Remediation of the Ruddiman
Creek Main Branch and Pond
Muskegon County, Michigan

Great Lakes Legacy Act Program
March 2011
AEPA
       U.S. Environmental Protection Agency
       Great Lakes National Program Office
       77 West Jackson Boulevard
       Chicago, IL 60604-3511
Michigan Department of Natural Resources
and Environment
525 West Allegan Street
Lansing, Ml 48909-7973

-------

-------
U.S. Environmental Protection Agency
 Great Lakes National Program Office
    77 West Jackson Boulevard
    Chicago, Illinois 60604-3511

-------

-------
Remediation of the Ruddiman Creek Main
              Branch and Pond
        Muskegon County, Michigan

       Great Lakes Legacy Program
                    Prepared for:
           U.S. Environmental Protection Agency
             Great Lakes National Program Office
                77 West Jackson Boulevard
                Chicago, Illinois 60604-3511
   Michigan Department of Natural Resources and Environment
                   Water Division
                   Constitution Hall
                  South Tower, 2nd Floor
                 525 West Allegan Street
                 Lansing, Michigan 48933
                    March 2011

-------

-------
                                                              ACKNOWLEDGMENTS
ACKNOWLEDGMENTS
This document was prepared under the direction of Marc Tuchman, Project Manager,
EPA Great Lakes National Program Office and Mike Alexander, Project Manager,
Michigan Department of Natural Resources and Environment; Susan Boehme, Coastal
Sediment Specialist, Illinois/Indiana Sea Grant College Program; and Louis Blume, Work
Assignment and Quality Assurance Manager, EPA Great Lakes National Program Office.
The report was prepared by Judith Schofield, Molly Middlebrook Amos, Reina Downing,
Ken Miller, Harry McCarty, Rex Bryan, and Elizabeth Benjamin of Computer Sciences
Corporation, under EPA Contract Number EP-W-06-046. Significant portions of the text
in this report are based on the information in the project report by Environmental Quality
Management, Inc., titled Remediation of the Ruddiman Creek Main Branch and Pond,
Muskegon, Michigan,  September 2006.

The Ruddiman Creek Main Branch and Pond Remediation Project was accomplished
through the efforts of several project partners. Marc Tuchman, Project Manager, EPA
Great Lakes National Program Office and Michael Alexander, Project Manager, Michigan
Department of Natural Resources and Environment wish to acknowledge the assistance
of the Muskegon Lake Watershed Partnership for the Muskegon Lake Area of Concern
and several other local organizations who played an active and key role in all aspects of
the  project and were strong advocates for their community.
March 2011

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
                                                                        March 2011

-------
                                                              TABLE OF CONTENTS
TABLE OF CONTENTS
ACKNOWLEDGMENTS	i

LIST OF ACRONYMS AND ABBREVIATIONS	ix

EXECUTIVE SUMMARY	xi

1.0 PROJECT DESCRIPTION	1
    1.1  General Site Description	2
    1.2  Site History	4
    1.3  Project Objectives	7
    1.4  Project Funding	8
    1.5  Project Management	9
         1.5.1   Project Planning, Training, and Permits	9
         1.5.2   Proj ect Communication, Roles, and Responsibilities	11
         1.5.3   Public Outreach and Community Involvement	13
    1.6  Data Management Procedures	14
         1.6.1   Data Management	14
         1.6.2   Sediment Confirmation Data	15
         1.6.3   Database	15
         1.6.4   Public Access	16
    1.7  Remedial Design and Cleanup Goals	16
         1.7.1   Remedial Design	16
         1.7.2   Cleanup Target Levels for Contaminants of Concern	17

2.0 SITE PREPARATION AND SET UP	21
    2.1  Site Survey and Resource Mobilization	21
    2.2  Work Area Delineation	21
    2.3  Site Security	23
    2.4  Site Access	23
    2.5  Construction of the Creek Dissipation, Diversion and Dewatering Systems ... 24
         2.5.1   Headwater Dissipation Structure	25
         2.5.2   Dam and Channel Diversion Systems	25
         2.5.3   Pumping Systems	27
         2.5.4   Sediment Dewatering	27
    2.6  Installation of Containment Measures and Other Structural Devices in
         RuddimanPond	28

3.0 DREDGING OPERATIONS AND DISPOSAL OF DREDGED MATERIAL	31


March 2011                                                                    iii

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
    3.1  Dredging Operations within the Ruddiman Creek Remediation Area	31
         3.1.1  Excavation Activities in Areas I, H, and G	32
         3.1.2  Excavation Activities in Areas F andE	33
         3.1.3  Excavation Activities in AreaD	34
         3.1.4  Excavation Activities in Area C	35
         3.1.5  Excavation Activities in AreaB	36
         3.1.6  Sediment Removed from Unsurveyed Areas	36
    3.2  Excavation Operations within the Ruddiman Pond Remediation Area	37
    3.3  Transport and Disposal of Contaminated Sediments	38

4.0 ENVIRONMENTAL MONITORING OF REMEDIATION ACTIVITY IMPACTS	43
    4.1  Air Monitoring	43
    4.2  Water Monitoring and Treatment	46
         4.2.1  Surface Water Monitoring	46
         4.2.2  Wastewater Monitoring and Treatment	48

5.0 SEDIMENT CONFIRMATION SAMPLING AND ANALYSIS	51
    5.1  Sediment Confirmation Sampling Design	51
         5.1.1  Technical Approach to Statistical Sampling Design	51
         5.1.2  Decision Statement	53
         5.1.3  Confirmation Sample Locations	55
         5.1.4  Data Interpretation	55
    5.2  Sampling and Analysis	56
         5.2.1  Sampling Methods	57
         5.2.2  Analytical Methods	58
    5.3  Quality of Sediment Confirmation Data	58

6.0 PROJECT RESULTS	61
    6.1  Post-Dredging Sediment Confirmation Sample Results in Ruddiman Creek
         Main Branch	61
         6.1.1  Post-Primary Dredging Sediment Sample Results for Ruddiman
               Creek	61
         6.1.2  Post-Secondary Dredging Sediment Sample Results for Ruddiman
               Creek	63
    6.2  Post-Dredging Sediment Confirmation Sample Results in Ruddiman Pond
         remediation area	63
         6.2.1  Post-Primary Dredging Sediment Sample Results for Ruddiman
               Pond	63
         6.2.2  Post-Secondary Dredging Sediment Sample Results for Ruddiman
               Pond	64
    6.3  Sediment Volume Removed	71
    6.4  Final Confirmation	71
iv                                                                     March 2011

-------
                                                            TABLE OF CONTENTS
        6.4.1  Ruddiman Creek Main Branch	72
        6.4.2  Ruddiman Pond	72

7.0 RESIDUAL COVER PLACEMENT, DEMOBILIZATION, AND RESTORATION	73
    7.1  Placement of Residual Cover	73
        7.1.1  Ruddiman Creek Main Branch	73
        7.1.2  Ruddiman Pond	74
    7.2  Demobilization	74
    7.3  Site Restoration and Environmental Enhancements	74
        7.3.1  Ruddiman Creek Main Branch	75
        7.3.2  Ruddiman Pond	75

8.0 CONCLUSIONS AND PROJECT ACCOMPLISHMENTS	77

9.0 FUTURE OF THE SITE	83

REFERENCES    	85

APPENDIX A    SUMMARY SEDIMENT CONCENTRATION DATA	87

AppENDixB     SUMMARY SEDIMENT CONCENTRATION DATA, 2004	93

APPENDIX C     RUDDIMAN CREEK MAIN BRANCH AND POND FACT SHEETS	95

APPENDIX D    RUDDIMAN CREEK MAIN BRANCH AND POND DESIGN DRAWINGS	101

List of Tables
Table 1-1    Average and Maximum Concentrations of Contaminants of Concern in
            Sediments in Ruddiman Pond and Ruddiman Creek Prior to Remediation
            and Site-Specific Target Levels	6
Table 1-2    Organizations Participating in the Ruddiman Creek and Pond Remediation
            Project	9
Table 1-3    Roles and Responsibilities of Key Governmental Project Management
            Personnel	12
Table 1-4    Primary Tasks Associated with Remediation of the Ruddiman Creek Site
            	16
Table 4-1    Air Monitoring/Sampling Activities, Parameters, Locations, Frequencies,
            and Action Levels	43
Table 4-2    Wastewater Quality Monitoring Parameters	49
Table 5-1    RMUs in Ruddiman Creek and Ruddiman Pond	52
Table 5-2    Decision Rules for Achieving Project-Specific Remediation Goals	56
Table 6-1    Summary of Mean Concentrations Observed Among All RMUs in
            Ruddiman Creek Main Branch, Post-Primary Dredge Confirmation
            Samples	62
Table 6-2    Summary of Mean Concentrations Observed Among All RMUs in
            Ruddiman Pond, Post-Primary Dredge Confirmation Samples	64
March 2011

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Table 6-3     Summary of Mean Concentrations Observed Among All RMUs in
             Ruddiman Pond, Post-Secondary Dredge Confirmation Samples	65
Table 6-4     Summary of Dredging Results by Remedial Phase for each RMU in
             Ruddiman Pond and Creek	67
Table 6-5     Volume of Sediment Removed from Ruddiman Creek and Pond, by
             Remediation Area	71
Table 8-1     Project Accomplishments and Awards	78

List of Figures
Figure 1-1    Ruddiman Creek and Pond	3
Figure 1-2    Relationship of Ruddiman Creek and Pond to Muskegon Lake and Lake
             Michigan	4
Figure 1 -3    Pre-remediation sediment total PCB concentrations at depth	6
Figure 1-4    Community discussion  of the remediation project	13
Figure 2-1    Ruddiman Creek Main  Branch RMUs B, C, D, E, and F (upstream)	22
Figure 2-2    Ruddiman Creek Main  Branch RMUs G, H, and I (downstream)	22
Figure 2-3    Ruddiman Pond RMUs	23
Figure 2-4    Timber swamp mat access road to Ruddiman Creek Main Branch
             remediation area	24
Figure 2-5    Headwater dissipation structure	25
Figure 2-6    Sheet piling isolating a  portion of a creek channel	26
Figure 2-7    Creating a diversion channel around Area G using a tracked excavator
             (left). Construction of diversion channel around Area F (right)	26
Figure 2-8    By-pass pumping around Areas D and C	27
Figure 2-9    Sediment dewatering pads	28
Figure 2-10   Isolation of Ruddiman Pond work areas using multiple silt curtains	30
Figure 3-1    Tug and barge dredging operations within the Ruddiman Pond
             remediation area	38
Figure 3-2    Solidification of Ruddiman  Pond sediment	39
Figure 3-3    Sediments mixed with Calciment® in the drying bed	40
Figure 3-4    Addition of Calciment® to sediments on the dredging barge	41
Figure 3-5    Loading treated sediment for transportation to the Ottawa Farms  landfill42
Figure 4-1    Location of monitoring stations at the Ruddiman Creek site	45
Figure 4-2    On-site treatment system	48
Figure 5-1    Remedial management  units within Ruddiman Creek Main Branch	52
Figure 5-2    Remedial management  units within Ruddiman Pond	53
Figure 5-3    Sampling grids in Ruddiman Pond RMU A01	55
Figure 6-1    Kriging model used to determine sampling locations for RMUs
             A12-A14	65
Figure 6-2    Total PCB concentrations in Ruddiman Pond prior to remediation	69
Figure 6-3    Total PCB concentrations in Ruddiman Pond after primary dredging	70
Figure 6-4    Total PCB concentrations in Ruddiman Pond after secondary dredging . 70
Figure 7-1    Volunteer replanting efforts	76
Figure 7-2    Replanting efforts among the reestablished grass cover	76
Figure 8-1    Staff from the Ruddiman Creek Task Force and Illinois-Indiana Sea Grant
             win the 2006 State of the Lake Ecosystem Conference award	81
vi                                                                     March 2011

-------
                                                               TABLE OF CONTENTS
Figure 8-2    Theresa Bernhardt receives the President's Volunteer Service Award
             from EPA Administrator Stephen Johnson in August 2008	82
Figure 9-1    Appearance of Ruddiman Creek Main Branch remediation area six months
             after completion of remediation project	83
Figure 9-2    Appearance of Ruddiman Pond remediation area six months after
             completion of remediation project	83
March 2011                                                                     vii

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
viii                                                                       March 2011

-------
                                                    ACRONYMS AND ABBREVIATIONS
LIST OF ACRONYMS AND ABBREVIATIONS
AOC         Area of Concern
BaP          Benzo (a) Pyrene
BUI          Beneficial Use Impairment
CMI         Clean Michigan Initiative
COC         Contaminant of Concern
DQO         Data Quality Objective
EDD         Electronic Data Deliverable
EPA         U.S. Environmental Protection Agency
FSS          Field Split Sample
GLENDA    Great Lakes Environmental Database
GLLA       Great Lakes Legacy Act
GLNPO      Great Lakes National Program Office
GPS          Global Positioning System
HOPE       High Density Polyethylene
MDNRE     Michigan Department of Natural Resources and Environment
MS          Matrix Spike
MSD         Matrix Spike Duplicate
NIOSH       National Institute of Occupational Safety and Health
NOAA       National Oceanic and Atmospheric Administration
PCB          Polychlorinated Biphenyl
PVC         Polyvinyl Chloride
QAPP       Quality Assurance Project Plan
QC          Quality Control
RAP         Remedial Action Plan
RCRA       Resource Conservation and Recovery Act
RFS          Routine Field Sample
RI           Remedial Investigation
RMU        Remedial Management Unit
SVOC       Semivolatile Organic Compound
SW-846      Test Methods for Evaluating Solid Waste
VOC         Volatile Organic Compound
March 2011
                                                                           IX

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
                                                                        March 2011

-------
                                                               EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
This report describes a joint effort between the U.S. Environmental Protection Agency
Great Lakes National Program Office and the Michigan Department of Natural Resources
and Environment to remediate contaminated sediments in the Ruddiman Creek Main
Branch and Pond in Muskegon County, Michigan. The remediation site encompasses the
Main Branch of Ruddiman Creek, Ruddiman Pond, and approximately 39 acres of
associated wetland area. The Ruddiman Creek watershed is part of the Muskegon Lake
drainage system. Muskegon Lake is a 4,149-acre inland coastal lake located in Muskegon
County, Michigan, along the eastern shoreline of Lake Michigan. The Muskegon River
flows through the lake before emptying into Lake Michigan, and includes several
tributaries, one of which is Ruddiman Creek.

In 1985, Muskegon Lake was designated an Area of Concern due to water quality and
habitat problems associated with the historical discharge of pollutants in the Area of
Concern and the potential adverse effects on Lake Michigan resulting from the associated
pollutants. The Ruddiman Creek watershed historically has received direct discharges of
industrial and municipal wastewater, sewer overflows, and urban runoff from the
surrounding communities, and was identified as a major contributor to the degradation of
Muskegon Lake. The impacts associated with the Ruddiman Creek watershed that are
directly related to the presence of contaminated sediments include:

    •   Chemical toxins entering the food web through benthic organisms (bottom-
       dwelling aquatic plants and animals) exposed to or feeding on pollutants in the
       sediments.
    •   Advisories regarding fishing, boating, and swimming.
    •   Presence of oil sheens and debris.

The Ruddiman Creek Main Branch and Pond proposal was the third project to be
accepted and funded under the Great Lakes Legacy Act of 2002. This legislation was
specifically developed to address the contaminated sediment problem in the Great Lakes
Areas of Concern. The primary objectives of the project were to reduce relative risk to
March 2011                                                                      xi

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
humans, wildlife, and aquatic life, restore beneficial uses, and reduce sources of further
contamination in the watershed.

Great Lakes Legacy Act project activities at the site began in August 2005 and continued
through June 2006. Prior to dredging, steps were taken to divert the water flowing in
Ruddiman Creek. These included building a headwater dissipation structure, active
dewatering in the excavation areas using Calciment®, isolation of excavation areas with a
bypass pump, and diversion of natural creek flow with sheet pile dams. Water and air
monitoring strategies were also employed throughout the project to ensure the
remediation activities were not adversely affecting the  health of the ecosystem,
surrounding environment, or the remediation staff.

Contaminated sediments were removed from the Ruddiman Creek Main Branch and
Pond remediation site using environmental mechanical dredging techniques, including
long-reach excavators equipped with both  environmental buckets and standard
excavating buckets. After completion of this first round of dredging, the remaining
residual sediments were sampled and analyzed to verify the dredging activities reduced
contamination to acceptable levels. Results of these analyses suggested that high
concentrations of the contaminants of concern remained in some areas, and therefore
additional dredging or other cleanup actions were undertaken in these areas. By the end
of the effort, 89,870 cubic yards of contaminated sediments had been removed from the
site.  This material contained approximately:

   •   2,800 pounds of cadmium.
   •   204,000 pounds of chromium.
   •   126,000 pounds of lead.
   •   320 pounds of poly chlorinated biphenyls.

After removing the contaminated sediments, various combinations of sand, geotextile
fabric, and stone were installed to provide  a barrier between the benthic community and
any residual contaminated sediment. This cover will enhance natural attenuation, add
xii                                                                      March 2011

-------
                                                               EXECUTIVE SUMMARY
habitat for re-growth of healthy organisms on the bottom, and reduce exposure offish to
contamination through consumption of bottom-dwelling organisms.

In addition, a rock wing dam, braided stream channels, and a detention basin were
constructed downstream of the storm sewer outfall in the creek to dissipate energy during
storms and to minimize the effects of storm water on downstream water quality. Native
plant species were planted to stabilize the flood plain and control erosion along the creek
banks. For the first time in many years, salmon have been seen swimming up the creek
and the community is working on a plan to develop bike trails, nature signage, and
canoeing and kayaking routes in the waterways.

The remediation project is also expected to serve as a catalyst for redeveloping not only
the Ruddiman Creek Main Branch and Pond, but also the Muskegon Lake Area of
Concern. The community assisted in the development of the Muskegon Lake Ecological
Restoration Master Plan with funding from the U.S. Environmental Protection Agency
Great Lakes National Program Office habitat program that provides a blueprint to restore
the wetland, aquatic, shoreline, and riparian habitats in the Muskegon Lake Area of
Concern. This blueprint was the basis for a proposal submitted to National Oceanic and
Atmospheric Administration by the Great Lakes Commission on behalf of the Muskegon
Lake Watershed Partnership. In June 2009, the Commission was awarded $10 million in
federal "stimulus" funding under the American Recovery and Reinvestment Act for the
"shovel-ready" restoration projects described in the plan. The project is expected to
support 125 jobs, largely in engineering and construction, with more than $20 million
contributed by local sources through in-kind services, donations of land, and conservation
easements.

In 2007, the American Public Works Association awarded the Ruddiman Creek Main
Branch and Pond remediation project with the Chapter and Branch Award for "Project of
the Year." This  award recognized the complexity of this remediation project, and the
methods used to overcome obstacles were recognized as providing technical resources
necessary in future sediment remediation efforts.
March 2011                                                                      xiii

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
xiv                                                                       March 2011

-------
                                                              PROJECT DESCRIPTION
1.0    PROJECT DESCRIPTION
This report describes the Great Lakes Legacy Act (GLLA) sediment remediation project
in Ruddiman Creek and Pond, located in Muskegon County, Muskegon, Michigan. The
remediation site encompasses the Main Branch of Ruddiman Creek, Ruddiman Pond, and
approximately 39 acres of associated wetland area. The project was a joint effort between
the Great Lakes National Program Office (GLNPO) of the U.S. Environmental Protection
Agency (EPA) and the Michigan Department of Natural Resources and Environment
(MDNRE), hereafter referred to as the project team. Funding for this project was
provided by the GLLA and the Clean Michigan Initiative (CMI). Additional support for
the project was provided by the surrounding cities and communities, and from several
private firms operating under contract to EPA and MDNRE. A list of the organizations
involved in the Ruddiman Creek and Pond site remediation effort is provided in Section
1.5.
The Ruddiman Creek watershed is part of the Muskegon Lake drainage system.
Muskegon Lake is a 4,149-acre inland coastal lake located in Muskegon County,
Michigan that forms an embayment along the eastern shoreline of Lake Michigan.
Ruddiman Creek is one of several tributaries of the Muskegon River, which drains into
Muskegon Lake, and into Lake Michigan. In 1985, Muskegon Lake was designated an
Area of Concern (AOC) due to water quality and habitat problems associated with the
historical discharge of pollutants in the AOC, and the potential adverse effects on Lake
Michigan resulting from the associated pollutants.
The Ruddiman Creek watershed has historically received direct discharge of industrial
and municipal wastewater, sewer overflows, and urban runoff from the surrounding
communities; and was identified in the 1987 Muskegon Lake Remedial Action Plan
(RAP) as a major contributor to the  degradation of Muskegon Lake.  Therefore, the
Ruddiman Creek watershed was identified as part of the Muskegon Lake AOC; and the
observed negative impacts within the AOC, termed beneficial use  impairments (BUI), are
being addressed by the development and implementation of the RAP. As is  common in
many AOCs, the Ruddiman Creek watershed BUIs were found to be directly related to
the presence of contaminated sediments, and included:


March 2011                                                                       1

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
   •   Impairments to aquatic life - chemical toxins entered the food web through
       benthic organisms (bottom-dwelling aquatic plants and animals) exposed to or
       feeding on pollutants in the sediments.
   •   Impairments to recreational use - advisories were issued on fishing, boating, and
       swimming.
   •   Impairments to aesthetics - presence of oil sheens and debris.
EPA and MDNRE identified removal of the contaminated sediments in this section of the
AOC as a feasible approach to lessen or eliminate these impairments in the Muskegon
Lake AOC, and conducted sediment remediation at the Ruddiman Creek and Pond site in
2005.
Sections 1.1 and 1.2 provide a description and history of the Ruddiman Creek and Pond
remediation site. Section 1.3 includes a detailed description of the objectives associated
with the remediation effort. Section 1.4 details sources of funding for the remediation of
the site, and provides a general overview of the CMI and the GLLA as related to the
remediation effort. Project and data management are described in Sections 1.5 and 1.6,
respectively.

1.1    GENERAL SITE DESCRIPTION

The Ruddiman Creek and Pond remediation site, hereafter referred to as  the "Ruddiman
Creek site," is located in Muskegon County, Michigan. The site consists  of approximately
2.3 miles of creek, 39 acres of wetlands, and the 21-acre water body designated
Ruddiman Pond. There are three branches of Ruddiman Creek that flow into Ruddiman
Pond: the West Branch, the North Branch, and the Main Branch, as depicted in Figure 1-
1.  Only the Main Branch is included in the remediation site; however, the other two
branches contribute contaminants to the pond from storm runoff.
The Ruddiman Creek drainage area covers approximately 3,000 acres and includes the
cities of Muskegon, Norton Shores, Muskegon Heights, and Roosevelt Park. The
drainage area includes properties associated with industrial, commercial, residential, and
recreational usages, which also generate runoff that flows into the storm  water systems
and into the Ruddiman Creek watershed. The City of Muskegon owns a small park area
                                                                       March 2011

-------
                                                            PROJECT DESCRIPTION
that surrounds Ruddiman Pond and a larger park area located to the south of Ruddiman
Creek and Pond.
                     -,
              1
                                                    T--
                                                    v Ruddiman Pond
                                        Ruddiman Creek ^
                            iPlI
                            m*..


      Figure 1-1    Ruddiman Creek and Pond
The Main Branch begins at a 100-inch storm sewer outfall located east of Barclay Road
and flows through residential and wetland areas and discharges into the southeastern
portion of Ruddiman Pond. The Main Branch varies in width from 10 to 60 feet, and
typically has low-flow water depths ranging between 1 and 7 feet. The mean flow rate for
the creek is 3.1 cubic feet per second.  The width, depth, and flow increase during heavy
rain and  spring thaw.
Ruddiman Pond, where most of the remediation occurred, is bordered by McGraft Park
Road to the south, Addison Street to the east, and Lakeshore Drive to the north.
Ruddiman Pond discharges into Muskegon Lake through a channel flowing beneath
Lakeshore Drive, and Muskegon Lake discharges into Lake Michigan, as shown in
Figure 1-2. Ruddiman Pond is approximately 2,200 feet in length, with an average width
of 142 feet and an average depth of 9 feet.
March 2011

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
    Ruddiman Creek and Pond
             Muskegon, Ml
       Created by CSC
     Projection: Ml State Plane
      November 20, 2009
Figure 1-2   Relationship of Ruddiman Creek and Pond to Muskegon Lake and Lake
            Michigan
The remediation efforts described in this report addressed a portion the Ruddiman Creek
watershed where previous site investigations had shown high levels of contamination
(Section 1.2). Specifically, the remediation area encompassed 2.3 miles of the Main
Branch of Ruddiman Creek, Ruddiman Pond, and 39 acres of associated wetland area
adjacent to the pond and creek areas.

1.2    SITE HISTORY

After Muskegon Lake was designated an AOC, the Michigan Department of Natural
Resources evaluated information about Ruddiman Creek and Pond, and developed a RAP
to address historical contamination of sediments and surface water in the area.  The 1987
version of the RAP was updated in 1994, and again in 2002, based in part on additional
studies of the site.
                                                                      March 2011

-------
                                                               PROJECT DESCRIPTION
Between 1994 and 2004, the Ruddiman Creek watershed has been the subject of several
environmental studies by MDNRE, United States Army Corps of Engineers, and United
States Department of Health and Human Services Agency for Toxic Substances and
Disease Registry. Phase I of an environmental site assessment was completed in
September 1999 and Phase II in October 2000.
A Remedial Investigation (RI) of Ruddiman Creek was conducted in 2002 to characterize
the sediment contamination and to provide the basis for a remedial design to mitigate the
impacts. The objectives of the RI study included:
   •   Vertically and horizontally delineate sediment contamination within the
       Ruddiman Creek watershed.
   •   Evaluate potential impacts to human health and aquatic life.
   •   Estimate the volume of affected sediments within the Ruddiman Creek watershed.
   •   Evaluate potential for continued sources and/or recontamination.
   •   Evaluate remedial alternatives.
The RI included testing for the regulatory characteristic of "toxicity" defined in Section
261.24 of the Resource Conservation and Recovery Act (RCRA). The RI also included
sediment toxicity testing, which is not related to the RCRA characteristic. The results of
these various investigations indicated that volatile organic compounds (VOC),
semivolatile organic compounds (SVOC), polychlorinated biphenyls (PCBs), metals
(lead, cadmium, and chromium), and benzo(a)pyrene (BaP) (a polycyclic aromatic
hydrocarbon) were all present at concentrations exceeding the Consensus-based Sediment
Quality Guidelines1 probable effect concentrations found in MacDonald et al. (2000) at
many sampling locations throughout the creek and pond. Based on these data and the
associated potential impacts on the Muskegon Lake AOC, the project team identified
PCBs, BaP, cadmium, chromium, and lead as the Contaminants of Concern (COCs) for
the Ruddiman Creek site cleanup. Table 1-1 provides a summary of average and
maximum concentrations of the COCs in Ruddiman Creek and Ruddiman Pond observed
during an investigation of the site in 2004,  as well as site-specific target levels used as
cleanup criteria.
1 Sediment Quality Guidelines (SQGs) as defined in Development and Evaluation of Consensus-Based
 Sediment Quality Guidelines for Freshwater Ecosystems (MacDonald et al., 2000).
March 2011

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
 I Table 1-1  Average and Maximum Concentrations of Contaminants of Concern in
            Sediments in Ruddiman Pond and Ruddiman Creek Prior to Remediation and
            Site-Specific Target Levels*
    Contaminant
   Benzo(a)pyrene
     Ruddiman Pond
Average        Maximum
             Concentration
                        3.4
                                    Ruddiman Creek
                                                            Target
                               Average         Maximum      Level
                                            Concentration
1.90(70,24)
 2.8 (65, 22)
   19
  Total PCBs
0.77 (96, 24)
                        67
0.85 (57, 22)
   19
  <1
   Cadmium
5.03 (72, 23)
                        25
5.41 (57, 19)
   31
   Chromium
 295 (72, 23)
                      2,090
320(57, 19)
2,040
<400
   Lead
 172(72,23)
                      1,200
201 (57, 19)
  895
<900
* All concentrations in mg/kg, dry weight, from Earth Tech, 2004 Technical Memorandum for Ruddiman
 Creek Soil and Groundwater Investigation, Muskegon, Michigan. The values shown in parentheses are the
 number of samples and the number of stations, respectively, used to develop the averages. The average
 concentrations are weighted down the length of the cores collected at each station. Appendix B provides
 additional comparisons of pre-remedial sediment concentrations for the site.

Contamination of the sediments was observed from 0 to 9 feet below the surface of the

sediment. Figure  1-3 illustrates the relationship between total PCB concentration and

depth below the surface. The results are presented in |ig/kg, the units used by the

laboratory that analyzed the samples (decimal points in the figure legend simply indicate

that the listed ranges do not overlap).
        Total PCBs

        ug/kg

        ^B ° • 50°
        ^B 5°0.1 - 800

        ^B 800.1 - 1.000

        |   | 1.000.1-1.200

        |   | 1,200.1-1.500

        |   | 1,500.1-2.000

        |   | 2,000.1-2.500

         II] 2.500.1 -3.000

        ^B 3,000.1 -3.392

        	 RMU
      Target Level = 1000 ug/kg
                                      Exaggeration in Ihe Z direction lor visualization
Figure 1-3   Pre-remediation sediment total PCB concentrations at depth
                                                                                March 2011

-------
                                                               PROJECT DESCRIPTION
In March 2004, MDNRE submitted a proposal to GLNPO for GLLA funding to
remediate Ruddiman Creek Main Branch and Pond. The project began in August 2005, as
a partnership with federal funding from the GLLA (65 percent) and non-federal funding
(35 percent) from the MDNRE CMI. Numerous other participants were involved in the
successful cleanup of Ruddiman Creek site, as shown in Table 1-2 (Section 1.5).

1.3    PROJECT OBJECTIVES

The main objective of the remediation of this project was to remove an estimated 72,000
cubic yards of contaminated sediments from the site, taking the first step to substantially
improve the environment by mitigating the associated BUIs. The activities were designed
and implemented to accomplish the following three specific objectives:
    Objective 1: Reduce Relative Risk to Humans, Wildlife, and Aquatic Life.
    Contaminated sediments were dredged from the site to permanently reduce the
    amount of COCs present and available to the food chain. A residual cover was placed
    over the dredged areas to further reduce the bioavailability of COCs. The overall
    effect of remediation efforts at the Ruddiman Creek site was expected to result in
    reduced risks to aquatic organisms, wildlife, and humans in both the Ruddiman Creek
    watershed and in Muskegon Lake.
    Objective 2: Restore Beneficial Uses. Sediments containing elevated levels of COCs
    were removed and various restoration and environmental enhancement measures
    (e.g., riprap riffles,  energy dissipation devices, braided stream channels, etc.) were
    implemented after remediation. Together, these efforts are expected to reduce toxic
    effects to aquatic biota, and therefore, improve the food chain and the entire
    ecosystem. These remedial measures were also expected to improve the condition and
    stability of the aquatic habitat, particularly for the benthic organisms, which will
    further enhance the rest of the aquatic environment and the higher trophic level
    organisms. Finally, these improvements directly resulted in improved aesthetics and
    potential recreational uses of the Ruddiman Creek watershed.
    Objective 3: Source Control. In an effort to reduce sources of further contamination
    in the Ruddiman Creek watershed, environmental enhancement activities, such as

March 2011                                                                       7

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
   aggregate placement, installation of energy dissipation devices, and stream armoring,
   were implemented. These activities complemented other measures performed by the
   City of Muskegon and the MDNRE Remediation Redevelopment Division, including
   improvements to the storm water management programs and storm sewer
   infrastructure system.

1.4    PROJECT FUNDING

The Great Lakes make up one fifth of the fresh water on the earth's surface, providing
water, food, recreation, and transportation to more than 35 million Americans. The
quality of this resource is of great importance and, although the discharge of toxic and
persistent chemicals from industrial and municipal wastes into the Great Lakes has been
substantially reduced over the past 20 years, contaminated sediments remain at certain
sites, affecting water quality. Recognizing the importance of this resource, the United
States Congress enacted the GLLA specifically to address the problem of contaminated
sediment in Great Lakes AOCs, including the Muskegon Lake AOC. The Act provides
for the remediation of contaminated sediment in any AOC, of which there are 30 either
wholly or partly within the United States. The GLLA was reauthorized by Congress in
October 2008, providing two additional years of funding, and allowing GLNPO to
continue making great strides with sediment cleanups in the Great Lakes AOCs.
The State of Michigan CMI provided the  non-federal matching funds for the remediation
of the Ruddiman Creek site. The CMI is a $675 million bond that was approved by
Michigan voters in November 1998 to improve and  protect Michigan's water resources.
The major CMI programs are administered by the Michigan Departments of
Environmental Quality, Natural Resources,  and Community Health.
The $14.2 million remediation project at the Ruddiman Creek site was funded with the
support of $8.9 million from GLNPO under the GLLA, and $5.3 million in matching
funds from MDNRE under the CMI.
                                                                       March 2011

-------
                                                                   PROJECT DESCRIPTION
1.5    PROJECT MANAGEMENT


The remediation project was a collaborative effort involving multiple partners and

sources of funding at the federal, state, and local level. The participants developed project

planning documents, agreements, and strategies to ensure effective communication, clear

understanding of responsibilities, and adherence to project requirements among all  the

parties involved. These documents, agreements, and strategies are summarized in the

subsections below.  Table 1-2 provides a list of the organizations participating in the

remediation project.

 Table 1-2  Organizations Participating in the Ruddiman Creek and Pond Remediation
            Project
 Federal
       EPA; federal sponsor of the GLLA project
       > EPA GLNPO; lead organization on behalf of EPA
       > EPA Region 5; provided contractor support to GLNPO for the project


       State of Michigan; non-federal sponsor of the project
       > MDNRE; lead organization on behalf of the State
       Muskegon Lake Watershed Partnership
       Ruddiman Creek Task Force
       Illinois/Indiana Sea Grant
       U.S. Army Corps of Engineers
       City of Muskegon, Michigan
       City of Muskegon Heights, Michigan
       City of Norton Shores, Michigan
       City of Roosevelt Park, Michigan
       Muskegon County Publicly-Owned Treatment Works/Muskegon County Wastewater Management System
1.5.1  Project Planning, Training, and Permits

EPA and MDNRE entered into a project agreement for the remediation of the Ruddiman

Creek and Pond. The agreement detailed the financial, technical, and logistical

obligations and responsibilities of EPA and MDNRE (Section 1.4). Through this

agreement, GLNPO and MDNRE developed a formal strategy of commitment and

communication to facilitate successful completion of the remediation project.

A series of project planning documents was developed for the technical approaches to the

remedial action. These plans detailed all necessary actions to achieve project goals while
March 2011

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
adhering to applicable federal, state, and local requirements. These project planning
documents included the following:
    •   Work Plan.
    •   Site Safety and Health Plan.
    •   Contractor Quality Control Plan.
    •   Quality Assurance Project Plan (QAPP).
    •   Environmental Protection Plan.
    •   Land and Water/Sediment Surveys.
These documents were subject to approval by EPA, MDNRE, and appropriate
stakeholders; and once approved, were included as appendices to the final work plan. The
work plan was based primarily on engineering specifications and drawings, and
discussions conducted during the project kickoff meeting and other project planning
activities. The final work plan provided a mechanism for ensuring that all project
objectives and strategies were clearly understood by all involved parties and that the
associated strategies included a project design and quality control procedures to ensure
project data would be reliable and of sufficient quality to support EPA decisions
regarding the Ruddiman Creek site remediation project. Remediation and construction
work began after the approval of the work plan and an official Notice to Proceed from the
U.S. government. Copies of all required permits, licenses, and access agreements (e.g.,
the Joint Environmental permit,  Soil Erosion Control Plan, and residential access
agreements) were maintained at  the project site.
A variety of training programs and related activities were conducted at the site to ensure
the protection of both workers and the general public, and to prevent accidents at the
work site. Examples of these programs and activities included:
    •   Use of an on-site orientation training module to orient new site workers in
       conjunction with the Site Safety and Health Plan.
    •   Requirement that all personnel working at the site review the Site Safety and
       Health Plan and sign a form documenting that they had read the plan, understood
       its contents, and would abide by the plan.
    •   Requirement that all field personnel provide current certifications to demonstrate
       they were  qualified to perform their respective jobs and to operate the applicable
       equipment or machinery.

10                                                                       March 2011

-------
                                                                PROJECT DESCRIPTION
    •   Conducting daily "tailgate" safety meetings prior to each shift in which relevant
       health and safety issues were discussed.
    •   Conducting mandatory safety briefings prior to commencing each new task to
       discuss task-specific risks and precautions.
There were no lost-time injuries or reportable accidents at the site over the course of the
remediation project, which reflects the effectiveness of these planning procedures.
Other planning activities included control measures that were implemented during the
project mobilization and set-up stages to minimize disturbance to local residents and the
general public. Such control measures included:
    •   Close communication and coordination with local parties (park and city  officials,
       residents, general public, etc.) concerning planned mobilization, site set  up, and
       work activities to ensure the safety and protection of all individuals and  property.
    •   Routine maintenance cleaning and a street sweeping service that was hired to
       clean public streets twice a week during early stages of the project and as-needed
       thereafter.
    •   Construction of a perimeter fence and use of a uniformed security guard service.

1.5.2  Project Communication,  Roles, and Responsibilities
GLNPO and the State of Michigan put together a team of representatives from all parties
involved in major project activities to ensure communication among all participants
involved in the project, address technical and logistical issues as they  arose, and
communicate problem resolutions to all involved parties. The communication procedures
included regularly scheduled conference calls, progress meetings, daily activity  reports,
and project management teams.
GLNPO served as EPA's lead office on the project. Because EPA Region 5 provided
extensive support, including access to the EPA Region 5 Superfund contract,
representatives from both EPA offices (GLNPO and Region 5 Superfund) participated in
project management and served as members of the project team. The roles and
responsibilities of the key governmental project management personnel from are
delineated in Table 1-3.
March 2011                                                                        11

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Table 1-3 Roles and Responsibilities of Key Governmental Project Management
| Personnel |
Key Person, Organization, 0 ......
y ^Q|ea Responsibility
Marc Tuchman
EPAGLNPO
Project Manager
Mike Alexander
MDNRE
Project Manager
Sam Berries
EPA
Federal On-site Coordinator
Louis Blume
EPA GLNPO
Quality Assurance Manager
Ida Levin
EPA Region 5 Superfund
Quality Assurance Manager
Susan Boehme
Illinois/Indiana Sea Grant
Liaison to EPA GLNPO
• Serve as primary GLNPO contact
• Financial and contractual monitoring
• Ensure that decision objectives are met at project completion
• Negotiate and approve contract modifications
• Review and approve project plans
• Serve as pri mary contact f or M D N RE
• Negotiate and approve contract modifications
• Review and approve project plans
• Serve as primary EPA Emergency and Rapid Response Services contact
• Oversee site activities
• Approve modifications to project plans relating to site activities
• Review and approve Daily Activity Quality Control Report
• Approve all corrective actions impacting site activities
• Approve QAPP and work plans
• Assist in the development of quality documentation and identification of project
quality objectives
• Ensure that all environmental collection activities are covered by appropriate
quality documentation
• Review and approve QAPP on behalf of GLNPO
• Assist in the review of quality related items
• Ensure contract required quality items are met
• Review QAPP and make recommendations for QAPP approval
• Outreach to community
• Prepare fact sheets and update content for website
Weekly conference calls provided progress updates and status information to all involved
parties. These meetings were also used as a forum to communicate new issues and
challenges that required resolution or decisions. Urgent issues and challenges were
communicated through ad hoc conference calls, meetings, or on-site discussions. The
decisions resulting from on-site discussions were documented in the daily activity
reports. Decisions resulting from meetings and conference calls were documented
through meetings minutes and group emails.
These adaptive management techniques and open communication strategies enabled the
project team to keep the Ruddiman Creek site remediation project on track, despite
logistical challenges encountered during project activities. For example, one of the most
significant challenges encountered was the amount of peat present at the site and its
extreme depths in some locations. While attempting to build roads on which to move
12
March 2011

-------
                                                                PROJECT DESCRIPTION
equipment around the site, the project participants discovered that building materials
deposited in some areas promptly sank into the ground, and that an amphibious dump
truck was unable to traverse through the peat formation. This obstacle was overcome by
modifying the intended course of action specified in the Work Plan to allow the
achievement of associated project goals; in this particular case, through the use of
floating high density polyethylene (HDPE) mats that permitted traffic across the site
(Section 3.1.3). The final decisions concerning resolution of this and other challenges
were documented in the daily activity reports.

1.5.3  Public Outreach and Community Involvement

The  project team  employed a variety of
approaches  to keep  the  public informed
and  involved.   These  included  public
meetings  and Web-based site  tours  to
foster  the  involvement  of  the  local
communities. Examples include:
   •  August 24,  2005 site tour -
       photographs of preparation of the
       site for remediation are viewable     Figure 1 -4   Community discussion of the
       at:                                            remediation project
       http://www.epa.gov/glla/ruddiman/sitetour.html.
   •  October, 2005 site tour - photographs of the site and various remediation
       activities are available at: http://www.epa.gov/glla/ruddiman/sitetour_10_05.html.
   •  December 5, 2005 site tour - additional photographs illustrating continued
       progress of dredging through the winter are viewable at:
       http ://www.epa.gov/glla/ruddiman/sitetour_l 2_05 .html.
   •  January 9, 2006 public meeting - discussion of progress on sediment cleanup with
       presentation (Figure 1-3) is available at
       http://www.epa.gov/glla/ruddiman/pubmeetngjan92006.html.
   •  April 10, 2006 public walk through - explanation  of the post-dredging restoration
       of the site is available at
       http://www.epa.gov/glla/ruddiman/walkthru_4_l 0_06.html.
Signs were posted at the site entrance identifying the remediation effort as a jointly
funded sediment cleanup project and naming the major project  sponsors and participants.
March 2011
13

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
EPA also maintains a website for the remediation project at:
http://www.epa.gov/glla/ruddiman/index.html. The website contains general information
and connections to other Web pages, including:
   •   Several fact sheets (Appendix C) -
       http://www.epa.gov/glla/ruddiman/ruddfctsht.pdfand
       http://www.epa.gov/glla/ruddiman/ruddimancleanup_fmish.pdf.
   •   Engineering drawings - http://www.epa.gov/glla/ruddiman/eng_drawings.pdf.
   •   A photo journal - http://www.epa.gov/glla/ruddiman/ruddimancleanup_.pdf.
EPA also maintains a GLLA website, located at: http://www.epa.gov/glla/index.html,
with links to topics such as:
   •   Executive summaries for proposed GLLA projects and proposals.
   •   A fact sheet about the GLLA.
   •   Text of the GLLA.
   •   GLNPO's strategy to restore and protect the Great Lakes.

1.6    DATA MANAGEMENT PROCEDURES

Data management procedures are outlined in the project planning documents, and
included using standard protocols for recording field data and remedial activities, defined
electronic data deliverables (EDD) for laboratory data, chain-of-custody forms for
transferred  samples,  and a data logging system to track all field and laboratory data
submitted for independent data verification.

1.6.1  Data Management
Project contractors are responsible for managing the majority  of field data, laboratory
data, and other project information gathered during preparation and implementation of
the project, which included:
   •   Original planning documents developed for the project.
   •   All permits, licenses, and access agreements. Copies of these were maintained at
       the project site at all times throughout the remediation and site restoration
       activities.
   •   Site survey data, including pre-work survey data and surveys conducted
       throughout and upon completion of remediation activities.
14                                                                      March 2011

-------
                                                                PROJECT DESCRIPTION
    •   Standard forms used to document construction inspections and data quality
       verifications as specified by MDNRE and GLNPO. All quality control exceptions
       were documented on a daily form known as the Quality Control (QC) Report.
    •   Field information recorded each day in daily logbooks. This included weather
       conditions, personnel present, all field measurements and observations, and any
       deviations from original sampling plan. Entries into the logbooks were made as
       activities occurred or samples were collected. Calibrations of any field equipment
       were documented in the logbooks. Instrument readings taken during the
       remediation were documented in boring logs, in the field logbook, or both. Daily
       logbooks were stored at the project site and were turned over for inclusion in the
       project file at the completion of field activities.
    •   Field sampling records. Upon collection, each sediment sample was classified in
       the field in accordance with the Unified Soil Classification System (American
       Society for Testing and Materials D2487). Visual and olfactory observations were
       also recorded. Once  samples were collected, a chain-of-custody  record was
       created for each sample. This record then accompanied the sample to the
       laboratory.
    •   Laboratory data generated by MDNRE during analysis of sediment samples.
       These data were reported electronically and in hard copy.

1.6.2  Sediment Confirmation Data

Sediment samples collected during the course of the remediation were analyzed by

several laboratories to confirm that dredging targets were met. To minimize costs

associated with delay of field activities, the laboratories delivered the data from in the

form of EDDs, as well as in hard-copy data packages. The sediment confirmation results

were provided in the form of summary-level data reports that included data qualifiers. Per

the QAPP, all laboratory data and records were included in final analytical reports

submitted to MDNRE.

1.6.3  Database

GLNPO developed a database to archive and maintain all GLLA project sediment

contamination data.  This database  contains sediment confirmation data for project-

specific COCs and their  respective location information. Field observations and all

relevant collection information are also contained in this database. The database is

compatible with the Query Manager Data Management System administered by the

National Oceanic and Atmospheric Administration (NOAA).
March 2011                                                                       15

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
1.6.4  Public Access
GLNPO has provided data generated for the Ruddiman Creek Main Branch and Pond
Remediation Project to stakeholders and other interested parties. The sediment chemistry
data from the project are available at the Great Lakes Environmental Database
(GLENDA) website. Interested parties can access and follow the instructions provided on
the GLENDA Query System page
(http://www.epa.gov/glnpo/monitoring/data_proj/glenda/glenda_query_index.html) in
order to receive project data. In addition, GLNPO has uploaded the sediment
confirmation data to a standard GLLA database and public access can be provided
through written request (see www.epa.gov/glnpo/feedpp.html for contact information).

1.7    REMEDIAL DESIGN AND CLEANUP GOALS

Based on the project objectives outlined in Section 1.3, the project team developed a
remedial design and established cleanup goals, or target levels, to achieve those
objectives.

1.7.1  Remedial Design
The basic elements of the remedial design consisted of mechanically dredging
contaminated sediments from the creek and pond, treating the dredge soil on site with a
solidification agent, dewatering the material on  site, transporting it off site for disposal,
installing clean cover materials over the remaining sediments, and restoring any areas of
the site disturbed during remediation.
The project consisted of 19 tasks designed to achieve the remediation project objectives.
The technical approaches used to accomplish these tasks are described in the subsequent
sections of this report. Table 1-4 provides an overview of the primary work tasks.
         Table 1-4  Primary Tasks Associated with Remediation of the
                   Ruddiman Creek Site
                                    Description of Work Activity
1
2
3
4
Mobilization, project planning, and management
Install new fence
Set up and operate dewatering system
Establish sewer outfall system
16
March 2011

-------
                                                              PROJECT DESCRIPTION
         Table 1-4  Primary Tasks Associated with Remediation of the
                  Ruddiman Creek Site
                                   Description of Work Activity
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Construct access roads
Install headwater dissipation systems
Set up dam and channel diversion systems
Dredge creek sediment
Construct energy dissipation devices along main branch
Creek/wetlands restoration
Transport and dispose of creek sediment
Install silt curtains in pond
Operate dewatering system for pond
Dredge pond sediment
Transport and dispose of pond sediment
Purchase sand backfill materials
Purchase rock backfill material
Place sand and rock backfill
Demobilization
1.7.2  Cleanup Target Levels for Contaminants of Concern
The MDNRE Water Division developed site-specific sediment criteria that formed the
basis for the cleanup target levels for the Ruddiman Creek and Pond site remediation
shown in Table 1-1 (Earth Tech, March 2004). MDNRE developed these sediment criteria
through the use of a three-tiered approach. Specifically, this approach took into
consideration potential impacts to human health and wildlife from bioaccumulative
chemicals of concern, potential impacts to humans through direct contact with
contaminated sediments, and potential impacts to aquatic life.  Environmental costs,
environmental benefits, and economic costs were also considered when establishing these
criteria. MDNRE developed site-specific sediment criteria for cadmium, chromium, lead,
benzo(a)pyrene, and total PCBs, as described below.
Cadmium and Chromium:
MDNRE developed the site-specific sediment criteria for cadmium and chromium based
on toxicity testing. Standard toxicity tests using midge larvae (Chironomus tentans) and
an amphipod (Hyalella azteca) were conducted using sediment collected from seven
locations within the Ruddiman Creek watershed. The results of these tests indicated that
sediment toxicity was closely related to the concentrations of cadmium and chromium,
March 2011
17

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
but not to any other chemicals. The toxicity testing also demonstrated that Hyalella
azteca was more sensitive to cadmium and chromium than Chironomus tentans. Hyalella
azteca toxicity ranged from 12 percent to 94 percent mortality, with growth showing
similar correlations. Based on the toxicity testing results for Hyalella azteca and
professional judgment, MDNRE established a site-specific sediment criterion of 10
mg/kg for cadmium and a site-specific sediment criterion of 400 mg/kg for chromium
(see Section 5.1.4).
Benzo(a)pyrene:
MDNRE developed the site-specific sediment criterion for BaP based on potential human
health effects resulting from direct contact with sediment. MDNRE used the same
approach and equation that is used for direct contact with soil and is outlined in Part 201,
Environmental Remediation of the Natural Resources and Environmental Remediation,
Michigan Natural Resources and Environmental Protection Act R299.5746. The equation
considers both incidental ingestion of sediment and absorption through the skin. In
developing the sediment criterion, MDNRE considered the potential frequency and
duration of these dermal and ingestion exposures.
Dermal exposure and ingestion are age related in humans, with children 2 to 12 years old
being the most vulnerable group. Therefore, MDNRE derived the site-specific sediment
criterion for children in this age range by modifying the soil dermal absorption and the
soil ingestion factors used in the equation to represent this age group. Other factors
modified in the equation were the ingestion rate, exposure frequency, and the dermal
exposure frequency. MDNRE assumed an exposure frequency of 52 days per year for
both dermal and ingestion exposures. This was based on exposure four times per week
during the warmer summer months (June through August) and twice per month during
the cooler months of May and  September. Using the child exposure scenario resulted in a
sediment value of 16 mg/kg for BaP. Given lower exposure scenarios for infants and
those  older than 12, the criterion affords  protection of all other age groups.
Lead:
The existing MDNRE level for direct contact with lead in soil is 400 mg/kg. EPA
published a sediment criterion  for lead of 900 mg/kg in March 1998 (EPA, March  1998)

18                                                                      March 2011

-------
                                                              PROJECT DESCRIPTION
that is based on direct contact. MDNRE decided that the sediment criterion of 900 mg/kg
was sufficiently protective and applied it to this project.
Total PCBs:
Michigan's Department of Community Health has issued fish consumption advisories for
both Ruddiman Creek and Muskegon Lake because of the presence of PCB and other
contaminants that accumulate in fish exposed to contaminated sediments. MDNRE
established a sediment quality criterion for PCBs of 1  mg/kg for Ruddiman Creek. This
criterion is not based solely on sediment exposure, but also considers exposure to PCBs
in fish from Muskegon Lake.
March 2011                                                                     19

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
20                                                                      March 2011

-------
                                                         SITE PREPARATION AND SETUP
2.0    SITE PREPARATION AND SET UP
The remedial design chosen for the project focused on dredging contaminated sediments
from the creek and pond, dewatering those sediments on site, and trucking them off site
for final disposal.  Prior to beginning those efforts, various site preparation activities were
needed, including:
   •   Conducting pre-work site surveys, mobilizing resources to the site, and work area
       preparation, as described in Sections 2.1, 2.2, and 2.3.
   •   Constructing access roads as described in Section 2.4.
   •   Constructing creek dissipation, diversion, and dewatering systems, as described in
       Section 2.5.
   •   Installing containment measures and other structural devices in and around
       Ruddiman  Pond, as described in Section 2.6.

2.1    SITE SURVEY AND RESOURCE MOBILIZATION

Prior to initiating work efforts at the site, a survey was conducted of all remediation areas
associated with the Ruddiman Creek Main Branch and Pond. The site survey provided a
baseline for post-dredging surveys and for subsequent calculations of the volume of
sediment removed.
Mobilization of personnel, equipment, and materials began on August 8, 2005. A number
of "good housekeeping" measures were instituted to mitigate dust, noise, and other
possible disturbances to the public and maintain worker and public safety.

2.2    WORK AREA DELINEATION

To facilitate the dredging and remediation efforts and achievement of project objectives,
the Ruddiman Creek Main Branch remediation area was partitioned into eight work areas
(also known as dredge areas): B, C, D, E, F,  Q H, and I. The size and location of each of
these work areas was a function of the ability to access the creek from banks, the levels of
contaminants in the area, and ability to control water flow. Several of these were divided
into smaller sub-work areas (e.g., Bl and B2), known as remedial management units
(RMU). Ruddiman Pond constituted Area A, which was subdivided into RMUs Al, A2,
A3, A4, and A5. The RMUs associated with the Ruddiman Creek Main Branch
March 2011                                                                      21

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
remediation area are depicted in Figures 2-1 and 2-2. The RMUs associated with the


Ruddiman Pond remediation area are depicted in Figure 2-3.
                                          yj Ruddiman  Cree
                                     
-------
                                                         SITE PREPARATION AND SETUP
2.3
Figure 2-3   Ruddiman Pond RMUs
SITE SECURITY
Temporary fencing and signs were used to demarcate work areas. Fencing was placed
around the command post area and partially around the main sediment staging and
dewatering area east of McGraft Park Road to provide security for equipment and
materials and to control site access by the general public. Uniformed security guards
provided off-hour security. McGraft Park Road was closed to through traffic for the
duration of the project to protect site personnel and the public. The road was reopened on
June 2, 2006.

2.4    SITE ACCESS

Eight temporary access and haul roads (with a total area of 82,117 square feet) were
constructed to support site operations. The roads extending out from Areas I, H, Q F, and
E of Ruddiman Creek Main Branch were constructed using various techniques,
depending on soil conditions, including:
March 2011
                                                                       23

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
   •  A soil stabilization product (e.g., GeoWeb®) made of synthetic materials that
      formed a web of open cells that were filled with a sand base and a gravel cap in
      soft areas.
   •  A gravel surface and geotextile fabric in more solid areas.
   •  Laying out multiple layers of timber swamp mats in areas where temporary roads
      were established (see Figure 2-4).

A combination of sand/geosynthetic/gravel roads and HDPE interlocking road mats were

used to construct the roadways to reach Ruddiman Creek Main Branch Areas E, D, C,
andB.
Figure 2-4  Timber swamp mat access road to Ruddiman Creek Main Branch remediation
           area

2.5   CONSTRUCTION OF THE CREEK DISSIPATION, DIVERSION AND
      DEWATERING SYSTEMS

In order to dredge contaminated sediments without releasing them into the flowing water

of the creek, steps had to be taken to minimize the amount of water in the excavation

areas during dredging. This was accomplished with a combination of control measures,
including:

   •  Construction of a dissipation structure at the headwater of the creek.
24
March 2011

-------
                                                          SITE PREPARATION AND SETUP
    •   Diversion of natural creek flow with sheet pile dams.
    •   Isolation of excavation areas with a bypass pump.
    •   Active dewatering in the excavation areas using Calciment®.
Appendix D provides the design drawings illustrating where creek dissipation, diversion,
and dewatering systems were installed.

2.5.1  Headwater Dissipation Structure
As  discussed in Section 1.1, the
main branch of Ruddiman Creek
begins at a 100-inch storm sewer
outfall  located   just  east  of
Barclay Street. The main branch
subsequently   flows   through
residential  and  wetland  areas,
until  reaching the  southeastern
portion of Ruddiman  Pond.  A
headwater  dissipation  structure   Figure 2-5  Headwater dissipation structure
was built west of the 100-inch outfall,  illustrated in Figure 2-5, to preclude suspended
sediments that may have eroded or been scoured by storm water surges at the outfall from
settling in any of the work areas downstream.

2.5.2  Dam and Channel Diversion Systems
The excavation areas in the Ruddiman Creek Main Branch were isolated with sheet piling
to block or dam the natural water flow, as illustrated in Figure 2-6. Sheet pile dams were
installed upstream and downstream from each excavation area, with the exception of
Areas H and I, where an earthen dam was constructed using sand, stone, and polyvinyl
chloride (PVC) liner material.
March 2011
25

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Figure 2-6   Sheet piling isolating a portion of a creek channel

Diversion channels were created around Areas G and F to allow the creek to flow around

the excavation areas and to minimize infiltration of water into the excavation areas

(Figure 2-7).
 Figure 2-7   Creating a diversion channel around Area G using a tracked excavator
             (left). Construction of diversion channel around Area F (right).
26
March 2011

-------
                                                        SITE PREPARATION AND SETUP
2.5.3  Pumping Systems
Groundwater and surface water runoff from storm events that accumulated in the
excavation areas was pumped to the on-site water treatment system (Section 4.2.2). In
addition, by-pass pumping occurred around Areas B, C, D, H, and I (Figure 2-8).
Figure 2-8   By-pass pumping around Areas D and C
A 6-inch diameter, 5,600-foot long HDPE pipeline was used to remove water from the
work areas. The pipeline was constructed by welding together 300- to 500-foot segments,
pulled into place using portable winches and was shortened as sediment removal
activities were completed in the main branch and work progressed back towards the
pond.

2.5.4   Sediment Dewatering
Prior to disposal, excavated sediments from most work areas were dewatered using
Calciment® as a solidification agent, which was added to the sediment in a mix pit
intermediate to the final staging area. Sediment was transferred to the final staging and
March 2011
27

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
dewatering area at the pond to sit and allow free water to decant, as illustrated in Figure
2-9. The dewatered material was transported to an off-site landfill (see Section 3.3).
Figure 2-9   Sediment dewatering pads

2.6    INSTALLATION OF CONTAINMENT MEASURES AND OTHER
       STRUCTURAL DEVICES IN RUDDIMAN POND

Several structures were installed in and around Ruddiman Pond to facilitate dredging

operations and prevent contaminated sediments from migrating into Muskegon Lake.

These included:

   •   A sheet wall dam at the west end of the channel that flows into Muskegon Lake.
       This dam was used to raise the pond level approximately two feet in order to
       provide added draft for the dredge plant and material barges.
   •   An access road to an offloading pier and a bin for storing the solidification agent
       (Calciment®). The road extended from McGraft Park Road to the offloading pier.
   •   A Calciment® storage bin west of the installed access road. The bin was
       constructed by laying 4-inch Geoweb® with 1- to 3-inch rock in webpockets to
28
March 2011

-------
                                                          SITE PREPARATION AND SETUP
       maintain a hard floor for scraping the Calciment®, and building an 8-foot tall
       concrete block wall around the area to contain the material.
    •   A barge offloading pier that extended 30 feet into the pond and was approximately
       40 feet wide. The pier was constructed by installing three 40-foot long sheet
       piling walls to make a three-sided box. The sheet piling was driven approximately
       20 feet into the ground. The inner space was leveled and filled with several feet of
       3-inch rock to create a solid work surface.
    •   Turbidity curtains and silt fence material to contain suspended sediments within
       Ruddiman Pond during dredging operations.
Appendix D provides the design drawings illustrating where containment and other
structural devices in the pond were installed.
A combination of semi-permeable and impermeable silt curtains was used to contain
contaminated sediments (Figure 2-10). Three parallel curtains were installed at the north
end of Ruddiman Pond, at the west side of Ruddiman Pond, and upgradient from the
outfall channel to Muskegon Lake, as the final line of defense to contain pond sediments
and preclude their migration to Muskegon Lake. The curtains extended from the west
shore to the east shore and downward to within less than one foot of the pond floor. A
series of 3-inch diameter steel posts were driven into the bottom of the pond at 20-foot
intervals on the downgradient/north side of the curtains. The posts were effective at
securing the curtains against the current flow out of the pond. The northern curtain was
deployed approximately 50 feet south of the Lake  Shore Drive Bridge. Field observations
and monitoring data indicated a fourth barrier in the outfall channel was required to
control high turbidity levels observed in the spring.
With the exception of Area A3 (Figure 2-3), the turbidity curtains were reconfigured to
seal off each areas as dredging was completed. For example, upon completion of
dredging in Area A5, the curtains were reconfigured to exclude that area and seal off the
east end of Area A3 to allow for dredging in Areas A3 and A4. While those areas were
being dredged, new curtains were deployed to seal off Areas Al and A2.  The curtains in
Area A3 remained in place until all dredging operations were in place because Area A3
was used for access to all other areas of the pond.  All of the curtains were inspected
frequently, repaired as needed, and removed after  completion of dredging operations.
March 2011                                                                        29

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Figure 2-10  Isolation of Ruddiman Pond work areas using multiple silt curtains
30
March 2011

-------
                               DREDGING OPERATIONS AND DISPOSAL OF DREDGED MATERIAL
3.0    DREDGING OPERATIONS AND DISPOSAL OF DREDGED MATERIAL
Contaminated sediments were removed from the Ruddiman Creek site using
environmental mechanical dredging techniques, including long-reach excavators
equipped with both environmental buckets and standard excavating buckets.
Removal activities began in the headwaters of the Ruddiman Creek Main Branch and
proceeded downstream towards Ruddiman Pond. Specifically, operations began in the
Ruddiman Creek Main Branch Area I, and subsequently moved downstream through
work areas H, Q F, E, D, C, and B, towards Ruddiman Pond (designated Area A). Many
of these work areas were divided into smaller segments, known as remedial management
units or RMUs, as illustrated in Section 2.
Sediments in each RMU were dredged as specified in the QAPP with procedures
modified, as necessary, to accommodate unforeseen conditions. Following completion of
removal activities within each work area, samples of the remaining substrate were
collected to confirm the COCs had been removed as planned. In accordance with project-
specific data quality objectives (Section 5), if observed concentrations of COCs in
confirmatory sampling exceeded cleanup goals, additional sediments in an RMU were
removed whenever possible.
Section 3.1 describes containment, sediment removal, and sediment solidification
activities within each area as work proceeded from the creek to the pond. Section 3.2
describes sediment removal operations in the Ruddiman Pond remediation area.
Transportation and disposal of sediments removed from the Ruddiman Creek Main
Branch and Pond are discussed in  Section 3.3.

3.1     DREDGING OPERATIONS WITHIN THE RUDDIMAN CREEK
       REMEDIATION AREA
Excavation activities in the Main Branch of Ruddiman Creek started in Area I, and
proceeded downstream towards Area B; except that Area G was started and completed
prior to Areas H and I, due  to issues with confirmatory sampling. In addition, excavation
activities in RMUs Cl  and  C2 occurred prior to those in Area D, because a peat
formation in Area D prevented the planned use of the long-reach excavator.
March 2011                                                                   31

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
The dredging operations associated with Areas I, H, and G were performed as described
in the work plan and in Section 3.1.1. Several operational challenges were encountered
further downstream, in Areas F, E, D, C, and B. The original strategies for dredging these
areas were modified to address those challenges, as described in Sections 3.1.2 through
3.1.5.

3.1.1  Excavation Activities in Areas I, H, and G
Areas I, H, and G are located along the Main Branch of Ruddiman Creek, east of Barclay
Avenue (Figure 2-2). These areas are wooded, with large trees on the ravine slopes and in
the bottom flood plain. In order to allow remediation activities to proceed, large trees
were removed from the roadway footprint and the specific areas of the flood plain.
Access to Areas I, H, and G was through commercial properties off Sherman Boulevard,
and access to the staging pad was directly from Sherman Boulevard. The ravine was
reached using a steep-sloped access road cut down into the ravine, and a culvert bridge
was built to access Area G for excavation.
Area G: A 340-foot long temporary sheet pile wall was constructed along the south side
of the excavation areas in Area G concurrently with extending a timber swamp mat road.
After completion of a diversion ditch around Area Q excavation of the area began on
September 22, 2005, and work was completed on October 13, 2005. During this period,
346 dump-truck loads of excavated sediment were hauled to the staging pad for final
dewatering, yielding 6,995 tons of material for disposal.
Upon completion of excavation activities, samples were collected in the area to evaluate
achievement of cleanup goals. Two RMUs in Area G initially exceeded the cleanup
criteria (Section 5). Therefore, an additional four feet of sediment was removed in these
RMUs. After the excavation area recharged with groundwater, a final survey of Area G
was performed to determine the volume of sediment removed. The primary dredging
removed 5,524 cubic yards of sediment, and secondary dredging in the three sub-areas
removed an additional 700 cubic yards, for a total of 6,224 cubic yards. Ageotextile
membrane was placed over the excavation area and covered with a layer of sand and
stone, followed by collection of more confirmation samples. The geotextile was used to
prevent the sand from sinking into the peat formation at the bottom of the excavation.

"32                                                                       March 2011

-------
                                 DREDGING OPERATIONS AND DISPOSAL OF DREDGED MATERIAL
Areas H and I: Areas H and I were over-dredged by one foot so that the streambed could
be covered immediately after completing the confirmation sampling and post-dredging
surveying. This approach was necessary to minimize the impact of potential rain events
on the excavation area. Sediment removal activities in these areas began on October 14,
2005 and were completed on October 17, 2005. During this period, 364 dump-truck loads
of excavated sediment, weighing a total of 1,141 tons, were hauled to the staging pad for
dewatering and disposal. Confirmation sampling of the areas indicated that
concentrations of COCs were below the target levels, with the exception of total PCBs. A
total of 568 cubic yards of sediment were removed. A layer of sand was placed over the
excavated area, followed by placement of geotextile, and then a 6-inch stone layer.

3.1.2  Excavation Activities in Areas F and  E
Areas F and E each were divided into two RMUs. RMUs F2, Fl, and E2 were located on
the east side of Glenside Boulevard, while RMU El was located on the west side of the
same street.
RMUs F2 and Fl: After completion of the sheet pile dams and a diversion channel to
dewater these RMUs, excavation activities began on November 30, 2005 and were
completed on December 7,  2005. Each RMU was excavated to  a depth of 5 feet, with an
additional 2 feet excavated  in RMU F2. Because of continual sidewall failures, the EPA
On-Scene Coordinator was present during all periods of excavation below  5 feet. This
prevented unauthorized over-excavating of material (i.e., soil flowing into the excavation
from the work area). The EPA On-Scene Coordinator ensured that depth removal
objectives were achieved. After confirmation sampling of the RMUs demonstrated the
remediation objectives had  been achieved and no additional  excavation was needed, the
isolation dams were removed. A total  of 490 cubic yards of contaminated sediment were
removed from Area F during the remediation process. A 3-foot layer of sand backfill was
placed in Area F, covered by geotextile fabric, and a final 6-inch layer of rock backfill. In
addition, a riffle structure consisting of rock check  dams extending from the edge of the
wetland across the creek channel was installed as an erosion control measure to minimize
sediment migration during flood events.
March 2011                                                                      33

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
RMUs E2 and El: These RMUs were dredged while "wet," i.e., through standing water.
The excavation of RMU E2 was completed in a single day (December 7, 2005), and
excavation of RMU El was completed over a two-day period from December 13 to 14,
2005. Confirmation sampling of both RMU demonstrated the remedial objectives were
achieved and no additional excavation was needed. A total of 299 cubic yards of
contaminated sediment were removed from Area E. A riffle structure was constructed
(similar to the one in Area F) on January 5, 2006, as an erosion control measure.

3.1.3  Excavation Activities in Area D
A 41- to 43-foot thick peat formation underlay Area D and was unable to support an
access road or heavy equipment. Therefore, removal tactics within this area were
modified to accommodate the conditions. Several modifications  were made:
   •   Use of an amphibious excavator for sediment removal and backfill placement.
   •   Use of floating, interlocking HOPE road mats on the soft soils instead of the
       conventional road building materials used at other locations.
   •   Use of crawler carriers with a 2-cubic yard capacity (tracked dump trucks that
       exerted low ground pressures) to move excavated sediment and backfill to and
       from the excavation area.
   •   Deciding to over-dredge the work area by one foot to increase the probability that
       dredging efforts removed enough contaminated sediment during the first dredging
       pass.
As described in Section 2.5, Area D was isolated with sheet pile  dams. These sheet pile
dams, positioned upstream, at RMU El,  and downstream, at RMU C2, allowed the  creek
flow to be pumped  and redirected around Areas D and C and thus, bypass the excavation.
Dredging activities in Area D were conducted from February 22  through February 28,
2006. Although active dewatering was performed during the dredging process,
groundwater recharge on the isolated section was greater than the rate at which the water
treatment plant could process the water. Therefore, the team dredged Area D while wet.
Infiltration water was pumped to the water treatment plant, and excavated sediment was
shuttled to a mix pit located adjacent to RMU C2. Calciment® was used to solidify the
material in the mix pit before being transferred to the staging area for off-site disposal. A
total of 2,132 tons of sediment were hauled from Area D. The post-excavation survey was
34                                                                      March 2011

-------
                                 DREDGING OPERATIONS AND DISPOSAL OF DREDGED MATERIAL
performed by boat in this area, and indicated that 1,485 cubic yards of contaminated
sediment were removed.

3.1.4  Excavation Activities in Area C
Although Area C is downstream of Area D, remediation activities were initiated in Area
C prior to those in Area D to keep the project progressing while the access issues
associated with the peat formation in Area D were resolved as described in Section 3.1.3.
RMU Cl, as well as part of RMU C2, could be accessed with the long-reach excavator.
The remainder of RMU C2, and all of RMU C3, were excavated using the same approach
used for Area D.
RMU Cl and a portion of RMU C2 were isolated by sheet pile dams and actively
dewatered during the dredging process. Calciment® was mixed into the sediment in situ,
and the solidified material was transported to a staging pad for curing and eventual off-
site disposal.
The initial dredging activities in this area were completed on February 7, 2006, with a
total of 1,330 tons of material removed. A silt curtain was installed to further isolate the
area from flood events that might transport contaminants from the still unexcavated
portions of RMUs C2, C3, and D.
The remaining portion RMU C2 and  all of RMU C3 were also isolated by sheet pile dams
and actively dewatered during the excavation process. The material was removed using
an amphibious excavator (instead of the long-reach excavator), and shuttled wet to the
mix pit with crawler carriers (instead of dump trucks). A total of 1,201 tons of material
was removed from RMUs C2 and C3.
Confirmation sampling in Area C determined the cleanup objectives were not met in
RMUs Cl and C3. Therefore, additional 1,309 tons of material was excavated from
March 15 to 17, 2006.  Confirmation samples were collected and analyzed again to verify
cleanup objectives were met. A total of 3,482 tons of material was removed from Area C
(2,623 cubic yards).
March 2011

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
3.1.5  Excavation Activities in Area B
Area B was isolated by sheet pile dams and actively dewatered during the excavation
process. The downstream dam was constructed of PVC sheet piling to prevent sinking
into the peat formation. Excavation began on March 31, 2006. After the first 4 feet of
material was removed, the hydrostatic head differential between the pond and Area B was
too great, and water from the pond flowed up under the sheet wall into Area B. Several
efforts were made to seal out water with Calciment® dikes, but the excavation of Area B
had to be completed while wet. As a result of these conditions, Area B was over-
excavated by one foot, post-removal confirmation samples were collected, and restoration
proceeded without waiting for the sample results. Excavation was completed  on April  14,
2006. Removed sediments were transferred to a mix pit (built adjacent to the  primary
staging pad), where they were solidified with Calciment®. Site conditions in Area B
resulted in excessive sloughing of the creek bank and upwelling of sediment in the area,
making a post-excavation survey difficult within the constraints of the project schedule.
Therefore, after consultations among the project team members, the box-cut volume was
estimated based on the dimensions of the dredged area and combined with information on
the load volumes of the tracked  crawlers used to transport the sediment to the mixing pit.
That approach yielded an estimate of 2,038 cubic yards of contaminated sediment that
were removed from Area B. After completion of the post-excavation sampling, a
geotextile liner was placed over the entire excavation area and covered with a 6-inch
layer of sand backfill. All support infrastructures were then removed.

3.1.6  Sediment  Removed from Unsurveyed Areas
As noted in Section 3.1.5, portions of Area B presented difficulties  conducting a post-
excavation survey. Other areas of the creek also could not be surveyed due to other site-
specific conditions. Therefore, after discussions amongst the project team members, the
parties agreed on an estimate of 14,472 cubic yards as the total volume of sediment
remove from the creek. This estimate exceeds the sum of the volumes cited for the
individual areas above by approximately 745 cubic yards, and is referred to later in this
report as the volume of the "unsurveyed areas."
36                                                                     March 2011

-------
                                DREDGING OPERATIONS AND DISPOSAL OF DREDGED MATERIAL
3.2    EXCAVATION OPERATIONS WITHIN THE RUDDIMAN POND
       REMEDIATION AREA
To facilitate excavation efforts in Ruddiman Pond, the water level in the pond was raised
by two feet to increase the draft depth for the dredges and barges. Turbidity curtains were
placed in Ruddiman Pond to contain sediments in the work areas and avoid the release of
contaminated sediment during project activities, including dredging, sediment transfers,
and handling (Section 2.6). The water level was maintained below the level of the outfall
culvert of the West Branch of Ruddiman Creek, located west of the primary staging area,
to keep water from flowing into the West Branch.
Excavation operations within Ruddiman Pond were initiated at the upgradient end of the
pond and progressed toward  the outfall. The dredging sequence in the pond began in
RMU A5, subsequently progressing to RMUs A4, A3, and A2; and was completed in
RMU Al (Figure 2-2).  Due to barge access conditions and sediment migration control
measures, the original dredging sequence was modified slightly. For example, a portion
of RMU A3 was dredged to gain access to RMU A5 from the barge offloading pier.
One dredge plant and two material barges were used to dredge the pond (Figure 3-1). The
dredge plant consisted  of:
    •   A 40 x 40-foot sectional barge with spud attachments to fix the position during
       dredging,
    •   A long-reach excavator equipped with a Dredge Pack/Global Positioning System
       (GPS) and a 2.5-cubic yard environmental bucket,
    •   A harbor tug to position the barge, and
    •   An oil containment boom and absorbent boom deployed around the barge to
       contain oil released during dredging operations.
Each of the two material barges consisted of a 40 x 40-foot sectional barge with a 3-foot
high steel wall welded  in place two to four feet from the exterior perimeter. This created
an area with a storage capacity of 70 to 90 cubic yards of material. The barge and
dredging equipment were mobilized and launched from the offloading pier on September
1 and  2, 2005.
March 2011                                                                      37

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Figure 3-1    Tug and barge dredging operations within the Ruddiman Pond remediation
            area
A total of 75,398 cubic yards of contaminated sediments were removed from the pond.
Upon completion of the dredging activities, a 6-inch layer of sand was applied across the
pond floor. The coverage was verified by sampling the sand layer and analyzing the sand
samples for the contaminants of concern (Section 6). After COC concentrations in the
sand layer were verified to be below the associated target levels, a layer of rock was
applied on top of the sand across the pond area (Section 7 includes a discussion of sand
and rock layer application). A total of 8,056 cubic yards of rock and 15,225 cubic yards
of sand were applied in the pond.

3.3   TRANSPORT AND DISPOSAL OF CONTAMINATED SEDIMENTS
The offloading pier served as the point of departure and port for all dredging operations
involving the dredge plant and material barges. The barges with dredged sediment were
pumped free of standing water, which was then transferred to the on-site water treatment
plant (Section 4.2.2).
38
March 2011

-------
                                 DREDGING OPERATIONS AND DISPOSAL OF DREDGED MATERIAL
An excavator was used to mix Calciment® into the contaminated sediment, as shown in
Figure 3-2. Some fugitive dust was generated from the Calciment® during mixing, as
seen in Figure 3-2, and while efforts were made to minimize such dust, it could not be
eliminated. The sediment was solidified before being loaded into dump trucks for hauling
to the staging area. The solidification process released heat from the wet sediments,
resulting in the steam seen rising from the mixture in Figures 3-3 to 3-5. The primary
staging area used to dewater sediments removed from the pond and from Area B of the
creek was located across from McGraft Park on the north side of McGraft Park Road.
Three additional, temporary staging areas were used to load and transport  solidified
sediments from all other areas within the creek.

Figure 3-2   Solidification of Ruddiman Pond sediment
Excavated sediment that had been mixed with Calciment® was hauled to a drying bed for
dewatering and solidification. The perimeter of the specially constructed drying bed was
made of interlocking concrete blocks forming a rectangle (Figure 3-3). The foundation of
the drying bed was made of sand, topped by a waterproof, heat-sealed, heavy plastic
March 2011
39

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
membrane. All drainage from the sediment was collected in porous plastic pipe on top of
the plastic liner and pumped to the treatment system (Section 4.2.2).
Figure 3-3   Sediments mixed with Calciment  in the drying bed
The original plan included solidifying the sediment from Ruddiman Creek with
Calciment®, and the sediment and Calciment® mixture subsequently would be hauled to a
drying bed for dewatering and solidification. However, this process was not feasible in
some areas. Therefore, to minimize handling of wet sediment, active dewatering of the
dredged materials was employed during dredging.
In Areas F, Q H, and I, Calciment® was added to the sediment in place. In other areas,
Calciment® was added in a mix pit intermediate to the final staging area as the sediment
was being removed or in the barge (Figure 3-4).
40
March 2011

-------
                                 DREDGING OPERATIONS AND DISPOSAL OF DREDGED MATERIAL
Figure 3-4   Addition of Calciment to sediments on the dredging barge
Area E was excavated while completely wet, and then the dredged sediment was
transferred to the final staging and dewatering area at the pond. The material was allowed
to sit and drain so that free water could be decanted off before the material was
transported to the off-site landfill.
The contaminated water from the drying bed, along with other contaminated water from
sediment removal operations, was treated to a level  deemed acceptable by Muskegon
County, and then pumped to a sewer manhole that drains to the Muskegon County
Wastewater Facility for final processing. Atotal of 3,241 truckloads (157,645 tons) of
creek and pond sediments, staging pad materials, and road material waste were
transported approximately 22 miles to the Ottawa Farms landfill in Coopersville,
Michigan, for disposal (Figure 3-5).
March 2011
41

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Figure 3-5   Loading treated sediment for transportation to the Ottawa Farms landfill
42
March 2011

-------
                             ENVIRONMENTAL MONITORING OF REMEDIATION ACTIVITY IMPACTS
       ENVIRONMENTAL MONITORING OF REMEDIATION ACTIVITY
       IMPACTS
Environmental monitoring was undertaken to ensure the remediation activities were not
adversely affecting the health of the ecosystem, the surrounding environment, or the
remediation staff, and were not causing exceedances of applicable federal, state, and local
standards. Air quality was monitored prior to, and throughout the project, as described in
Section 4.1. Water quality was monitored during the project as described in Section 4.2.

4.1    AIR MONITORING
Air quality  was monitored at the site prior to and during dredging operations. Air
monitoring used National Institute for Occupational Safety and Health (NIOSH) air
sampling methods for project-specific COCs, as well as real-time air monitoring for
VOCs and particulates. Table 4-1  summarizes the air monitoring/sampling activities,
parameters, frequencies, and action levels.
Table 4-1   Air Monitoring/Sampling Activities, Parameters, Locations, Frequencies, and
           Action Levels
   Activity
Parameter/
 Method
Locations/Tasks
Frequency
 Basis for Corrective
Action & Action Levels
Perimeter Air
Sampling -
Background
Perimeter Air
Sampling -
Definitive
PCBs by NIOSH
5503
Metals by
NIOSH 7300
Results in 2
working day
PCBs by NIOSH
5503
Metals by
NIOSH 7300
Results in 2
working day
Pond: 4 locations*
Pond: 4 locations*
Creek: 3 locations*
All locations were
sampled on 2
separate events prior
to any dredging
operations.
All locations were
sampled the first 6
days of dredging
operations and every
14 days of dredging
operations thereafter.
Corrective action taken if
the following action
levels were exceeded for
one day:
• PCBs: 0.5 mg/m3
• Cadmium: 0.2 mg/m3
• Chromium: 0.5 mg/m3
• Lead: 0.05 mg/m3
Corrective action taken if
the following action
levels were exceeded for
one day:
• PCBs: 0.5 mg/m3
• Cadmium: 0.2 mg/m3
• Chromium: 0.5 mg/m3
• Lead: 0.05 mg/m3
March 2011
                                                               43

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Table 4-1   Air Monitoring/Sampling Activities, Parameters, Locations, Frequencies, and
           Action Levels
   Activity
Parameter/
 Method
Locations/Tasks
Frequency
 Basis for Corrective
Action & Action Levels
Perimeter Air
Monitoring -Real
Time






Personnel Air
Monitoring






VOCs by
MultiRAE
PLUS
Participates by
Pprcnnpl
n oi oui loi
DataRAM
L/C! LCI r\rA I v I
Results
available
immediately
PCBs by NIOSH
5503
Metals by
NIOSH 7300




Pond: 4 locations*

Creek: 3 locations*






Pond: 1 location
(dredge operator)

Creek: 1 location in
each section of the
creek (excavator
operator)

All locations were
monitored every 2
hours throughout the
work day on any day
that dredging (pond)
or excavation (creek)
operations were
conducted.


Each task was
sampled the first 6
days of dredging
operations and every
14 days of dredging
operations thereafter.


Corrective action taken if
a > 5 parts per million
total VOCs reading was
sustained for 15 minutes
or if a visible dust plume
was seen moving from
the work areas



Corrective action taken if
the following action
levels were exceeded for
one day:
• PCBs: 0.5 mg/m3
• Cadmium: 0.2 mg/m3
• Chromium: 0.5 mg/m3
• Lead: 0.05 mg/m3
* Three of the four pond sampling stations were located downwind (adjacent) to pond operations to reflect
  site conditions and one was located upwind of pond operations to reflect daily background levels. Two of
  the four creek sampling stations were located downwind and one was located upwind of creek operations.
Air sampling stations were located along the perimeter of the Ruddiman Creek site as
illustrated in Figure 4-1. Samples were collected from each of the pond perimeter stations
prior to initiation of dredging operations on two separate days to establish background
atmospheric levels for cadmium, chromium, lead,  and PCBs. Upon initiation of dredging
operations, samples were collected from the same stations during first six days of
dredging operations and every 14 days of dredging operations thereafter. Air
concentrations were determined using NIOSH Method 5503 for PCBs and NIOSH
Method 7300 for metals. No exceedances were measured during work activities.

Air monitoring samples were shipped to a laboratory for analysis. The laboratory
provided the analytical results within two business days of sample receipt. The analytical
results were verified by reviewing the QC sample  results reported by the laboratory. To
ensure that project-specified action levels for cadmium, chromium, lead, and PCBs were
not exceeded at the Ruddiman Creek site, the field sample data obtained from  a
downwind monitoring station were compared to the correlated upwind (background) field
sample data and to the established project-specific action levels identified in Table 4-1.
44
                                                          March 2011

-------
                              ENVIRONMENTAL MONITORING OF REMEDIATION ACTIVITY IMPACTS

   .Jf,  TURBIDITY STATION

   •  AIR MONITORING STATION
(htofl nn »n him IT/ fmitrnnnnUl ("Unity M«fno
-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
To evaluate potential worker exposure, personnel air monitoring was conducted for those
individuals identified as having the highest probability of exposure; specifically, the
dredge operator at the Ruddiman Pond work area and the excavation operator at the
Ruddiman Creek Main Branch work area. Personnel air monitoring for cadmium,
chromium, lead, and PCBs was performed once per day during the first six days of
dredging operations, and on a biweekly basis thereafter, using the NIOSH methods
specified above.

4.2    WATER MONITORING AND TREATMENT
Two types of water quality monitoring were conducted during the  project. Turbidity
measurements were collected in Ruddiman Creek and Pond to determine the impact of
dredging and sediment removal activities. These surface water monitoring activities are
described in Section 4.2.1. In addition, wastewater samples were collected from the on-
site wastewater treatment system and analyzed for a variety of parameters, as required by
the Muskegon County Wastewater discharge permit issued for the  project. These
wastewater treatment and monitoring activities are described in Section 4.2.2.

4.2.1   Surface Water  Monitoring
The remediation activities within Ruddiman Pond required installation of turbidity
curtains to contain suspended sediments and prevent contaminated sediment from
migrating off site (see Figure 2-10). In order to verify the effectiveness of the silt
curtains, it was necessary to establish the baseline levels of turbidity in the creek and
pond. Therefore, prior to the start of dredging, turbidity was measured every two hours,
over several  days, to determine baseline turbidity levels and establish action levels for
later use.
Once  dredging began, turbidity was measured daily in both the creek and the pond to
assess water quality. Water quality samples were collected at three fixed monitoring
locations. Each water quality monitoring station consisted of a TROLL 9000 turbidity
meter, data logger, telemetry unit, and a solar-powered panel. The  water quality
monitoring stations were placed at approximately half the maximum depth of the water
level at each location (Figure 4-1).

46                                                                      March 2011

-------
                              ENVIRONMENTAL MONITORING OF REMEDIATION ACTIVITY IMPACTS
Each turbidity meter was programmed to record measurements at half-hour intervals. The
turbidity data were downloaded in one-hour intervals during removal activities. Turbidity
was measured in the Main Brach of Ruddiman Creek both upstream and downstream
from the locations where removal activities took place. Each location was treated as an
isolated work area (see Section 2.2  for a discussion of work area delineation). Grab
samples of creek water were collected both upstream and downstream of a given work
area each day prior removal activities and every four hours thereafter. The turbidity of
these grab samples was measured using a hand-held turbidity monitor (Horiba Water
Quality Checker U-10) and results were recorded in the site log book.
In addition to turbidity monitoring,  surface water was monitored for oil sheens during
dredging, and floating oil booms were placed around each dredge area as a precautionary
measure.
As a result of difficulties in establishing baseline turbidity levels and accounting for the
effect of rain events on turbidity, exceedances of the action level for turbidity tended to
occur frequently. When the turbidity was elevated in the Main Branch of Ruddiman
Creek or exceeded the action levels established for the pond, the reading was confirmed
by taking a second measurement. If the readings continued to exceed action levels after
60 minutes, the following actions were taken:
   •   The turbidity meter was checked for accuracy and calibration.
   •   A second (hand-held) meter was used to confirm the initial readings.
   •   If an exceedance was observed, the result was immediately reported to the On-
       Scene Coordinator.
   •   Potential causes of the elevated levels were evaluated. This included observing
       conditions in the area of the monitoring location for any sign of wildlife or other
       external stimuli that could have caused an increase in turbidity, evaluating the
       readings immediately before the elevated reading(s), evaluating weather
       conditions, inspecting the turbidity curtain in the pond, and evaluating the
       controls used in the creek.
   •   Dredging and excavation activities were halted until the source of increased
       turbidity was determined  or the measurements were below the action level.
March 2011                                                                        47

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
4.2.2  Wastewater Monitoring and Treatment
As discussed in Section 2.5, temporary dams and diversion channels were constructed to
isolate excavation areas along Ruddiman Creek Main Branch. To further minimize water
in these areas, groundwater and surface water that had accumulated from storm events
were pumped to an on-site water treatment system, depicted in Figure 4-2. This system
was also used to treat water generated during dewatering activities at the offloading pier
and at each of the sediment staging areas. Atotal of 5,374,850 gallons of wastewater from
the combined generation points was treated with the on-site system and discharged to the
Muskegon County publicly owned treatment works.
Figure 4-2   On-site treatment system
The on-site treatment system was configured to remove particles by settling and filtration
and to remove organic compounds by sorption on activated carbon. The system included:
   •   A 21,000-gallon equalization tank.
   •   A 18,000-gallon weir tank.
   •   A 4-inch trash pump.
   •   Sand filters.
                                                                        March 2011

-------
                             ENVIRONMENTAL MONITORING OF REMEDIATION ACTIVITY IMPACTS
   •   Bag filters fitted with 10-micron bags.
   •   Cartridge filter housings fitted with 0.5-micron filters.
   •   An activated carbon system (configured with two parallel trains of lead vessels
       and lag vessels).
   •   A flow meter.
   •   An automatic sampler.
The equalization tank and weir tank were used as a reservoir when the sporadic flow of
water from dewatering activities did not require operating the treatment plant. As a result,
the plant operated only a few days some months (i.e., only six days in November 2005).
Composite and grab samples of treated effluent were collected using a time-based,
refrigerated automated sampling device and analyzed for the water quality monitoring
parameters defined in the discharge permit issued by the Muskegon County Wastewater
Management System (Permit #RUDD-s01a, June 15, 2005) and detailed in Table 4-2.
The samples were delivered to an analytical laboratory on the day of collection.
 Table 4-2  Wastewater Quality Monitoring Parameters
    Parameters for Composite Samples
 Metals:  Cadmium, Chromium, Copper,
         Lead, Mercury, Nickel, Silver
 Cyanide
 Phosphorus
 SVOCs:  bis(2-Ethylhexyl)phthalate,
         Naphthalene
       Parameters for Grab Samples
PH
Total Suspended Solids
Biochemical Oxygen Demand
Flashpoint
Ammonia
VOCs:  Acetone, Tetrachloroethene, Toluene,
       1,1,1-Trichloroethane
The flow discharged from the on-site water treatment system to the Muskegon County
Wastewater Management System was measured with using a flow meter. The maximum
allowed flows were 200 gallons per minute and 200,000 gallons per day discharged into
the 30-inch public sewer. The flow meter was monitored on an hourly-basis to document
the discharge was within the permit limits.

In November and December 2005, staff at the Muskegon County Wastewater
Management System notified the project team to indicate there were issues with the self-
monitoring reports submitted for October and November 2005. Noted issues included that
samples were collected using inappropriate techniques and reports were delivered late. In
addition, the November 2005 results for biochemical oxygen demand and pH were ruled
March 2011
                                       49

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
invalid; therefore, the permitting authority did not use those results. As a consequence,
the on-site treatment plant was ruled out of compliance for October and November 2005.
The project team corrected the sample collection procedures for all future sampling
events, and records indicate the treatment plant was in compliance with its discharge
permit from January 2006 through April 2006, when it ceased operations.
50                                                                       March 2011

-------
                                        SEDIMENT CONFIRMATION SAMPLING AND ANALYSIS
5.0    SEDIMENT CONFIRMATION SAMPLING AND ANALYSIS
A statistical sampling design was developed to determine if enough contaminated
sediments were removed to meet the cleanup target levels for all COCs (see Section
1.7.2). The basis of the statistical sampling design is described in Section 5.1. Sections
5.2 and 5.3 provide additional details concerning implementation of the sampling design
at the site, including the location of sampling points, sample collection procedures,
analytical procedures, and quality control strategies.

5.1   SEDIMENT CONFIRMATION SAMPLING DESIGN
A statistical sampling design for collection and analysis of sediment confirmation
samples was developed to determine whether concentrations of all COCs were below pre-
established site-specific cleanup target levels in the Ruddiman Creek Main Branch and
Pond remediation areas. The sampling design was developed in accordance with the Data
Quality Objective (DQO) process, EPA's seven-step systematic planning process  and
Guidance on Choosing a Sampling Design for Environmental Data Collection (for Use in
Developing a Quality Assurance Project Plan)  (EPAQA/G-5S). The sampling design
served three purposes:
   •  Determine whether site-specific cleanup target levels were achieved.
   •  Establish the level  of residual contamination remaining after dredging activities
      were been completed.
   •  Establish a baseline from which to monitor residual management.
Attachment E to the QAPP provides detailed information on technical approach for the
sediment confirmation sampling design and residual analysis.

5.1.1 Technical Approach to Statistical  Sampling Design

To confirm that dredging activities had achieved the target levels for all COCs, a  grid
system was established over the entirety of the  project area. The system consisted of 100
x 100-foot (10,000 square foot)  grids, each of which was designated as a RMU. Thirteen
RMUs were established in the dredging areas along Ruddiman Creek Main Branch and
twenty-five RMUs were established along Ruddiman Pond, as presented in Table 5-1 and
Figures 5-1 and 5-2.

March 2011                                                                      51

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
| Table 5-1 RMUs in Ruddiman Creek and Ruddiman Pond
Remediation Area
Ruddiman Pond
Ruddiman Creek
Main Branch

Remedial Ma
iMumoer OT KIVIUS
A1
A2
A3
A4
A5
B
C
D
E
F
G
H, I
1
8
7
1
8
2
2
3
2
2
2
2
nagement Unit (RMUs)
RMU Designation
A03
A01 -A02,A04-A09
A10-A15, A18
A16
A17, A19, A20-A25
B1 -B2
C1 -C3
D1 -D3
E1 -E2
F1 -F2
G1 -G2
H&l
Figure 5-1    Remedial management units within Ruddiman Creek Main Branch
52
March 2011

-------
                                         SEDIMENT CONFIRMATION SAMPLING AND ANALYSIS
Figure 5-2   Remedial management units within Ruddiman Pond
5.1.2  Decision Statement
As part of the DQO process, a decision statement was developed for confirmation
sampling. The principle study question associated with post-excavation sediment
sampling and residuals analysis was identified as follows:
       "Has the dredging removed the contaminated sediment sufficiently to
      proceed with placement of the residual cover? "
It was agreed that additional remedial activities would be considered in a given RMU if
the average concentration of any COC in the RMU exceeded the project-specific cleanup
criteria. GLNPO and MDNRE were responsible for determining whether to perform
further dredging activities or to proceed with placement of the residual cover based on
analytical sediment analysis results and other project factors such as logistics and
resources.
March 2011
53

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
A statistical power analysis was conducted and a power curve developed for optimizing
the sampling design in the style recommended by EPA's Guidance for the Data Quality
Objective Process (EPA QA/G-4). To develop the power curve, existing sediment data
were needed to estimate the variability that might be expected in the sediment
confirmation sample concentrations collected in support of the remediation effort.
Sediment contaminant data collected in the 19992 and 20023 pre-remediation
investigations were used for this purpose. This was a conservative approach in terms of
protection of the environment, since the contaminant concentrations in the post-remedial
confirmation samples  were expected to have lower variability than the pre-remedial
samples. These historical data demonstrated strong log normality and a definable
variogram4 with a non-symmetrical range. Therefore, the data were log-transformed for
use in developing the  sampling design.
Part of process  of developing the power curve involved specifying limits for the
acceptable decision error, based on the chances of a false positive or false negative
decision. For a remediation project, a false positive decision is an incorrect determination
that a COC was still present above the target level, and could result in unnecessary
additional remediation and dredging. A false negative decision is an incorrect
determination that the COCs were no longer present at target levels, and could result in
unwanted risks to human health and the environment.
The sediment confirmation sampling strategy was designed to achieve 90 percent power
in detecting an exceedance of the target level when the true average concentration of a
contaminant of concern in the RMU is greater than the target level. This allowed
decisions to be  made with false positive rates of 20 percent (or confidence of 80 percent)
and false negative rates of less than 10 percent (or power of 90 percent).
    Remedial Investigation ofRuddiman Creek, Muskegon, Michigan, prepared by Earth Tech for
    MDNRE, Surface Water Quality Division, June 17, 2002.
   3 Phase II Site Investigation Report, prepared by DLZ for MDNRE, Surface Water Quality Division,
    October 2000.
   4 A variogram is a key function in geostatistics that can be used to characterize the roughness of a data
    set.
54                                                                        March 2011

-------
                                         SEDIMENT CONFIRMATION SAMPLING AND ANALYSIS
5.1.3  Confirmation Sample Locations
Based on the power curve and acceptable decision error, four sediment samples per RMU
were determined to be necessary for evaluating the post-remediation site conditions
against the project cleanup criteria. Therefore, each of the 100 x 100-foot RMUs was
divided into four equal 50 x 50-foot cells, as illustrated in Figure 5-3, using RMU A01 as
an example.
                                 A-01a
                                               RMU A-01
         Legend
         A    Sample
              Subsamplefor
              composite
              RMU
       Figure 5-3   Sampling grids in Ruddiman Pond RMU A01
This approach yielded a total of 152 cells overlaying the Ruddiman Creek Main Branch
and Pond dredging areas, and provided adequate coverage over the entire dredge area.
Section 5.2 describes the procedures for collecting and homogenizing these confirmation
samples.

5.1.4  Data Interpretation
Statistical tests were used to evaluate whether the remediation activities achieved the
project-specific goals. Those tests were based on a null hypothesis (Ho) that the
concentrations of the contaminants of concern were less than project-specified target
levels. The decision rules for the project-specific COCs are presented in Table 5-2.
March 2011
                                                                                55

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
| Table 5-2 Decision Rules for Achieving Project-Specific Remediation Goals |
Contaminants Null (H0) and Alternate (hU Hypotheses 1
Cadmium and Chromium
Lead
Total PCBs
Benzo(a)pyrene
H0: Cadmium < 10 mg/kg or Chromium <
H-i: Cadmium > 10 mg/kg and Chromium
400 mg/kg
> 400 mg/kg
H0: Lead < 900 mg/kg
H-i: Lead > 900 mg/kg
H0: Total PCBs < 1 mg/kg
H-i: Total PCBs > 1 mg/kg
H0: Benzo(a)pyrene < 16 mg/kg
H.,: Benzo(a)pyrene > 16 mg/kg
Note that the alternate hypothesis (Hj) for cadmium and chromium is based on observing
both cadmium above 10 mg/kg and chromium above 400 mg/kg. Cadmium and
chromium were chosen as the two metals of greatest concern at this site. The combination
of the two metals was used as the cleanup target level based on the sediment toxicity data
collected during the earlier remedial investigation (Earth Tech, 2002). Specifically, the
observed sediment toxicity could not be related to the observed concentrations of any
single metal in the sediment samples. However, there was a correlation between the
mortality ofHyallela azteca and the total metal concentration. Therefore, the decision
rule for the metals was based on the combined effects of cadmium and chromium.

The average concentration of each COC was calculated for each of the 100 x 100-foot
RMUs and compared to the respective cleanup target levels. If the average concentrations
observed in a given RMU exceeded the corresponding target levels, then additional
remedial activities (e.g., dredging and excavation) were considered, based on the level of
exceedances observed, the distribution of contaminants, and other site-specific
considerations. Section 6 provides the results and a discussion of these comparisons.

5.2    SAMPLING AND ANALYSIS
Sediment confirmation sampling was conducted after the initial remediation activities
were completed, generally as described in Section 5.1. However, there were a few
instances where modifications to this design were necessary due to unique operational
challenges or to facilitate achievement of overall project objectives. Results of sediment
confirmation sampling are presented and discussed in Section 6. Modifications to the
56
March 2011

-------
                                         SEDIMENT CONFIRMATION SAMPLING AND ANALYSIS
sampling design, related operational challenges, and subsequent decision making
processes are also discussed in associated area-specific sections within Section 6.

5.2.1  Sampling Methods
The sampling design called for collecting one homogenized composite sample from each
50 x 50-foot cell, yielding four routine field samples (RFS) per RMU, for a total of 160
samples collected. One surficial sample (0 to 6 inches in depth) was collected from the
center of each quadrant of each of 50 x 50-foot grid, and then used to form four
composite samples per RMU (Figure 5-3). Depending on conditions, samples were
collected with a Ponar sampler, an Eckman dredge, or a disposable scoop. Correct grid
placement for sample collection was determined and documented using GPS equipment
and staking procedures. The actual sample location coordinates were recorded prior to
sampling.
The four grab samples collected within each 50 x 50-foot cell were composited in a clean
stainless steel bowl and thoroughly homogenized using clean stainless steel spoons and
spatulas. Because thorough homogenization of the samples prior to filling the sample
containers was critical for creation of representative composite samples, unrepresentative
material such as stones and wood chips were removed, and the sample was mixed until
uniform texture and color were obtained. The details of all sampling activities were
recorded in field log books.
Due to the importance of the sediment confirmation sample results in evaluating the
success of the remediation effort, the sediment confirmation samples were supplemented
with a suite of QC samples, including:
   •   Field Split Samples (FSS) were prepared by using extra volume from each
       composite created when preparing the RFSs. At least 15 sets of these splits (i.e., a
       10 percent frequency) were prepared at randomly selected locations provided
       where RFSs were collected. An additional two sets of splits were prepared at
       locations sampled after the secondary dredging activities. The FSSs were placed
       in the same type of jars that were used for the RFSs and labeled in the same
       fashion as the  routine field samples. Thus, the samples were submitted to the
       laboratory "blind."
   •   Matrix Spikes/Matrix Spike Duplicates (MS/MSD) were prepared by using extra
       volume of the  final homogenized composite material from the RFSs. The goal

March 2011                                                                      57

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
       was to collect MS/MSD aliquots at a frequency of 10 percent (i.e., 15 pairs). At
       least 21 sets of MS/MSD aliquots were submitted to the laboratory. Unlike the
       FSSs, which were sent as "blind" QC samples, the MS/MSD samples were clearly
       designated as QC samples for the laboratory staff. Locations of the MS/MSDs
       were selected at random by the samplers.
5.2.2  Analytical Methods
Sediment sample analyses were performed by the MDNRE Environmental Laboratory.
SW-846 Method 8082A was used to determine PCBs. MDNRE Environmental
Laboratory SOP 500, which is based on SW-846 Method 8270 and employs gas
chromatography with mass spectrometry as the detection system, was used to determine
BaP. MDNRE Environmental Laboratory SOP 349, which is based on EPA Method 200.8
and employs inductively coupled plasma spectrometry with mass spectrometry detection,
was used to determine cadmium, chromium, and lead.

5.3    QUALITY OF SEDIMENT CONFIRMATION DATA
Due to the importance of the sediment confirmation samples in determining whether
remedial activities had achieved project objectives, all the data were reviewed as
described in the QAPP (Environmental Quality Management, 2005). In addition, results
were evaluated to verify they provided sensitivity, precision, accuracy, representativeness,
completeness, and comparability required to support these decisions. This section
provides a brief description of the results of the assessment.
   •   Sensitivity: The laboratory's reporting thresholds for cadmium, chromium, and
       lead were sufficient to meet both the action and reporting levels specified for the
       project all samples analyzed. Although  the laboratory's nominal reporting
       thresholds for BaP and PCBs were sufficient to meet both the action and reporting
       levels established for the project, the actual reporting levels the laboratory
       achieved were elevated by both the moisture and any analytical interferences
       present in the sediments. Both of these factors substantially increased the actual
       reporting limits, and a few samples exceeded the reporting limit goals established
       in the QAPP. In a few cases, the PCB reporting limits for an individual sample
       exceeded the total PCB cleanup criterion. The elevated reporting limits were still
       sufficient to meet the cleanup criteria specified for BaP in all samples analyzed.

58                                                                     March 2011

-------
                                         SEDIMENT CONFIRMATION SAMPLING AND ANALYSIS
    •   Precision: Precision was examined in two ways: (1) by comparing results of RFSs
       with their field duplicate samples to assess precision of the entire sampling and
       analytical system, and (2) by comparing results from MS samples with their MSD
       pairs to determine analytical precision. In all cases, analytical precision was
       within the acceptable ranges specified in the QAPP. The QAPP did not specify
       criteria for acceptable field precision, so a default value of 50 percent was used,
       and was met in all cases in which field precision could be calculated.
    •   Bias: Analytical bias was estimated by calculating recoveries of the COCs in
       various QC samples. Although some negative bias was observed for each COC,
       those biases were within the acceptance  criteria specified in the QAPP.
    •   Completeness and Representativeness: The sediment confirmation sampling
       strategy was intended to generate data that were representative of the entire area
       of interest. All collected samples were analyzed for the target COCs.
       Subsequent sampling activities were targeted in areas where sample confirmation
       results suggested that remediation goals  had not been met, as described in Section
       5.1.4. For example, following the initial  dredging of Ruddiman Pond Area A3, the
       analytical results for the confirmation samples suggested some concentrations
       were slightly above the established action levels. To ensure that project budgets
       could be directed at re-dredging those areas with the most significant contaminant
       residues, the technique of "kriging" was used in Area A3. Kriging is a spatial and
       variance interpolation method used to predict values across the site by using data
       from known locations. Kriging can be used to compute best linear unbiased
       estimates and create contours, or isopleths, of data across an area. The data for
       Area A3 were kriged using a smaller (10 x 10) sampling grid, which was used to
       identify the locations of a new subset of samples that would be representative of
       the areas in which re-dredging was determined to be necessary.
    •   Comparability: Comparability is the confidence with which one data set can be
       compared to other data sets. Sediment confirmation data were generated using
       standard analytical methods. All the sampling and analytical procedures used in
       evaluating sediment conditions in this project were well-documented and are

March 2011                                                                        59

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
       available in the QAPP, facilitating comparability of the sediment confirmation
       results.
60                                                                        March 2011

-------
                                                                PROJECT RESULTS
6.0    PROJECT RESULTS
Sediment confirmation samples were collected in the Ruddiman Creek Main Branch and
Pond remediation areas based on the statistical sampling design described in Section 5.1.
The initial set of sediment confirmation samples was collected immediately following the
first phase of dredging operations (primary dredging). In most cases, each RMU was
evaluated by comparing the mean concentrations of the COCs from the four samples
collected in each RMU to the target levels for the project (shown in Section 1, Table 1-1).
Additional dredging or other cleanup actions were undertaken if the mean concentration
exceeded the target levels for lead, total PCBs or BaP, or if the mean concentration for
both chromium and cadmium exceeded their target levels.  Results from the post-primary
dredging sediment sampling indicated high levels of contamination still remained in a
subset of RMUs in the creek and pond. In general, subsequent dredging and sampling
activities were performed in accordance with project-specific decision rules as detailed in
the project QAPP and described in Section 5.1.2.
Sediment confirmation sampling efforts in the creek and pond remediation areas are
summarized in Sections 6.1 and 6.2, respectively. Section  6.3 describes the volumes of
sediment removed. Section 6.4 describes the results of the final confirmation samples.

6.1    POST-DREDGING SEDIMENT CONFIRMATION SAMPLE RESULTS IN
       RUDDIMAN CREEK MAIN BRANCH
6.1.1   Post-Primary Dredging Sediment Sample Results for Ruddiman
       Creek
Initial removal activities were completed within the Ruddiman Creek Main Branch
remediation area on September 22, 2005. A total of 60 post-primary dredging sediment
samples were collected and analyzed. With the exception of RMUs Cl, D2, and D3, four
post-primary dredging samples were collected from each of the 13 RMUs in the creek
remediation area. Additional samples were collected within RMUs Cl, D2 and D3.
As discussed in Section 3.1.3, Area D was characterized by a thick formation of peat, and
removal tactics and objectives were modified to accommodate these conditions.
Specifically, RMUs D2 and D3 were over-dredged by an additional foot during primary
dredging activities, after which, four confirmation samples were collected in each of

March 2011                                                                    61

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
these RMUs. Rather than wait for the results from the confirmation samples, the sand and
stone cover was immediately applied in RMUs D2 and D3. However, additional
problems were encountered during placement of the residual cover that required the
placement of a new cover over the affected areas (see Section 7). As a result, two more
samples were collected from RMUs D2 and D3 after the second placement of cover.
In response to a flood event in RMU C2, additional sampling was conducted in Area Cl.
As described in Section 3.1.4, because of the possibility that materials from RMU C2
could have migrated into RMU Cl during the flood event, RMU C2 was re-dredged.
Therefore, four more samples were collected from RMU Cl  following completion of re-
dredging and upstream activities.
Table 6-1 presents summary-level results for all 60 post-primary dredging confirmation
samples for the creek remediation area. The individual sample results are included in
Appendix A of this report.
Table 6-1  Summary of Mean Concentrations Observed Among All RMUs in Ruddiman
          Creek Main Branch, Post-Primary Dredge Confirmation Samples
  Contaminant of    Cleanup
    Concern       Criterion
Number of RMUs   RMUs with COCs   Pooled  Minimum   Maximum
Meeting Cleanup     Exceeding      RMU     RMU      RMU
   Criterion      Cleanup Criterion   Mean1    Mean      Mean
Total PCBs (ppb)
Cadmium/Chromium
(ppm)
Lead (ppm)
Benzo[a]pyrene (ppb)
1,000
10
400
900
16,000
10/13
11/13
13/13
13/13
G1.G2, H&l
C1.C3
Not applicable
Not applicable
809
6.1
375
202
3,653
0
1.1
45
19
2,031
3,260
12.3
812
376
7,675
1 Calculated as the mean of the 13 individual RMU means
ppb = parts per billion = ug/kg
ppm = parts per million = mg/kg
Primary dredging effectively removed the contaminated sediments in eight of the 13
RMUs, with mean concentrations in the confirmation samples below the target levels for
all the COCs in those eight RMUs. Three RMUs exceeded the target levels for total
PCBs, and two RMUs exceeded the target levels for both cadmium and chromium. All 13
of the RMUs achieved target levels for lead and BaP.
RMUs Gl, G2,  and H and I exceeded the total PCB target level of 1,000 ppb, with mean
total PCB concentrations for these RMUs ranging between 1,690 and 3,260 ppb. RMUs
Cl and C3 exceeded target levels for both cadmium and chromium, with mean cadmium
62
                                              March 2011

-------
                                                               PROJECT RESULTS
concentrations of 12.3 and 10.1 ppm, respectively, and mean chromium concentrations of
812 and 553 ppm, respectively.

6.1.2  Post-Secondary Dredging Sediment Sample Results for Ruddiman
       Creek
Eight post-secondary dredging sediment confirmation samples were collected and
analyzed from the creek remediation area following secondary dredging activities; four
each in RMUs Cl and C3. The mean concentrations of all the COCs in these samples fell
below the target levels in RMU Cl, and only exceeded the target level for chromium in
RMUC3.
As discussed in Section 3.1.1, removal activities in RMUs Gl and G2 were modified due
to problems with groundwater recharge. The initial secondary dredging plan included
removal of two feet of sediment; however, a total of four feet of sediment was removed.
A residual cover was placed in RMUs Gl and G2 without the collection of post-
secondary dredging confirmation samples. RMU Gl was re-sampled after placement of
the residual cover (Section 7). Results of the final confirmation samples are discussed in
Section 6.4.
As discussed in Section 3.1.1, Areas H and I were over-dredged during primary dredging
activities by one foot so that the streambed could be covered immediately after
completing the confirmation sampling. This approach was necessary to minimize the
impact of potential rain events on the excavation area; therefore, post-secondary dredging
confirmation sampling was not conducted in these areas. A layer of sand was placed over
the excavated area, followed by placement of geotextile, and then a 6-inch stone layer.

6.2    POST-DREDGING SEDIMENT CONFIRMATION SAMPLE RESULTS  IN
       RUDDIMAN POND REMEDIATION AREA
6.2.1  Post-Primary Dredging Sediment Sample Results for Ruddiman Pond
Initial removal activities were completed within the Ruddiman Pond remediation area on
September 19, 2005. A total of 100 post-primary dredging sediment samples were
collected in the pond remediation area; four samples from each of the 25 RMUs.
March 2011                                                                   63

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Table 6-2 presents summary-level results of all 100 post-primary dredging confirmation
samples for the pond remediation area. The individual sample results are included in
Appendix A of this report.
Table 6-2  Summary of Mean Concentrations Observed Among All RMUs in Ruddiman
          Pond, Post-Primary Dredge Confirmation Samples1
                          Number of RMUs   RMUs with COCs   Pooled   Minimum  Maximum
                          Meeting Cleanup     exceeding     RMU     RMU      RMU
Contaminant of    Cleanup   ..  ..   ..              ..        „....     „....      „....
   -            - .. .     Meeting Cleanup     exceeding      RMU     RMU      RMU
   Concern       Criterion      - " .        «,     /. •» •     *,   -,     *,        *,
                           Criterion      Cleanup Criterion   Mean2     Mean      Mean
Total PCBs (ppb)
Cadmium/Chromium
(ppm)
Lead (ppm)
Benzo[a]pyrene (ppb)
1,000
10
400
900
16,000
21/25
11/25
23/25
25/25
A10-A12.A20
A01-A07.A10,
A11.A13.A14,
A20-A22
A01.A06
Not applicable
614
9.8
748
524
3,861
0
1.6
111
57
2,246
2,333
15.5
1,744
935
5,425
1 The table provides the range of all RMU means, regardless of whether the RMU exceeded the criterion.
2 Calculated as the mean of the individual RMU means
ppb = parts per billion = ug/kg
ppm = parts per million = mg/kg
Comparison of RMU Mean Concentrations to the Cleanup Criteria after Primary
Dredging of Ruddiman Pond:
Primary dredging effectively removed contaminated sediments in ten of the 25 Ruddiman
Pond RMUs, with mean concentrations in confirmation samples below target levels for
all the COCs in those ten RMUs. Fourteen RMUs exceeded target levels for both
cadmium and chromium, and four RMUs exceeded the target level for total PCBs. All 25
of the RMUs achieved the target level for BaP.
RMUs A10, Al 1, A12, and A20 exceeded the total PCB target level of 1,000 ppb, with
mean RMU concentrations ranging between 1,050 and 2,333 ppb. Among the 14 RMUs
for which target levels for both cadmium and chromium were exceeded, mean cadmium
concentrations  ranged between 10.2 and 15.5 ppm, and mean chromium concentrations
ranged between 596 and 1,744 ppm. Additionally, the mean lead concentration exceeded
the target level of 900 ppm in RMUs Al  and A6, with mean lead concentrations of 928
and 935 ppm, respectively.

6.2.2  Post-Secondary Dredging Sediment Sample Results for  Ruddiman
       Pond
The post-primary dredging confirmation  data for the 25 RMUs in the pond indicated that
secondary dredging was needed in RMUs A01-A07, A10-A14, and A20-A22. To
64
                                                                     March 2011

-------
                                                                     PROJECT RESULTS
simplify secondary dredging efforts, the kriging model shown in Figure 6-1 was used to
identify specific areas within RMUs A12-A14 to target for additional dredging. In this
model, stippled areas were estimated to have a high probability of exceeding the target
level for at least one COC, and were selected for removal of additional sediment.
 631200-
 631000-
 630800-
            12612200       12612400       12612600       12612800       18613000       18613200
Figure 6-1   Kriging model used to determine sampling locations for RMUs A12 - A14
Table 6-3 presents summary-level results of the post-secondary dredging confirmation
samples collected in the pond remediation area. The samples collected in RMUs A01-
A07, A10, and Al 1 were analyzed for all COCs. The samples collected in RMUs A20-
A22 were analyzed for only chromium and cadmium. The individual samples results are
included in Appendix A of this report.
Table 6-3 Summary of Mean Concentrations Observed Among All RMUs in Ruddiman
Pond, Post-Secondary Dredge Confirmation Samples1
l
Contaminant of
Concern
Total PCBs (ppb)
Cadmium/Chromium
(ppm)
Lead (ppm)
Benzo[a]pyrene (ppb)
.. Number of RMUs RMUs with COCs Pooled Minimum Maximum
^ ; Meeting Cleanup exceeding RMU RMU RMU
Criterion - r. . -. - .. . „„ 2
Criterion Cleanup Criterion Mean Mean Mean
1,000
10
400
900
16,000
8/9
9/12
9/9
9/9
A06
A01.A05.A21
Not applicable
Not applicable
232
7.6
487
357
4,797
0
3.1
187
123
3,413
2,333
12.7
716
617
7,113
1 The table provides the range of all RMU means, regardless of whether the RMU exceeded the criterion.
2 Calculated as the mean of the individual RMU means
ppb = parts per billion = ug/kg
ppm = parts per million = mg/kg
March 2011
65

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Comparison of RMU Mean Concentrations to the Cleanup Criteria after Secondary
Dredging of Ruddiman Pond:
Secondary dredging effectively removed contaminated sediments in 11 of the 15 RMUs
which exceeded the target levels after the primary dredging efforts. Mean concentrations
in the secondary dredging confirmation samples fell below the target levels for all the
COCs in these 11 RMUs. RMUs A01, A05, and A21 exceeded target levels for both
cadmium and chromium,  with mean cadmium concentrations ranging between 11.6 and
12.7 ppm, and mean chromium concentrations ranging between 543 and 716 ppm. RMU
A06 exceeded the total PCBs target level  of 1,000 ppb, with a mean RMU concentration
of 2,333 ppb.
For the kriged samples in RMUs A12 - A14, the mean concentrations of the five samples
from these RMUs were below the target levels for total PCBs, lead, and cadmium. BaP
was not assessed in these  three RMUs. Chromium had a mean concentration of 443.6
ppm, which exceeded the target level of 400 ppm. However, the decision rule for these
two metals required that both exceed their target levels. Because the mean cadmium
concentration for these RMUs fell below its target level of 10 ppm in these five samples,
no further dredging action was necessary for RMUs A12 - A14.
Table 6-4 summarizes the results for each RMU based on the primary, secondary, and
post-sand sediment confirmation samples. For each RMU and COC, a dot signifies the
mean concentration fell below the target level, while an "x" signifies the mean
concentration exceeded the target level. If a cell in the table is blank, samples were not
collected in that RMU during that phase of confirmation sampling.
66                                                                    March 2011

-------
                                                                         PROJECT RESULTS
Table 6-4 Summary of Dredging Results by Remedial Phase for each RMU in Ruddiman
Pond and Creek
Site Primary Dredge Secondary Dredge Post Sand
Category RMU Cd/Cr BaP Pb PCB Cd/Cr BaP Pb PCB Cd/Cr BaP Pb PCB
Creek
Pond
B1
B2
C1
C2
C3
D1
D2
D3
E1
F1
G1
G2
H&l
A01
A02
A03
A04
A05
A06
A07
A08
A09
A10
A11
•
•
X
•
X
•
•
•
•
•
•
•
•
X
X
X
X
X
X
X
•
•
X
X
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
X
•
•
•
•
X
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
X
X
X
•
•
•
•
•
•
•
•
•
X
X


•

•








X
•
•
•
X
•
•


•
•













•
•
•
•
•
•
•


•
•













•
•
•
•
•
•
•


•
•













•
•
•
•
•
X
•


•
•










•


•



•
•
•














•























•


•



•
•
•














•


•



•
•
•




March 2011
67

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Table 6-4 Summary of Dredging Results by Remedial Phase for each RMU in Ruddiman
| Pond and Creek I
Site Primary Dredge Secondary Dredge Post Sand
Category RMU Cd/Cr BaP Pb PCB Cd/Cr BaP Pb PCB Cd/Cr BaP Pb PCB
Pond
A121
A131
A141
A15
A16
A17
A18
A19
A20
A21
A22
A23
A24
A25
•
X
X
•
•
•
•
•
X
X
X
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
X
•
•
•
•
•
•
•
X
•
•
•
•
•
•
•
•





•
X
•

















•
•
•











•
•
•



































































 RMUs A12-A14 were assessed as a single group, based on five samples (locations chosen from kriging
models), rather than based on RMU-specific means.
To further illustrate the effect of dredging on COC concentrations, Figures 6-2 through 6-
4 show the estimated distributions of total PCBs throughout the pond remediation area.
Figure 6-2 is a three-dimensional kriging map of the distribution of total PCB
concentrations prior to any remedial activities. Figure 6-3 shows the distribution of total
PCB concentrations after primary dredging. As the figures illustrate, the areas exceeding
the total PCBs target level of 1,000 ug/kg are found mainly in RMUs A1-A6 and A10-
A12, plus an additional hotspot within RMU A20. Figure 6-4 shows the distribution of
total PCB concentrations after secondary dredging. This figure illustrates the estimated
total PCB concentrations fell below the target level throughout the site, with the
exception of a hot spot around RMU A06 and a smaller area within RMU A12.
Additional  remedial activities including a sand residual cover were applied to this area, as
                                                                          March 2011

-------
                                                                        PROJECT RESULTS
described in Section 6.4. The exceedance at RMU A12 only covered a small area and
only slightly exceeded the target level, and as stated above, mean concentrations for total
PCBs did not exceed the target level in RMUs A12-A14.
    Ruddiman  Pond  Pre-remediation  data  analysis
         Top Core
         0-0.5'
         Fourth Core
         5-9'
         Total PCBs
         ug/kg
         j^H 0-500
         |^B £00.1 - 800
         I   | 800.1 -1.000
         |   | 1.000.1-1,200
         |   | 1.200.1-1,500
         |   | 1,500.1 -2,000
         |   | 2,000.1 -2,500
         j^B 2,600.1 -3.000
         ^H 3.000.1 - 3,392
         	 RMU
Target Level = 1000 ugfkg
                              Exaggeration in the Z direction for visualiztion
Figure 6-2   Total PCB concentrations in Ruddiman Pond prior to remediation
March 2011
                                                        69

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
                      1 I   | 1000.1-1.200
                          ~~ 1200.1-1.500
                        |   | 1.500.1-2.000
                        I   | 2. OOP. I-2.500
                                                  Pond after primary dredging
                                              Ruddiman  Pond
Figure 6-4   Total PCB concentrations in Ruddiman Pond after secondary dredging
70
March 2011

-------
                                                                 PROJECT RESULTS
6.3    SEDIMENT VOLUME REMOVED
The site was surveyed after completion of removal activities to determine the final
volume of sediment removed from the Ruddiman Creek site. Based on that survey and
other considerations described in Section 3.1.6, a total of 89,870 cubic yards of
contaminated sediment were removed, exceeding the original project goal of 72,220
cubic yards by approximately 24 percent.
Table 6-5 displays the volumes of sediment removed based on the post-dredging survey
at each location, with the exception of Ruddiman Creek Area B, where site conditions
and schedule constraints precluded the survey. After consulting with the project team, the
box cut volume (a simple estimate of the area excavated times the excavation depth) was
used as the removal volume for Area B. An additional volume is shown for the
"unsurveyed areas" described in Section 3.1.6.
 Table 6-5  Volume of Sediment Removed from Ruddiman Creek and Pond, by
Remediation Area
Area Volume Estimation Method Estimated Volume Removed (cubic yards) 1
Ruddiman Pond
Creek Area B
Creek Area C
Creek Area D
Creek Area E
Creek Area F
Creek Area G
Creek Area H & 1
Unsurveyed Areas
Post-Removal Survey
Box Cut Volume
Post-Removal Survey
Post-Removal Survey
Post-Removal Survey
Post-Removal Survey
Post-Removal Survey
Post-Removal Survey
Various
Creek Total
Creek and Pond Total
75.3981
2,038
2.6231
1,485
299
490
6,2241
568
745
14,472
89,870
  Includes sediment removed during both primary and secondary dredging.
6.4    FINAL CONFIRMATION
The removal of 89,870 cubic yards of contaminated sediment from the Ruddiman Creek
Main Branch and Pond remediation areas dramatically reduced the levels of COC across
the site.
A layer of sand was applied to each RMU in which post-secondary dredging sample
results exceeded the target level for at least one COC. Following placement of that sand
cover, additional confirmation samples were collected in some of the affected RMUs.
March 2011
71

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Summaries of those post-cover application sample results are presented in Sections 6.4.1
and 6.4.2.

6.4.1   Ruddiman Creek Main Branch
Final post-sand confirmation sampling in the Ruddiman Creek Main Branch was limited
to three locations in RMU Gl. The mean concentrations of all of the COCs in these
samples fell below the target levels.

6.4.2   Ruddiman Pond
Final post-sand confirmation sampling in Ruddiman Pond was necessary for RMUs A01,
A05, A06, and A07. For RMUs A05 and A06, samples were collected at all four original
locations. Two locations were sampled for RMU A01 and one location was sampled for
RMU A07. As stated in Section 6.2.2, the mean concentrations of the samples collected
after the secondary dredge efforts in RMU A07 met the target levels for all COCs.
However, the cadmium and chromium results for one of the four post-secondary dredging
samples at RMU A07 were notably higher than the others. As a precaution, an additional
layer of sand was applied to RMU A07, and a final confirmation sample was collected at
this location. For RMUs A01, A05, A06, and A07, the mean concentration of the post-
sand confirmation samples was below the target level for each COC.
As discussed in Section 6.2.2, mean cadmium and chromium concentrations for RMU
A21 exceeded their individual target levels; however, only two samples in RMU A21
exceeded the target levels for both cadmium and chromium. Due to scheduling
limitations, these two sampling locations (A21_B and A21_D) were covered with sand
after sampling and no further dredging or sampling was conducted.
72                                                                    March 2011

-------
                             RESIDUAL COVER PLACEMENT, DEMOBILIZATION, AND RESTORATION
        RESIDUAL COVER PLACEMENT, DEMOBILIZATION, AND
        RESTORATION
Site restoration activities began in Ruddiman Creek Main Branch and Pond remediation
areas following completion of excavation and dredging operations in each work area. The
general objective of restoration activities was to return all disturbed areas of the site to
pre-construction or improved conditions and to perform enhancements that would prevent
habitat degradation. Site restoration activities included:
   •   Placing a cover layer of aggregate or sand in each RMU or work areas.
   •   Removing temporary roads and project support structures and facilities.
   •   Grading, seeding, and replanting of indigenous perennials and bushes removed
       during construction work.
Additional environmental enhancement activities in selected areas included:
   •   Installing energy dissipation and riprap riffle structures at strategic locations along
       the Ruddiman Creek Main Branch.
   •   Creating deeper pools.
   •   Armoring portions of the creek with rock.
   •   Leaving select diversion channels  constructed during site preparation in place to
       create a braided stream effect.
Sections 7.1, 7.2, and 7.3 describe residual cover placement, demobilization, site
restoration activities and environmental enhancements in the Ruddiman Creek site
remediation areas, respectively.

7.1    PLACEMENT  OF RESIDUAL COVER
7.1.1   Ruddiman Creek Main Branch
As described in Section 3, RMUs in the Ruddiman Creek Main Branch remediation area
were backfilled with a combination of sand, geotextile fabric,  and rock. The resulting
residual cover should facilitate restoration of the creek to its natural depth; provide a
series of barriers to prevent any residual contaminants from entering the creek; and
provide suitable substrate for aquatic life.  After completion of excavation and
confirmation sampling activities within a given RMU, a layer  of sand was applied as
backfill to serve as  the first of several barriers designed to preclude residual
March 2011                                                                      73

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
contamination from entering the creek. The amount of sand applied was dependent upon
area-specific conditions and planned remedial activities. The sand layer in Areas D, E,
and F was three feet deep and at least six inches deep in Areas B, Q H, and I. Sand was
not applied in Area C. An 8-ounce layer of non-woven geotextile fabric was applied over
the sand layer, followed by 6-inch thick layer of 3-inch rock backfill. This sequence was
generally followed within the creek remediation area, but was modified to address
challenges associated with two work areas. The geotextile fabric was applied first in
Areas G and D (RMUs D2 and D3) to prevent the sand layer from sinking into the peat
formation.
In RMU Dl, the sand backfill and geotextile fabric broke through the bottom of the
streambed and dropped into the underlying peat formation, resulting in upheavals of other
areas within this RMU. The raised sections were pushed down, a new section of
geotextile was applied, and then covered with another 6-inch sand layer. The final step
was to cap Area Dl with a 6-inch layer of stone.

7.1.2  Ruddiman Pond
After completion of excavation and confirmation sampling activities in the Ruddiman
Pond remediation area, a 6-inch layer of sand backfill was spread throughout the pond,
followed by a layer of rock.

7.2    DEMOBILIZATION
Demobilization activities began in phases as the remediation tasks were completed.  As
portions of the project were completed, resources that were  no longer necessary for the
remaining tasks were demobilized. The equipment was cleaned and decontaminated prior
to removal and final demobilization occurred on June  9, 2006. Results for soil samples
collected from the three former staging areas indicated there was no residual
contamination at the site as a result of remedial activities.

7.3    SITE RESTORATION AND ENVIRONMENTAL ENHANCEMENTS
Site restoration activities at the Ruddiman Creek site were conducted throughout the
course of the project. For example, after completion of work, disturbed areas were
74                                                                     March 2011

-------
                             RESIDUAL COVER PLACEMENT, DEMOBILIZATION, AND RESTORATION
generally applied with a temporary seed. The temporary seed was applied at a rate of one
to three pounds per 1,000 square feet to stabilize the disturbed area and control erosion.
Permanent seed was applied at a rate of approximately 0.3 pounds per 1,000 square feet
(12 pounds per acre) during the spring of 2006 to allow the seed to become well
established in the disturbed areas. A variety of herbaceous plants and shrubs were planted
on some of the former site roadways, at a density of approximately 3-feet off center, or
roughly 16 plants and shrubs per 100 square feet.

7.3.1  Ruddiman Creek Main  Branch
An estimated 300,000 square feet (almost seven acres) of site restoration was required as
a result of cleanup operations. Site restoration activities included establishing a stable
slope in the excavation areas, removing operations infrastructure, re-establishing
vegetation, and restoring creek flow to both the original and diversion channels.
Additional site restoration activities included the creation of deep-water retention and
sedimentation basins in the excavation cavities associated with Areas F and G, as well as
armoring the streambed in Areas H and I with wing dams to dissipate flood stream
velocity. Three riffle  structures were constructed to serve as erosion-control measures to
minimize sediment migration during flood events. The resulting riffle structures extended
from one side of the flood plain to the other, and were built at the headwaters of Area F
and at the tail waters of RMU El and Area C.

7.3.2  Ruddiman Pond
An estimated area of 25,000 square feet around the edge of the pond required site
restoration, including the  area around the temporary barge off-loading pier. The disturbed
areas were re-vegetated after removal of all infrastructure and restoration of the stream
bank slopes. The disturbed area adjacent to the pond remediation area was seeded with
temporary seed, as well as permanent seed that included a wetland-edge mix of grasses
and a flower-to-grass ratio of 5:1. Turtle flower was also planted along the pond. As in
the creek area, a variety of herbaceous plants and shrubs were planted on some of the
former site roadways, and were seeded with permanent seed with a flower-to-grass ratio
of 10:1.

March 2011                                                                        75

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
A portion of the upland areas was planted with mixed height grasses and flowers with a
flower-to-grass ratio of 14:1. The remaining upland areas were planted with a roadside
seed mix. The surface of the seeded areas was mulched with shredded straw.
Figures 7-1 and 7-2 illustrate some of the replanting efforts and the resulting restoration
of the site.
                                                                              -
Figure 7-1   Volunteer replanting efforts
Figure 7-2   Replanting efforts among the
            reestablished grass cover
76
                                 March 2011

-------
                                            CONCLUSIONS AND PROJECT ACCOMPLISHMENTS
8.0    CONCLUSIONS AND PROJECT ACCOMPLISHMENTS
As noted in Section 1.3, there were three objectives of this project:
       1.  Reduce relative risk to humans, wildlife, and aquatic life.
       2.  Restore beneficial uses.
       3.  Source control.
Although these objectives were ambitious, they were also key to the design and the
successful implementation of the project.
The removal of nearly 90,000 cubic yards of contaminated sediments had an immediate
positive impact on the health of the system and significantly reduced the exposure to the
benthos. It will take time to determine the long-term impacts on the food web from the
reductions in contaminant levels, which also is affected by other sources of
contamination. However, the overall impact of the project is expected to result in reduced
risks to aquatic organisms, wildlife, and humans in both the Ruddiman Creek watershed
and in Muskegon Lake. Thus, it is expected that the first objective will be met over time.
The key objective for the community surrounding Ruddiman Creek and Pond was to
restore their ability to use this recreational asset in their neighborhood and for some, their
backyards. The creek and pond are now well suited for kayaking and canoeing and the
surrounding park areas provide walking trails and can be used for other events. This is the
first of many steps to achieve the second objective. The community continues to maintain
and improve the restored habitat, has begun monitoring programs in the watershed, and
the site is being used for education and outreach activities.
The third objective was achieved through the installation of measures such as riprap
riffles,  energy dissipation devices, and braided stream channels that control stormwater
flows near the sources to Ruddiman Creek and Pond. Such structures have stopped high
flow/high erosion events into the pond and this decreased flow is expected to decrease the
introduction of toxics and sediments into Ruddiman Creek and Pond. These measures
have improved the stability of the aquatic habitat, and improved aesthetics and
recreational uses of the Ruddiman Creek watershed. The original channel of the Main
Branch of Ruddiman Creek was restored, and open water areas were created in the once
sediment-clogged and cattail-filled Ruddiman Pond. The blanket of stones placed on the

March 2011                                                                      77

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
bottom and sides of areas of the creek reduced stream bank erosion and decreased the

amount of sand and silt flowing downstream. As described in Section 7.1.1, additional

measures were completed to seal upstream sections of the Main Branch, where scouring

and erosion were of particular concern. Various flow dissipation structures were installed,

such as wing dams, detention ponds, streambank armoring, and riffle structures.

Extensive plantings of native flora stabilized the flood plain and slopes wherever the

natural ground cover was disturbed.

In addition, the project was successful in other key areas:

    •   Communication among project participants and stakeholders.

    •   Outreach to, and involvement with, the local community.

    •   Obstacles associated with project implementation.

    •   Use of specialized equipment and materials.

    •   Use of innovative planning tools and statistical methods.

    •   Recognition from outside parties  regarding project achievements.

Examples of specific project achievements are presented in Table 8-1 below.
 Table 8-1   Project Accomplishments and Awards
    The Ruddiman Creek Task Force and Illinois-Indiana Sea Grant won the 2006 State of the
    Lake Ecosystem Conference award "for exceptional performance and dedication to the
    Ruddiman Creek Great Lakes Legacy Act Sediment Remediation Project."
    The project was awarded the 2007 Chapter and Branch Award for "Project of the Year" by
    the American Public Water Works Association Michigan Chapter- Midwest Branch; and
    specifically recognized for:
    >  Successfully achieving all remediation project objectives
    >  Outstanding project team communication, including the use of weekly calls, which
       provided a forum for progress and decision making, and ensured a high level of
       communication between the project participants
    > Use of innovative technologies to facilitate achievement of project objectives, including
       using:
       •   The DQO process to plan the remediation effort
       •   Modified  excavation tactics to account for unique conditions and facilitate
          achievement of project objective
       •   Kriging to optimize removal of contaminated sediments at the lowest possible cost,
          while still achieving goal of removing public health hazards
    >  Demonstrating resources for future remediation efforts (e.g., use of a mixture of
       Calciment® for solidification of contaminated sediment)
    The President's Volunteer Service Award was given to Theresa Bernhardt who spent
    thousands of hours over 12 years championing the cleanup of Ruddiman Creek and Pond.
78                                                                         March 2011

-------
                                           CONCLUSIONS AND PROJECT ACCOMPLISHMENTS
 Table 8-1  Project Accomplishments and Awards
    The award was presented by then EPA Administrator Stephen Johnson in August 2008.
 Contaminants Removed
    89,870 cubic yards of contaminated sediments were removed, containing approximately:
    > 2,800 pounds of cadmium
    > 204,000 pounds of chromium
    > 126,000 pounds of lead
    > 320 pounds of PCBs
At the project completion celebration, United States Representative Pete Hoekstra (R-
Holland) said:
    "A lot of times, we go to Washington and we pass a bill and we declare a victory
   and nothing has happened. This is actually a case where we go to Washington, we
   pass a bill, it comes back and it almost works exactly the way we envisioned it to
   work, and that's because of all the folks that have come together that have shared
   the same vision... "
In addition, State Senator Gerald VanWoerkom (R-Norton Shores) celebrated the
removal of the polluted sediments to which wading children had been exposed.
Muskegon Mayor Steve Warmington was pleased to see Ruddiman Creek and Pond
returning to normal and "breathing on its own. "
A number of challenges were encountered during the remediation project. Working in the
peaty soils along Ruddiman Creek required modifications of the excavation activities,
specifically with respect to road construction methods and dredging equipment. Further
problems included the need for increased water quality monitoring to account for storm
and flooding changes, seasonal changes, spawning activity, and algal blooms.
The project objectives were successfully accomplished in spite of these challenges, due,
in part, to the high level of communication among all of the project participants. For
example, road construction was impossible within the lowest branch segment upstream of
Ruddiman Pond. After discussion  among the participants in the weekly conference calls,
interlocking FtDPE mats were used to create a floating road and small crawler carriers
capable of being supported by the  floating road were used in the effected work area.
Although improvised  quickly, these amphibious removal tactics proved to be very
successful and allowed completion of the removal activities.

March 2011                                                                      79

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
A number of other technological innovations were utilized during both the planning and
implementation of the remediation project, including: use of EPA's DQO process to
develop a statistically-based sampling design for sediment confirmation analysis; and use
of kriging to interpolate complex patterns of contamination and identify areas that exceed
the target levels of a given contaminant of concern (see Section 5). The DQO process
allowed the development of a remediation plan that minimized the collection of data that
were inconsequential with respect to verifying the success of the remediation, and instead
focused on ensuring confirmation data were of sufficient quantity and quality to confirm
the remediation project's success at a specific degree of confidence. Kriging, on the other
hand, allowed the cost-effective removal of sediment in Area A3 in Ruddiman Pond.
There were other operational successes as well. For example, laser instrumentation was
used to establish the proper depth for sediment removal during excavation and enabled
accurate removal of sediments to specified depths. The dewatering pads worked well,
with minimal subsurface impact  and enabled easy loading of materials for the next phase.
Heating the wastewater treatment plant was also effective in preventing pipelines from
freezing during the winter months.
Because of the significant accomplishments associated with the project, the American
Public Works Association Michigan Chapter awarded the Ruddiman Creek remediation
project with the 2007 "Project of the Year Award." This award recognized the complexity
of the remediation project and that the methods used to overcome obstacles provided
technical resources necessary in future sediment remediation efforts. The degree of
cooperation between all parties was also recognized as illustrating the benefits of a
teamwork concept that drove the remediation project to its successful completion.
Together, the Ruddiman Creek Task Force and Illinois-Indiana Sea Grant won the 2006
State of the Lake Ecosystem Conference "for exceptional performance and dedication to
the Ruddiman Creek Great Lakes Legacy Act Sediment Remediation Project" (Figure 8-
1).
In addition, Theresa Bernhardt, a substitute teacher, mother of three, and volunteer
activist from Muskegon, Michigan, was awarded the President's Volunteer Service Award
                                                                        March 2011

-------
                                           CONCLUSIONS AND PROJECT ACCOMPLISHMENTS
in August 2008 (Figure 8-2). This award recognized the thousands of hours that Ms.

Bernhardt spent over 12 years championing the cleanup of Ruddiman Creek and Pond.
Figure 8-1   Staff from the Ruddiman Creek Task Force and Illinois-Indiana Sea Grant
            win the 2006 State of the Lake Ecosystem Conference award
March 2011
81

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Figure 8-2   Theresa Bernhardt receives the President's Volunteer Service Award
            from EPA Administrator Stephen Johnson in August 2008
82
March 2011

-------
                                                                  FUTURE OF THE SITE
 9.0    FUTURE OF THE SITE
 Historically, Ruddiman Creek Main Branch and Pond were severely affected by
 contamination from the area's industries and run-off from storm sewers. Aquatic life had
 all but disappeared and safe recreational opportunities were extremely limited. Following
 the removal of contaminated sediments from the creek and pond, salmon were seen
 swimming up the creek for the first time in many years and the visual appearance of the
 creek and pond were improved (Figures 9-1 and 9-2).
Figure 9-1   Appearance of Ruddiman Creek  Figure 9-2   Appearance of Ruddiman Pond
           Main Branch remediation area                remediation area six months
           six months after completion of                after completion of remediation
           remediation project                         project
 In an effort to prevent the site from returning to pre-remediation conditions, local
 officials developed a number of plans to reduce the volume of pollutants transported to
 the creek via storm sewers in the greater Muskegon area. In addition, the City of
 Muskegon enacted a stormwater pollution control ordinance in August 2008 that requires
 that the site plan for any development or redevelopment project involving a site over one
 acre include stormwater control and treatment measures.
 Although the remediation effort is over and the heavy equipment has been removed,
 interest in the site remains high. The site will be monitored by a number of entities. U.S.
 EPA will conduct post-remediation sampling and a total maximum daily load assessment.
 Grand Valley State University will monitor benthic invertebrates in the pond, and several
 groups have suggested assessing birds and reptiles in the area as well.
 March 2011
83

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
The community plans to develop bike trails, nature signage, and canoeing and kayaking
routes in the cleaned up waterways. Community action groups are making efforts to
maintain the vegetation, including a volunteer project to minimize invasive plants.
The remediation project is also expected to serve as a catalyst for redeveloping not only
the Ruddiman Creek Main Branch and Pond, but also the Muskegon Lake AOC. To
further ensure an improved habitat and as a follow-up to the sediment remediation
project, the community assisted in the development of the Muskegon Lake Ecological
Restoration Master Plan with funding from the EPA GLNPO habitat program. The plan
provides a blueprint to restore the wetland, aquatic,  shoreline, and riparian habitats in the
Muskegon Lake AOC. This extensive blueprint provides detailed information about the
projects needed to move toward a restored Muskegon AOC and delisting of beneficial
use impairments.
The blueprint sets priorities for projects, identifies costs, and recommends who best
undertake the work. This blueprint was the basis for a proposal submitted to NOAA by
the Great Lakes Commission on behalf of the Muskegon Lake Watershed Partnership. In
June 2009, NOAA awarded the Commission ten million dollars in federal "stimulus"
funding under the American Recovery and Reinvestment Act for restoration projects in
the AOC (http://www.glc.org/announce/09/06muskegon.html). The blueprint detailed
"shovel-ready" projects to begin restoration, which were key to the stimulus funding. The
project is expected to support 125 jobs, largely in engineering and construction. More
than  twenty million dollars will be contributed by local sources through in-kind services,
donations of land, and  conservation easements.
84                                                                      March 2011

-------
                                                                    REFERENCES
REFERENCES
DLZ, October 2000, Phase II Site Investigation Report, prepared for the MDNRE,
Surface Water Quality Division.

Earth Tech, June 17, 2002, Remedial Investigation ofRuddiman Creek, Muskegon,
Michigan, prepared for the MDNRE, Surface Water Quality Division.

Earth Tech, 2004, Technical Memorandum for Ruddiman Creek Soil and Groundwater
Investigation, Muskegon, Michigan. Grand Rapids, Michigan

Earth Tech, March 2004, Focused Feasibility Study ofRuddiman Creek, Muskegon,
Michigan. Grand Rapids, Michigan

Environmental Quality Management, Inc., July 21, 2005, Final Work Plan, Remediation
of the Ruddiman Creek Main Branch and Pond, Muskegon, Michigan. Cincinnati, Ohio.

Environmental Quality Management, Inc., September 2006, Remediation of the
Ruddiman Creek Main Branch and Pond, Muskegon, Michigan, Draft Final Project
Report, Cincinnati, Ohio.

Environmental Quality Management, Inc., October 2005, Quality Assurance Project
Plan, Ruddiman Creek Main Branch and Pond, Muskegon, Michigan.

MacDonald, D.D., C.G Ingersoll, and T.A. Berger. 2000. [Sediment Quality Guidelines
(SQGs) as defined in] Development and Evaluation of Consensus-Based Sediment
Quality Guidelines for Freshwater Ecosystems. Arch. Environ. Contam. Toxicol.
39:20-31.

Michigan Department of Natural Resources, Lansing, Michigan, October 1987, Remedial
Action Plan for Muskegon Lake Area of Concern.

Michigan Department of Natural Resources, Lansing, Michigan, October 1999,
Muskegon Lake Area of Concern Remedial Action Plan: 1994 Update.

Muskegon Conservation District, 2002, Muskegon Lake Community Action Plan: 2002
Remedial Action Plan Update.

EPA, March 1998, Lead Risk Assessment Issues Related to the Green Bay Paint Sludge
Site. Region 5 Technical Work Group for Lead.

EPA, 2002, Guidance for Data Usability in Risk Assessment. Office of Emergency and
Remedial Response. Washington, DC.

EPA, September 1994,  Guidance for the Data Quality Objective Process. EPA QA/G4.
March 2011                                                                    85

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
EPA, December 2002, Guidance on Choosing a Sampling Design for Environmental
Data Collection for Use in Developing a Quality Assurance Project Plan. EPA QA/G-5S.
86                                                                   March 2011

-------
                                                      APPENDIX A
APPENDIX A  SUMMARY SEDIMENT CONCENTRATION DATA
SUMMARY SEDIMENT CONFIRMATION DATA
Lab Sampling Total PCBs Chromium Cadmium Lead BaP
Sample Phase Sample ID Date (M9/kg) (m9/kg) (m9/kg) (m9/kg) (M9/kg)
B1-A
B1-B
B1-C
B1-D
B2-A
B2-B
B2-C
B2-D
C1-A
C1-B
C1-C
C1-D
C1-A1
C1-B1
C1-C1
C1-D1
C1-AR
C1-BR
C1-CR
C1-DR
C2-A
C2-B
C2-C
C2-D
C3-A
C3-B
C3-C
C3-D
C3-AR
C3-BR
C3-CR
C3-DR
D1-A
D1-B
D1-C
D1-D
D2-A
D2-B
D2-C
D2-D
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
A77233
A77234
A77235
A77236
A77237
A77239
A77240
A77241
A74460
A74461
A74462
A74463
A74791
A74792
A74793
A74794
A75621
A75622
A75623
A75624
A74795
A74796
A74797
A74798
A74799
A74800
A74801
A74802
A75425
A75426
A75427
A75428
A74803
A74804
A74805
A74806
A74716
A74717
A74718
A74719
4/14/2006
4/14/2006
4/14/2006
4/14/2006
4/14/2006
4/14/2006
4/14/2006
4/14/2006
2/15/2006
2/15/2006
2/15/2006
2/15/2006
3/3/2006
3/3/2006
3/3/2006
3/3/2006
3/18/2006
3/18/2006
3/18/2006
3/18/2006
3/3/2006
3/3/2006
3/3/2006
3/3/2006
3/3/2006
3/3/2006
3/3/2006
3/3/2006
3/16/2006
3/16/2006
3/16/2006
3/16/2006
3/3/2006
3/3/2006
3/3/2006
3/3/2006
2/28/2006
2/28/2006
2/28/2006
2/28/2006
720
ND
ND
940
ND
ND
ND
ND
ND
460
440
270
610
ND
960
620
NA
NA
NA
NA
490
390
700
ND
530
640
580
ND
NA
NA
NA
NA
660
2200
ND
730
1100
ND
ND
ND
393
301
224
639
51
33
41
56
609
1062
641
695
762
808
1301
621
410
213
461
202
455
366
322
85
819
451
481
462
149
610
843
324
660
618
684
251
1181
371
275
175
3.76
3.74
3.09
7.22
1.08
0.9
0.99
1.38
9.87
11.35
7.38
6.09
25.13
23.36
8.27
7.34
8.93
4.2
18.69
7.17
5.8
2.83
26.87
1.88
7.84
7.61
16.37
8.58
2.67
11.18
14.79
7.23
5.65
5.65
111
12.07
18.02
7.9
6.5
3.36
194
129
128
316
26
10
16
22
227
462
431
253
338
336
695
269
NA
NA
NA
NA
230
152
215
58
336
226
262
195
NA
NA
NA
NA
220
266
250
183
260
206
183
123
17000
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
NA
NA
ND
ND
ND
ND
ND
4000
ND
ND
NA
NA
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
March 2011
87

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Sample
D2-E
D2-F
D3-A
D3-B
D3-C
D3-D
D3-E
D3-F
E1-A
E1-B
E1-C
E1-D
FL-A
FL-B
FL-C
FL-D
G1-A
G1-B
G1-C
G1-D
G1-ASAND
G1-CSAND
G1-DSAND
G2-A
G2-B
G2-C
G2-D
H&I1-A
H&I1-B
H&I1-C
H&I1-D
A01-A
A01-B
A01-C
A01-D
A01-AR
A01-BR
A01-CR
A01-DR
A01-C1
A01-D1
A02-A
A02-B
sur
Phase
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
Post Sand
Post Sand
Post Sand
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
Post Sand
Post Sand
1° Dredge
1° Dredge
MMARYi
Lab
Sample ID
A74720
A74721
A74722
A74723
A74724
A74726
A74727
A74728
A72820
A72821
A72822
A72823
A72289
A72291
A72292
A72293
A67567
A67568
A67569
A67570
A69736
A69737
A69738
A67572
A67573
A67574
A67575
A67612
A67613
A67615
A67616
A75218
A75219
A75220
A75221
A77305
A77306
A77307
A77308
A78384
A78385
A75222
A75223
5EDIMEN'
Sampling
Date
2/28/2006
2/28/06
2/28/06
2/28/06
2/28/06
2/28/06
2/28/06
2/28/06
12/15/2005
12/15/2005
12/15/2005
12/15/2005
12/9/2005
12/9/2005
12/9/2005
12/9/2005
10/17/2005
10/17/2005
10/17/2005
10/17/2005
11/3/2005
11/3/2005
11/3/2005
10/17/2005
10/17/2005
10/17/2005
10/17/2005
10/17/2005
10/17/2005
10/17/2005
10/17/2005
3/14/06
3/14/06
3/14/06
3/14/06
4/18/06
4/18/06
4/18/06
4/18/06
5/4/06
5/4/06
3/14/06
3/14/06
FCONFIR
Total PCBs
(Mg/kg)
1100
ND
ND
ND
1100
ND
ND
ND
ND
300
480
480
ND
ND
930
ND
3400
500
2680
190
ND
ND
ND
ND
ND
190
7400
1770
2200
8200
870
ND
880
930
1090
ND
ND
ND
ND
ND
ND
1160
860
MATION C
Chromium
(mg/kg)
850
83
64
108
2404
132
178
274
170
56
59
380
86
250
470
68
560
270
420
49
ND
ND
ND
70
3.4
62
710
160
210
290
430
891
1457
903
856
755
675
736
681
102
266
1143
1169
)ATA
Cadmium
(mg/kg)
13.46
1.52
1.39
1.7
17.12
2.16
2.82
4.34
2.7
0.92
0.92
8.1
1.7
4.3
13
1.1
5.3
4.6
7.2
0.84
ND
ND
ND
1.5
ND
1.9
8.4
4.2
4.7
4.3
5.8
12.73
20.1
12.64
12.96
19.87
10.23
10.65
9.92
2.03
5.22
13.6
13.79
Lead
(mg/kg)
214
70
29
41
1165
94
85
165
120
64
47
130
28
96
240
53
610
410
360
47
ND
ND
ND
68
2.4
85
590
120
270
270
200
727
1430
798
755
598
607
657
605
75
199
748
760
BaP
(Mg/kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4100
6800
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
5600
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
ND
ND
                                                                        March 2011

-------
                                                                                APPENDIX A
Sample
A02-C
A02-D
A02-AR
A02-BR
A02-CR
A02-DR
A03-A
A03-B
A03-C
A03-D
A03-AR
A03-BR
A03-CR
A03-DR
A04-A
A04-B
A04-C
A04-D
A04-AR
A04-BR
A04-CR
A04-DR
A05-A
A05-B
A05-C
A05-D
A05-AR
A05-BR
A05-CR
A05-DR
A05-AS
A05-BS
A05-CS
A05-DS
A06-A
A06-B
A06-C
A06-D
A06-AR
A06-BR
A06-CR
A06-DR
A06-AS
sur
Phase
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
Post Sand
Post Sand
Post Sand
Post Sand
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
Post Sand
MMARYi
Lab
Sample ID
A75225
A75226
A77309
A77310
A77312
A77313
A75227
A75228
A75229
A75230
A77928
A77929
A77930
A77931
A75231
A75232
A75233
A75234
A77314
A77315
A77316
A77317
A75235
A75236
A75237
A75238
A77318
A77319
A77320
A77321
A79337
A79338
A79339
A79340
A75239
A75240
A75241
A75243
A77322
A77323
A77324
A77326
A79341
5EDIMEN'
Sampling
Date
3/14/06
3/14/06
4/18/06
4/18/06
4/18/06
4/18/06
3/14/06
3/14/06
3/14/06
3/14/06
4/26/06
4/26/06
4/26/06
4/26/06
3/14/06
3/14/06
3/14/06
3/14/06
4/18/06
4/18/06
4/18/06
4/18/06
3/14/06
3/14/06
3/14/06
3/14/06
4/18/06
4/18/06
4/18/06
4/18/06
5/22/06
5/22/06
5/22/06
5/22/06
3/14/06
3/14/06
3/14/06
3/14/06
4/18/06
4/18/06
4/18/06
4/18/06
5/22/06
FCONFIR
Total PCBs
(Mg/kg)
940
820
ND
ND
ND
ND
1980
470
440
ND
ND
650
ND
ND
1100
800
630
ND
ND
ND
ND
ND
1000
830
640
580
ND
700
ND
1300
100
93
ND
ND
990
740
1220
1000
4600
ND
ND
ND
75
MATION C
Chromium
(mg/kg)
960
1198
672
244
497
440
2497
994
2803
681
355
943
96
54
1397
906
813
490
686
489
440
456
1388
950
1168
458
626
589
399
822
23
41
2.3
3
931
857
1045
1621
636
645
338
313
15
)ATA
Cadmium
(mg/kg)
12.87
11.24
10.03
3.89
8.88
7
12.92
13.28
22.5
5.74
2.62
13.13
1.43
1.13
15.34
13.26
16.46
7.85
9.48
8.06
7.01
7.26
15.16
14.34
15.7
7.6
9.32
8.84
6.4
21.71
0.33
0.76
ND
ND
13.98
13.4
14.6
19.42
9.84
9.93
5.21
4.86
ND
Lead
(mg/kg)
763
770
601
198
439
355
1186
409
449
232
123
809
40
18
1036
775
1030
360
482
400
335
358
1031
899
927
334
467
432
319
962
19
34
1.6
2.3
802
768
868
1301
493
499
259
250
12
BaP
(Mg/kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
14000
5100
ND
ND
ND
ND
ND
ND
ND
NA
NA
NA
NA
ND
5000
ND
5300
ND
ND
ND
ND
NA
March 2011
89

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Sample
A06-BS
A06-CS
A06-DS
A07-A
A07-B
A07-C
A07-D
A07-AR
A07-BR
A07-CR
A07-DR
A07-A1
A08-A
A08-B
A08-C
A08-D
A09-A
A09-B
A09-C
A09-D
A10-A
A10-B
A10-C
A10-D
A10-AR
A10-BR
A10-CR
A10-DR
A11-A
A11-B
A11-C
A11-D
A11-AR
A11-BR
A11-CR
A11-DR
A12-A
A12-B
A12-C
A12-D
A13-A
A13-B
A13-C
sur
Phase
Post Sand
Post Sand
Post Sand
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
Post Sand
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
MMARYi
Lab
Sample ID
A79342
A79343
A79344
A75360
A75361
A75362
A75363
A77327
A77328
A77329
A77330
A78383
A75351
A75352
A75354
A75355
A75356
A75357
A75358
A75359
A73971
A73972
A73973
A73974
A74464
A74465
A74466
A74467
A73894
A73895
A73969
A73970
A74468
A74469
A74470
A74471
A73890
A73891
A73892
A73893
A73886
A73887
A73888
5EDIMEN'
Sampling
Date
5/22/06
5/22/06
5/22/06
3/15/06
3/15/06
3/15/06
3/15/06
4/18/06
4/18/06
4/18/06
4/18/06
5/4/06
3/15/06
3/15/06
3/15/06
3/15/06
3/15/06
3/15/06
3/15/06
3/15/06
1/31/06
1/31/06
1/31/06
1/31/06
2/15/06
2/15/06
2/15/06
2/15/06
1/30/06
1/30/06
1/31/06
1/31/06
2/15/06
2/15/06
2/15/06
2/15/06
1/30/06
1/30/06
1/30/06
1/30/06
1/30/06
1/30/06
1/30/06
FCONFIR
Total PCBs
(Mg/kg)
ND
ND
ND
780
440
430
680
400
700
ND
ND
ND
520
510
ND
ND
ND
310
ND
ND
2400
3500
1420
2010
ND
ND
ND
ND
1380
530
ND
2290
ND
ND
ND
ND
ND
2450
610
1500
550
ND
640
MATION C
Chromium
(mg/kg)
2.7
2.3
6.7
860
822
864
424
2120
157
343
242
672
992
1158
111
583
371
351
9.4
26
964
1495
882
890
112
120
204
311
932
747
415
1000
194
106
79
599
34
1968
754
689
1009
293
929
)ATA
Cadmium
(mg/kg)
ND
ND
0.25
14.28
13.89
11.04
12.88
16.81
2.65
6.47
3.39
9.71
13.27
12.38
6.12
4.78
3.58
4.34
0.35
0.33
17.6
14.72
13.05
12.23
1.85
2.33
3.35
4.96
11.5
15.29
7.74
15.58
3.83
2.15
1.44
8.47
0.99
14.71
11.38
12.64
14.44
5.91
15.77
Lead
(mg/kg)
2.2
1.5
5.1
775
753
633
757
854
114
267
173
425
707
406
270
192
150
189
3.5
9.9
765
910
739
683
56
81
152
202
741
775
336
951
154
72
49
372
46
908
591
697
1012
281
843
BaP
(Mg/kg)
NA
NA
NA
ND
ND
ND
6400
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
ND
5100
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
90
March 2011

-------
                                                                                APPENDIX A
Sample
A13-D
A14-A
A14-B
A14-C
A14-D
S-1
S-2
S-3
S-4
S-5
A15-A
A15-B
A15-C
A15-D
A16-A
A16-B
A16-C
A16-D
A17-A
A17-B
A17-C
A17-D
A18-A
A18-B
A18-C
A18-D
A19-A
A19-B
A19-C
A19-D
A20-A
A20-B
A20-C
A20-D
A20-A RD
A20-B RD
A20-C RD
A20-D RD
A21-A
A21-B
A21-C
A21-D
A21-ARD
sur
Phase
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
Kriged Samples
Kriged Samples
Kriged Samples
Kriged Samples
Kriged Samples
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
MMARYi
Lab
Sample ID
A73889
A73881
A73882
A73884
A73885
A78378
A78379
A78380
A78381
A78382
A73877
A73878
A73879
A73880
A72115
A72116
A72117
A72118
A70888
A70889
A70890
A70891
A73873
A73874
A73875
A73876
A70966
A70967
A70969
A70970
A70962
A70963
A70964
A70965
A72119
A72120
A72121
A72122
A70957
A70958
A70960
A70961
A72123
5EDIMEN'
Sampling
Date
1/30/06
1/30/06
1/30/06
1/30/06
1/30/06
5/4/06
5/4/06
5/4/06
5/4/06
5/4/06
1/30/06
1/30/06
1/30/06
1/30/06
12/7/05
12/7/05
12/7/05
12/7/05
11/15/05
11/15/05
11/15/05
11/15/05
1/30/06
1/30/06
1/30/06
1/30/06
11/16/05
11/16/05
11/16/05
11/16/05
11/16/05
11/16/05
11/16/05
11/16/05
12/7/05
12/7/05
12/7/05
12/7/05
11/16/05
11/16/05
11/16/05
11/16/05
12/7/05
FCONFIR
Total PCBs
(Mg/kg)
630
ND
1300
ND
ND
690
ND
ND
1360
ND
ND
ND
ND
ND
890
1640
620
720
ND
ND
310
ND
ND
ND
ND
ND
ND
720
260
540
910
870
1180
2200
NA
NA
NA
NA
660
670
670
810
NA
MATION C
Chromium
(mg/kg)
381
914
683
440
348
491
186
99
1242
200
439
363
655
453
590
300
960
900
240
66
130
6.5
97
411
5.6
215
39
640
470
750
2500
850
760
1600
500
410
630
630
500
880
820
630
150
)ATA
Cadmium
(mg/kg)
8.76
14.31
11.52
8.93
6.92
7.15
3.76
3.67
21.97
3.79
8.66
7.79
9.91
8.22
9.2
4.7
12
11
3.9
0.71
1.6
ND
1.73
7.59
ND
3.1
0.86
9.3
8
11
13
12
11
26
7.7
6.4
8.8
8.6
5.5
14
13
8.4
2.1
Lead
(mg/kg)
431
834
620
396
339
305
164
138
747
145
363
313
396
322
420
190
480
460
130
32
64
2.8
71
301
3.9
126
27
360
300
430
1100
620
430
1200
NA
NA
NA
NA
170
760
620
380
NA
BaP
(Mg/kg)
ND
ND
ND
ND
ND
NA
NA
NA
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
NA
NA
ND
ND
ND
ND
NA
March 2011
91

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
Sample
A21-B RD
A21-C RD
A21-D RD
A22-A
A22-B
A22-C
A22-D
A22-A RD
A22-B RD
A22-C RD
A22-D RD
A23-A
A23-B
A23-C
A23-D
A24-A
A24-B
A24-C
A24-D
A25-A
A25-B
A25-C
A25-D
BC-01
BC-02
BC-03
BC-04
GC-01
GC-02
MP-1
MP-2
MP-3
MP-4
MP-5
MP-6
sur
Phase
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
2° Dredge
2° Dredge
2° Dredge
2° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
1° Dredge
Staging Pad
Staging Pad
Staging Pad
Staging Pad
Staging Pad
Staging Pad
Staging Pad
Staging Pad
Staging Pad
Staging Pad
Staging Pad
Staging Pad
MMARYi
Lab
Sample ID
A72124
A72126
A72127
A70884
A70885
A70886
A70887
A72128
A72129
A72130
A72131
A70879
A70881
A70882
A70883
A70875
A70876
A70877
A70878
A70870
A70871
A70872
A70874
A76660
A76661
A76662
A76663
A76664
A76665
A79528
A79529
A79530
A79531
A79532
A79533
5EDIMEN'
Sampling
Date
12/7/05
12/7/05
12/7/05
11/15/05
11/15/05
11/15/05
11/15/05
12/7/05
12/7/05
12/7/05
12/7/05
11/15/05
11/15/05
11/15/05
11/15/05
11/15/05
11/15/05
11/15/05
11/15/05
11/15/05
11/15/05
11/15/05
11/15/05
4/7/06
4/7/06
4/7/06
4/7/06
4/7/06
4/7/06
5/24/06
5/24/06
5/24/06
5/24/06
5/24/06
5/24/06
FCONFIR
Total PCBs
(Mg/kg)
NA
NA
NA
790
340
900
410
NA
NA
NA
NA
620
340
340
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MATION C
Chromium
(mg/kg)
860
670
490
1200
790
1200
760
550
790
220
310
660
1100
580
400
330
90
180
81
79
150
190
140
28
17
34
18
16
12
3.3
5.5
8.2
2.1
3.1
14
)ATA
Cadmium
(mg/kg)
11
9.1
25
15
9.6
11
9
5.9
10
1.7
3.9
9
8.7
7.2
5.6
5.5
1.7
2.4
1.4
1.5
2.2
2.6
2.8
0.72
0.42
0.74
0.33
0.32
ND
ND
ND
ND
ND
ND
0.23
Lead
(mg/kg)
NA
NA
NA
770
450
710
440
NA
NA
NA
NA
450
660
390
300
290
56
140
69
76
130
260
270
56
34
47
30
30
22
3.7
4.2
8.3
18
14
38
BaP
(Mg/kg)
NA
NA
NA
ND
ND
ND
ND
NA
NA
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
120
140
ND
290
170
ND
ND
ND
ND
ND
140
  ND = non-detect
  NA = not applicable
92
March 2011

-------
                                                                  APPENDIX B
APPENDIX B  SUMMARY SEDIMENT CONCENTRATION DATA, 2004
           Sediment Concentrations from 2004 Sediment Survey
 Ruddiman Creek
   Contaminant
Maximum Sediment
  Concentration
(mg/kg, dry weight)
Cleanup Criterion
   (mg/kg, dry
    weight)
   Ratio of Maximum
Sediment Concentration
  to Cleanup Criterion
Benzo(a)pyrene
Cadmium
Chromium
Total PCBs
19
31
2,040
19
16
10
400
1
1.19
3.10
5.10
19.00
Ruddiman Pond
Benzo(a)pyrene
Cadmium
Chromium
Total PCBs
3.4
25
2,090
67
16
10
400
1
0.21
2.50
5.23
67.00
Data taken from Earth Tech, 2004 Technical Memorandum for Ruddiman Creek Soil and Groundwater
Investigation, Muskegon, Michigan.
March 2011
                                                       93

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
94                                                                      March 2011

-------
                                             APPENDIX C
       Ruddiman Creek Main Branch and Pond



         Fact Sheets: July 2005 and May 2006
March 2011                                             95

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
96                                                                      March 2011

-------
«*EPA
   United States
   Environmental Protection
   Agency
  For more information
  If you would like more information on
  the Ruddiman Creek/Ruddiman Pond
  project, you may contact one of the
  following team members:

  MarcTuchman
  Project Manager
  Great Lakes National Program Office
  (312) 353-1369
  tuchman.marc@epa.gov

  Don de Blasio
  Community Involvement Coordinator
  EPA Region 5
  (312) 886-4360
  deblasio.don@epa.gov

  Sam Borries
  Remedial Project Manager
  EPA Region 5
  (312) 353-8360
  borries.samuel@epa.gov

  To reach EPA staff toll-free, call (800)
  621-8431,10 a.m. - 5:30 p.m.,
  weekdays.

  Mike Alexander
  Team Supervisor
  Michigan DEQ
  (517) 335-4189
  alexandm@michigan.gov

  To learn more about the Great Lakes
  Legacy Act, please visitwww.epa.gov/
  glla/
Ruddiman  Creek/Pond
Dredging  Project Will  Remove
Contaminants
                                  Muskegon Lake Area of Concern
                                  Muskegon, Michigan
                                                  July 2005
The long-awaited cleanup of Ruddiman Creek and Ruddiman Pond will
begin soon, according to U.S. Environmental Protection Agency's Great
Lakes National Program Office and the Michigan Department of
Environmental Quality. The federal and state agencies recently agreed
on details of the cleanup plan. Work on this Great Lakes Legacy Act
project may begin as soon as  mid-August.
Ruddiman Creek and Ruddiman Pond are part of the designated
Muskegon Lake "area of concern" or AOC. Contaminants are present at
high enough concentrations that they can affect human health, wildlife
and aquatic life. Currently the main branch of Ruddiman Creek is posted
as a no swimming, fishing or  recreation area due  in part to
contaminated sediment. EPA and Michigan DEQ, in  partnership with a
local public advisory council, have developed a contaminated sediment
removal and site cleanup project for the creek and the pond.
The $10.6 million project is expected to take about nine months to
remove about 80,000 cubic yards of contaminated sediment (mud).
Under the Great Lakes Legacy Act of 2002,  $6.9 million or 65 percent of
cleanup costs are paid for with federal funds. The other 35 percent or
                                   This is an aerial view of the area where contaminated sediment will be removed
                                   from Ruddiman Creek and Ruddiman Pond.

-------
$3.7 million must be non-federal, in this instance funds
from the state's Clean Michigan Initiative.

The main contaminants of concern include cadmium,
found in the sediment with a maximum level of 25
parts per million; chromium, found at 5,900 ppm;
polychorinated biphenyls, usually called PCBs, found at
6 ppm; and lead, found at  1,200 ppm.  This project will
remove  a substantial amount of these contaminants: an
estimated 2,800 pounds of cadmium, 320 pounds of
PCBs, 204,000 pounds of chromium and 126,000
pounds  of lead.

Project details
The sediment removal and cleanup project will have
different approaches for the  creek and the pond. Creek
sediment cleanup includes road construction to get
access to the creek. The creek will be diverted and
temporary walls will be constructed so the sediment
can be removed under dry conditions. The pond will be
dredged and any resuspended sediments will be
controlled with barriers called silt curtains. The
curtains will hold the material stirred up during
dredging. Contaminated sediment will be hauled by
truck to a licensed landfill near Muskegon, and
sampling will be done during and after the project to
make sure contamination levels are reduced.

Finally, after sediment cleanup, the creek and pond will
be reconstructed and water flow patterns restored.
Bare sections will also be replanted with native species
of flowers, trees and grasses.
   About the Great Lakes Legacy Act
   Although discharges of toxic substances into the Great Lakes have been reduced over the last 20 years, high
   concentrations of pollution remain in the bottom of some rivers and harbors. That poses a potential risk to
   people and wildlife. As a result, states have issued advisories in most locations around the Great Lakes
   against eating locally caught fish. The tributaries and harbors identified as having pollution problems are
   known as "areas of concern," or AOCs. There are 31 AOCs on the American side of the Great Lakes.
   Ruddiman Creek is part of the Muskegon Lake AOC.

   Congress passed and the President signed the Great Lakes Legacy Act of 2002 to address the problem of
   contaminated sediment in these 31 areas. The Legacy Act authorizes $270 million in funding over five years
   for cleanups. Fiscal Year 2004 was the first in which  Legacy Act funds were available for projects, and
   Congress appropriated $10 million. For the current fiscal year, Congress appropriated $22.3 million.

-------
 United States
 Environmental Protection
 Agency
For more information
If you would like more information
on the Ruddiman Creek/Ruddiman
Pond project, you may contact one
these team members:

Marc Tuchman
Project Manager
EPA Great Lakes National Program
Office
(312)353-1369
tuchman.marc@epa.gov

To reach EPA staff toll-free, call
(800) 621-8431,10 a.m. - 5:30 p.m.,
weekdays.

Mike Alexander
Project Manager
Michigan DEQ
(517)335-4189
alexandm@michigan.gov

To learn more about the Great Lakes
Legacy Act, please visit epa.gov/glla/
Great Lakes  Legacy  Act
Cleanup of Ruddiman Creek
Finished  on  Schedule
                                Muskegon Lake Area of Concern
                                Muskegon, Michigan
                                                 May 2006
Federal and state government officials say the $13.5 million dredging and
cleanup project for Ruddiman Creek and Ruddiman Pond finished on
schedule this month and resulted in the removal of about 90,000 cubic
yards of contaminated mud. U.S. Environmental Protection Agency's
Great Lakes National Program Office and the Michigan Department of
Environmental Quality oversaw the cleanup effort, which lasted about nine
months.

Ruddiman Creek and Ruddiman Pond are part of the designated Muskegon
Lake "area of concern" or AOC. Contaminants present in the creek and
pond posed potential health risks to humans and wildlife exposed to the
pollution. The cleanup project should help speed the lifting of fishing and
recreation bans in effect on the main branch of Ruddiman Creek.

EPA and Michigan DEQ, in partnership with the citizen groups Muskegon
Lake Public Advisory Council and the Ruddiman  Creek Task Force,
developed a contaminated sediment removal and site cleanup project for
the creek and the pond. Local citizens worked for years advocating for
the cleanup, which finally got moving thanks to the federal Great Lakes
                                This is an aerial view of the area where contaminated sediment was removed from
                                Ruddiman Creek and Ruddiman Pond.

-------
Legacy Act (see box last page for more details on the
GLLA). Legacy Act funds paid for 65 percent, or about
$8.8 million, of the Ruddiman Creek project. Ihe other
35 percent, or $4.7 million, came from the state's Clean
Michigan Initiative.

The Legacy Act strives to streamline the cleanup process
while emphasizing collaboration among governments and
community groups. EPA officials hailed the Ruddiman
Creek project as successfully achieving these purposes.


Ihe main contaminants of concern at Ruddiman Creek
included lead, cadmium, chromium andpolychorinated
biphenyls, usually called PCBs. The project removed
126,000 pounds of lead, 2,800 pounds of cadmium,
204,000 pounds of chromium and 320 pounds of PCBs.

The sediment removal and cleanup project used different
approaches for the creek and the pond. Creek sediment
cleanup included road construction to get access to the
water. The creek was diverted and temporary walls were
constructed so the sediment could be removed under
dry conditions. Ihe only snag in the project occurred
during the winter when a road turned out to be too soft
to support equipment trying to reach the northern end
of Ruddiman Creek. The problem was quickly solved by
                                                    building a pontoon road and by using a special dredge
                                                    mounted on floats.

                                                    The pond was dredged, and barriers called silt
                                                    curtains held the material stirred up during the work.
                                                    Contaminated sediment was hauled by truck to a licensed
                                                    landfill near Muskegon, and sampling was done during
                                                    and after the project to make sure contamination levels
                                                    were reduced.

                                                    For the first time during an EPA dredging project, the
                                                    Agency posted weekly updates and plotted the volume of
                                                    sediment removed on an Agency Web site so people could
                                                    follow the cleanup progress.

                                                    After dredging was completed, the creek and pond were
                                                    reconstructed and water flow patterns restored. Workers
                                                    are currently finishing up by replanting bare sections of
                                                    the banks and construction roads with native species
                                                    of flowers, trees and grasses. The public was given a
                                                    walking tour of the area in April. The community will
                                                    be responsible for follow-up care and monitoring of the
                                                    restoration area. Local environmental activists say there
                                                    are already reports of lake salmon returning to Ruddiman
                                                    Creek. During the dredging, great blue herons perched
                                                    on silt curtains to watch for fish.
About the                       Act
Although discharges of toxic substances into the Great Lakes have been reduced over the last 20 years, high
concentrations of pollution remain in die bottom of some rivers and harbors. That poses a potential risk to people
and wildlife. As a result, states have Issued advisories in most locations around the Great Lakes against eating
locally caught fish. Ihe tributaries and harbors identified as having pollution problems are known as "areas of
concern," or AOCs. There are 31 AOCs on the American side of the Great Lakes. Ruddiman Creek is part of the
Muskegon Lake AOC.
Congress passed and die President signed the Great Lakes Legacy Act of 2002 to address die problem of
contaminated sediment in these 31 areas. Ihe Legacy Act authorizes $270 million in funding over five years
for cleanups. Fiscal Year 2004 was die first in which Legacy Act funds were available for projects, and Congress
appropriated $9.9 million. In 2005 Congress appropriated $22.3 million, and $29.6 million was appropriated in
2006 for Legacy Act cleanups. The President has requested $49.6 million in the proposed 2007 budget. Ruddiman
Creek joins the Black Lagoon near Detroit and Hog Island in Superior, Wis., as completed Legacy Act projects.
Hie largest Legacy Act project to dare in both cost ($50 million) and volume (600,000 cubic yards of sediment) is
currently underway In Ashtabula, Ohio.

-------
                                             APPENDIX D
       Ruddiman Creek Main Branch and Pond



                  Design Drawings
March 2011                                            101

-------
REMEDIATION OF RUDDIMAN CREEK MAIN BRANCH AND POND
102                                                                      March 2011

-------
D
 C
 B
A
                   8
7
                                              RIFFLE STRUCTURES
                                               -SHEET PILE
                                          DIVERSION CHANNEL







4


                                                                                                                   DIVERSION CHANNEL
                                                                  TEMPORARY CULVERT
                                                                  (TYPICAL OF 2)
2





                                                                                                                                                                                      STAGING/PROCESSING
                                                                                                                                                                                      AREA (SEE SHEET 13)
                                                                                                                               SHEET PILE
                                                                                                                               BARRIER WALL
                                                                                                                               (TO BLOCK AND
                                                                                                                               REDIRECT GROUNDWATER)
                                                                                                                                             SHEET PILE
                                                                                                                                                                                     N MORSTADT
                                                                                                                                                                                SOLE:    1=100
                                                                                                                                                                                                                       ENVIRONMENTAL QUALITY
                                                                                                                                                                                                                       MANAGEMENT, INC.
                                                                                                                                                                                                                       1800 CARILLON BLVD.
                                                                                                                                                                                                                       CINCINNATI, OHIO 45240
                                                                                                                                                                                                                       P (513)825-7500
                                                                                                                                                                                                                       F (513)825-7495
                                                                                                                                                                                                             RUDDIMAN CREEK
                                                                                                                                                                                                              BARCLAY ROAD AREA
                                                                                                                                                                                                       D
                                                                                                                                                            030228.0036
                   8
7
                                                                                     FIGURE A-1

                                                                                         1

-------
RUSHES AND SEDGES
                                                                                                              ENVIRONMENTAL QUALITY
                                                                                                              MANAGEMENT, INC.
                                                                                                              1800 CARILLON BLVD.
                                                                                                              CINCINNATI. OHIO 45240
                                                                                                              P (513)825-7500
                                                                                                              F (513)825-7495
                                                                                                      RUDDIMAN CREEK
                                                                                                      GLENSIDE BLVD. AREA
                                                                                                                  FIGURE A-2
030228.0036

-------
LJMFT OF
SHORE  UNE DISTURBANCE

                                                                                                                                                          ENVIRONMENTAL QUALITY
                                                                                                                                                          MANAGEMENT. INC.
                                                                                                                                                          1800 CARILLON BLVD.
                                                                                                                                                          CINCINNATI, OHIO 45240
                                                                                                                                                          P (513)825-7500
                                                                                                                                                          F (513)825-7495
                                                                                                                                                 RUDDIMAN CREEK
                                                                                                                                                      LAGOON AREA
FIGURE A-3
                                                                                                                                                030228.0036

-------