MW-1-97
MW-1-97
Well Type
s
s
s
Effective
Date
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L) Flag
3.1E-01
5.6E-01
1.9E-01
Number of
Samples
3
3
1
Number of
Detects
3
3
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
9/11/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-1-99
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
Date
Mann Kendall S Statistic:
B)
o
£
Concer
1 .4E-U2 -
1.2E-02-
1.0E-02-
8.0E-03 •
6.0E-03 •
4.0E-03 -
2.0E-03 •
n np4-nn .
*
*
* *
» ^
*
I '173
Confidence in
Trend:
I 100.0%
Coefficient of Variation:
°'87
Mann Kendall
Concentration Trend:
(See Note)
Data Table:
Well
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
MW-1-99
Well Type
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
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)
Result (mg/L) Flag
6.2E-03
5.3E-03
2.7E-03
3.9E-03
1.0E-02
1.2E-02
6.6E-03
3.2E-03
4.2E-03
2.9E-03
1 JE-03
2.7E-03
2.4E-03
2.2E-03
1 .9E-03
1 .OE-03 ND
1 .OE-03 ND
1 .4E-03
1. OE-03
1. OE-03 ND
1.3E-03
1.5E-03
I
Number of
Samples
1
3
2
3
2
2
1
1
1
2
1
3
2
2
1
1
3
1
3
2
3
3
D
Number of
Detects
1
3
2
2
2
2
1
1
1
2
1
3
2
2
1
0
0
1
1
0
3
3
MAROS Version 2.2, 2006, AFCEE
9/19/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well
MW-1-99
MW-1-99
MW-1-99
Well Type
T
T
T
Effective
Date
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L) Flag
1 .6E-03
2.0E-03
1 .6E-03
Number of
Samples
3
3
1
Number of
Detects
2
3
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
9/19/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-2-01
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 4/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1.00E+00-
j"
B)
•§- 1.00E-01 -
o
c
01
c 1.00E-02-
o
O
1.00E-03-
Data Table:
//
* * *
*
•
Well Well Type
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
MW-2-01
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
' *• ^ & <<& ^ ^eP ^ ^eP
^ Mann Kendall S Statistic:
I 37
Confidence in
Trend:
1 87.7%
Coefficient of Variation:
j 0.29
Mann Kendall
Concentration Trend:
(See Note)
I NT
Number of Number of
Constituent Result (mg/L) Flag Samples Detects
TRICHLOROETHYLENE (TCE) 6.6E-03 2 2
TRICHLOROETHYLENE (TCE) 5.9E-03 1 1
TRICHLOROETHYLENE (TCE) 2.4E-03 1 1
TRICHLOROETHYLENE (TCE) 1
JE-03 1 1
TRICHLOROETHYLENE (TCE) 7.7E-03 2 2
TRICHLOROETHYLENE (TCE) 9.8E-03 1 1
TRICHLOROETHYLENE (TCE) 1
.OE-02 3 3
TRICHLOROETHYLENE (TCE) 9.4E-03 2 2
TRICHLOROETHYLENE (TCE) 8.5E-03 2 2
TRICHLOROETHYLENE (TCE) 7.5E-03 1 1
TRICHLOROETHYLENE (TCE) 8.8E-03 1 1
TRICHLOROETHYLENE (TCE) 8.5E-03 3 3
TRICHLOROETHYLENE (TCE) 8.6E-03 1 1
TRICHLOROETHYLENE (TCE) 9.5E-03 3 3
TRICHLOROETHYLENE (TCE) 1
.1E-02 2 2
TRICHLOROETHYLENE (TCE) 9.0E-03 3 3
TRICHLOROETHYLENE (TCE) 8.7E-03 3 3
TRICHLOROETHYLENE (TCE) 8.5E-03 3 3
TRICHLOROETHYLENE (TCE) 8.2E-03 3 3
TRICHLOROETHYLENE (TCE) 8.3E-03 1 1
MAROS Version 2.2, 2006, AFCEE
9/11/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-2-99
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
5nc ni
.uc-uo •
4.5E-03 -
2C 4.0E-03 -
|> 3.5E-03 -
T 3.0E-03 •
o
s 2.5E-03 •
i 2.0E-03 •
| 1.5E-03-
o
O 1 OP nt
1 .UC-UO
5.0E-04 •
Oncj-nn
m\ICr\I\I
Data Table:
Well Well Ty
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
MW-2-99 T
/vvv
*
•
*
Effective
pe Date
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
Date
vvvvvv*
•
*
«
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)
/
-------
MAROS Mann-Kendall Statistics Summary
Well
MW-2-99
MW-2-99
MW-2-99
Well Type
T
T
T
Effective
Date
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L)
1 .OE-03
1 .OE-03
1 .OE-03
Flag
ND
ND
ND
Number of
Samples
3
3
1
Number of
Detects
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
9/19/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-3-01
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1.2E-03-
_ 1. OE-03 -
£ 8.0E-04 -
| 6.0E-04 •
§ 4.0E-04 -
o
0 2.0E-04 -
O.OE+00 •
Data Table:
•& >o ^3>
^> ^«» ^>-'
Date
^Q .0) ^Q ^5> ^Q ^5> ^0
Effective
Well Well Type Date
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
MW-3-01 T
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
11/15/2005
2/15/2006
5/15/2006
Constituent Result (mg/L) Flag
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1 .OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1 .OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1 .OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1 .OE-03
TRICHLOROETHYLENE (TCE) 1 .OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
TRICHLOROETHYLENE (TCE) 1. OE-03
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Mann Kendall S Statistic:
I °
Confidence in
Trend:
1 48.7%
Coefficient of Variation:
j 0.00
Mann Kendall
Concentration Trend:
(See Note)
I S
Number of Number of
Samples Detects
2 0
1 0
1 0
1 0
2 0
1 0
3 0
2 0
2 0
1 0
1 0
3 0
1 0
3 0
2 0
3 0
3 0
3 0
3 0
1 0
MAROS Version 2.2, 2006, AFCEE
9/19/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-3-99
Well Type: s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 4/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
2C 2.0E+00 -
E
c 1.5E+00 •
o
1
•E 1.0E+00 •
8
c
0 5.0E-01 •
00
Data Table:
Well Well Ty
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
MW-3-99 S
/vvv*
»*
* *
*
Effective
pe Date
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
Date
XVVVVV
•> ^ ^ ^ ^ ^
*
» • *
•
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)
y 4\ 4\ c^
Q Q ^^
<$• ^ <$•
••*.
Result (mg/L) Flag
1.2E+00
2.4E+00
2.4E+00
1.9E+00
1.8E+00
1.9E+00
1.8E+00
1.6E+00
1.8E+00
1.6E+00
1.6E+00
1.9E+00
1.4E+00
1.3E+00
1.1E+00
1.5E+00
1.5E+00
1.4E+00
1 .5E+00
1.7E+00
1.5E+00
1.5E+00
Mann Kendall S Statistic:
| -101
Confidence in
Trend:
1 99.1%
Coefficient of Variation:
j 0.19
Mann Kendall
Concentration Trend:
(See Note)
I D
Number of Number of
Samples Detects
1 1
3 3
2 2
1 1
1 1
2 2
1 1
1 1
1 1
2 2
1 1
3 3
2 2
2 2
1 1
1 1
3 3
1 1
3 3
2 2
3 3
3 3
MAROS Version 2.2, 2006, AFCEE
9/11/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well
MW-3-99
MW-3-99
MW-3-99
Well Type
s
s
s
Effective
Date
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L) Flag
1.6E+00
1.6E+00
1.4E+00
Number of
Samples
3
3
1
Number of
Detects
3
3
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
9/11/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-5-97
Well Type: s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
7.0E-01 -
^ 6.0E-01 -
F
•=• 5.0E-01 -
o
s 4.0E-01 •
| 3.0E-01 -
o 2.0E-01 •
O
1.0E-01 -
Data Table:
Well Well Ty
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
MW-5-97 S
/vvv
*
** *
A A
* *
Effective
pe Date
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
Date
vvvvvv%
»**
*»** **
* * * *
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)
fW*
^ <$•
» * •
Result (mg/L) Flag
6.8E-01
2.8E-01
2.6E-01
1.6E-01
1.7E-01
2.5E-01
2.0E-01
1.3E-01
1.2E-01
2.0E-01
2.2E-01
2.1E-01
1.7E-01
1.4E-01
1.5E-01
1.4E-01
1.1E-01
1.3E-01
1.6E-01
9.9E-02
8.4E-02
8.6E-02
Mann Kendall S Statistic:
I ~212
Confidence in
Trend:
1 100.0%
Coefficient of Variation:
j 0.69
Mann Kendall
Concentration Trend:
(See Note)
I D
Number of Number of
Samples Detects
1 1
3 3
2 2
3 3
2 2
2 2
1 1
1 1
1 1
2 2
1 1
3 3
2 2
2 2
1 1
1 1
3 3
1 1
3 3
2 2
3 3
3 3
MAROS Version 2.2, 2006, AFCEE
9/19/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well
MW-5-97
MW-5-97
MW-5-97
Well Type
s
s
s
Effective
Date
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L) Flag
7.4E-02
8.4E-02
7.1E-02
Number of
Samples
3
3
1
Number of
Detects
3
3
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
9/19/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-6-97
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
6.0E-03 •
_ 5.0E-03 -
£ 4.0E-03 -
| 3.0E-03 •
§ 2.0E-03 -
o
0 1.0E-03-
o.o&ooJ
Data Table:
Date
r£\* *!]* fA fA *^b» «.b» *A f& *JQ
Q Q Q Q \> \> Q O vT
•
*
Effective
Well Well Type Date
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
MW-6-97 T
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
11/15/2005
2/15/2006
5/15/2006
******
*
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)
Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD);
Due to insufficient Data (< 4 sampling events); ND = Non-detect
•
Result (mg/L) Flag
1.5E-03
1.3E-03
1.9E-03
2.1E-03
2.4E-03
3.2E-03
2.8E-03
4.6E-03
4.5E-03
3.9E-03
4.0E-03
4.0E-03
4.2E-03
4.8E-03
3.6E-03
3.8E-03
3.5E-03
Decreasing (D); No Trend (NT);
Mann Kendall S Statistic:
I 66
Confidence in
Trend:
1 99.7%
Coefficient of Variation:
I °'34
Mann Kendall
Concentration Trend:
(See Note)
I '
Number of Number of
Samples Detects
1 1
2 1
1 1
3 3
2 2
2 2
1 1
1 1
3 3
1 1
3 3
2 2
3 3
3 3
3 3
3 3
1 1
Not Applicable (N/A) -
MAROS Version 2.2, 2006, AFCEE
9/19/2006
Page 1 of 1
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-7-97
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1 AP no
I .OC-U^ •
1.6E-02-
j" 1.4E-02 -
£ 1.2E-02-
o 1.0E-02-
2 8.0E-03 •
c
g 6.0E-03 -
2 4.0E-03 -
2.0E-03 -
Oncj-nn
m\ICr\I\I
Data Table:
Well Well Ty
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
MW-7-97 T
/vvv
* * * *
• A A
A
* *
Effective
pe Date
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
Date
vvvvvv*
• »
• «
»^» * »»
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)
/
-------
MAROS Mann-Kendall Statistics Summary
Well
MW-7-97
MW-7-97
MW-7-97
Well Type
T
T
T
Effective
Date
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L) Flag
9.2E-03
9.4E-03
8.3E-03
Number of
Samples
3
3
1
Number of
Detects
3
3
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
9/19/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-8-97
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 4/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1 -
Concentration (mg/L)
o
0.01 •
x/y
•
Date
>w
•
* *
•
•
xvvy/x
*•*«•»*••„.
X
Mann Kendall S Statistic:
I ~224
Confidence in
Trend:
1 100.0%
Coefficient of Variation:
j 0.55
Mann Kendall
Concentration Trend:
(See Note)
I D
Data Table:
Well
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
Well Type
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
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)
Result (mg/L) Flag
3.4E-01
4.0E-01
4.0E-01
4.1E-01
2.5E-01
3.9E-01
3.6E-01
3.8E-01
3.3E-01
4.5E-01
2.9E-01
2.3E-01
1.8E-01
1.6E-01
1.2E-01
1.3E-01
1.1E-01
1.1E-01
1.2E-01
1.7E-01
1.2E-01
1.1E-01
Number of Number of
Samples Detects
1 1
3 3
2 2
1 1
1 1
2 2
1 1
1 1
1 1
2 2
1 1
3 3
2 2
2 2
1 1
1 1
3 3
1 1
3 3
2 2
3 3
3 3
MAROS Version 2.2, 2006, AFCEE
9/11/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well
MW-8-97
MW-8-97
MW-8-97
Well Type
T
T
T
Effective
Date
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L) Flag
9.1E-02
9.3E-02
8.7E-02
Number of
Samples
3
3
1
Number of
Detects
3
3
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
9/11/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-8-97
Well Type: T
COC: TETRACHLOROETHYLENE(PCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
7nc no
.Ut-Uz -
6.0E-02 •
^j
|) 5.0E-02 •
g 4.0E-02 -
S 3.0E-02 -
c
01
c 2.0E-02 -
o
O
1.0E-02-
OOE+00
Data Table:
Well Well Ty
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
MW-8-97 T
<$> £N $!
«$p^ _<}• »^ ^?'
<$• <$>
**\ ****
»»*
Effective
pe Date
5/4/2000
7/26/2000
8/24/2000
9/29/2000
10/27/2000
12/28/2000
1/22/2001
2/28/2001
3/28/2001
4/27/2001
5/22/2001
8/24/2001
9/26/2001
10/30/2001
2/19/2002
4/30/2002
7/31/2002
8/27/2002
11/20/2002
1/24/2003
2/26/2003
2/27/2003
Date
s & & & & & &
^ ^» oy -.<} f& .*&• ^y
3 X J Y* U v J
^
*
, **• '
> ^\-W •<*
**
Constituent
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
<* <& <§>
**p4V
\* ^?
>***
*
*
•
Result (mg/L) Flag
2.2E-02
2.2E-02
2.5E-02
2.8E-02
3.2E-02
3.5E-02
3.0E-02
3.4E-02
3.6E-02
2.9E-02
4.0E-02
3.8E-02
3.3E-02
3.2E-02
3.3E-02
3.8E-02
3.2E-02
4.0E-02
3.1E-02
3.0E-02
3.9E-02
3.6E-02
Mann Kendall S Statistic:
I 766
Confidence in
Trend:
1 100.0%
Coefficient of Variation:
I °'21
Mann Kendall
Concentration Trend:
(See Note)
I '
Number of Number of
Samples Detects
1 1
4 3
2 2
2 2
1 1
2 2
1 1
1 1
1 1
1 1
2 2
2 2
1 1
3 3
3 3
3 3
2 2
1 1
3 3
1 1
1 1
1 1
MAROS Version 2.2, 2006, AFCEE
9/13/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well Well Type
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
MW-8-97
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
4/25/2003
5/30/2003
7/30/2003
8/28/2003
10/24/2003
2/19/2004
4/28/2004
5/25/2004
6/26/2004
8/24/2004
10/21/2004
10/28/2004
12/21/2004
2/28/2005
3/28/2005
4/26/2005
5/30/2005
6/28/2005
7/25/2005
8/29/2005
9/29/2005
10/25/2005
11/28/2005
12/15/2005
1/30/2006
2/22/2006
3/23/2006
4/19/2006
Number of
Constituent Result (mg/L) Flag Samples
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
TETRACHLOROETHYLENE(PCE
3.7E-02
3.8E-02
4.1E-02
3.9E-02
3.6E-02
4.6E-02
4.0E-02
4.1E-02
3.7E-02
4.1E-02
4.3E-02
3.7E-02
4.2E-02
5.2E-02
6.3E-02
5.0E-02
4.1E-02
4.8E-02
4.2E-02
4.4E-02
4.3E-02
5.8E-02
4.8E-02
3.3E-02
4.5E-02
4.1E-02
4.8E-02
4.8E-02
1
2
1
2
3
3
1
1
1
3
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Number of
Detects
1
2
1
2
3
3
1
1
1
3
1
1
1
2
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
9/13/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: WS-5
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
7nc n9
.UE-U^ •
6.0E-02 •
^j
|) 5.0E-02 •
g 4.0E-02 -
S 3.0E-02 -
c
c 2.0E-02 -
o
O
1.0E-02-
Data Table:
Well Well Ty
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
WS-5 T
/vw
**
*
»
•
Effective
pe Date
2/15/1999
5/15/1999
11/15/1999
8/15/2000
11/15/2000
11/15/2001
5/15/2002
11/15/2002
5/15/2003
11/15/2003
5/15/2004
11/15/2004
5/15/2005
11/15/2005
5/15/2006
Date
A'VVVVVV
*
•
* *
» »
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)
VVV*
P ^^ X^
•
Result (mg/L) Flag
3.3E-02
6.3E-02
2.4E-02
4.9E-02
2.7E-02
3.2E-02
4.9E-02
2.4E-02
2.4E-03
1.6E-02
6.5E-03
6.7E-03
1.3E-02
5.6E-03
2.3E-03
Mann Kendall S Statistic:
I ~67
Confidence in
Trend:
1 100.0%
Coefficient of Variation:
j 0.80
Mann Kendall
Concentration Trend:
(See Note)
I D
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
9/19/2006
Page 1 of 1
-------
MAROS Mann-Kendall Statistics Summary
Well: WS-10
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/30/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1 9P n9
I .^C-U^ •
_ 1.0E-02-
^J
£ 8.0E-03 -
o
s 6.0E-03 •
§ 4.0E-03 -
o
0 2.0E-03 -
Data Table:
Well Well Ty
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
WS-10 T
/vw
**
«
*
* *
•
Effective
pe Date
2/15/1999
5/15/1999
11/15/1999
8/15/2000
11/15/2000
11/15/2001
5/15/2002
11/15/2002
5/15/2003
11/15/2003
5/15/2004
11/15/2004
5/15/2005
11/15/2005
5/15/2006
Date
A'VVVVVV
^
* *
•
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)
VVV*
P ^^ X^
» »
Result (mg/L) Flag
9.7E-03
7.1E-03
2.6E-03
2.9E-03
1.3E-03
1.0E-03 ND
3.9E-03
4.4E-03
6.3E-03
5.9E-03
6.1E-03
4.6E-03
5.6E-03
5.6E-03
5.7E-03
Mann Kendall S Statistic:
I 12
Confidence in
Trend:
1 70.4%
Coefficient of Variation:
I °'47
Mann Kendall
Concentration Trend:
(See Note)
1 NT
Number of Number of
Samples Detects
1 1
1 1
1 1
1 1
1 1
1 0
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
9/19/2006
Page 1 of 1
-------
MAROS Mann-Kendall Statistics Summary
Well: 211
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/3/1999 to 5/5/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1.00B-00
1.00E-01 -
o
2 1.00E-02-
§
O 1.00E-03-
1.00E-04
Date
Mann Kendall S Statistic:
Confidence in
Trend:
Coefficient of Variation:
0.61
Mann Kendall
Concentration Trend:
(See Note)
Data Table:
Well
211
211
211
211
211
211
211
211
211
211
211
211
211
211
211
Well Type
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
Effective
Date
2/15/1999
5/15/1999
11/15/1999
5/15/2000
11/15/2000
11/15/2001
5/15/2002
11/15/2002
5/15/2003
11/15/2003
5/15/2004
11/15/2004
5/15/2005
11/15/2005
5/15/2006
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)
Result (mg/L)
1.8E-03
3.7E-04
1.0E-03
1.0E-03
2.2E-03
1.0E-03
3.3E-04
1.0E-03
1.0E-03
2.3E-04
3.1E-04
3.4E-04
1.0E-03
1.0E-03
1.0E-03
Flag
ND
ND
ND
ND
ND
ND
ND
ND
Number of
Samples
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Number of
Detects
1
1
0
0
1
0
1
0
0
1
1
1
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
9/12/2006
Page 1 of 1
-------
MAROS Mann-Kendall Statistics Summary
Well: D-106
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/3/1999 to 5/5/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1nnd.nn
.UUt^UU -
j"
O)
•§- 1.00E-01 -
o
c
01
c 1.00E-02-
o
O
1 nnF nt
1 .UUC'UO
Data Table:
Well W
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D-106
D
«#lXp4^P4*P41
•
» •
•
* * •
Effective
fell Type Date
T 2/15/1999
T 5/15/1999
T 11/15/1999
T 5/15/2000
T 11/15/2000
T 11/15/2001
T 5/15/2002
T 11/15/2002
T 5/15/2003
T 11/15/2003
T 5/15/2004
T 11/15/2004
T 5/15/2005
T 11/15/2005
T 5/15/2006
ate
^454>4^4^$>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)
^
Result (mg/L) Flag
7.6E-03
4.2E-03
1.2E-03
1.3E-03
2.7E-03
3.8E-03
1.3E-03
1.4E-03
5.3E-03
1.2E-03
4.0E-03
1.5E-03
4.4E-03
3.1E-03
3.2E-03
Mann Kendall S Statistic:
I 5
1
Confidence in
Trend:
1 57.7%
Coefficient of Variation:
j 0.60
Mann Kendall
Concentration Trend:
(See Note)
1 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
9/12/2006
Page 1 of 1
-------
MAROS Mann-Kendall Statistics Summary
Well: D-107
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/5/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1 9P ni
1 .^C-UO •
Inc ni
^^ .Ut-Uo •
£ 8.0E-04 -
c
s 6.0E-04 •
c
g 4.0E-04 -
o
0 2.0E-04 -
Oncj-nn
m\ICr\I\I
Data Table:
Well Well Ty
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
D-107 T
/VVV*o
• A A A 4
W V W ^
•
Effective
pe Date
2/15/1999
5/15/1999
11/15/1999
5/15/2000
11/15/2000
11/15/2001
5/15/2002
11/15/2002
5/15/2003
11/15/2003
5/15/2004
11/15/2004
5/15/2005
11/15/2005
5/15/2006
Date
^VVVVVVV
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)
^vv*
.. ^ ^
Result (mg/L) Flag
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
1.0E-03 ND
2.8E-04
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 6
Confidence in
Trend"
I
Coefficient of Variation:
j 0.20
Mann Kendall
Concentration Trend:
(See Note)
I NT
Number of Number of
Samples Detects
1 0
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
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
9/19/2006
Page 1 of 1
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-10-97
Well Type: s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/3/1999 to 5/5/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1 nnFt-nn
j
O)
•§- 1.00E-01 -
o
c
01
c 1.00E-02-
o
O
Data Table:
Well V\i
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
MW-10-97
X^ ^ X^
*
fell Type
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
Da
A 4 4'
yO ^^^ yC
Effective
Date
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
te
*£\* «fb «fb «A* **bi t& «!
^K ^^ ^-» ^- ^*- ^-f ^
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)
V*
Result (mg/L) Flag
1.0E-03 ND
3.9E-03
1.5E-02
2.0E-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
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
Mann Kendall S Statistic:
I -61
1
Confidence in
Trend:
1 91 .9%
Coefficient of Variation:
I 1'67
Mann Kendall
Concentration Trend:
(See Note)
1 PD
Number of Number of
Samples Detects
1 0
3 2
2 2
3 2
3 0
3 0
3 0
3 0
3 0
3 0
3 0
3 0
3 0
3 0
3 0
3 1
3 0
3 0
3 0
3 0
3 0
3 0
MAROS Version 2.2, 2006, AFCEE
9/12/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well
MW-10-97
MW-10-97
MW-10-97
Well Type
s
s
s
Effective
Date
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L)
1 .OE-03
1 .OE-03
1 .OE-03
Flag
ND
ND
ND
Number of
Samples
3
3
1
Number of
Detects
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
9/12/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: MW-5
Well Type: s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/3/1999 to 5/5/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
Date
**
Mann Kendall S Statistic:
~a>
o
Concentra
1.2E-02-
1.0E-02-
8.0E-03 •
6.0E-03 •
4.0E-03 -
2.0E-03 •
n np4-nn .
*
• * »
***** *
» ******
I ~152
Confidence in
Trend:
1 100.0%
Coefficient of Variation:
0.30
Mann Kendall
Concentration Trend:
(See Note)
Data Table:
Well
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
MW-5
Well Type
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
Effective
Date
2/15/1999
5/15/1999
8/15/1999
11/15/1999
5/15/2000
11/15/2000
5/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
11/15/2003
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
8/15/2005
11/15/2005
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)
Result (mg/L) Flag
9.2E-03
4.6E-03
1.0E-02
9.2E-03
8.2E-03
1.0E-02
1.2E-02
7.0E-03
8.9E-03
8.3E-03
7.4E-03
7.5E-03
5.5E-03
6.0E-03
6.2E-03
4.9E-03
5.7E-03
5.8E-03
4.8E-03
6.4E-03
5.1E-03
4.8E-03
Number of
Samples
1
1
1
1
1
1
1
2
1
2
1
2
1
2
1
1
1
2
1
1
3
2
Number of
Detects
1
1
1
1
1
1
1
2
1
2
1
2
1
2
1
1
1
2
1
1
3
2
MAROS Version 2.2, 2006, AFCEE
9/12/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well
Well Type
Effective
Date
Constituent
Result (mg/L)
Flag
Number of
Samples
Number of
Detects
MW-5
MW-5
2/15/2006 TRICHLOROETHYLENE (TCE) 4.8E-03
5/15/2006 TRICHLOROETHYLENE (TCE) 5.3E-03
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
9/12/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: P-202
Well Type: s
COC: TRICHLOROETHYLENE (TCE)
Time Period: 3/3/1999 to 5/5/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
Date
# J? f ^ & ^ # ^ ^ ^ & J
> .0* .o4 Oy^> .£> J*> .^> oy^> .^> o^ .^P <$>
^ ^^ i?*
E
o
1
c
i
o
o
1.6E-U2 -
1.4E-02-
1.2E-02-
1.0E-02-
8.0E-03 •
6.0E-03 -
4.0E-03 •
2.0E-03 -
n np4-nn .
* * * *
*» *
^ ^
^ V ^
«*
*
Mann Kendall S Statistic:
I ~167
Confidence in
Trend:
I 100.0%
Coefficient of Variation:
r
0.20
Mann Kendall
Concentration Trend:
(See Note)
Data Table:
Well
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
P-202
Well Type
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
s
Effective
Date
2/15/1999
5/15/1999
11/15/1999
5/15/2000
11/15/2000
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
2/15/2005
5/15/2005
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)
Result (mg/L) Flag
1.5E-02
1.4E-02
9.4E-03
1.2E-02
9.9E-03
1.3E-02
1.3E-02
1.4E-02
1.2E-02
1.4E-02
1.3E-02
1.1E-02
1.1E-02
1.1E-02
9.0E-03
9.3E-03
6.6E-03
9.5E-03
9.0E-03
9.2E-03
1.0E-02
1.0E-02
Number of
Samples
1
1
1
1
1
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Number of
Detects
1
1
1
1
1
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
MAROS Version 2.2, 2006, AFCEE
9/12/2006
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well
P-202
P-202
P-202
P-202
Well Type
s
s
s
s
Effective
Date
8/15/2005
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Result (mg/L) Flag
1 .OE-02
9.6E-03
7.4E-03
8.4E-03
Number of
Samples
3
3
3
2
Number of
Detects
3
3
3
2
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
9/12/2006
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Well: WD-10
Well Type: T
COC: TRICHLOROETHYLENE (TCE)
Time Period: 1/1/1999 to 5/5/2006
Consolidation Period: Quarterly
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: Specified Detection Limit
J Flag Values : Actual Value
1 9P ni
1 .^C-UO •
Inc ni
^^ .Ut-Uo •
£ 8.0E-04 -
c
s 6.0E-04 •
c
g 4.0E-04 -
o
0 2.0E-04 -
Oncj-nn
m\ICr\I\I
Data Table:
Well Well Ty
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
WD-10 T
/VVV*o
•
Effective
pe Date
2/15/1999
5/15/1999
11/15/1999
5/15/2000
11/15/2000
11/15/2001
5/15/2002
11/15/2002
5/15/2003
11/15/2003
5/15/2004
11/15/2004
5/15/2005
11/15/2005
5/15/2006
Date
^VVVVVVV
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)
^vv*
.. ^ ^
Result (mg/L) Flag
1.0E-03 ND
1.1E-04
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 12
Confidence in
Trend"
I 70.4%
Coefficient of Variation:
I °'24
Mann Kendall
Concentration Trend:
(See Note)
1 NT
Number of Number of
Samples Detects
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
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
9/19/2006
Page 1 of 1
-------
MAROS Zeroth Moment Analysis
Project: Stageright
Location: Stageright
COC: TRICHLOROETHYLENE (TCE)
User Name: MV
State: Michigan
Change in Dissolved Mass Over Time
Date
Porosity: 0.31
Saturated Thickness:
1 -
"5
in
in
I
0.1 •
* * *
* * * * *
•
•
•
Data Table:
Effective
2/15/1999
5/15/1999
11/15/1999
5/15/2000
8/15/2000
11/15/2000
2/15/2001
5/15/2001
8/15/2001
11/15/2001
2/15/2002
5/15/2002
8/15/2002
11/15/2002
2/15/2003
5/15/2003
8/15/2003
11/15/2003
2/15/2004
5/15/2004
8/15/2004
11/15/2004
Date 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)
.••••*••••.
Estimated
Mass (Kg)
O.OE+OO
O.OE+OO
O.OE+OO
3.9E-01
4.1E-01
3.6E-01
3.4E-01
3.5E-01
4.0E-01
3.5E-01
3.0E-01
1.6E-01
3.3E-01
2.8E-01
3.0E-01
2.5E-01
2.3E-01
2.0E-01
2.2E-01
2.3E-01
2.4E-01
2.2E-01
Number of Wells
1
1
1
8
9
9
8
9
12
12
12
13
14
14
14
14
14
14
14
14
14
14
Uniform: 50 ft
Mann Kendall S Statistic:
I ~105
Confidence in
Trend:
J 98.0%
Coefficient of Variation:
| 0.45
Zeroth Moment
Trend:
II D
MAROS Version 2.2, 2006, AFCEE
9/11/2006
Page 1 of 2
-------
MAROS Zeroth Moment Analysis
Effective Date
2/15/2005
5/15/2005
8/15/2005
11/15/2005
2/15/2006
5/15/2006
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Estimated
Mass (Kg)
2.5E-01
2.3E-01
2.3E-01
2.1E-01
2.3E-01
2.0E-01
Number of Wells
14
14
14
14
14
14
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. Moments are not calculated for sample events with less than 6 wells.
MAROS Version 2.2, 2006, AFCEE
9/11/2006
Page 2 of 2
-------
ATTACHMENT D
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
ilectronic, 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
-------
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
-------
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
Stageright
MDEQ agrees that chloride, alkalinity and TDS sampling
and analysis can be reduced
Comment noted.
JS
Comment 2f
and BV
Stageright
(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
Page 3 of21
-------
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
Page 4 of21
-------
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)
Stageright
(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, D106, 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
Page 5 of21
-------
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. |S
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,
Stageright
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
Page 6 of21
-------
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, groundwater flow 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
Page 7 of21
-------
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
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(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
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(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
Stageright
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
Stageright
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
Stageright
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.
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(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.
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(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
Stageright
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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(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.
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(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.
MHPRB
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.
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(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.
MHPRB
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
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(Continued)
Commenter
MHPRB
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,
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(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"' 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
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(Continued)
Commenter
MH PRB
Comment 7
MHPRB
Comment 8
MHPRB
Comment 9
MHPRB
Comment 10
MHPRB
Comment 11
MHPRB
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.
11) 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 1 a 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.
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(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
groundwaterand soil contamination?
16) 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.
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(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.
MHPRB
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.
MHPRB
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.
MHPRB
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.
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RESPONSE TO MDEQ's COMMENTS ON
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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. (JSEPA
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.
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