Office of Solid Waste and EPA-540-R-11 -019
Emergency Response February 2011
(5102G) www.epa.gov/tio
www.clu-in.org/optimization
Streamlined Remediation System Evaluation
Wash King Laundry Superfund Site
Pleasant Plains Township, Michigan
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STREAMLINED REMEDIATION SYSTEM EVALUATION
WASH KING LAUNDRY SITE
PLEASANT PLAINS TOWNSHIP, LAKE COUNTY, MICHIGAN
Report of the Streamlined Remediation System Evaluation
Conference Call Conducted for the Wash King Laundry Site
July 26, 2010
Revised Report
February 18,2011
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NOTICE
Work described herein was performed by GeoTrans, Inc. (GeoTrans) for the U.S. Environmental
Protection Agency (U.S. E.P.A). Work conducted by GeoTrans, including preparation of this report, was
performed under Work Assignment #48 of EPA contract EP-W-07-078 with Tetra Tech EM, Inc.,
Chicago, Illinois. Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
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PREFACE
This report was prepared as part of a project conducted by the United States Environmental Protection
Agency Office of Superfund Remediation and Technology Innovation (U.S. EPA OSRTI) in support of
the "Action Plan for Ground Water Remedy Optimization" (OSWER 9283.1-25, August 25, 2004). The
objective of this project is to conduct Remediation System Evaluations (RSEs) at selected pump and treat
(P&T) systems that are jointly funded by EPA and the associated State agency. The project contacts are
as follows:
Organization
Key Contact
Contact Information
U.S. EPA Office of Superfund
Remediation and Technology
Innovation
(OSRTI)
Jennifer Hovis
USEPA Headquarters - Potomac Yard
2777 Crystal Drive
Arlington, VA 22202
phone: 703-603-8888
hovis.iennifer@epa.gov
Tetra Tech EM, Inc.
(Contractor to EPA)
Therese Gioia
Tetra Tech EM Inc.
1881 Campus Commons Drive, Suite 200
Reston,VA20191
phone: 815-923-2368
Therese.Gioia(o)tetratech.com
GeoTrans, Inc.
(Contractor to Tetra Tech EM, Inc.)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
phone: 732-409-0344
dsutton@geotransinc. com
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TABLE OF CONTENTS
NOTICE i
PREFACE ii
TABLE OF CONTENTS iii
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 2
1.3 DOCUMENTS REVIEWED 2
1.4 PERSONS CONTACTED 3
1.5 BASIC SITE INFORMATION AND SCOPE OF REVIEW 3
1.5.1 LOCATION 3
1.5.2 SITE HISTORY, POTENTIAL SOURCES, AND RSE SCOPE 3
1.5.3 HYDROGEOLOGIC SETTING 4
1.5.4 POTENTIAL RECEPTORS 5
1.5.5 DESCRIPTION OF GROUND WATER PLUME 6
2.0 SYSTEM DESCRIPTION 7
2.1 P&T SYSTEM 7
2.2 SVE SYSTEM 8
2.3 IN-SITU BIO-REMEDIATION 8
2.4 MONITORING PROGRAM 9
3.0 SYSTEM OBJECTIVES, PERFORMANCE, AND CLOSURE CRITERIA 10
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 10
3.2 TREATMENT PLANT OPERATION STANDARDS 10
4.0 FINDINGS 11
4.1 GENERAL FINDINGS 11
4.2 SUBSURFACE PERFORMANCE AND RESPONSE 11
4.2.1 GROUND WATER FLOW AND PLUME CAPTURE 11
4.2.2 GROUND WATER CONTAMINANT CONCENTRATIONS 12
4.3 COMPONENT PERFORMANCE 15
4.3.1 GROUNDWATEREXTRACTION SYSTEM 15
4.3.2 AIR STRIPPERS 15
4.3.3 VAPOR GAC 15
4.3.4 SVE SYSTEM 15
4.3.5 BIOREMEDIATION SYSTEM 16
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF ANNUAL COSTS 16
4.4.1 UTILITIES 16
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS 17
4.4.3 LABOR 17
in
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4.4.4 CHEMICAL ANALYSIS 17
4.5 APPROXIMATE ENVIRONMENTAL FOOTPRINTS ASSOCIATED WITH REMEDY 17
4.5.1 ENERGY, AIR EMISSIONS, AND GREENHOUSE GASES 17
4.5.2 WATER RESOURCES 18
4.5.3 LAND AND ECOSYSTEMS 18
4.5.4 MATERIALS USAGE AND WASTE DISPOSAL 18
4.6 RECURRING PROBLEMS OR ISSUES 18
4.7 REGULATORY COMPLIANCE 18
4.8 SAFETY RECORD 18
5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE
ENVIRONMENT 19
5.1 GROUND WATER 19
5.2 SURF ACE WATER 19
5.3 AIR 19
5.4 SOIL 19
5.5 WETLANDS AND SEDIMENTS 19
6.0 RECOMMENDATIONS 20
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS 20
6.1.1 SAMPLE P&T DISCHARGE AND RESIDENTIAL WELLS FOR LEAD 20
6.1.2 COMPLETE INSTITUTIONAL CONTROLS 20
6.1.3 JET EW-5 AND MEASURE/TRACK EXTRACTION WELL SPECIFIC CAPACITY 20
6.1.4 EVALUATE AND MANAGE SOIL VAPORS 21
6.2 RECOMMENDATIONS TO REDUCE COSTS 21
6.2.1 CONSIDER DISCONTINUING PUMPING FROM EW-4 21
6.2.2 REDUCE METALS ANALYSIS 21
6.2.3 RECONFIGURE AIR STRIPPERS AND POSSIBLY RESIZE AIR STRIPPER BLOWERS 22
6.2.4 MODIFY GROUNDWATER MONITORING PROGRAM 22
6.3 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT 24
6.3.1 PREPARE AN ANNUAL REPORT 24
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE Our 25
6.4.1 INVESTIGATE SOURCES IN LAGOON AREA AND PIPING TO FORMER LAGOONS.. 25
6.4.2 DEVELOP AN EXIT STRATEGY 26
6.5 RECOMMENDATIONS FOR ADDITIONAL GREEN PRACTICES 27
6.5.1 USE DEDICATED TUBING 27
6.5.2 CONSIDERATIONS FOR RENEWABLE ENERGY AT THE SITE 27
Tables
Table 6.1 Cost Summary Table
Table 6.2 Sustainability Summary Table
Attachments
Attachment A - Selected Figures from Existing Reports
Attachment B - Electricity Generation and Emissions
IV
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1.0 INTRODUCTION
1.1 PURPOSE
During fiscal years 2000 and 2001 independent reviews called Remediation System Evaluations
(RSEs) were conducted at 20 operating Fund-lead pump and treat (P&T) sites (i.e., those sites
with P&T systems funded and managed by Superfund and the States). Due to the opportunities
for system optimization that arose from those RSEs, EPA OSRTI has incorporated RSEs into a
larger post-construction complete strategy for Fund-lead remedies as documented in OSWER
Directive No. 9283.1-25, Action Plan for Ground Water Remedy Optimization. A strong interest
in sustainability has also developed in the private sector and within Federal, State, and Municipal
governments. Consistent with this interest, OSRTI has developed a Green Remediation Primer
(http://cluin.org/greenremediation/) and now as a pilot effort considers green remediation during
independent evaluations.
The RSE process involves a team of expert hydrogeologists and engineers that are independent of
the site, conducting a third-party evaluation of the operating remedy. It is a broad evaluation that
considers the goals of the remedy, site conceptual model, available site data, performance
considerations, protectiveness, cost-effectiveness, closure strategy, and sustainability. The
evaluation includes reviewing site documents, potentially visiting the site for one day, and
compiling a report that includes recommendations in the following categories:
Protectiveness
Cost-effectiveness
Technical improvement
Site closure
Green remediation
The streamlined RSE process or RSE-lite is similar to the RSE process but does not include a site
visit.
The recommendations are intended to help the site team identify opportunities for improvements.
In many cases, further analysis of a recommendation, beyond that provided in this report, may be
needed prior to implementation of the recommendation. Note that the recommendations are
based on an independent evaluation, and represent the opinions of the evaluation team. These
recommendations do not constitute requirements for future action, but rather are provided for
consideration by the Region and other site stakeholders.
Wash King Laundry Site was selected by EPA OSRTI based on a nomination from EPA Region 5
and the State of Michigan due to the upcoming transition of the site from a long-term remedial
action (LTRA) to operations and maintenance (O&M).
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1.2 TEAM COMPOSITION
The RSE team consists of the following individuals:
Name
Doug Sutton
Sarah Farron
Affiliation
GeoTrans, Inc.
GeoTrans, Inc.
Phone
732-409-0344
732-409-0344
Email
dsutton@geotransinc.com
sarah.farron@geotransinc.com
In addition, Jennifer Hovis from EPA Headquarters participated in the RSE-lite conference call.
1.3 DOCUMENTS REVIEWED
The following documents were reviewed. The reader is directed to these documents for
additional site information that is not provided in this report.
EPA Superfund Record of Decision - March 1993
Technical Memorandum Predesign Field Investigations - June 1995
EPA Explanation of Significant Differences - July 1996
EPA Five-Year Review Report - September 2006
Long-Term Monitoring Network Optimization Evaluation, June 2006
Great Lakes March 2006 Weekly Report - April 2006
Operation and Maintenance Manual, Carbonair
In-Situ Bioremediation Work Plan and Proposal - July 2009
Quarterly Report and Remedial Systems Summary - July 2006
Quarterly Report and Remedial Systems Summary - October 2006
Quarterly Report and Remedial Systems Summary - January 2007
Quarterly Report and Remedial Systems Summary - April 2007
Quarterly Report and Remedial Systems Summary - July 2007
Quarterly Report and Remedial Systems Summary - October 2007
Quarterly Report and Remedial Systems Summary - January 2008
Quarterly Report and Remedial Systems Summary - April 2008
Quarterly Report and Remedial Systems Summary - July 2008
Quarterly Report and Remedial Systems Summary - October 2008
Quarterly Report and Remedial Systems Summary - January 2009
Quarterly Report and Remedial Systems Summary - April 2009
Quarterly Report and Remedial Systems Summary - July 2009
Quarterly Report and Remedial Systems Summary - October 2009
Quarterly Report and Remedial Systems Summary - January 2010
Electronic Data
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1.4 PERSONS CONTACTED
The following individuals associated with the site participated in the conference call:
Name
Shari Kolak
Keith Krawczyk
Bill Bolio
James Wilson
Affiliation
U.S. EPA Region 5
(RPM)
Michigan DNRE
Michigan DNRE
Lakeshore Env.
Phone
312-886-6151
517-335-4103
Email
kolak. shari@epa.gov
KRAWCZYKK@michigan.gov
DNRE= "Department of Natural Resources and Environment'
1.5 BASIC SITE INFORMATION AND SCOPE OF REVIEW
1.5.1
LOCATION
According to the 2006 Five Year Review and other site documents, the Wash King Laundry Site
("the site") is located south of the city of Baldwin in Pleasant Plains Township, Lake County,
Michigan, in the Pere Marquette River Basin. It is bordered on the east by a north-south trending
line approximately 300 feet east of M-37, Star Lake Road (76th Street) to the south, the C & O
Railroad to the west, and the Middle Branch Pere Marquette River to the north. The Pere
Marquette Subdivision Plat which comprises the site, includes 123 residential lots, most of which
are not used on a year-round basis. Housing in the area consists primarily of mobile homes,
trailers, and cottages. Numerous commercially developed lots exist along Highway M-37. The
site is generally flat except for a steep embankment leading down to the Middle Branch Pere
Marquette River.
1.5.2
SITE HISTORY, POTENTIAL SOURCES, AND RSE SCOPE
According to the site documents, the Wash King Laundry facility was a small, privately-owned
laundromat that operated between 1962 and 1978 as Wash King Laundry and continued until
1991 under different ownership until the latter owner filed for bankruptcy. Beginning in 1962,
the facility discharged laundry wastes (detergent and bleach) to four nearby seepage lagoons
located about 500 feet west of the laundry facility. As part of the laundry operations/services, dry
cleaning was conducted, which included the use of the solvent perchloroethene or
tetrachloroethylene (PCE). Consequently, PCE was also discharged to the unlined wastewater
lagoons until late 1978. Laundry detergent wastes and PCE were first detected in the
groundwater by state personnel in August 1973, when the contamination was detected in
residential wells located in the vicinity of the lagoons.
In 1976, further contamination (PCE) of groundwater was discovered, and the State of Michigan
issued a Notice of Noncompliance and Order to Comply to the Wash King Laundry owner. In
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1977, concentrations of PCE up to 6,000 ug/L were recorded in the Wash King Laundry well, and
up to 20,000 ug/L in an adjacent restaurant well, located directly down-gradient of the former
laundry building. In 1978, Wash King Laundry agreed to cease all dry cleaning operations.
In 1979, a preliminary hydrogeologic investigation was initiated to obtain information related to
groundwater contamination and flow and soil types at the site. Subsequent investigations and
analysis indicate that a groundwater contaminant plume(s) is migrating toward the Middle Branch
of the Pere Marquette River.
While high levels of organic contaminants were generally not present in soil samples collected
from the lagoons, high levels of PCE contamination in soil were detected near the Wash King
Laundry building. Breakdown products of PCE, such as Trichloroethene (TCE) and cis-1,2-
Dichloroethylene (cis-l,2-DCE) have also been detected.
In 1983, the state negotiated a settlement with the site owner, specifying that he construct a public
water supply system to serve residences and businesses in the area of contamination. Two wells
were subsequently developed into a deeper uncontaminated aquifer to supply water for the public
water system. The main well is located on Wash King Laundry property and is 259 feet deep.
The standby well is located on the Windjammer Restaurant property adjacent to Wash King
Laundry, and is 240 feet deep. Local residents were offered the opportunity to connect to this
water supply in 1984. Those that did not connect are now participating in a residential well
sampling program. The residential wells are sampled on an annual basis.
The Wash King Laundry site was placed on the National Priorities List of Superfund sites in
1983. The Remedial Investigation/Feasibility Study (RI/FS) process, lead by the MDNR, began
in September 1988 with an emphasis on data collection and site characterization. The Record of
Decision was signed in March 1993, followed by an Explanation of Significant Differences in
June 1996, and a remedy design thereafter. Remedy implementation began in June 1999 and
included building demolition, tank removal, installation of a pump and treat (P&T) system, and
installation of a soil vapor extraction (SVE) system. The P&T system and SVE system were fully
operational in April 2001. In July 2009, the site contractor provided a work plan for
implementing in-situ bioremediation of the groundwater and saturated soils in the vicinity of the
former Wash King Laundry facility. In-situ bioremediation began in January 2010.
This RSE-lite focuses on all aspects of site remediation including the P&T system, SVE system,
in-situ bioremediation, and site-wide monitoring program.
1.5.3 HYDROGEOLOGIC SETTING
Information in this section is primarily from site documents and does not include interpretation by
the RSE-lite team.
The site is in the Pere Marquette River basin, which provides drainage for a 681.6 square mile
area. The river flows generally westward, discharging into Lake Michigan. The Pere Marquette
River and its tributaries are classified by the State of Michigan as "top quality main streams" and
"trout streams".
A series of end moraines and ground moraines were deposited in this region by the Lake
Michigan Lobe of the Wisconsin glaciation. Most of the boundaries of the basin are comprised of
end moraines. Glacial outwash between moraines covers more than half of the drainage basin.
The outwash plains are relatively level, but are dissected in places by streams and pitted with
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kettle holes formed by melting blocks of glacial ice. The Middle Branch of the Pere Marquette
River, which forms the northern boundary of the Site, is one of these dissecting streams.
Glacial deposits in this region range from approximately 400 to 600 feet thick. The bedrock
underlying the glacial deposits is the Mississippian Age Michigan Formation, which is not
utilized as an aquifer in this region.
Site soils are generally composed of fine- to medium-grained sands to a depth of approximately
75 to 100 feet below ground surface (bgs), with some interbedded clay, sand and clay, and gravel
lenses, ranging in thickness from one to several feet. These deposits are underlain by a thicker
clay layer that begins at about 85 feet below ground surface and subdivides the shallow sandy
aquifer from a deeper, predominantly sandy aquifer that extends to a depth of approximately 350
feet bgs. Figures 15B, 16B, and 17B (see Attachment A) provide north-south cross-sections of
the geology to the top of the clay layer.
Aquifers in the region are predominantly outwash sands and gravels. Groundwater recharge
occurs on uplands with sandy soils. Groundwater in the upper aquifer generally flows to the
north-northeast, discharging into the Middle Branch Pere Marquette River. It is uncertain if
deeper groundwater in the upper aquifer also discharges to the river. The overall horizontal
hydraulic gradient is about 0.0055 feet per foot. A pumping test conducted as part of the 1995
predesign investigation yields a hydraulic conductivity of approximately 1 x 10"3 cm/s
(approximately 2.8 feet per day) to 1 x 10"2 cm/s (approximately 28 feet per day). Horizontal
hydraulic conductivities from slug tests conducted in many monitoring wells varies from 0.9 feet
per day to 340 feet per day. Vertical hydraulic gradients are downward near the source area and
are upward near the river.
1.5.4 POTENTIAL RECEPTORS
Contaminant exposure pathways considered to be most significant at the site at the time of the
ROD are summarized as follows:
Exposure of children to contaminated lagoon sediment through incidental ingestion and
dermal absorption while playing in the lagoons.
Exposure of residents to contaminated groundwater resulting from use of a well within
the contaminated groundwater plume or by migration of groundwater contaminants to
existing wells. Exposure may occur through ingestion or dermal contact with
contaminated water. It would also be possible for exposure to occur through inhalation
during household water usage.
Exposure of individuals to contaminated soils at a future residence(s) developed at the
site (e.g., on top of the lagoons). Exposure may occur through incidental ingestion of soil
and dermal contact. It is assumed that contaminants in either lagoon sediments or
subsurface soils at current concentrations would be available for exposure as a result of
site development.
Exposure of recreational users of the Middle Branch of the Pere Marquette River to
contaminated surface water. Exposures may occur through incidental ingestion and
dermal contact with surface water while swimming. (Even though this exposure route is
more unlikely than the ones noted above, it was still considered in the risk analysis.)
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Subsequent to the ROD, the lagoon sediments/soils were found to not pose a risk to human health
but soils near the former Wash King Laundry building did pose a risk to human health and
continued groundwater contamination. These findings, the decision to not excavate lagoon
sediments/soils, and the decision to install the SVE system near the former building are
documented in the BSD. Backfilling and grading of the lagoons has subsequently occurred and
operation of the SVE system continues as needed.
The ROD documented that contamination levels in the surface water and river sediments do not
pose an unacceptable risk. Therefore, the only remaining potential receptors are associated with
potential use of contaminated groundwater and potential exposure to soil contamination or soil
vapors near the former Wash King Laundry building.
1.5.5 DESCRIPTION OF GROUND WATER PLUME
The predominant contaminants of concern that remain in ground water are PCE, TCE, and cis-
1,2-DCE. At most locations, PCE is typically found in higher concentrations than the other two
compounds. Figures 14, 23, and 23B (see Attachment A) show the horizontal extent and
concentrations of the contaminant plume in this area based on analytical results from March
2008, October 2008, and October 2009, respectively.
These figures show that the highest concentrations (which range from 1,400 ug/L to 25,000 ug/L
for PCE at MW-101S) are located in the shallow zone (-30 to 50 ft) in the immediate vicinity of
the former Wash King Laundry facility. This area of high concentration extends approximately
120 feet north of the building to EW-2. A larger area of moderate to high concentrations exists to
the north of the building in the intermediate to deep zones (-50 to lOOfeet). This deeper
contamination extends to the area near the MW-306 well cluster, where the highest
concentrations are detected in the intermediate well, MW-306I. Concentrations downgradient of
the source area in 2009 were as high as 3,000 ug/L in deep MW-303, which is screened from
approximately 90 to 100 feet bgs.
A smaller area of groundwater contamination at depths between 50 and 80 feet near the MW-307
cluster is shown on the figures for March and October 2008. PCE concentrations in March 2008
at this location were highest (520 ug/L) at the intermediate well MW-307I.
The vertical distribution of contamination is also presented in the north-south cross-sections
presented in Figures 15B, 16B, and 17B.
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2.0 SYSTEM DESCRIPTION
The operational remedies include a P&T system, SVE system, and in-situ bioremediation. The P&T and
SVE systems began operation in April 2001, and in-situ bioremediation began in January 2010. Each of
these remedies is discussed in more detail below.
2.1 P&T SYSTEM
The original P&T system consisted of five extraction wells; however, a sixth (EW-3) and seventh (EW-7)
extraction well were added in October 2008 and July 2010, respectively. These wells significantly
improve control of source area contamination. The extraction well locations are depicted in Figure 21
(see Attachment A). Extraction well EW-3 was installed in the area of the former Wash King Laundry
building and is fully screened through the upper till (source area) and deep portion of the main aquifer.
EW-7, also fully screened, was installed approximately 25 feet east of EW-2, which contains only a five-
foot screen set near the water table. EW-2 has been shut down indefinitely.
Extracted groundwater is treated by two Carbonair STAT 180 low-profile air strippers arranged in
parallel. Four 4,000-pound vapor granular activated carbon (GAC) units are provided for treating the air
stripper off-gas but are not used because air permit requirements are met without using the units. Treated
water is discharged to the subsurface via a lagoon located north and west of the former laundry facility
lagoons. The following table provides key information regarding the extraction network based on
information provided by the site team.
Well Name
EW-1
EW-2
EW-3
EW-4
EW-5
EW-6
EW-7
Screen Interval
Elevation
(ft AMSL)
792.8-737.8
780.0-775.0
782.7 - 722.7
750.3-725.3
757.0-737.0
741.2-721.2
786.5-726.5*
Extraction Rate
(gpm)
35
0
25
25
20
60
60
July 2010
PCE+TCE
Concentration
(ug/L)
18.8
420
2,100
3.1
67.2
157.9
190
* Approximated based on provided depth interval and elevation of nearby EW-2
The total flow rate is approximately 225 gpm, and the average influent concentration varies from
approximately 200 ug/L to 500 ug/L (approximately 335 ug/L based on a weighted average of the values
in the above table). The P&T system is co-located in a small building with the SVE and in-situ
bioremediation systems. The building is heated with natural gas during the winter.
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2.2 SVE SYSTEM
The SVE system consists of SVE wells at five locations, with two locations having two screens set at
different depths in the vadose zone for a total of seven SVE wells.
There are two 1,500-pound vapor phase granular activated carbon tanks in series located in the treatment
building that are no longer used. The system meets air discharge requirements without treatment. A
blower extracts soil vapors at approximately 350 to 400 cubic feet per minute. A silencer is used in
conjunction with the blower so that remedial operations are not a noise nuisance to the community.
SVE wells are controlled by butterfly valves and solenoid valves with control relays to allow programmed
operation of the wells. The SVE vapors pass through an air/water separator tank to separate liquid water
present in SVE vapors. Water separated by the air/water separator is combined with the untreated water
in the groundwater treatment system.
The SVE system began operating on a cyclic basis in late October 2007. According to the January 4,
2008 Quarterly Report of Groundwater and SVE System Sampling, the decision to reduce system
operating time was based on the predominance of non-detectable levels of VOCs in the majority of
combined influent air samples from the previous two years. This measure was also intended to conserve
electricity and reduce energy costs. Currently, the SVE system runs for 1 week and is then shut off for 2
or more weeks. The site team believes the SVE is reasonably successful in the upper 25 feet of soil.
The following table summarizes recent soil vapor concentrations at each of the SVE locations.
Well Name
SVE-1
SVE-2
SVE-3
SVE-4S
SVE-4D
SVE-5S
SVE-5D
June 2010 PCE
Concentration
(ug/L or mg/m3)
0.400
0.590
0.097
1.4
61
0.42
0.58
TCE concentrations are less than PCE
concentrations by a factor of approximately
100.
2.3 IN-SITU BIO-REMEDIATION
The in-situ bioremediation system was implemented after additional investigation (completed in 2009)
identified a remaining, significant source area at the location of the former Wash King Laundry building.
The bioremediation system includes 67 two-inch injection wells with screen intervals from 32 feet bgs to
57 feet bgs, arranged in six injection arrays containing between 10 and 12 wells per array. The screened
interval of these injection wells corresponds to the general thickness of the upper till layer source material
in the vicinity of the former Wash King Laundry building. PCE concentrations in saturated soil ranged
up to approximately 40,000 ug/Kg at locations sampled. A distribution wheel located in a concrete vault
controls which array receives the reagents. The system is depicted in Figures 26c, 27, and 28 (see
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Attachment A). The system uses the Oppenheimer Formula CL product, which involves injection of
microorganisms, a biocatalyst, and nutrients. Each of the six injection arrays received 250 pounds of
product mixed with 2,000 gallons of water in January 2010, followed by the same process in September
2010. Addition of nutrients is an on-going process. Another similar bioremediation event will be
implemented in 2011.
2.4 MONITORING PROGRAM
Process Monitoring
Volatile organic compounds (VOCs) are sampled quarterly at each of the extraction wells, the combined
extracted groundwater (influent), and the effluent from each of the air strippers. Vapors from each of the
SVE wells, the combined SVE vapors, and the air stripper off-gas vapors are also sampled quarterly for
VOCs.
Groundwater Monitoring
Groundwater has been monitored for VOCs at many of the 64 monitoring wells on a semi-annually basis
to develop a robust dataset needed to evaluate remedial progress, using low-flow sampling methods and
disposable polyethylene tubing. Metals are monitored on an annual basis at monitoring well locations
within the contaminant plume, at the P&T effluent area, and at background locations Water levels are
monitored once per year under pumping and non-pumping conditions.
Bioremediation Performance Monitoring
Nine source area monitoring wells and three extraction well locations are monitored quarterly for VOCs,
select inorganic indicator parameters associated with bioremedial activity.
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3.0 SYSTEM OBJECTIVES, PERFORMANCE, AND
CLOSURE CRITERIA
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The ROD for the Wash King Laundry Site identifies the following Remedial Action Objectives (RAOs):
Prevent ingestion and dermal contact with lagoon sediments
Prevent ingestion and dermal contact with contaminated groundwater by a hypothetical future
resident
The 1993 ROD specified the use of Michigan Type A and Type B cleanup criteria for the lagoons and
groundwater, based on the Environmental Response Act, 1982 PA 307, as amended. However, at the
time of the BSD in 1996, the Type A and Type B cleanup criteria were no longer supported by the current
State regulations, and therefore, the BSD prescribed use of the Part 201 residential cleanup criteria as
RAO's.
The residential cleanup criteria generated under Part 201, Environmental Remediation, of Act 45 lof the
NREPA and applied for this site include the treatment standards in the following table for the primary
contaminants of concern identified during the Remedial Investigation and Feasibility Study:
Contaminant of Concern
PCE
TCE
cis 1,2-DCE
Cleanup Criteria (jig/L)
5
5
70
State standards and Federal maximum contaminant levels also apply to other contaminants, including
lead.
3.2 TREATMENT PLANT OPERATION STANDARDS
There is no formal permit or permit equivalency for regulating the discharge of the treated water. The site
team maintains undetectable VOC concentrations in the effluent. The SVE and P&T systems have
separate permits for air discharge. Both systems must discharge less than 0.03 pounds of VOCs per hour.
10
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4.0 FINDINGS
4.1 GENERAL FINDINGS
The observations provided below are not intended to imply a deficiency in the work of the system
designers, system operators, or site managers but are offered as constructive suggestions in the best
interest of the EPA and the public. These observations have the benefit of being formulated based upon
operational data unavailable to the original designers. Furthermore, it is likely that site conditions and
general knowledge of ground water remediation have changed overtime.
4.2 SUBSURFACE PERFORMANCE AND RESPONSE
4.2.1 GROUND WATER FLOW AND PLUME CAPTURE
Groundwater flow under non-pumping and pumping conditions in 2008 (prior to the installation of EW-7)
are presented in Figures 11 and 13 (see Attachment A). Figure 11 illustrates that groundwater flows to
the north, north-east toward the river, and the slight curvature of the contours in the vicinity of EW-6 may
result from incomplete aquifer recovery prior to collecting the non-pumping round of water levels. Figure
13 provides the site team's depiction of the horizontal capture zone. The RSE-lite team evaluated the
water levels and potentiometric surface map and generally agrees with the interpreted potentiometric
surface map and extent of the capture zone in the vicinity of EW-4, EW-5, and EW-6. In general, when
evaluating capture in the area of these wells, the intermediate and deep wells should generally be used
because that is the interval where most of the contamination is present. There are a few instances where
water levels from individual wells do not appear accurate based on water level measurements from
surrounding wells or other wells in the well cluster. MW-202D and MW-206D are a few examples. The
inconsistencies appear to occur during each water level event, suggesting that a survey error may be the
cause.
Comparing the extraction rate from EW-5 and EW-6 to the groundwater flow rate, saturated thickness,
and approximate plume width yields a similar interpretation of plume capture to that from the
potentiometric surface maps.
Q = Saturated Thickness x Width x Hydraulic Gradient x Hydraulic Conductivity
5,775ft3/day = 70ft x 500ft x 0.0055ft/ft x 30ft/day
5,775 ff/day = 30 gpm
In the above calculations, the hydraulic conductivity of 30 feet per day is the approximate upper range of
the hydraulic conductivity calculated from the pumping test during the 1995 predesign investigation. It is
unclear if this is a reasonable average hydraulic conductivity to apply in the area of EW-5 and EW-6. The
actual pumping rate from these two wells is approximately 65 gpm. Therefore, based on these
assumptions and pumping rates, there is a factor of safety of more than 2.0 to account for heterogeneity,
potential erroneous assumptions regarding the hydraulic conductivity, and other factors.
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The capture zones in the vicinities of EW-1 and EW-2 is based on limited data. The extent of capture
from EW-2 may be overestimated in Figure 13. Use of water level data from the new 400 series
monitoring wells will provide more information to interpret capture and extraction from EW-7, which is
now occurring, will greatly improve capture in this area. Based on the observed drawdown and the
background water hydraulic gradient, the interpreted capture zone near EW-1 is likely a reasonable
approximation.
4.2.2 GROUND WATER CONTAMINANT CONCENTRATIONS
VOCs
This section evaluates groundwater contaminant trends along potential migration pathways under non-
pumping conditions that were then influenced by pumping starting in 2001. The three pathways can be
observed by review of the Figures 8 and 11 (see Attachment A) in which groundwater under non-
pumping conditions flows north and north-northeast. It is noted that although the three pathways are
discussed separately, the pathways may overlap making it difficult to attribute all contamination at a
particular sampling location to only one pathway or source
East Pathway - This pathway has the highest contaminant concentrations by a significant margin,
and has resulted PCE in the upper till layer near the former Wash King Laundry building, likely
from the former leaking storage tank, and perhaps poor housekeeping practices. This pathway
extends north-northeast through EW-2 and EW-7 toward the MW-309 cluster, then east of State
Road M-37 at the north-south location of EW-6, and then northeast toward the MW-306 cluster.
Since pumping began in 2001, groundwater in this pathway near EW-6 flows more directly
toward EW-6, some contamination past EW-6 is pulled back toward EW6, and contamination on
the eastern fringe of the pathway is pulled west.
Mid Pathway - This potential pathway initiates at some point between the former Wash King
Laundry building and the original discharge lagoons or at the southern most reach of the original
discharge lagoons. The area immediately east of the current remediation building would be a
reasonable approximation of this location. Contamination would flow from this location north-
northeast toward the MW-308 cluster, to the MW-206 cluster, to the MW-205 cluster, and
onward toward the Middle Branch of the Pere Marquette River. It is also possible, that the
contamination observed at these specified locations result completely or partially from dispersed
East or West Pathway contamination. However, if the contamination does result from a third
contamination source between the former Wash King Laundry building and the original discharge
lagoons, this third source area would not be addressed by the existing remedy or other more
aggressive efforts to address the other two source areas.
West Pathway - This pathway originates from or near the former discharge lagoons and migrates
north and north-northeast near MW-215, toward the MW-212 cluster and on to the MW-307
cluster.
It is the RSE-lite team's experience that contaminant plumes are often narrower than conceptually
depicted, and that adhering to such narrowly defined pathways is not unreasonable. The following
observations are made with respect to each of these pathways. The RSE-lite team also, however, notes
that there may be reasonable competing conceptual models for contaminant sources and migration.
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East Pathway
Contamination at MW-309D has remained as high as 1,000 ug/L despite source area
pumping, suggesting that the EW-2 has not provided sufficient containment. The RSE-
lite team believes that the core of this contaminant plume migrates toward MW-303 and
is then captured by EW-6
Under pumping conditions, the eastern fringe of this pathway is directed through the
MW-306 cluster such that concentrations of approximately 50 ug/L continue. This
contamination may or may not be fully captured by the extraction network.
PCE concentration decreases at MW-3 cluster are consistent with the plume being pulled
west toward EW-6.
The bioremediation remedy and the new extraction well (EW-7) should address this
pathway at its source.
Mid Pathway
The existence of this pathway suggests that there is a source of PCE somewhere between the
former building and the former lagoons, perhaps a leak in the former discharge pipe. The area
immediately east of the current remediation building would be a reasonable approximation of this
location. It is also possible that source area contamination in the former lagoon area extends
sufficiently south to fall in line with the same migration pathway.
Contamination along this pathway may have been pulled east by pumping from EW-2
such that a slight increase was noted at the MW-207 cluster after pumping began.
The MW-308 cluster was only recently installed, so 10 years of results are not available
at this location. However, PCE concentrations at the MW-308 cluster are in the 50 ug/L
range despite 10 years of pumping, suggesting that the source of this contamination
(regardless of its exact location) is not fully captured.
PCE concentrations at the MW-206 cluster have also remained relatively consistent,
suggesting the source is not fully contained. However, under pumping conditions,
contamination at the MW-206 cluster may also be diffuse contamination from the above-
discussed East Pathway because pumping appears to cause a more northerly rather than
north-northeasterly flow groundwater direction between the former Wash King Laundry
building and the MW-206 cluster.
PCE concentrations at MW-205 have been influenced by pumping at EW-5 and EW-6,
which has modified groundwater flow direction. PCE concentrations at the MW-205
cluster increased from an initial concentration of 50 ug/L to over 1,000 ug/L between
2002 and 2003, and have since decreased back to approximately 100 ug/L. The
concentrations at the MW-205 cluster may now represent a blend of contamination from
the original East and Mid Pathways.
If the conceptual model described here is true, the source of this pathway has not and will
not be captured by existing P&T system or remediated by the recently implemented
bioremediation efforts in the vicinity of the former Wash King Laundry building.
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West Pathway
PCE concentrations at MW-215, MW-103, and MW-104 have all declined to at or below
cleanup standards, suggesting that EW-1 and EW-4 have been successful at containing
the plume along this pathway. Note that a PCE concentration of 21 ug/L in 2008 was
detected at D-1A (approximately 60 feet below ground surface and adjacent to EW-1) in
2008, suggesting that contamination persists in this source area that continues to be
captured by EW-1. The contamination in this area likely results from use of the original
discharge lagoons by the laundry facility. The discharge lagoons were constructed in fine
sand, which is present to a depth of approximately 20 feet. A 20 to 30-foot thick dense,
very fine sand till underlies this fine sand, and D-1A is screened in the gravelly sand
beneath the till. It is possible that PCE contamination in the till is slowly leaching into
the underlying gravelly sand, causing a long-term dilute source of contamination to the
more transmissive gravelly sand. Operation of EW-1 will likely need to continue for a
many years unless the source can be identified and removed.
The location of well cluster MW-307 may be located along the core of this plume. PCE
concentrations have decreased from over 500 ug/L in 2008 to approximately 300 ug/L in
2010. It is unclear what the initial concentrations were at this location prior to pumping.
The RSE-lite team believes that concentrations at this location will likely continue to
decrease and may have lingered as a result of a stagnation point in groundwater flow
created by the pumping from EW-4, EW-5, and EW-6.
It should be noted that PCE concentrations at the MW-306 and MW-307 cluster exceed the groundwater-
surface water interface (GSI) criteria.
Metals
The site team analyzes samples annually for 12 metals, including lead. Zinc, iron, manganese, and
occasionally aluminum have concentrations that exceed criteria. The historic concentrations were
substantially higher for total metals than for dissolved metals, and recent samples collected with low-flow
sampling are substantially lower than historic values. The RSE-lite team therefore believes that some
contribution of the detected metals resulted from turbidity in the well during sampling.
Historic groundwater monitoring indicates a history of lead contamination in groundwater with
concentration decreases in some locations correlated with the onset of the P&T system. Recent sampling
indicates substantially improved groundwater quality with respect to lead. The RSE-lite team counts 10
monitoring points that had exceedances of the lead criteria in either 2009 or 2010. One of these was MW-
105, which is located far east of the site and may be impacted by lead from a historic localized gasoline
release (unassociated with the Wash King site). The other exceedances are typically within a factor of 2
of the cleanup standard. Based on the historic distribution of lead in groundwater, the former lagoon area
appears to have been the primary source of groundwater contamination from lead. For example, MW-
215, which is located downgradient of the lagoons had concentrations as high as 97 ug/L when the P&T
system started operating. Concentrations have since declined to be consistently below the cleanup
standard of 4 ug/L. This decrease in the lead concentration likely results from capture provided by EW-1.
Similarly, lead contamination at MW-212S and MW-212D were above 100 ug/L when the P&T began
operation and have subsequently decreased by an order of magnitude, presumably due to plume capture
and/or redirection of the lead contaminated groundwater.
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The P&T system is not designed to treat lead, but the effluent is occasionally sampled for lead, and lead is
not detected in the effluent.
4.3 COMPONENT PERFORMANCE
4.3.1 GROUND WATER EXTRACTION SYSTEM
EW-l, EW-3, EW-4, and EW-7 have 3 HP submersible electric pumps and EW-5 and EW-6 have 5 HP
pumps. The site team did not report the pump sizes for EW-2. For the purpose of this evaluation, it is
assumed that EW-2 has a 1 HP pump. The site team reports some limited well and pump fouling from
iron. The site team recently cleaned the pumps and risers and rehabilitated EW-3, EW-5, and EW-6. The
rehabilitation exercise involved removing the riser and pump, steam cleaning the pump, cleaning the
pump in acid-water solution, and surging/scraping the well-screens. Well maintenance chemicals were
added to maintain a pH of 1.5 for 24 to 72 hours prior to replacing the pumps. The flow rate from EW-5
still appears to be low, and the site team is considering jetting the well for further cleaning. The RSE-lite
team has observed success from jetting wells at other sites and suggests proceeding with well jetting as an
option for rehabilitating EW-5. )
4.3.2 AIR STRIPPERS
According to the O&M manual, the STAT 180 air strippers each have seven trays and are fitted with a 25
HP pressure blower rated for 900 cfm at a pressure of 66 inches of water. This sizing assumed use of the
vapor GAC units, which are no longer used. The vendor software output in the O&M manual suggests
that each of the air strippers were sized to treat approximately 130 gpm of water (total capacity of 260
gpm) with a PCE concentration of 2,200 ug/L. With all wells pumping, the actual flow rate is
approximately 225 gpm with an average influent concentration between 200 ug/L and 500 ug/L. Based
on these findings, it appears that the system is likely overdesigned for the current conditions. The treated
water from both air strippers has routinely been non-detect for VOCs, and there is likely room to decrease
the air flow rate to the air strippers without sacrificing treatment effectiveness. To decrease the air flow
rate and saving the associated electricity would require installation of variable frequency drives, replacing
the existing blowers with smaller units, or discontinuing operation of one of the existing air strippers.
4.3.3 VAPOR GAC
The vapor GAC units are not longer used.
4.3.4 SVE SYSTEM
The SVE system now runs for one week and is then off for three weeks. SVE-4D has the highest vapor
concentrations (as high as 61 ug/L or 61 mg/m3) when extraction is reinitiated. The vapors extracted by
SVE-4D and the other wells may be the result of VOC volatilization from groundwater (not contaminated
vadose zone soil) or from the upper till source area in the vicinity of the former building.
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4.3.5
BlOREMEDIATION SYSTEM
The as-built schematics for the bioremediation system are show in Figures 26C, 27, and 28 (see
Attachment A). The RSE-lite team has little additional information on system operation and performance
and therefore cannot comment on system performance or effectiveness.
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
ANNUAL COSTS
The project team has not provided specific cost information for this remedy, with the exception of the
costs associated with the bioremediation remedy. The RSE-lite team estimates that annual costs for P&T
operation, SVE operation, and groundwater monitoring are approximately $220,000 as described in the
following table. The values in the table for these remedy components are estimates by the RSE-lite team
based on experience and professional judgment.
Item Description
Project Management
Reporting (quarterly reports)
Routine system O&M labor
Electricity
Natural gas
Materials
Disposal
Groundwater monitoring labor
Laboratory analysis - process water and vapor
Laboratory analysis - groundwater
Non-routine maintenance
Total
Approximate Annual Cost
$18,000
$18,000
$31,200
$45,000
Unknown
Negligible
Negligible
$64,000
$4,300
$20,400
$20,000
$220,900
In addition to the above costs, the bioremediation system requires approximately $85,000 for
materials per year. Oversight and system checks are conducted as part of the routine visits for the
P&T and SVE systems
4.4.1
UTILITIES
Electricity costs are based on estimated electricity usage by the following motors:
Submersible pumps: four 3HP, two 5HP, and one 1HP
Air stripper blowers: two 25 HP
SVE blower: 10 HP
All motors with the exception of the SVE blower are assumed to operate continuously at 75% efficiency
and at 75% load. The SVE blower is assumed to operate 33% of the time. Based on these assumptions,
the total electricity usage is approximately 500,000 kWh per year. Assuming the average state electricity
rate from www.eia.gov of $0.09 per kWh, this translates to a cost of approximately $45,000 per year.
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Natural gas is used to heat the building and, as required, to have a tempered water supply available for
emergency purposes; however, insufficient information is available to the RSE-lite team to estimate
usage.
4.4.2
NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
The bioremediation materials include the microorganisms, biocatalyst, and nutrients required for one year
of operation. GAC is no longer used at the site.
4.4.3
LABOR
Labor costs for project management assume 15 hours per month at $100 per hour. Routine O&M costs
assume 8-hour visits per week at $75 per hour. Groundwater sampling assumes four wells are sampled
per day by a two-person team that costs $2,000 for labor, materials, and sampling equipment.
4.4.4
CHEMICAL ANALYSIS
Chemical analysis assumes a cost of $60 per sample for VOCs and $50 per sample for analysis of 12
metals. Trip blanks, duplicate samples, and various other quality assurance samples are included.
4.5 APPROXIMATE ENVIRONMENTAL FOOTPRINTS ASSOCIATED WITH
REMEDY
4.5.1
ENERGY, AIR EMISSIONS, AND GREENHOUSE GASES
The primary use of energy and associated emissions of greenhouse gases and criteria air pollutants is
associated with site electricity usage. Contributions from operator and sampling technician travel are
negligible, as is the operation of sampling generators and pumps. Attachment B provides the electricity
generation mix and estimated emissions associated with electricity for the electricity provider, Consumers
Energy. The following table summarizes energy usage plus emissions for the estimated 500,000 kWh of
electricity used per year at the site.
Gas Emitted
Energy usage
Carbon dioxide
Nitrogen dioxide
Sulfur dioxide
Energy Usage and Emissions
per Year
5,745 MMBtu
1,030,900 Ibs
1,360 Ibs
4,7451bs
Energy usage assumes 33% thermal efficiency at power plant and 10% loss due to
transmission and distribution
Emissions assume 500,000 kWh per year of electricity usage. Emissions due not account for
resource extraction (e.g., coal mining) or transmission losses.
Energy usage and emissions for analyzing the samples and for the production of the bioremediation
materials are unknown. However, based on a document titled U.S. Carbon Dioxide Emissions and
Intensities Over Time: A Detailed Accounting of Industries, Government and Households, April 2010,
approximately 1 Ib of CO2 is emitted per dollar of gross domestic product. In the absence of other
information, it is assumed that the laboratory and the manufacturer also have emission profiles of
approximately 1 Ib of CO2 emitted per dollar of sample cost or per dollar of material. Laboratory costs
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are approximately $25,000 per year and bioremediation materials are approximately $85,000. Based on
these values, the carbon dioxide emissions would be approximately 110,000 Ibs per year, which is
approximately 10% of the emissions associated with the electricity usage. Absent other information, it is
reasonable to assume that the energy usage and other gas emissions are similarly small compared to the
on-site electricity usage.
Without GAC treatment of the air stripper off-gas, the P&T system emits approximately 330 pounds of
PCE, a hazardous air pollutant, to the atmosphere per year. The SVE system is likely emitting
approximately 1.3 pounds of PCE to the atmosphere per year.
4.5.2 WATER RESOURCES
The primary use of water associated with the site is the extraction and treatment by the P&T system;
however, all of this water is treated and reinjected into the same aquifer such that there is no net affect on
local water resources.
4.5.3 LAND AND ECOSYSTEMS
The remedy involves use of existing infrastructure; therefore, continued O&M has very little impact on
the surrounding land and ecosystems. One nearby resident has complained about noise from the air
stripper and rumbling underfoot when the pumps operate to transmit effluent to the discharge lagoons.
4.5.4 MATERIALS USAGE AND WASTE DISPOSAL
With the exception of the bioremediation reagents, materials are not used at the site because GAC is no
longer used at the site. No appreciable waste is generated for disposal except for materials (e.g., tubing
and personal protection equipment) associated with groundwater sampling.
4.6 RECURRING PROBLEMS OR ISSUES
No recurring problems or issues were reported by the site team.
4.7 REGULATORY COMPLIANCE
The treatment systems routinely comply with the air permits. The P&T system routinely achieves
undetectable VOC concentrations at the air stripper effluent.
4.8 SAFETY RECORD
No health and safety issues were identified during the RSE-lite conference call.
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
Some residences located immediately west of Oakland Drive still utilize water supply wells on their
property. Local residents west of Oakland Drive were given the option to tie into a water supply system
paid for by the former owner (deceased) of the site. Those that did not opt to connect are participating in
a well sampling program, and the site team reports that there are no VOCs detected in those wells. PCE is
likely discharging to the Middle Branch of the Pere Marquette River. The site team reports evaluating
river sediments and water quality during the remedial investigation, and the Five Year Review reports that
no VOCs were detected in surface water. However, concentrations at the MW-306 and MW-307 clusters
exceed the state groundwater-surface interface (GSI) criteria of 45 ug/L for PCE, and no other monitoring
locations are present (or practical to install) between these clusters and the river. The exceedance of the
screening criteria suggests the need to revisit a GSI evaluation; however, the remediation of the
contamination between MW-306/MW-307 and the river would be difficult given the terrain.
Furthermore, the majority of the contamination in this area may migrate and discharge to the river and be
flushed with clean water before an appropriate remedy could be conceived, designed, and installed. As a
result, the RSE-lite team suggests focusing efforts on containing and remediating plume south of these
points so that any future discharges of PCE to surface water can be mitigated or avoided.
5.2 SURFACE WATER
Please refer to Section 5.1.
5.3 AIR
PCE is emitted directly to the air within compliance limits, and preliminary air modeling by the RSE-lite
team indicates that this emission rate would not result in an appreciable increased risk to human health.
Soil vapor concentrations measured in the SVE wells is sufficiently high to be concerned about vapor
intrusion into the neighboring restaurant. The use of the SVE system likely mitigates the potential for the
problem, but additional evaluation may be warranted.
5.4 SOIL
Site surface soils have been remediated or the exposure pathway has been eliminated. Subsurface soils
may continue to be impacting groundwater.
5.5 WETLANDS AND SEDIMENTS
Please refer to Section 5.1.
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6.0 RECOMMENDATIONS
Cost estimates provided herein have levels of certainty comparable to those done for CERCLA Feasibility
Studies (-30%/+50%), and these cost estimates have been prepared in a manner generally consistent with
EPA 540-R-00-002, A Guide to Developing and Documenting Cost Estimates During the Feasibility
Study, July, 2000. The costs presented do not include potential costs associated with community or public
relations activities that may be conducted prior to field activities. The costs and sustainability impacts of
these recommendations are summarized in Tables 6-1 and 6-2.
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS
6.1.1 SAMPLE P&T DISCHARGE AND RESIDENTIAL WELLS FOR LEAD
Groundwater containing elevated metals has historically and may continue to be extracted by the P&T
system. The site team should sample the extraction wells and P&T system discharge for appropriate
metals to determine if impacted water is extracted and is being discharged to the subsurface at
concentrations that exceed standards. The RSE-lite team anticipates that lead concentrations from EW-1
and EW-4 are likely higher than those from the other well locations. This sampling should likely
continue quarterly for one year and the data evaluated to determine if further monitoring or additional
considerations are merited. The site team should also sample residential wells for lead along with VOCs
during each sampling event. The cost for implementing this recommendation is relatively small (e.g.,
under $1,000) because all locations are already sampled for VOCs and laboratory analysis for lead is
relatively inexpensive.
6.1.2 COMPLETE INSTITUTIONAL CONTROLS
The site team indicated there are on-going efforts to evaluate institutional controls necessary to prevent
human exposure to contaminated groundwater. The RSE-lite team recommends that these efforts
continue and that institutional controls be put in place to restrict the use of groundwater that would result
in human exposure or spreading the plume.
6.1.3 JET EW-5 AND MEASURE/TRACK EXTRACTION WELL SPECIFIC CAPACITY
The site team has experienced fouling in the extraction wells, particularly EW-5. Rehabilitation efforts
improved pumping conditions at the wells, but EW-5 reportedly continues to pump less than intended.
The RSE-lite team recommends that the site team pressure jet the EW-5 extraction screen to further
rehabilitate the well. In addition, the site team should measure specific capacity of EW-5 on a quarterly
basis. This involves dividing the extraction rate by the amount of drawdown caused by pumping. The
site team could use a representative static water level measurement (e.g., 789 feet AMSL) and hold it
constant on a move forward basis, measure the water level quarterly during pumping, and divide the
extraction rate by the difference between the selected static water level and the pumping water level. A
consistently decreasing specific capacity indicates well fouling is occurring and that well maintenance
measures are appropriate. This proposed method of measuring specific capacity will result in some
variation as the regional water level rises and falls with the season, but the approach should still provide
an early warning as to when well maintenance is required. The RSE-lite team estimates that pressure
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jetting might cost on the order of $5,000 for one well, which is significantly smaller than abandoning the
well, installing a replacement well, and connecting the replacement well to system piping. Measuring and
tracking the specific capacity should not appreciably impact management and reporting costs.
6.1.4 EVALUATE AND MANAGE SOIL VAPORS
The RSE-lite team believes that the SVE system likely addresses the shallow (e.g., less than 30 feet below
ground surface) soil contamination. Any persistent soil vapor contamination is likely due to volatilization
of VOCs from the contaminated groundwater and/or from the upper till source area. Therefore, the RSE
team believes that the only reason to operate the SVE system is to mitigate vapor intrusion to the adjacent
restaurant, which is immediately north of the building property, and to the hotel immediately south of the
site. The RSE-lite team recommends sampling indoor air at the restaurant and any other building within
100 feet of the source area for VOCs under the current operational program for the SVE system (i.e., 1
week on and two weeks off). If the results indicate indoor air impacts, the site team will need to address
them by either increasing the operational frequency of the SVE system or potentially using vapor
mitigation systems for the affected buildings. If the results indicate no indoor air impacts, the RSE-lite
team suggests discontinuing the SVE system and sampling indoor air again on a monthly basis to
determine if indoor air becomes impacted. If indoor air is not impacted over a pre-determined period
(e.g., 6 months), then the SVE system can remain off and the sampling could be eliminated or reduced in
frequency (e.g., quarterly). The cost for 7 sampling events (including labor, and two summa canister
samples per event) would likely be approximately $10,000. If the SVE system remains off for 6 months
instead of operating at its current frequency, this cost of $10,000 would be partially offset by
approximately $1,000 in savings. Future savings from not operating the SVE system would be
approximately $2,000 per year from reduced electricity usage plus additional savings from reduce O&M
parts and labor.
6.2 RECOMMENDATIONS TO REDUCE COSTS
6.2.1 CONSIDER DISCONTINUING PUMPING FROM EW-4
EW-l appears to have successfully captured much of the contamination that would migrate to EW-4, and
the VOC concentrations at EW-4 and nearby MW-301S and MW-301D are routinely below standards.
The RSE-lite team suggests discontinuing pumping from EW-4 because it is extracting water that already
meets standards. Discontinuing pumping from EW-4 may also help ease the stagnation zone that is
inhibiting flushing of the contamination in the vicinity of the MW-307 cluster. The RSE-lite team
estimates that this will reduce electricity usage by 20,000 kWh per year and may reduce the electricity bill
by approximately $1,800 per year. The well can continue to be sampled along with the other extraction
wells to confirm concentrations in EW-4 remain below standards.
6.2.2 REDUCE METALS ANALYSIS
The site team analyzes samples annually for 12 metals, but only lead appears to continue to impact water
quality. The RSE-lite team suggests eliminating the metals analysis for the other 11 metals if a cost
savings can be realized. The RSE-lite team estimates that approximately $2,500 per year might be saved
by implementing this recommendation plus potential additional savings resulting from reduced data
management requirements.
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6.2.3 RECONFIGURE AIR STRIPPERS AND POSSIBLY RESIZE AIR STRIPPER BLOWERS
The air strippers are overdesigned for the current application. Vendor software for the air strippers
suggests that one air stripper with 7 trays can treat 200 gpm at 500 ug/L and a factor of safety of 2.0 to
non-detect effluent standards. The treatment plant, however, operates two of these air strippers. The
RSE-lite team recommends sending all extracted water to one of the air strippers in a phased approach to
confirm that one air stripper can provide the necessary level of treatment.
In addition, the current blowers were sized assuming the vapor GAC vessels and associated ducting
would be used and are not optimally configured for current operation. The site team should contact
Carbonair (the air stripper manufacturer) or New York Blower (the blower manufacturer) to determine the
costs and savings of purchasing a new appropriately sized blower with the GAC vessels bypassed and
process ducting reduced accordingly.
Assuming the same blower is used, the RSE-lite team estimates that operating one air stripper will reduce
electricity usage by approximately 164,000 kWh per year and reduce electricity costs by approximately
almost $15,000 per year. Additional savings could be realized if the blower is replaced or a variable
frequency drive is used. If the pressure can be reduced to 45 inches of water by removing the GAC
vessels and some ducting, electricity usage might be further reduced by 50,000 kWh per year for
additional annual savings of $4,500 per year. An initial investment to make the modification will be
required. The site team should consider all of the recommendations in this report, including the
implications of additional source area investigation and remediation (see Section 6.4), before investing in
different equipment for the air strippers.
6.2.4 MODIFY GROUNDWATER MONITORING PROGRAM
During the RSE-lite conference call, the site team stated that it was sampling a robust number of wells
semi-annually for VOCs for a few years to obtain a comprehensive data set, and would then reduce the
number of sampling locations and/or frequency as appropriate. The RSE-lite team provides for
consideration by the site team the following suggested groundwater monitoring program for VOCs and
lead.
Evaluate Capture Along East Pathway
Sample the following wells semi-annually to track the progress of remediation downgradient of the source
area as a result of source area remediation via bioremediation and/or capture by EW-7. A semi-annual
frequency is selected because the RSE-lite team estimates that the seepage velocity may be higher than
200 feet per year and decreases in PCE concentrations in this area downgradient of the source area may
occur relatively quickly once the source is remediated or controlled.
MW-4
MW-309S
MW-309D
MW-3S
MW-3D
Sample the following wells annually to track progress of aquifer restoration downgradient of EW-5 and
EW-6. This frequency is chosen because the wells are relatively far downgradient of the source area.
Changes in concentration as a result of source area remediation or control will happen slower, and
contaminant flushing of this area may be slowed due to the pumping of EW-5 and EW-6.
MW-305S
22
-------
MW-305I
MW-305D
MW-306S
MW-306I
MW-306D
Sample the following wells for performance monitoring of the bioremediation system or other source are
remediation attempts. Thereafter, sample annually to track progress of aquifer restoration. If
concentration declines are slow and restoration is expected to take many years, consider extending the
sampling frequency to every two years as long as the contamination is captured by EW-2, EW-3 and/or
EW-7.
MW-101S
MW-101D
MW-401S
MW-401D
MW-402S
MW-403S
MW-403I
Sample the following wells every two years to keep track of remedy progress. The reason for the
suggested frequency reduction is provided:
MW-213S because it is within the capture zone of EW-7
MW-213D because it is within the capture zone of EW-7
MW-303 because it is within the capture zone of EW-6
Note that sampling at MW-304S, MW-304I, MW-304D, and MW-105 would no longer occur because
they historically were not contaminated and continue to not be contaminated.
Evaluate Capture, Contaminant Migration, and Aquifer Restoration Along Mid Pathway
Sample the following wells semi-annually to evaluate capture of the potential Mid Pathway source and
efforts to remediate that source. A semi-annual frequency is selected because the RSE-lite team estimates
that the seepage velocity may be higher than 200 feet per year and decreases in PCE concentrations in this
area downgradient of the source area may occur relatively quickly once the source is remediated or
controlled.
MW-205S
MW-205D
MW-206S
MW-206D
MW-207S
MW-207D
MW-308S
MW-308D
Note that sampling at MW-102S, MW-102D, MW-202S, MW-202I, and MW-202D would no longer
occur because they historically were not contaminated and continue to not be contaminated.
23
-------
Evaluate Capture, Contaminant Migration, and Aquifer Restoration Along West Pathway
Sample the following wells semi-annually for the first two years following the shutdown of EW-4 to see
how PCE concentrations change at each location. If concentrations increase at some locations, revisit the
site conceptual model and consider various alternatives for achieving restoration. If the wells remain
clean or cleanup, take steps to demonstrate attainment of aquifer restoration goals for this part of the
aquifer.
MW-103
MW-104
MW-212S
MW-212D
MW-215
MW-301S
MW-301D
MW-307S
MW-307I
MW-307D
Sample MW-2D every two years as long as EW-1 is operating at the same rate because it is within the
capture zone of EW-1. If source area remediation is considered for the lagoon area, increase the
frequency to semi-annual to monitor the effects of source area remediation.
Note that sampling at MW-204S, MW-204D, MW-21 IS, MW-21 ID, and MW-201 would no longer
occur because they historically were not contaminated and continue to not be contaminated.
Once the bioremediation performance monitoring has been completed, the above program would involve
23 samples semi-annually, and 6 to 13 samples annually, and 4 to 11 samples every two years. The RSE-
lite team estimates that this might reduce sampling costs to between by $26,000 and $31,500 for a cost
reduction of approximately $32,500 to $38,000 per year. Laboratory costs for VOCs would be reduced
by approximately $6,000.
6.3 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT
6.3.1 PREPARE AN ANNUAL REPORT
The site consultant should prepare an annual report that documents the site conceptual model and
evaluates concentration trends and water level measurements against this conceptual model. The
effectiveness of plume capture, progress toward aquifer restoration, and changes to the conceptual model
should be documented. The report should also include the current and historic groundwater monitoring
data along the extraction well and blended influent data for the P&T system. The current quarterly
reports are sufficiently detailed. Rather than repeat the findings from these reports, the four quarterly
operational reports should be included as an attachment to the annual report. The RSE-lite team estimates
that approximately $10,000 is needed each year to prepare this report.
24
-------
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT
6.4.1 INVESTIGATE SOURCES IN LAGOON AREA AND PIPING TO FORMER LAGOONS
The consistent PCE concentrations at EW-1 suggest that there is a source, perhaps relatively small, that
persists in the lagoon area. As long as this source remains, EW-1 will need to continue pumping. Source
area investigation and subsequent remediation, if successful, would allow pumping from EW-1 to be
discontinued. Additionally, the RSE-lite team believes that continuing contamination at the MW-308
cluster and the increase in concentrations at the MW-207 cluster with the onset of pumping suggests there
is a source for the "Mid Pathway". This source would lie between the former Wash King Laundry
building and the former lagoons (e.g., near the current remediation building) and may have resulted from
a potential leak in the former 500-foot pipe to the lagoons. Alternatively, there may be a source in the
southern portion of the lagoons that migrates north-northeast to the east of the EW-1 capture zone.
Therefore, even if bioremediation of the source near the former Wash King Laundry building is
successful, as long as Mid Pathway source remains and is not controlled, the aquifer upgradient of EW-5
and EW-6 will remain contaminated and EW-5 and EW-6 will need to continue to operate.
The RSE team recommends that the site team review historic documents and data to determine those
potential areas and depths that were not investigated and to use the information from this review and the
migration pathways discussed in this RSE report to develop a direct-push investigation to identify the
sources of the West Pathway and Mid Pathway. Once the source is identified, the site team can evaluate
the need for further characterization and remediation options. The RSE-lite team suggests a phased
approach to identifying and characterizing these source areas.
The first phase would involve installing three monitoring wells to a depth of approximately 60 to 70 feet
below ground surface with soil samples collected every 10 feet. One monitoring well would be
immediately north (e.g., 10 feet north) of the location of the former discharge lagoon shown on Figure 2-5
of the 1995 Technical Memorandum Predesign Field Investigations. Another well would be installed
near the current treatment building in a direct line between the new monitoring well just described and the
MW-308 cluster. The third well would be installed midway between the former Wash King Laundry
Facility and MW-2D. These three wells, along with D-1A, D-1B, D-1C, and MW-2D would be sampled
once, and all of these wells plus MW-215, MW-207S/D, and MW-401I/D would be gauged twice. One
gauging event should be conducted with EW-1 pumping and the other one should be conducted several
days after EW-1 has been temporarily shut down to provide water level information under pumping and
non-pumping conditions. The PCE results and the water levels would be used to better understand
groundwater flow in this part of the site and to try to identify the path of the plume core from this source
area.
Based on these results, the site team could use direct-push to collect soil samples at several locations from
as deep as the rig will allow. Based on experience, site team suggests this is approximately 25 feet below
ground surface, and the RSE-lite team hopes that this corresponds to at least the upper several feet of the
till. This phase could involve approximately three days of soil sampling to depths of approximately 25
feet below ground surface, which should translate to approximately 20 locations. These locations should
coincide with the areas of the each of the former discharge locations (particularly the southernmost ones)
and a several locations along the former discharge pipe near the existing treatment plant building. This
phase should help identify where PCE contamination migrated downward into the till.
A third, phase would involve additional borings and discrete soil sampling based on the findings from the
earlier phases. The site team will likely need to use hollow stem auger drilling to obtain deeper soil
samples and groundwater samples. The locations would be based on the results from the first two phases,
25
-------
but the RSE-lite team estimates that sampling may be taken at up to 5 locations, with samples from
several depth intervals from 30 feet to 80 feet. This should provide enough information to identify the
source, but additional characterization at a later date may be needed prior to design of a source area
remedy.
These three phases of investigation, or a similarly dynamic work plan for characterization, should help the
site team identify the source and provide sufficient characterization to consider various, viable remedial
options. The RSE-lite team estimates that this investigation may cost of approximately $100,000 to
develop the plan, implement the plan, and report the results and conclusions. This cost is based on the
following approximate values:
$15,000 for plan development (including review of historic documents)
$25,000 for the first three monitoring wells, including one round of sampling and two rounds of
gauging
$15,000 for the direct-push borings
$30,000 for the deeper borings
$15,000 to analyze and report results
6.4.2 DEVELOP AN EXIT STRATEGY
The site team has already made important additions to the site remedy, including the installation of EW-3
and EW-7, and the source area bioremediation system. These two components have not been operating
for long enough for the RSE-lite team to comment on their performance. Nevertheless, the RSE-lite team
believes they are important steps in attempting to reach site closure. The site team should develop an exit
strategy that documents a path forward for sequentially ending active remediation, delisting the site, and
closing the site.
If EW-7 is successful at controlling the source for the East Pathway or the bioremediation system is
successful at remediating that source, then much of the aquifer between that source and EW-5 and EW-6
will begin to cleanup. It may only take a few years to see substantial results. However, the RSE-lite team
believes that identification and either control or remediation of the source for the Mid Pathway will also
be needed to reach aquifer restoration of the area upgradient of EW-5 and EW-6 and to allow pumping
from EW-5 and EW-6 to be discontinued. The RSE-lite team already believes that pumping from EW-4
can be discontinued.
The above-mentioned investigation (if funded and implemented) should identify the source(s) for the
West and Mid Pathway(s). Design and implementation of the remedial options for these pathways should
be postponed until after the effectiveness of the current bioremediation efforts have been evaluated. If
bioremediation has been successful or will be successful at removing the source near the former Wash
King Laundry building, then the P&T system will no longer be needed for the East Pathway and a source
area remedy should likely be attempted for the lagoon/piping source areas so that P&T can be
discontinued altogether. If the bioremediation remedy is not or will not be successful, then the sit team
will either need to consider alternative source area remedial approaches or continue with P&T as a
containment remedy for all contaminant pathways. If the P&T system will need to continue operating to
contain the source near the former Wash King Laundry facility, then using the P&T system to control the
West and Mid Pathways would likely be more cost effective than aggressively remediating them.
The exit strategy should be developed after the investigation of the sources for the West and Mid
Pathways and after the conclusion of the initially scoped bioremediation system. These additional points
26
-------
of information will allow the site team to make practical decisions regarding source area remediation.
The RSE-lite team estimates that development of the exit strategy for this site will cost approximately
$10,000 total for a draft and final document.
6.5 RECOMMENDATIONS FOR ADDITIONAL GREEN PRACTICES
6.5.1 USE DEDICATED TUBING
The site team currently uses new polyethylene tubing for each sampling event. Although this is relative
cost-effective due to the relatively low price of polyethylene tubing, it involves use of materials and
disposal of materials that could otherwise be reused. The RSE-lite team suggests that sampling be
conducted with dedicated tubing for each well. Once the sampling is completed for a particular well, the
tubing could be left in the well for the next sampling event. If dedicated tubing is used, the site team
should consider using Teflon-lined tubing. The cost impacts of this recommendation are minor, but it
should avoid the use and disposal of over 6,000 feet of polyethylene tubing each year.
6.5.2 CONSIDERATIONS FOR RENEWABLE ENERGY AT THE SITE
The current remedy is electricity intensive, and the remedy footprint could be substantially reduced by
using renewable energy. However, the site team has invested in a bioremediation remedy, and the RSE-
lite team encourages source investigation and remediation to hopefully end or significantly reduce the
operation of the P&T system. Given this new direction, the RSE-lite team does not encourage
consideration and investment into a renewable energy system for the site. If the site team chooses to
reduce the remedy footprint through the use of renewable energy, it could consider green power
purchasing through the local utility (if available) or through the purchase of renewable energy certificates.
Green power purchasing would increase costs by approximately $0.03 per kWh, but would avoid
significant capital costs for renewable energy system design and installation.
27
-------
Table 6-1. Cost Summary Table
Recommendation
6.1.1 S AMPLE P&T
DISCHARGE AND
RESIDENTIAL WELLS FOR
LEAD
6.1.2 COMPLETE
INSTITUTIONAL CONTROLS
6.1.3 JETEW-5AND
MEASURE/TRACK
EXTRACTION WELL SPECIFIC
CAPACITY
6.1.4 EVALUATE AND
MANAGE SOIL VAPORS
6.2.1 CONSIDER
DISCONTINUING PUMPING
FROMEW-4
6.2.2 REDUCE METALS
ANALYSIS
6.2.3 RECONFIGURE AIR
STRIPPERS AND POSSIBLY
RESIZE AIR STRIPPER
BLOWERS
6.2.4 MODIFY
GROUNDWATER
MONITORING PROGRAM
6.3.1 PREPARE AN ANNUAL
REPORT
6.4.1 INVESTIGATE
SOURCES IN LAGOON AREA
AND PIPING TO FORMER
LAGOONS
Reason
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Cost Reduction
Cost Reduction
Cost Reduction
Cost Reduction
Technical
Improvement
Site Closeout
Additional
Capital
Costs ($)
$200
Not provided
$5,000
$9,000
$0
$0
$0
$0
$0
$100,000
Estimated
Change in
Annual Costs
($/yr)
$0
$0
$0
($2,000)
($1,800)
($2,500)
($15,000)
($38,500)
To
($44,000)
$10,000
Estimated
Change in
Life-Cycle
Costs
S*
$200
$0
$5,000
($51,000)
($54,000)
($75,000)
($450,000)
($1,155,000)
To
($,320,000)
$300,000
Discounted
Estimated
Change in
Life-Cycle
Costs
S**
$200
$0
$5,000
($30,200)
($38,300)
($49,000)
($294,000)
($754,600)
To
($862,400)
$196,000
Not quantified
-------
Recommendation
Reason
Additional
Capital
Costs ($)
Estimated
Change in
Annual Costs
($/yr)
Estimated
Change in
Life-Cycle
Costs
Discounted
Estimated
Change in
Life-Cycle
Costs
6.4.2 DEVELOP AN EXIT
STRATEGY
Site Closeout
$10,000
Not quantified
6.5.1 USE DEDICATED
TUBING
Green Practice
Negligible
6.5.2 CONSIDERATIONS
FOR RENEWABLE ENERGY
AT THE SITE
Green Practice
Not quantified
Costs in parentheses imply cost reductions
* assumes 30 years of operation with a discount rate of 0% (i.e., no discounting)
**
assumes 30 years of operation with a discount rate of'.
-------
Table 6-2. Green Remediation Summary Table
Recommendation
6.1.1 SAMPLE P&T DISCHARGE
AND RESIDENTIAL WELLS FOR LEAD
6.1.2 COMPLETE INSTITUTIONAL
CONTROLS
6.1.3 JETEW-5AND
MEASURE/TRACK EXTRACTION
WELL SPECIFIC CAPACITY
6.1.4 EVALUATE AND MANAGE
SOIL VAPORS
6.2.1 CONSIDER DISCONTINUING
PUMPING FROM EW-4
6.2.2 REDUCE METALS ANALYSIS
6.2.3 RECONFIGURE AIR STRIPPERS
AND POSSIBLY RESIZE AIR STRIPPER
BLOWERS
6.2.4 MODIFY GROUNDWATER
MONITORING PROGRAM
6.3.1 PREPARE AN ANNUAL
REPORT
Reason
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Cost Reduction
Cost Reduction
Cost Reduction
Cost Reduction
Technical
Improvement
Green Remediation Effects
Negligible increases or decreases in
remedy footprint
Negligible increases or decreases in
remedy footprint
Negligible increases or decreases in
remedy footprint
Potential to reduce electricity usage
and associated emissions by
approximately 22,000 kWh per year
Potential to reduce electricity usage
and associated emissions by
approximately 20,000 kWh per year
Reduction in energy and materials
usage by laboratory associated with
sample analysis
Potential to reduce electricity usage
and associated emissions by
approximately 164,000 to 214,000
kWh per year.
Reduction in energy and materials
usage by laboratory associated with
sample analysis. Small reductions in
energy and emissions associated
with less technician travel and less
small generator use for sampling.
Negligible increases or decreases in
remedy footprint
-------
Recommendation
6.4. 1 INVESTIGATE SOURCES IN
LAGOON AREA AND PIPING TO
FORMER LAGOONS
6.4.2 DEVELOP AN EXIT STRATEGY
6.5.1 USE DEDICATED TUBING
6.5.2 CONSIDERATIONS FOR
RENEWABLE ENERGY AT THE SITE
Reason
Site Closeout
Site Closeout
Green Practice
Green Practice
Green Remediation Effects
Increases in footprint associated with
on-site diesel usage for direct-push
rig operation plus energy and
materials associated with laboratory
analysis. Substantial life-cycle
remedy footprint decreases
associated with decreased P&T
operation if source can be found and
remediated in a timely manner.
Negligible increases or decreases in
remedy footprint
Potential to eliminate use and
disposal of 6,400 feet of
polyethylene tubing each year.
Use of renewable energy could
reduce remedy emissions footprints
by approximately 90% due to the
electricity intensive nature of the
remedy.
-------
ATTACHMENT A
FIGURES FROM EXISTING REPORTS
-------
-------
-------
NORTH
GW FLOW
LEVATION
Ft. USGS
g
OO ffl
ts s
IV .«.-./.. ,....7^
---
N..TI . .1 . \-' V
T-S: -TV"?
Graved SA/VD & GRAVEL
MEDIUM
SAND
'i;-r.V'..i.
w/Coarser ...
Sand & Tr...
.
MEDIUM
MEDIUM
V... CLAY- -:.
PCE=19
(12/17/09)
':?-"_w/ Random
''' °Gravel
w/Gravel \ "'
ALL VOCs =
MEDIUM
SAND
VS/LTY
CMY
.. MYERS
CROSS SECTION
Nl - SI
Based on the cumulative historical soil boring logs, the predominant and/or average grain size
description for the fluvial deposits is "Medium Sand". Lesser amounts of Silt, Fine and Coarse
Sand, and Gravel were also described as being present at random depths and locations, as
clarified in smaller print Discrete low permeability layers (i.e. Clays, Silts, Very Fine Sands, or
poorly sorted mixtures thereof [e.g. Fine-Grained Tills]), layers of Coarse Sand and Gravel, and
in some cases Fine Sand, are mapped as distinct units.
SCALES:
HORIZONTAL
VERTICAL
r=120'
l"=20f
LAKESHORE
ENVIRONMENTAIL, INC
PCE ISOCONCENTRAT1OW 8(10/27/09)
CROSS SECTION Nl -SI
WASH K.INO LAUNDRY
9247 S. M-37
BALDWIN. MICHIGAN _
06-712-01
FEBRUARY 2010
FIGURE 15 B
-------
NORTH
ELEVATION -
Ft. USGS ft,
GW FLOW
cs _
o oo Csl
cscs
MED - CRS SAWD
1V/GRAVEL
S/L7Y V.F. TO FINE
SAND TILL
MEDILitil
SILTY/ GRAVELLY
SILT TILL
VppE= f-;}' ;.: ipt.F^itV^'ni
:.. :.T.Q'FINE:.
; :G.KAV.EL.;
SILTY/GRAVELLY V.F
TO FINE SAND TILL
(w/ Wet Sandy Seams)
FINE; SAND"... '
SLIGHTLY SILTY/
GRAVELLY V.F. TO
FINE SAND TILL
1000
SILTY V.F. TO
FINE SAND TILL
PCE=18
;&^/y^::JS£3
F'IN'E's'ANb\ *
MEDIUM
'-. "-... S.ILTy./-CLA-YJEY..
..: ..'':.-' "-VJFto
BS.AND'-. : '-.-..
SILTY/CLAYEY
FINE SAND
FINE SAND
w/ some Gravel
720
SANDY/FINE GRAVELY
SILT TILL
-PCE^KD
PCE=2.5
PCE=32
SLIGHTLY
SANDY/GRAVEL
FINE SILT TILL
SILTY FINE SAND
WITH GRAVEL
PCE= 1,900
(12/17/09)
CROSS SECTION
N2 - S2
'CLAYEYS/LT/V
(with till textured seam
PCE ISOCONCENTRATIONS (10-27-09
CROSS SECTION N2-S2
LAKESHORE
ENVIRONMENTAL, INC.
WASH KING LAUNDRY
9247 S. M-37
BALDWIN, MICHIGAN
HORIZONTAL 1"=120'
VERTICAL r=20f
Based on the cumulative historical soil boring logs, the predominant and/or average grain size
description for the fluvial deposits is "Medium Sand". Lesser amounts of Silt, Fine and Coarse
Sand, and Gravel were also described as being present at random depths and locations, as clarified
in smaller print. Discrete low permeability layers (i.e. Clays, Silts, Very Fine Sands, or poorly
sorted mixtures thereof [e.g. Fine-Grained Tills]), layers of Coarse Sand and Gravel, and in some
cases Fine Sand, are mapped as distinct units.
-------
It
£
ELEVATION
Ft. USGS
S3
820-
800
SILTY V.F. TO FINE
SAND TILL
(w/ Wet Sandy Seams)
SILTY FINE SAND
780
S/L7Y/ GRAVELLY V.F.
TO FINE SAND TILL
(w/ Wet Sandy Seams)
5000
JQOQ160.
SLIGHTLY SILTY/-
GRAVELLY V.F. TO CjQO.
FINE SAND TILL
FINE SAND TO
CRS. GRAVEL
PCE-1,900,
(12/17/09)
NORTH
EDIUM*
'' Sand
5-J7^> FINE SAND..
"^^^'' '
.: w/ Crs Sand
T-S/LTY CMY '
=? -' '.yf/mmor ]
COARSE SAND
& GRAVEL
-.D.'-CRS".
SAND & GRAVEL
vt//Fine Gravel ..''
..&Tr. Gravel
~l ...' ." :^rtS?
PCE=I90
2/17/09)
CROSS SECTION
N3 - S3
800
780
760
740
720
jj; Based on the cumulative historical soil boring logs, the predominant and/or average grain size
description for the fluvial deposits is "Medium Sand". Lesser amounts of Silt, Fine and Coarse
Sand, and Gravel were also described as being present at random depths and locations, as
clarified in smaller print. Discrete low permeability layers (i.e. Clays, Silts, Very Fine Sands,
or poorly sorted mixtures thereof [e.g. Fine-Grained Tills]), layers of Coarse Sand and Gravel,
and in some cases Fine Sand, are mapped as distinct units.
SCALES:
HORIZONTAL
VERTICAL
r=i20!
r=20f
LAKESHOEE
ENVIRONMENTAL, INC
PCE ISOCONCENTRATION (10/27/09)
CROSS SECTION N3 - S3
WASH KING LAUNDRY
9247 S. M-37
BALDWIN, MICHIGAN
1)6-712-01
FEBRUARY 20tO
FIGURE 17 B
-------
siife '''"<,-"
''''v:'s
-------
-------
-------
(I CINV1MVO
-------
-------
-------
-------
67 - INTERMEDIATE TILL FORMATION
REMEDIAL BifECTION LOCATIONS.
)2" PVCSCKEENS SET BETWEEN 32-57']
TYPICAL WELL DETAIL
GROUND LEVEL
2" THREADED
2 PVC
CROSS
DISTRIBUTION
LINES
2" PVC
INJECTION
WELL
EXISTING S.V.E.
HEADER VAULT
DISTRIBUTION
WHEEL
2" HPDE INJECTION ' " '
FROM BUILDING ,
FORMER WASH KING
LAUNDRY BUILDING
TILL ZONE REMEDIATION GRID
AND PIPING LAYOUT - AS BUILT
LAKESHORE
ENVIRONMENTAL, INC
WASH KING LAUNDRY
9247 S. M-37
BALDWIN, MICHIGAN
SCALE: 1" = 30'
NOVEMBER, 2009
-------
TREATED GROUNDWATER
DISCHARGE SUMP ^\\\\\\\\\\\\\
WATER
SUPPLY
PUMP
REACTION
I TANK I
* 1,000 I
GALLON
MIXING
TANK
« 2,000
GALLONS
TRANSFER
PUMP
\METER
INJECTION
PUMP
REMEDIATION SHED
SCHEMATIC
17
TO
HEADER
VAULT
/////////i
TO
REMEDIATION
SHED
TO INJECTION POINTS
HEADER VAULT
SCHEMATIC
MODEL 6606
HYDROTEK
VALVE
EXISTING
CONCRETE
SVE VAULT
NOT TO SCALE
LAKESHORE
ENVIRONMENTAL, INC.
IN-SITU BIO-REMEDIATION
SYSTEM SCHEMATIC
WASH KING LAUNDRY
9247 S. M-37
BALDWIN, MICHIGAN
JULY, 2009
06-712-01
FIGURE 27
-------
CATALYST WATER
(2" P.V.C.) -
GRAVITY FLOW
CATALYST
DOSING UNIT
(110 V)-TIMER
CATALYST REACTOR
(60 GALLON) ON
ELEVATED STAND.
SOURCE WATER
(1" P.V.C.)
SOURCE WATER
FILL PUMP
(1 AMP- 115V)-
SWITCHED BY FLOAT
IN MAIN TANK -
HIGH=OFF.
RAISED
CONCRETE
FLOOR,
TYP.
EXISTING GROUNDWATER
PUMP & TREAT
SYSTEM STRIPPERS
LEGEND
<8> MANUAL VALVE
4 FLOW DIRECTION
4000 GALLON P.E.
DOSING TANK
CATALYST
RECIRCULATION LINE
(2" P.V.C.) -
TO TOP OF TANK
MICROBE MIXING BARREL
3/4" GARDEN HOSE
LINE OUT
(2" P.V.C.) -
FROM SIDE OF TANK
INJECTOR PUMP
(3/4 HP- 10-115/230 V)
SWITCHED BY FLOAT -
HIGH= ON.
INJECTION SYSTEM
CONTROL PANEL
FLOW METER
(GALLONS)
SOLENOID VALVE
(12V) POWER
SWITCHED BY FLOAT -
HIGH=OPEN.
BACKFLOW
PREVENTER
GAUGE (P.S.I.)
INJECTION LINE
(2" P.V.C.) -
TO HEADER VAULT
LAKESHORE
ENVIRONMENTAL, INC.
NOT TO SCALE
IN-SITU BIO-REMEDIATION
SYSTEM AS-BUILT
WASH KING LAUNDRY
9247 S. M-37
BALDWIN, MICHIGAN
FEBRUARY, 2010
06-712-01
FIGURE 28
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ATTACHMENT B
ELECTRICITY GENERATION MIX AND EMISSIONS
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Projected Environmental Characteristics of Consumers Energy Electricity
OCTOBER 1,2006 - SEPTEMBER 30,2007
Fuel mix used to generate
total electricity supplied
by Consumers Energy
57.4%
20.5%
16.7%
0.3%
1.5%
0%
<0.1%
0%
0.9%
Regional* average
fuel mix used to
generate electricity
70.0%
23.3%
4.7%
0.4%
0.7%
0%
<0.1%
0%
0.3%
Fuel source
Coal
Nuclear
Gas
Oil
Hydroelectric
Biofuel
Biomass P)
Solar
Solid Waste Incineration
Wind (2)
Wood
Other (3)
Emissions/waste
in pounds per
megawatt-hour
Sulfur Dioxide
Carbon Dioxide
Oxides of Nitrogen
High-level Nuclear Waste W
During the reporting period, Consumers Energy purchased 24.3 percent of the electricity it supplied from other
suppliers. The fuel mix used to generate this purchased electricity could not be discerned; regional average
fuel mix data was used in this table to approximate the actual fuel mix of purchased electricity. The method for
calculating emissions at the company level has changed. The emissions associated with some of the purchased
power is now included.
Please note: Numbers do not add to 100 percent due to rounding.
* Regional average fuel mix data was compiled from Michigan, Illinois, Indiana, Ohio and Wisconsin.
(1) The high-level waste generated by the Palisades Nuclear Plant is not discharged to the environment.
(2) This energy type is provided in part at the request of customers who voluntarily have agreed to pay addi-
tional costs to increase the amount of renewable and environmentally friendly energy the company provides.
(3) "Other" fuel source is the Ludington Pumped Storage Plant.
Solid Waste
Hydro
Oil
/- Biomass121
/AWind(2)
/rWood
/VOther'31
Nuclear
Coal
2.8%
Consumers Energy's
emissions/waste
for fossil/nuclear
generation
9.49
2,061.8
2.72
0.0069
0.5%
0%
Regional* average
emissions/waste
for fossil/nuclear
generation
11.56
2,132.5
3.32
0.0083
Percentage of fuel type used to
produce Consumers Energy's
total electricity
Biomass^ r Solid Waste
Hyt4fWMd
Poo ^NW/
\ |M
Nuclear
!
Coal
Regional* average fuel mix used
to generate electricity
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