EPA 542-R-14-002
Office of Solid Waste and Emergency Response
United States Office of Superfund Remediation and
Environmental Protection Technology Innovation
Agency
Remedial Design Optimization Review Report
East 67th Street Ground Water Plume NPL Site
Odessa, Ector County, Texas
EPA Region 6
www.clu-in.org/optimization I www.epa.gov/superfund/remedytech www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
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OPTIMIZATION REVIEW
EAST 67TH STREET GROUND WATER PLUME NPL SITE
ODESSA, ECTOR COUNTY, TEXAS
EPA REGION 6
FINAL REPORT
January 10, 2014
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EXECUTIVE SUMMARY
NATIONAL OPTIMIZATION STRATEGY BACKGROUND
The U.S. Environmental Protection Agency's definition of optimization is as follows:
"Efforts at any phase of the removal or remedial response to identify and implement
specific actions that improve the effectiveness and cost-efficiency of that phase. Such
actions may also improve the remedy's protectiveness and long-term implementation
which may facilitate progress towards site completion. To identify these opportunities,
Regions may use a systematic site review by a team of independent technical experts,
apply techniques or principles from Green Remediation or Triad, or apply some other
approaches to identify opportunities for greater efficiency and effectiveness"1
An optimization review considers the goals of the remedy, available site data, conceptual site model
(CSM), remedy performance, protectiveness, cost-effectiveness and closure strategy. A strong interest in
sustainability has also developed in the private sector and within Federal, state and municipal
governments. Consistent with this interest, optimization now routinely considers green remediation and
environmental footprint reduction during optimization reviews.
An optimization review includes reviewing site documents, interviewing site stakeholders, potentially
visiting the site for one day and compiling a report that includes recommendations in the following
categories:
• Protectiveness
• Cost-effectiveness
• Technical improvement
• Site closure
• Environmental footprint reduction
The recommendations are intended to help the site team identify opportunities for improvements in these
areas. In many cases, further analysis of a recommendation, beyond that provided in this report, may be
needed prior to implementation of the recommendation. Note that the recommendations are based on an
independent review and represent the opinions of the optimization review team. These recommendations
do not constitute requirements for future action, but rather are provided for consideration by the EPA
Region and other site stakeholders. Also note that while the recommendations may provide some details
to consider during implementation, the recommendations are not meant to replace other, more
comprehensive, planning documents such as work plans, sampling plans and quality assurance project
plans (QAPP).
The national optimization strategy includes a system for tracking consideration and implementation of the
optimization recommendations and includes a provision for follow-up technical assistance from the
optimization review team as mutually agreed upon by the site management team and EPA OSRTI.
1 EPA. 2012. Memorandum: Transmittal of the National Strategy to Expand Superfund Optimization Practices from
Site Assessment to Site Completion. From: James. E. Woolford, Director Office of Superfund Remediation and
Technology Innovation. To: Superfund National Policy Managers (Regions 1-10). Office of Solid Waste and
Emergency Response (OSWER) 9200.3-75. September 28.
January 2014 i
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Optimization Review East 67th Street Ground Water Plume NPL Site
SITE-SPECIFIC BACKGROUND
The East 67th Street Ground Water Plume Superfund Site (East 67th Street Site) is located in Odessa, Ector
County, Texas in EPA Region 6. The site was added to the National Priorities List (NPL) on March 7,
2007, and is managed as a fund-lead site. A Remedial Investigation (RI) and report were finalized in May
2010 and a Record of Decision (ROD) was signed in September 2011. The site is currently in the
Remedial Design (RD) phase. The site was nominated for an optimization review at the request of the
Region 6 Remedial Project Manager (RPM) in January 2013.
The site consists of a contaminated groundwater plume originating from a 1985 release of alcohols,
naphtha-based solvents and tetrachloroethene (PCE) from above ground tanks. The plume encompasses
an area of at least 60 acres in the Trinity Aquifer, which is the only source for drinking water in the area
outside of the Odessa city limits. The primary contaminants of concern (COCs) are PCE, trichloroethene
(TCE) and cis-l,2-dichloroethene (cis-1,2 DCE). The current CSM is detailed in documents including the
ROD, RI reports, and data evaluation summaries. A summary of the CSM components relevant to RD is
provided below.
SUMMARY OF CONCEPTUAL SITE MODEL AND KEY FINDINGS
The source of Site contamination was a single release of 15,000 gallons of chemicals, including 635
gallons of PCE, caused by an act of vandalism at the former Delta Solvents Company facility in March of
1985. The original spill was remediated at the time of release, but a resulting groundwater plume was
identified by the Texas Commission on Environmental Quality (TCEQ) during routine monitoring of
public water supplies in 2004. The plume is located in a rural residential area with some light industry.
Area groundwater is also affected by elevated nitrate concentrations, most likely resulting from septic
releases.
Site stratigraphy consists of unconsolidated overburden deposits overlying shale bedrock of the Dockum
Group at a depth of approximately 145 feet (ft) below ground surface (bgs). Overburden deposits consist
of:
Quaternary Alluvium - eolian sand, unsaturated
• Ogallala Formation - differentiated as follows:
o Caprock consisting of fractured caliche, unsaturated
o Upper sand number 1 (US1), unsaturated
o Upper clay number 1 (UC1), unsaturated
o Upper sand number 2 (US2), saturated or unsaturated depending on rainfall
o Upper clay number 2 (UC2), saturated or unsaturated depending on rainfall
• Trinity Sands, differentiated as follows:
o Lower sand number 1 (LSI), saturated
o Lower clay number 1 (LCI), saturated
o Lower sand number 2 (LS2), saturated
The dissolved-phase plume is present in US2 (saturated at the time of the optimization review) and
LSI. Contaminants are transported in the subsurface in both the dissolved phase and vapor phase.
Existing private water supply wells are not typically grouted above the screened interval, or have long
screen intervals, that allow contamination from US2 to migrate vertically past the UC2 and into the
LSI. The TCEQ has installed granular activated charcoal (GAC) water filtration systems on 14 private
wells located within the plume in LSI and is presently providing operation and maintenance on the
systems.
January 2014
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Optimization Review East 67ffi Street Ground Water Plume NFL Site
The optimization review team identified the following data gaps in the current CSM relevant to RD:
The quantity of mass remaining in vadose zone soils that is capable of causing long-term
contamination and its potential response to soil vapor extraction (SVE) treatment;
• Extent of dissolved groundwater contamination in US2;
Potential effect of active in situ bioremediation (ISB) on secondary water quality issues such as
mobilization of arsenic, manganese and iron;
• Potential mechanisms for vertical migration of contamination;
Extent of contaminant migration and time frame for aquifer restoration once relevant supply wells
are plugged and abandoned.
r^ oo
SUMMARY OF RECOMMENDATIONS
The optimization review team identified the following priorities for RD and implementation:
• Eliminate exposure pathways and vertical migration by replacing specific private water supply
wells that may function as conduits to LS1.
• Improve plume monitoring by installing new groundwater monitoring wells.
• Increase priority of implementing US2 ISB groundwater remedy, rather than the proposed
extraction and treatment remedy. Use extracted groundwater for ISB substrate blending and
delivery.
• Conduct small-scale soil vapor extraction (SVE) pilot test in source area. SVE pilot will improve
characterization of contaminant mass remaining in the vadose.
Evaluate the need for active remediation in LS 1 after plugging supply wells that appear to be
contaminant transport conduits to the lower unit. If remediation is required in LSI, ISB is
recommended.
• Implement remedy performance monitoring.
• Establish exit criteria for each active remedy component.
• No recommendations were identified for improvements in data management or green remediation
goals.
January 2014 iii
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CONTENTS
NOTICE AND DISCLAIMER VI
PREFACE VII
LIST OF ACRONYMS AND ABBREVIATIONS VIII
1.0 OBJECTIVES OF THE OPTIMIZATION REVIEW 1
2.0 OPTIMIZATION REVIEW TEAM 2
3.0 REMEDIAL ACTION OBJECTIVES AND PROPOSED REMEDIES 3
3.1 REMEDIAL ACTION OBJECTIVES AND AFFECTED MEDIA 3
3.2 PROPOSED REMEDIES 6
3.3 CURRENT EXIT STRATEGY 7
4.0 FINDINGS 8
4.1 DATA GAPS AND CHARACTERIZATION 8
4.2 REMEDIAL STRATEGY 8
5.0 RECOMMENDATIONS 10
5.1 ELIMINATE EXPOSURE PATHWAY AND VERTICAL MIGRATION BY REPLACING SPECIFIC
PRIVATE WATER SUPPLY WELLS AND INSTALLING NEW MONITORING POINTS 10
5.1.1 RECOMMENDATION 5.1.1: PLUG, ABANDON AND REPLACE KEY WATER SUPPLY
WELLS 10
5.1.2 RECOMMENDATION 5.1.2: INSTALL ADDITIONAL MONITORING WELLS IN US2
AND LSI 10
5.2 INCREASE PRIORITY OF IMPLEMENTING US2ISB 11
5.2.1 RECOMMENDATION 5.2.1: INCREASE PRIORITY OF US2 ISB REMEDY 11
5.2.2 RECOMMENDATION 5.2.2: USE EXTRACTED GROUNDWATER FOR ISB SUBSTRATE
BLENDING AND DELI VERY 11
5.3 SVE PILOT TEST 12
5.3.1 RECOMMENDATION 5.3.1: CONDUCT SMALL-SCALE SVE PILOT TEST IN SOURCE
AREA VADOSE ZONE 12
5.4 DETERMINE NEED FOR ACTIVE REMEDIATION OF LSI 12
5.4.1 RECOMMENDATION 5.4.1: EVALUATE LS1 AFTER WELL PLUGGING AND US2
REMEDIATION TO DETERMINE NEED FOR ACTIVE REMEDIATION OF LS 1 12
5.4.2 RECOMMENDATION 5.4.2: ACTIVELY REMEDIATE LSI USING ISB 13
5.5 REMEDY PERFORMANCE MONITORING 13
5.5.1 RECOMMENDATION 5.5.1: IMPLEMENT REMEDY PERFORMANCE MONITORING 13
5.6 DATA MANAGEMENT 14
5.7 CONSIDERATIONS FOR ESTABLISHING EXIT CRITERIA 14
5.7.1 RECOMMENDATION 5.7.1: ESTABLISH EXIT CRITERIA FOR EACH REMEDY
COMPONENT 14
5.8 RECOMMENDATIONS RELATED TO ENVIRONMENTAL FOOTPRINT REDUCTION 15
January 2014
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Optimization Review East 67th Street Ground Water Plume NFL Site
TABLES
1 OPTIMIZATION REVIEW TEAM 2
2 OTHER OPTIMIZATION REVIEW CONTRIBUTORS 2
3 COCS AND CLEANUP GOALS 5
4 AFFECTED OR POTENTIALLY AFFECTED MEDIA ON SITE 5
5 REMEDIAL ACTION OBJECTIVES 6
6 REMEDIES PROPOSED IN THE ROD 6
7 IDENTIFIED DATA GAPS 8
8 RECOMMENDATION SUMMARY 15
FIGURES
1 SITE LOCATION 1
2 SOURCE AREA 3
3 PCE PLUME 3
4 GEOLOGIC CROSS-SECTION 4
APPENDICES
A REFERENCES A-l
B SUPPORTING FIGURES FROM EXISTING DOCUMENTS B-l
C MAROS ANALYSIS REPORTS C-l
D RECOMMENDED PERFORMANCE MONITORING D-l
January 2014
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NOTICE AND DISCLAIMER
Work described herein, including preparation of this report, was performed by Terra Tech for the U.S.
Environmental Protection Agency under Work Assignment 2-58 of EPA contract EP-W-07-078 with Terra Tech
EM, Inc., Chicago, Illinois. The report was approved for release as an EPA document, following the Agency's
administrative and expert review process.
This optimization review is an independent study funded by the EPA that focuses on protectiveness, cost-
effectiveness, site closure, technical improvements and green remediation. Detailed consideration of EPA policy
was not part of the scope of work for this review. This report does not impose legally binding requirements, confer
legal rights, impose legal obligations, implement any statutory or regulatory provisions or change or substitute for
any statutory or regulatory provisions. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
Recommendations are based on an independent evaluation of existing site information, represent the technical views
of the optimization review team and are intended to help the site team identify opportunities for improvements in the
current site remediation strategy. These recommendations do not constitute requirements for future action, rather
they are provided for consideration by the EPA Region and other site stakeholders.
While certain recommendations may provide specific details to consider during implementation, these are not meant
to supersede other, more comprehensive planning documents such as work plans, sampling plans and quality
assurance project plans (QAPP), nor are they intended to override Applicable or Relevant and Appropriate
Requirements (ARAR). Further analysis of recommendations, including review of EPA policy may be needed prior
to implementation.
January 2014 vi
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PREFACE
This report was prepared as part of a national strategy to expand Superfund optimization practices from
site assessment to site completion implemented by the U.S. Environmental Protection Agency Office of
Superfund Remediation and Technology Innovation (OSRTI)2. The project contacts are as follows:
ORGANIZATION
KEY CONTACT
CONTACT INFORMATION
EPA OSRTI
Kirby Biggs
EPA OSRTI
Technology Innovation and Field Services
Division
2777 Crystal Dr.
Arlington, VA 22202
biggs.kirby@epa.gov
phone: 703-823-3081
Tetra Tech
(Contractor to EPA)
Jody Edwards, P.G.
Tetra Tech
1881 Campus Commons Drive, Suite 200
Reston,VA20191
iody.edwards@tetratech.com
phone: 802-288-9485
Peter Rich, P.E.
Tetra Tech
51 Franklin St.
Ste. 400
Annapolis, MD 21401
peter.rich@tetratech.com
phone: 410-990-4607
GSI Environmental
(Contractor to Tetra Tech)
Mindy Vanderford,
Ph.D
GSI Environmental, Inc.
2211 Norfolk, Suite 1000
Houston, TX 77098
mvanderford@gsi-net.com
phone: 713-522-6300x186
2 EPA. 2012. Memorandum: Transmittal of the National Strategy to Expand Superfund Optimization Practices from
Site Assessment to Site Completion. From: James. E. Woolford, Director Office of Superfund Remediation and
Technology Innovation. To: Superfund National Policy Managers (Regions 1-10). Office of Solid Waste and
Emergency Response (OSWER) 9200.3-75. September 28.
January 2014
VII
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LIST OF ACRONYMS AND ABBREVIATIONS
(ig/L Micrograms per Liter
ARAR Applicable or Relevant and Appropriate Requirements
bgs Below Ground Surface
CSM Conceptual Site Model
COC Contaminant of Concern
cis-1,2 DCE c/s-l,2-Dichloroethene
EPA U.S. Environmental Protection Agency
ERT Emergency Response Team
ft Feet
GAC Granular Activated Carbon
HQ Headquarters
ISB In Situ Bioremediation
LC Lower Clay
LS Lower Sand
MAROS Monitoring and Remediation Optimization Systems
MCL Maximum Contaminant Level
NPL National Priorities List
ORP Oxidation Reduction Potential
OSRTI Office of Superfund Remediation and Technology Innovation
PCE Tetrachloroethene (aka Perchloroethylene)
QAPP Quality Assurance Project Plans
RAC Remedial Action Contractor
RAO Remedial Action Objective
RD Remedial Design
RI Remedial Investigation
ROD Record of Decision
RPM Remedial Project Manager
SVE Soil Vapor Extraction
TCE Trichloroethene
TCEQ Texas Commission on Environmental Quality
TOC Total Organic Carbon
UC Upper Clay
US Upper Sand
VOC Volatile Organic Compound
January 2014
Vlll
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1.0 OBJECTIVES OF THE OPTIMIZATION REVIEW
For more than a decade, the Office of Superfund Remediation and Technology Innovation (OSRTI) has
provided technical support to the EPA regional offices through the use of independent (third party)
optimization reviews at Superfund sites. The East 67th Street Ground Water Plume Superfund Site (East
67th Street Site) was nominated for an optimization review at the request of the Region 6 Remedial
Project Manager (RPM) in January 2013. The current optimization review of the site is intended to
improve protectiveness, reduce cost and reduce the time required to attain cleanup goals.
FIGURE 1. Site location
(Excerpt from Figure 1 of the September 2011 ROD. A
full size version of this figure is provided in Appendix
To this end, an optimization review team (described
below) was assembled and met with regulatory
stakeholders and consultants in Dallas, Texas to review
site data, remediation goals, potential funding and time
frames to implement the remedy. This report is a
summary of the recommendations of the optimization
review team based on a review of Site documents and
meeting with stakeholders.
The site is located in Odessa, Ector County, Texas in
EPA Region 6 (Figure 1). The site was added to the
National Priorities List (NPL) on March 7, 2007. A
Remedial Investigation (RI) and report was finalized in
May 2010 and a Record of Decision (ROD) was signed
in September 2011. The site is currently in the
Remedial Design (RD) phase.
Objectives of the RD optimization review included:
Review of conceptual site model (CSM)
Review of Remedial Action Objectives (RAO)
• Review of proposed remedies and associated
costs
• Provide recommendations for:
o CSM improvements
o Remedy improvements
o Prioritization and sequencing of the remedy components
o Performance monitoring metrics in support of exit criteria for each remedy component
January 2014
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2.0 OPTIMIZATION REVIEW TEAM
The RD optimization review team consisted of the independent, third-party participants listed below.
The optimization review team collaborated with representatives of EPA Headquarters and EPA Region
6, the Texas Commission on Environmental Quality (TCEQ) and representatives of EA Engineering,
Science and Technology, Inc. (EA), the Remedial Action Contractor (RAC) for EPA.
The independent (third-party) optimization review team consisted of the following individuals:
TABLE 1. Optimization Review Team
NAME
Doug Sutton
Mindy Vanderford
ORGANIZATION
Tetra Tech
GSI Environmental, Inc.
PHONE
732-409-0344
713-522-6300
EMAIL
doug . sutton@tetratech . com
mvanderford@gsi-net.com
The following individuals contributed to the optimization review process, including being present for
the onsite review meeting:
TABLE 2. Other Optimization Review Contributors
NAME
Kirby Biggs
Tom Kady
Vincent Malott
Marilyn Czimer Long
Buddy Henderson
Jay Snyder
Luis Vega
ORGANIZATION
EPAHQ
EPA HQ ERT
EPA Region 6
TCEQ
TCEQ
EA
EA
TITLE/PARTY
Optimization Review Lead
Optimization Review Team
RPM and Region 6 Optimization Liaison
Project Technical Support
Project Manager
RAC Consultant
RAC Consultant
EA = EA Engineering, Science and Technology, Inc.
ERT = Environmental Response Team
HQ = Headquarters
RAC = Remedial Action Contract
TCEQ = Texas Commission on Environmental Quality
A meeting to discuss the site was held at Region 6 Headquarters in Dallas, Texas on April 25, 2013.
Documents reviewed for the optimization review effort are listed in Appendix A.
This optimization review used existing environmental data to interpret the CSM, evaluate potential future
remedy performance and make recommendations to improve the remedy. The quality of the existing data
was evaluated by the optimization review team prior to using the data for these purposes. The evaluation
for data quality included a brief review of how the data were collected and managed (where practical, the
site quality assurance project plan is considered), the consistency of the data with other site data and the
use of the data in the optimization review. Data that were of suspect quality were either not used as part of
the optimization review or were used with the quality concerns noted. Where appropriate, this report
provides recommendations made to improve data quality.
January 2014
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3.0 REMEDIAL ACTION OBJECTIVES
AND PROPOSED REMEDIES
The site includes a contaminated groundwater plume originating from a 1985 release of alcohols,
naphtha-based solvents and tetrachloroethene (PCE) from above ground tanks. The plume encompasses
an area of at least 60 acres in the Trinity Aquifer, which is the only source for drinking water in the area
outside of the Odessa city limits. The primary contaminants of concern (COCs) are PCE,
trichloroethene (TCE) and cis-l,2-dichloroethene (cis-1,2 DCE). The current CSM is detailed in
documents including the ROD, RI reports and data evaluation summaries. A summary of the CSM
components relevant to RD is provided below.
3.1 REMEDIAL ACTION OBJECTIVES AND AFFECTED MEDIA
Remedial Action Objectives (RAOs) for the site have been developed to address COCs associated with
the release of 15,000 gallons of chemicals, including 635 gallons of PCE released by an act of
vandalism at the former Delta Solvents Company facility in March of 1985 (Figure 2). The former
Delta Solvents Company facility is currently occupied by Brenntag Facilities. The site was identified by
the TCEQ during routine monitoring of public water supplies in 2004. The plume is located in a rural
residential area with some light industry (Figure 3).
FIGURE 2. Location of source area as
indicated by passive soil gas sampling.
(Figure is an excerpt of Figure 8 from the
September 2011 ROD. A full size version of the
figure is provided in Appendix B.)
FIGURE 3. 2013 Distribution of
PCE contamination in the LSI.
(Figure is an excerpt of a figure prepared by EA Engineering,
Science and Technology. A full size version of the
figure is provided in Appendix B.)
January 2014
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Optimization Review
East 67th Street Ground Water Plume NPL Site
Site stratigraphy (Figure 4) consists of unconsolidated overburden deposits overlying the shale bedrock
of the Dockum Group. The Docum Group begins at a depth of approximately 145 feet (ft) below
ground surface (bgs). Overburden deposits consist of:
• Quaternary Alluvium, eolian sand, unsaturated
Ogallala Formation, differentiated as follows:
o Caprock consisting of fractured caliche, unsaturated
o Upper sand number 1 (US1), unsaturated
o Upper clay number 1 (UC1), unsaturated
o Upper sand number 2 (US2), saturated or unsaturated depending on rainfall
o Upper clay number 2 (UC2), saturated or unsaturated depending on rainfall
Trinity Sands, differentiated as follows:
o Lower sand number 1 (LSI), saturated
o Lower clay number 1 (LCI), saturated
o Lower sand number 2 (LS2), saturated
FIGURE 4. Geologic cross-section illustrating the various
sand and clay layers at the East 67th Street Site.
US2 and LSI are contaminated. US2 is sometimes saturated. LSI is always saturated and is the interval screened by most
existing water supply wells in the area. Most existing water supply wells in the LSI are not grouted above the screen interval
and serve as preferential vertical pathways for contamination to migrate from US2 to LSI. New water supply wells can be
installed in LS2. (Figure is an excerpt of a Figure 3 from the September 2011 ROD. A full size version of the figure is provided
in Appendix B.)
The dissolved-phase plume is present in US2 (saturated at the time of the optimization review) and
LSI. Contaminants are transported in the subsurface in both the dissolved phase and vapor phase.
Existing private water supply wells are not typically grouted above the screened interval, or have long
January 2014
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Optimization Review
East 67th Street Ground Water Plume NPL Site
screen intervals, that allow contamination from US2 to migrate vertically past the UC2 and into the
LSI. The TCEQ has installed granular activated charcoal (GAC) water filtration systems on 14 private
wells located within the plume in LSI and is presently providing operation and maintenance on the
systems.
Site COCs and cleanup levels based on federal Maximum Contaminant Levels (MCLs) are shown in
Table 3. Affected and potentially affected media along with potential exposure/migration pathways are
summarized in Table 4. Table 5 lists RAOs for the source area and downgradient groundwater.
TABLE 3: COCs and Cleanup goals
CONSTITUENT NAME
AFFECTED MEDIA
CLEANUP GOAL
PCE
Trinity Aquifer
TCE
cis-1,2 DCE
70
Benzene
Vinyl chloride
Hg/L = micrograms per liter
TABLE 4: Affected or Potentially Affected Media on Site
MEDIUM
Vadose Zone
Soils
Occasionally
saturated lower
Ogallala
Formation (US2)
Trinity Sands
aquifer (LSI and
LS2)
Indoor air
LOCATION
Quaternary eolian sands
and Ogallala Formation
(USlandUS2)in
source area around
Brenntag Facilities
building
Approximately 50 to 70
feet (ft) below ground
surface (bgs)
65 ft or less of saturated
thickness between 80
and 145 ft bgs
Commercial businesses
and residences
COMPOSITION
Sands, silts, fine sands
and gravels separated
by layers of clay (UC1
and UC2)
Highly transmissive,
unconsolidated fine- to
medium- grained sands
Highly transmissive,
unconsolidated fine- to
medium- grained sands
POTENTIAL
EXPOSURE/MIGRATION
PATHWAYS
Infiltration to groundwater/direct
exposure by excavation
Migration to LSI through
unsealed wells or UC2 clay
Primary local water supply
Vapor intrusion study not completed
January 2014
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Optimization Review
East 67th Street Ground Water Plume NPL Site
TABLE 5: Remedial Action Objectives
REMEDIAL ACTION
Prevent Exposure
Plume Containment
Aquifer Restoration
Source Control
REMEDIAL ACTION OBJECTIVE
Prevent human exposure to COCs from water supply wells at concentrations above
MCLs or concentration standards identified in Applicable or Relevant and
Appropriate Requirements (ARARs)
Prevent or minimize further migration of COCs in groundwater at concentrations
exceeding the MCLs or identified by ARARs
Restore the groundwater to its expected beneficial uses, wherever practicable, so that
concentrations of COCs are less than the applicable MCLs or concentrations
identified in ARARs
Prevent or minimize further migration of COCs in the vadose zone soils that would
cause concentrations of COCs in groundwater to exceed MCLs or identified in
ARARs and mitigate potential vapor intrusion
3.2 PROPOSED REMEDIES
Table 6 lists the remedies proposed in the ROD.
TABLE 6: Remedies Proposed in the ROD
REMEDY
Install Water
Supply Line
Ground Water
Extraction and
Treatment
In Situ
Biodegradation
Treatment Zones
Soil Vapor
Extraction and
Well Abandonment
Institutional
Controls
Five-Year Reviews
TARGET
MEDIUM
Drinking water
Ground Water
(Trinity Aquifer)
Ground Water
(Trinity Aquifer)
Source Area
Residential
properties and
area groundwater
All site media
DESCRIPTION
Install water supply line from City of Odessa to homes and
businesses with private water supply wells impacted by the site
contamination or that may be impacted in the near future.
Connection to the water supply line is voluntary.
This alternative does not include continued maintenance of the
filtration systems. Continued maintenance and or plugging and
abandonment of existing supply wells will be responsibility of the
property owner.
Install extraction wells to pump groundwater from the
contaminated interval of the Ogallala and Trinity aquifers to
provide hydraulic containment of the plume. Transfer the
extracted water to central treatment plant remove volatile organic
compounds (VOCs) via an air stripper with off-gas treatment.
Install additional monitoring wells and conduct additional
groundwater sampling to update and monitor the extent of the
VOC plume.
Utilize in situ biostimulation and/or bioaugmentation to treat the
plume interior through reductive dechlorination.
Extract contaminated soil vapors from the target zone over 3
years.
Abandon an estimated ten private water supply wells suspected of
serving as vertical conduits between US2 and LSI. Replace
abandoned wells with new supply wells in LS2 with cement
casing constructed to prevent vertical migration of contaminants.
Implement restrictive covenants, deed notices, and/or other area-
wide restrictions of groundwater use.
Prepare reports to document remedy performance and
protectiveness.
January 2014
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Optimization Review East 67th Street Ground Water Plume NPL Site
Subsequent to the ROD, the site team identified the following potential deviations from the remedies
described in the ROD:
Plug, abandon and replace existing impacted supply wells and postpone construction of a water
line pending the results of the other remedy components in reducing the dissolved plume
concentrations.
Focus on the in situ bioremediation (ISB) component of the remedy and avoid use of the pump
and treat system due to the more expensive treatment requirements for removal of nitrate (from
suspected septic tank or agricultural releases) that is present in the groundwater.
• Pilot test soil vapor extraction (SVE) to determine if it is needed or will be effective in meeting
RAOs.
3.3 CURRENT EXIT STRATEGY
The ROD identifies short-term expectations that the exposure to contaminated groundwater will be
prevented, that plume migration will be controlled and that source area soil will be remediated.
Subsequent to the ROD, the focus of the site team has been on addressing the higher concentration
portions of the plume in an attempt to close the site without the need for a water line or long-term
groundwater extraction and treatment.
January 2014
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4.0 FINDINGS
Discussions during the optimization meeting and the optimization review team's document review
resulted in the key findings identified in this section.
4.1 DATA GAPS AND CHARACTERIZATION
Table 7 presents identified data gaps identified by the optimization review team that may influence RD.
TABLE 7. Identified data gaps
MEDIUM
DATA GAP
POTENTIAL RECOMMENDATION
Vadose zone
Remaining mass in
vadose zone that is
capable of causing
human exposure or
groundwater
contamination above
cleanup goals and can be
removed by SVE
Concur with Site team to pilot test a small-scale SVE
system to evaluate potential mass removal and if a full-
scale Soil vapor extraction (SVE) system is merited. See
Recommendation 5.3.
US2 groundwater
Extent of dissolved
contamination in US2
Install additional monitoring wells to delineate
contamination and serve as potential injection wells for
an in situ bioremediation (ISB) remedy. See
Recommendation 5.2.
US2andLSl
groundwater
Effect of ISB on
secondary water quality
issues such as
mobilization of arsenic,
manganese and iron
Pilot test ISB to determine extent of secondary water
quality issues resulting from ISB. See Recommendation
5.2.
US2, UC2 and
LSI groundwater
Mechanism for vertical
migration of
contamination
With GW-205 and GW-210 already plugged, evaluate
concentrations at MW-9 to determine if plugging GW-
205 and GW-210 prevents further impacts to the LSI in
the vicinity of MW-9. See Recommendation 5.1.
LSI groundwater
Extent of contaminant
migration and time
frame for aquifer
restoration once relevant
supply wells are plugged
and abandoned.
Develop targets for limiting contaminant migration and
for aquifer restoration timeframe. Develop a
contingency remedy to implement if targets are not
achieved. See Recommendation 5.4.
4.2 REMEDIAL STRATEGY
The optimization review team identified the following priorities for RD and implementation.
1. Plug and abandon unsealed wells that are allowing contamination to migrate vertically from the
US2totheLSl.
2. Provide permanent alternative water supply to those properties where water supply wells
currently have filtration systems.
January 2014
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Optimization Review East 67th Street Ground Water Plume NFL Site
3. Provide permanent alternative water supply to those properties where water supply wells are
likely to be impacted by site-related contamination within the next 5 years or that are likely to be
significantly affected by secondary water quality effects caused by remediation
4. Remediate contamination in US2.
5. Determine if SVE will provide a meaningful benefit.
6. Evaluate LSI concentrations to determine if active remediation is merited in the LSI.
7. Implement active remediation in LS1, if needed.
January 2014
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5.0 RECOMMENDATIONS
The optimization review team recognizes there are logistical constraints that may prevent timely
implementation of all remedy components. Consequently, the optimization recommendations reflect a
suggested prioritization of activities consistent with the remedial strategy presented in Section 4.2.
5.1
5.7.7
ELIMINATE EXPOSURE PATHWAY AND VERTICAL MIGRATION BY
REPLACING SPECIFIC PRIVATE WATER SUPPLY WELLS AND INSTALLING
NEW MONITORING POINTS
Recommendation 5.1.1: Plug, Abandon and
Replace Key Water Supply Wells
Benefits of Implementing Section 5.1
Recommendations
• Eliminate exposure pathway over
the long term for three residences
not connected to public water
supply.
• Significantly reduce or prevent
vertical migration of
contamination to the LS1.
• Provide key monitoring locations
to characterize the plume and
monitor and implement the ISB
remedy.
With respect to limiting vertical migration from the US2 to
the LSI, the site team and optimization review team
identified water supply wells (GW-19, GW-21, GW-22,
GW-24, GW-67 and Well-A) as private wells that should be
plugged, abandoned and replaced with wells screened in
LS2. In addition, the site team and optimization review team
agreed that private water supply well GW-23 should be
plugged and abandoned; this well does not need to be
replaced because water would be available to the GW-23
property owner from the replacement well for GW-24A.
Instead of installing a water line, well replacement would
also be conducted for the water supply wells that are
currently on filtration systems maintained by TCEQ.
5.1.2 Recommendation 5.1.2: Install Additional
Monitoring Wells in US2 and LSI
Water supply wells recommended for plugging and replacement represent areas of the plume with some
of the highest contaminant concentrations. The area between GW-24 and MW-27 represents up to 60
percent of the calculated dissolved contaminant mass in the LSI plume (see Appendix C - Monitoring
and Remediation Optimization Systems (MAROS) reports). The optimization review team cautions that
plugging and abandoning these wells could alter the groundwater flow direction in the US2 because
plugging and abandoning these wells will remove US2 groundwater "sinks" that are currently controlling
US2 groundwater flow. The optimization review team, therefore, recommends that the site team install
new US2 and LSI monitoring wells adjacent to water supply wells GW-21, GW-23, GW-24A and
additional LSI wells at GW-19 and GW-27 when those wells are plugged, abandoned and replaced. (The
optimization review team recommends installation of 4-inch wells.) The new US2 wells can be monitored
to determine the extent of US2 contaminant migration after the water supply wells are plugged and can
help determine the extent of contamination to be addressed by ISB. Monitoring wells MW-4, MW-9,
MW-10, and the three new LSI monitoring wells can be monitored to determine if plugging and
abandoning water supply wells GW-205 and GW-210 prevents further contaminant migration from the
US2 to the LS 1. The new LS 1 monitoring wells should be 4-inch diameter wells so that they can be
converted to groundwater extraction wells for the US2 ISB remedy, if necessary. If concentrations in
three noted existing LSI wells persist and are identified in the three new LSI wells, it may suggest
continued vertical migration from the US2 through the UC2 to the LSI. If this is the case, greater urgency
January 2014
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Optimization Review
East 67th Street Ground Water Plume NPL Site
should be placed on remediating the US2 in a timely manner. Monitoring of other LS1 water supply wells
should also continue to determine if additional wells should be plugged, abandoned and replaced.
The optimization review team agrees with the site team's estimated cost of approximately $40,000 to
plug, abandon and replace each water supply well and $10,000 to plug and abandon each monitoring well.
Based on the plugging, abandonment and replacement of up to 16 wells, installation of five additional
US2 wells and installation of three new LSI wells, the optimization review team estimates a cost of
approximately $750,000. The costs for monitoring of the wells discussed in this section are presented in
Section 5.5.
5.2 INCREASE PRIORITY OF IMPLEMENTING US2ISB
Benefits of Implementing Section 5.2
Recommendations
• Prioritizing source remediation
over plume containment expedites
the aquifer restoration process and
provides the potential opportunity
to avoid a long-term costly
containment remedy.
• The approach significantly
reduces or prevents vertical
migration of contamination to the
LSI.
• Key monitoring locations are
provided to characterize the plume
and to implement and monitor the
ISB remedy.
5.2.1 Recommendation 5.2.1: Increase Priority of US2
ISB Remedy
The optimization review team places a high priority on
remediating the contaminant plume in US2 and agrees with
the site team that ISB is an appropriate remedial approach.
Prior to conducting the ISB remedy, the target area for
treatment needs to be identified. This might be achieved by
monitoring results from existing and proposed US2 wells
recommended in Section 5.1. An analysis of existing data
from 2013 indicates that the majority of dissolved mass is
found in the vicinity of water supply wells GW-21A, GW-
22A, GW-23, GW-24A and MW-27 (see Appendix C;
Percent of Mass by Well Report). Historically, water supply
well GW-205 and monitoring wells MW-09 and MW-27
have exhibited the highest concentrations of PCE.
Monitoring well MW-09 and water supply well GW-205
show decreasing trends, while monitoring well MW-27 has a
fairly stable concentration trend.
5.2.2 Recommendation 5.2.2: Use Extracted
Groundwater for ISB Substrate Blending and Delivery
The optimization review team suggests using permanent injection wells and extracted groundwater for
ISB reagent blending and injection. Impacted water from the three new LSI, 4-inch wells noted in Section
5.1 should be used if possible. Extracting the impacted water from the LSI aquifer for remediation
purposes should provide sufficient water for remediation and would provide some degree of LS 1 mass
removal, which should help mitigate contaminant migration and speed remedial progress. LSI wells that
are installed for this purpose also can be used to monitor the LS 1 after the water supply wells identified in
Section 5.1 are plugged and abandoned.
The optimization review team suggests that areas with contaminant concentrations more than four times
the cleanup goals be targeted for remediation. Assuming this area is less than 10,000 ft2, the remedy
would likely involve five injection wells, under 40,000 pounds of ISB substrate (based on use of
emulsified vegetable oil) and approximately 225,000 gallons of water. The injections could likely be
conducted within a 2-week period. Based on the installation of five US2 injection wells, 40,000 pounds of
ISB substrate, 2 weeks for injections and additional resources for planning and reporting, the optimization
review team estimates that ISB remedy implementation should cost under $300,000. A larger target
treatment zone would require additional cost or a different configuration of injections. Continued
monitoring on a quarterly basis for 2 years for VOCs, oxidation reduction potential (ORP), total organic
January 2014
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Optimization Review
East 67th Street Ground Water Plume NPL Site
carbon (TOC), arsenic, manganese and iron in the five injection wells and US2 monitoring wells would
be appropriate. A second round of ISB injections may be appropriate based on the results from the
analysis of 2 years of quarterly performance monitoring. The costs of performance monitoring are
discussed in Section 5.5.
5.3 SVE PILOT TEST
5.3.1 Recommendation 5.3.1: Conduct Small-Scale SVE
Pilot Test in Source Area Vadose Zone
Benefits of Implementing Section 5.3
Recommendations
• Determine the need for SVE and
obtain data to support a decision to
retain or eliminate SVE from the
final remedy.
The amount of mass in the source area, the potential for that
mass to be removed via SVE and the potential for that mass
to cause ongoing groundwater contamination is uncertain.
The optimization review team supports conducting a small-
scale SVE pilot test in the shallow unsaturated zone of the
source area to evaluate the mass removal and to determine if
broader-scale SVE is merited. If the pilot test suggests that
significant mass removal is possible, then it should be assumed that the mass can cause continued
groundwater contamination and broader-scale SVE should be applied. The pilot can involve vacuum
testing several existing vapor monitoring wells to determine the flow rate that can be obtained from each
well and the PCE and cis-1,2 DCE concentrations in the extracted vapors. Assuming three wells are tested
over the course of 2 to 3 days, the cost for the pilot test might be on the order of $15,000, excluding
planning and reporting.
5.4 DETERMINE NEED FOR ACTIVE REMEDIATION OF LSI
Benefits of Implementing Section 5.4
Recommendations
• Evaluation of the LSI water
quality over time following source
remediation and before an LS1
remedy provides the potential
opportunity to avoid
complications and cost associated
with a LSI remedy.
5.4.1 Recommendation 5.4.1: Evaluate LSI after Well
Plugging and US2 Remediation to Determine
Need for Active Remediation of LSI
Plugging and abandonment of the wells, as described in
Section 5.1, and remediation of US2 may be successful at
preventing further contaminant migration into the LSI, and
the absence of a continuing source to LSI may allow LSI to
reach cleanup goals without active remediation. Continued
monitoring of existing LSI wells, the new LSI wells noted
in Section 5.1 and some of the remaining LSI water supply
wells will help the site team monitor the progress toward
aquifer restoration. Based on this information, the site team can determine if active remediation is needed
in the LSI to help control contaminant migration, shorten the time frame for aquifer restoration or both.
The determination can be made based on the number of LS 1 wells that would require replacement if
remediation was not conducted compared to the number of LSI wells that would require replacement if
remediation was conducted.
The optimization review team and the site team discussed ISB and in situ chemical oxidation with ozone
as potential practical, remedial options. Both technologies cause temporary water quality issues. ISB
could result in increased dissolved arsenic, iron and manganese in groundwater. Odor may also be an
issue in some locations. Ozone could form hexavalent chromium or bromate. The optimization review
team favors ISB because of the larger radius of influence of each well and because less infrastructure is
needed than for ozone injections associated with chemical oxidation. In addition, degradation will occur
for several months after a single ISB injection. Depending on the extent of the secondary water quality
January 2014
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Optimization Review
East 67th Street Ground Water Plume NPL Site
issues, the site team may need to replace additional LSI water supply wells that might be impacted by the
ISB treatment.
5.4.2 Recommendation 5.4.2: Actively Remediate LSI Using ISB
If active remediation in LS1 is deemed necessary, the optimization review team would favor a target
treatment zone focusing on areas with PCE concentrations that are more than four times higher than the
cleanup goal. Assuming this volume of water could be treated with three ISB biobarriers installed at
various distances along the plume axis, this remedy might involve the installation of 15 dual-purpose
injection/extraction wells in the LSI, 200,000 pounds of emulsified vegetable oil (or equivalent amounts
of another substrate) and 1.5 million gallons of extracted water to blend and inject the substrate. Based on
these parameters and over a month in the field to conduct the injections, the optimization review team
estimates a cost of approximately $1 million for one round of ISB injection. Replacement of up to 10
additional LSI wells could cost another $400,000. An additional injection event would not likely be
needed. The costs for potential performance monitoring activities are discussed in Section 5.5.
Given the cost of this effort and the potential adverse effects on water quality, the optimization review
team encourages the site team to carefully determine if remediation is necessary for LSI before pursuing
remediation (that is, implement Recommendations 5.1, 5.2 and 5.3 first).
5.5 REMEDY PERFORMANCE MONITORING
5.5.1 Recommendation 5.5.1: Implement Remedy
Performance Monitoring
Benefits of Implementing Section 5.5
Recommendations
• Cost-effective monitoring program
and performance metrics will
optimize remedy operation and
allow shutdown of remedy
components in a timely manner.
The performance monitoring recommendations for the site,
including the monitoring described above, are provided in
Appendix D. The specified performance monitoring is
expected to cost approximately $250,000 over a two year
period.
Recommended remedy performance metrics include:
Well plugging, abandonment and replacement - These activities should significantly decrease the mass
discharge from the US2 to the LSI. Potential performance metrics should include the following:
Groundwater contaminant concentrations in wells (or replacement wells near) MW-04, MW-09, GW-24,
GW-22, GW-19, GW-67, MW-27 and the new LSI wells overtime relative to baseline groundwater
contaminant concentrations at the same wells.
Groundwater contaminant concentrations and statistical trends in wells listed above over time relative to
cleanup goals.
US2 ISB - The US2 ISB remedy should significantly reduce the PCE and other VOC concentrations in
the US2 and reduce mass discharge to the LS 1. A potential performance metric in addition to those noted
for well plugging (above) includes the following:
Reduction of PCE and VOC plume mass based on total dissolved mass calculations using VP-01 through
VP-05 and the new US2 wells.
LSI Aquifer Restoration - Signs of LSI restoration should become apparent after well plugging and US2
ISB. A potential performance metric in addition to those noted above includes the following:
January 2014
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Optimization Review
East 67th Street Ground Water Plume NPL Site
Changes in groundwater contaminant concentrations in other LS1 wells relative to baseline (current)
groundwater contaminant concentrations in LSI wells and relative to cleanup goals. Significant
contaminant concentration increases in some wells could indicate the potential for plume expansion and
the need for the LS 1ISB remedy to achieve aquifer restoration without affecting additional water supply
wells.
Additional performance monitoring evaluations can include calculations of dissolved plume mass and
mass flux through monitoring transects.
5.6 DATA MANAGEMENT
Data management activities for the site appear to have captured the majority of the data necessary to
support site decision making. Site data can be transferred between groups analyzing data fairly easily and
historic data are easy to interpret and visualize. No changes in site data management are recommended.
5.7 CONSIDERATIONS FOR ESTABLISHING
EXIT CRITERIA
5. 7.1 Recommendation 5.7.1: Establish Exit Criteria
for Each Remedy Component
The optimization review team has the following suggestions
for consideration by the site team in developing exit criteria.
Benefits of Implementing Section 5.7
Recommendations
• Criteria established to help avoid
operating long-term remedies
longer than necessary.
One potential exit criterion for the SVE system is attainment of a PCE mass removal rate that is some
given fraction of the initial PCE mass removal rate. The fraction should be calculated at the point where
further operation of the SVE system would result in negligible mass removal relative to mass removal at
startup. At this point, further SVE implementation would no longer be technically effective or cost
effective.
Another potential exit criterion for the SVE system can be based on a mass removal rate relative to the
current mass flux from the source area to the dissolved plume. For example, there is a given flux of PCE
mass from the source area to the dissolved plume that could be represented by the estimated groundwater
volume flow rate through an assumed cross-sectional area around VP-01 and multiplied by the PCE
concentration at VP-01. The exit criterion could be to shut down the SVE system when the rate of mass
removal from the SVE system is some multiple lower than the current mass flux rate through this cross-
sectional area.
The exit criterion for ISB of US2 should be to discontinue injections after the first round. One injection
should be enough to sufficiently reduce the plume mass to facilitate aquifer restoration; therefore,
additional injections should not be needed. If one injection is not effective in reducing average PCE (or
total VOC) concentration (or plume mass) in the target treatment area below the criteria used to select the
target treatment area, then it is unlikely that subsequent injections will be effective (unless the site team
gains information during the first injection that suggests another injection would be successful).
Additional study by the site team would be needed to help refine the above exit criteria for the various
remedy components to help avoid unnecessary operation of these remedies.
January 2014
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Optimization Review
East 67th Street Ground Water Plume NPL Site
5.8 RECOMMENDATIONS RELATED TO ENVIRONMENTAL FOOTPRINT
REDUCTION
No specific recommendations have been provided for environmental footprint reduction. However,
several of the above recommendations have the potential to reduce the remedy footprint by (1) carefully
evaluating the need for remediation before implementation and (2) developing an exit strategy for
remediation before implementing a remedy.
TABLE 8: Recommendation Summary
RECOMMENDATION
5.1.1 Plug, abandon and replace
(16) key water supply wells
5.1.2 Install additional
monitoring wells in US2 and
LSI
5.2.1 Increase priority of US2
ISB remedy
5.2.2 Use extracted groundwater
for ISB substrate blending and
delivery
5.3.1 Conduct small-scale SVE
pilot test in source area
5.4.1. Evaluate LSI after well
plugging and US2 remediation
to determine need for active
remediation of LSI
5.4.2 Install LSI ISB remedy, if
5.4.1 evaluation indicates
remedy is required
5.5.1 Implement remedy
performance monitoring
5.7.1 Establish exit criteria for
each remedy component
EFFECTIVENESS
X
X
X
X
X
X
X
COST REDUCTION
X
X
X
X
TECHNICAL
IMPROVEMENT
X
X
SITE CLOSURE
X
X
X
X
X
X
ENVIRONMENTAL
FOOTPRINT
REDUCTION
X
X
X
X
X
CAPITAL
COST
$670K
$80K
$300K
N/A
S15-20K
N/A
$1.4M
$250K
N/A
CHANGE
IN
ANNUAL
COST
N/A = Not applicable; cost for recommendation is not significantly greater than existing reporting and management activities.
January 2014
15
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APPENDIX A
REFERENCES
EA (2010a). Remedial Investigation, East 67th Street Ground Water Plume Superfiind Site. Lewisville,
Texas, EA Engineering, Science and Technology, Inc for US Environmental Protection Agency
Region 6.
EA (201 Ob). Feasibility Study Report, East 67th Street Ground Water Plume Superfund Site. Lewisville,
Texas, EA Engineering, Science and Technology, Inc for US Environmental Protection Agency
Region 6.
EA (2011). Technical Memorandum, qPCR and CSIA Data Evaluation. Lewisville, Texas, EA
Engineering, Science and Technology, Inc for US Environmental Protection Agency Region 6.
EA (2013). Data and Maps for January 2013 Groundwater Data. Dallas, Lewisville, Texas, EA
Engineering, Science and Technology, Inc. for US Environmental Protection Agency Region 6.
EPA (2011). Record of Decision East 67th Street Ground Water Plume Superfund Site. Dallas, TX, U.S.
Environmental Protection Agency Region 6.
EPA (2012). Transmittal of the National Strategy to Expand Superfiind Optimization Practices from Site
Assessment to Site Completion. Washington, D.C., U.S. Environmental Protection Agency, Office
of Solid Waste and Emergency Response.
January 2014 A-l
-------
APPENDIX B
SUPPORTING FIGURES FROM EXISTING DOCUMENTS
-------
,- sw'
-
\ \ • \Uv2Vl--^ IV-- ''Hp^i • jj ^N. ;v» V K''"'".'&'*V "''$•
' V ** * • •"------'• m* P'.-T—X A v—-^V;-;--*l ••% • -.^ ^tiS^-^'''-'*"''----^ " H*:°^l
^f\"af rl ^^t^iJ^fXX \ :V\ \ •
y > ! MV^IC"1'6i;?1' ^ ^S^v »* ^:i.":;:"^*^";^i'^--;;^^^ *vt;
// £Sf;l IK T^tl ,%-.|JJpr-n^
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\^ceVtgck^ - ^ %(*-^>^ -4V . JrPk c "|::^^"r'l\ H I
ATl'fjfl-^
0 500 1000 Feet
EA ENGINEERING,
SCIENCE, AND
TECHNOLOGY
EAST 67TH STREET
GROUND WATER PLUME
SUPERFUND SITE
Site Location
DESIGNED BY
CRF
DRAWN BY
CRF
CHECKED BY
DWR
SCALE
1:12,000
DATE
11/28/06
PROJECT NO
EPA6.0000.06
FIGURE
1
January 2014
B-1
-------
A A-7
MW-6 A-6
A-5
A-4 A-00 A
AL-9 f
i ^n^
.
Explanation Tetrachloroethene mass (nanograms)
• Monitor well location 10 - 500 ng
D Supply well 500-1,000ng
A Passive soil gas sample location I -\ QQQ - 3 000 ng
50 10°Feet ^H Above 3,000 ng
Source:
2007 Aerial photograph provided by Google Earth
N
0
c
(0
re
LU CO
1-13
LU rl LU
LJJ Q_ H
£*>
CO H
> O
CD Q Q
H z a:
a: o
CD LJJ
o
LJJ O
LJJ < O
LJJ LJJ Q
< O LJJ
LJJ CO I-
ID
o
o
i E
>- o
O H
LU CD
LU
O
CNJ
o
LU
CM
< O
Q
O
O
CM
111
_l
<
O
CO
00
Q
L1J
LJJ
X
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DQ
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January 2014
B-2
-------
r^ ^.^V —^> ^
* ¥*' -"..•""
" J«* I*"""***** ••** ^P
L. •**** I******
*> >- r
« A f~.
GW-207
2.4
GW-206
O 0.23LJ
jT Oiwov»-ao .GW-307
GW-64/^ GW-27 ) 4.8 Xn 4R,,,
" 2, /*' r* Vfe ^ • r V ^
^? feS^yic^
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^V ^ ~~^^\ '^"'^—...Tl. * «' , «^* ^D ^^ ".
'^5k -.; ^
<••%.
Base Map Source: 2008/2009 NAIP aerial photograph provided by TNRIS.
Explanation
Monitoring well
© Private water supply
MW-23 Well designation
4.1 PCE concentration (ug/L)
-------
APPENDIX C
MONITORING AND REMEDIATION OPTIMIZATION SYSTEM
ANALYSIS REPORTS
-------
MAROS Statistical Trend Analysis Summary
Project: East 67th Street
Location: Odessa
User Name: MV
State: Texas
Time Period: 1/31/2007 to 1/25/2013
Consolidation Period: No Time Consolidation
Consolidation Type: Median
Duplicate Consolidation: Average
ND Values: 1/2 Detection Limit
J Flag Values : Actual Value
Well
Source/
Tail
Number of
Samples
Number
of
Detects
Average
Cone. (mg/L)
Median Cone.
(mg/L)
All
Samples
"ND" ?
Mann-
Kendall
Trend
Linear
Regression
Trend
GW-01A
GW-02
GW-03
GW-04
GW-05
GW-07A
GW-08A
GW-101
GW-19A
GW-205
GW-206
GW-207
GW-213
GW-21A
GW-222
GW-227
GW-22A
GW-23
GW-24A
GW-27
GW-30
GW-301
GW-302
GW-304
GW-307
GW-66A
T
T
T
T
T
T
T
T
T
S
T
T
T
S
T
T
T
S
S
T
T
T
T
T
T
T
7
7
7
4
2
7
7
7
5
7
5
6
6
6
2
3
5
1
5
5
6
2
2
2
2
6
6
4
4
0
0
6
2
0
4
7
0
3
1
5
0
0
4
1
5
2
2
1
0
0
1
6
1.3E-03
5.2E-04
2.6E-04
3.1E-04
2.5E-04
1.7E-03
l.OE-03
3.9E-04
3.7E-03
5.7E-02
3.0E-04
5.1E-04
4.6E-04
2.5E-02
2.5E-04
2.5E-04
6.7E-02
1.9E-02
6.3E-02
8.1E-04
3.6E-04
2.2E-04
2.5E-04
2.5E-04
2.1E-04
9.7E-03
9.7E-04
5.0E-04
2.0E-04
2.5E-04
2.5E-04
1.2E-03
5.0E-04
5.0E-04
4.6E-03
3.9E-02
2.5E-04
5.0E-04
3.8E-04
6.4E-03
2.5E-04
2.5E-04
9.0E-02
1.9E-02
5.5E-02
5.0E-04
3.4E-04
2.2E-04
2.5E-04
2.5E-04
2.1E-04
l.OE-02
No
No
No
Yes
Yes
No
No
Yes
No
No
Yes
No
No
No
Yes
Yes
No
No
No
No
No
No
Yes
Yes
No
No
NT
S
NT
ND
ND
D
S
ND
S
D
ND
NT
S
PI
ND
ND
NT
N/A
S
1
S
N/A
ND
ND
N/A
NT
NT
S
NT
ND
ND
D
PD
ND
PI
D
ND
1
S
1
ND
ND
PI
N/A
S
PI
S
N/A
ND
ND
N/A
1
Wednesday, June 19, 2013
Page 1 of 5
January 2014
C-2
-------
MAROS Statistical Trend Analysis Summary
Project: East 67th Street
Location: Odessa
Well Name
Source/ Number of
Tail Samples
Number
of
Detects
Average
Cone. (mg/L)
User Name: MV
State: Texas
Median Cone.
(mg/L)
All
Samples
"ND" ?
Mann-
Kendall
Trend
Linear
Regression
Trend
cis-l,2-DICHLOROETHYLENE
MW-02
MW-04
MW-07
MW-08
MW-09
MW-10
MW-11
MW-12
MW-13
MW-14
MW-16
MW-18
MW-21
MW-22
MW-23
MW-24
MW-27
T
S
T
T
S
S
T
T
T
T
T
T
T
S
S
T
T
3
6
3
5
6
6
7
7
7
3
6
3
5
5
5
6
4
3
3
1
0
6
4
6
4
1
0
6
1
5
4
4
0
4
1.1E-02
1.3E-03
5.5E-04
4.0E-04
6.3E-02
7.0E-04
2.5E-03
8.3E-04
7.4E-04
4.2E-04
3.0E-03
4.0E-03
1.6E-02
3.9E-03
1.6E-03
7.5E-04
4.7E-02
1.1E-02
1.1E-03
5.0E-04
5.0E-04
6.3E-02
6.2E-04
2.7E-03
6.5E-04
5.0E-04
5.0E-04
2.9E-03
5.0E-04
1.7E-02
2.9E-03
1.1E-03
5.0E-04
4.6E-02
No
No
No
Yes
No
No
No
No
No
Yes
No
No
No
No
No
Yes
No
N/A
NT
N/A
ND
S
NT
PI
PD
NT
ND
NT
N/A
S
D
D
ND
NT
N/A
NT
N/A
ND
D
NT
1
D
NT
ND
NT
N/A
PD
D
D
ND
PI
GW-01A
GW-02
GW-03
GW-04
GW-05
GW-07A
GW-08A
GW-101
GW-19A
GW-205
GW-206
GW-207
GW-213
GW-21A
T
T
T
T
T
T
T
T
T
S
T
T
T
S
7
7
7
4
2
7
7
7
5
7
5
6
6
6
7
7
5
1
2
7
4
7
4
7
4
6
2
6
2.9E-03
1.7E-03
5.4E-04
3.0E-04
2.4E-04
4.8E-03
1.2E-03
2.9E-03
8.8E-03
6.5E-02
2.8E-04
2.1E-03
9.2E-04
9.9E-03
2.5E-03
1.8E-03
5.3E-04
2.5E-04
2.4E-04
3.0E-03
5.0E-04
2.8E-03
1.2E-02
7.0E-02
2.3E-04
1.9E-03
3.8E-04
7.7E-03
No
No
No
No
No
No
No
No
No
No
No
No
No
No
NT
S
PI
NT
N/A
D
PD
PD
NT
PD
NT
1
NT
PI
NT
1
1
NT
N/A
D
D
D
PI
D
NT
PI
NT
PI
Wednesday, June 19, 2013
Page 2 of 5
January 2014
C-3
-------
MAROS Statistical Trend Analysis Summary
Project: East 67th Street
Location: Odessa
Well Name
Source/ Number of
Tail Samples
Number
of
Detects
Average
Cone. (mg/L)
User Name: MV
State: Texas
Median Cone.
(mg/L)
All
Samples
"ND" ?
Mann-
Kendall
Trend
Linear
Regression
Trend
TETRACHLOROETHYLENE(PCE)
GW-222
GW-227
GW-22A
GW-23
GW-24A
GW-27
GW-30
GW-301
GW-302
GW-304
GW-307
GW-66A
MW-02
MW-04
MW-07
MW-08
MW-09
MW-10
MW-11
MW-12
MW-13
MW-14
MW-16
MW-18
MW-21
MW-22
MW-23
MW-24
MW-27
T
T
T
S
S
T
T
T
T
T
T
T
T
S
T
T
S
S
T
T
T
T
T
T
T
S
S
T
T
2
3
5
1
5
5
6
2
2
2
2
6
3
6
3
5
6
6
7
7
7
3
6
3
5
5
5
6
4
2
3
5
1
5
5
6
2
2
1
2
6
3
6
0
1
6
6
7
7
1
0
4
0
5
5
5
0
4
6.9E-04
2.6E-04
2.0E-02
2.5E-02
3.4E-02
5.3E-03
1.1E-03
l.OE-03
3.4E-04
2.2E-04
6.0E-04
3.7E-03
2.5E-03
9.4E-03
4.2E-04
5.1E-04
7.3E-02
9.9E-03
4.3E-03
7.2E-03
7.3E-04
4.2E-04
9.0E-04
4.2E-04
4.9E-03
1.4E-02
l.OE-02
7.5E-04
4.2E-02
6.9E-04
2.1E-04
2.5E-02
2.5E-02
3.5E-02
5.2E-03
1.1E-03
l.OE-03
3.4E-04
2.2E-04
6.0E-04
3.4E-03
2.0E-03
6.4E-03
5.0E-04
5.0E-04
8.0E-02
7.9E-03
4.4E-03
6.8E-03
5.0E-04
5.0E-04
9.6E-04
5.0E-04
5.3E-03
1.9E-02
l.OE-02
5.0E-04
3.9E-02
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
Yes
No
Yes
No
No
No
Yes
No
N/A
N/A
NT
N/A
NT
NT
S
N/A
N/A
N/A
N/A
S
N/A
NT
ND
NT
S
D
NT
NT
NT
ND
NT
ND
D
D
D
ND
S
N/A
N/A
PI
N/A
NT
1
S
N/A
N/A
N/A
N/A
1
N/A
NT
ND
PI
PD
D
PI
NT
NT
ND
PI
ND
PD
D
D
ND
S
GW-01A
GW-02
T
T
7
7
4
3
8.6E-04
3.6E-04
5.0E-04
4.1E-04
No
No
NT
S
NT
S
Wednesday, June 19, 2013
Page 3 of 5
January 2014
C-4
-------
MAROS Statistical Trend Analysis Summary
Project: East 67th Street
Location: Odessa
Source/ Number of
Well Name Tail Samples
Number
of
Detects
Average
Cone. (mg/L)
User Name: MV
State: Texas
Median Cone.
(mg/L)
All Mann- Linear
Samples Kendall Regression
"ND" ? Trend Trend
TRICHLOROETHYLENE (TCE)
GW-03
GW-04
GW-05
GW-07A
GW-08A
GW-101
GW-19A
GW-205
GW-206
GW-207
GW-213
GW-21A
GW-222
GW-227
GW-22A
GW-23
GW-24A
GW-27
GW-30
GW-301
GW-302
GW-304
GW-307
GW-66A
MW-02
MW-04
MW-07
MW-08
MW-09
MW-10
MW-11
MW-12
MW-13
MAROS Version 3.0
Release 352. Septemb
T
T
T
T
T
T
T
S
T
T
T
S
T
T
T
S
S
T
T
T
T
T
T
T
T
S
T
T
S
S
T
T
T
er2012
7
4
2
7
7
7
5
7
5
6
6
6
2
3
5
1
5
5
6
2
2
2
2
6
3
6
3
5
6
6
7
7
7
2
0
0
4
2
0
4
7
1
4
1
3
0
1
4
1
5
3
2
2
0
0
1
3
1
3
0
0
6
4
5
6
0
2.7E-04
3.1E-04
2.5E-04
6.9E-04
6.7E-04
3.9E-04
l.OE-03
7.5E-03
2.6E-04
4.6E-04
3.5E-04
1.2E-03
2.5E-04
2.0E-04
3.1E-03
2.8E-03
3.9E-03
9.8E-04
3.2E-04
2.5E-04
2.5E-04
2.5E-04
1.9E-04
1.1E-03
4.8E-04
9.3E-04
4.2E-04
4.0E-04
8.2E-03
5.7E-04
1.1E-03
9.7E-04
6.8E-04
2.5E-04
2.5E-04
2.5E-04
5.0E-04
5.0E-04
5.0E-04
1.3E-03
6.7E-03
2.5E-04
4.9E-04
3.8E-04
5.4E-04
2.5E-04
2.5E-04
4.0E-03
2.8E-03
4.2E-03
5.0E-04
2.7E-04
2.5E-04
2.5E-04
2.5E-04
1.9E-04
7.6E-04
5.0E-04
5.0E-04
5.0E-04
5.0E-04
8.6E-03
5.0E-04
1.1E-03
9.2E-04
5.0E-04
No
Yes
Yes
No
No
Yes
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
Yes
Yes
No
No
No
No
Yes
Yes
No
No
No
No
Yes
NT
ND
ND
D
NT
ND
NT
D
NT
NT
S
NT
ND
N/A
NT
N/A
NT
1
S
N/A
ND
ND
N/A
NT
N/A
NT
ND
ND
S
D
NT
NT
ND
Wednesday, June
NT
ND
ND
D
NT
ND
PI
D
PI
1
S
1
ND
N/A
PI
N/A
PI
1
S
N/A
ND
ND
N/A
NT
N/A
NT
ND
ND
D
D
1
NT
ND
19, 2013
Page 4 of 5
January 2014
C-5
-------
MAROS Statistical Trend Analysis Summary
Project: East 67th Street
Location: Odessa
Well Name
User Name: MV
State: Texas
Number All Mann- Linear
Source/ Number of of Average Median Cone. Samples Kendall Regression
Tail Samples Detects Cone. (mg/L) (mg/L) "ND" ? Trend Trend
TRICHLOROETHYLENE (TCE)
MW-14
MW-16
MW-18
MW-21
MW-22
MW-23
MW-24
MW-27
T
T
T
T
S
S
T
T
3
6
3
5
5
5
6
4
1
2
0
4
5
4
1
4
4.2E-04 5.0E-04
3.7E-04 3.8E-04
4.2E-04 5.0E-04
1.5E-03 1.4E-03
1.5E-03 1.8E-03
l.OE-03 8.7E-04
7.2E-04 5.0E-04
5.3E-03 5.0E-03
Note: Increasing (1); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing
(N/A) - Due to insufficient Data (< 4 sampling events); No Detectable Concentration (ND)
No
No
Yes
No
No
No
No
No
(D); No Trend
N/A
S
ND
S
D
S
NT
S
(NT);
N/A
S
ND
PD
D
D
NT
S
Not Applicable
The Number of Samples
and Number of Detects shown above are post-consolidation values.
MAROS Version 3.0
Release 352, September 2012
Wednesday, June 19, 2013
Page 5 of 5
January 2014
C-6
-------
MAROS Mann-Kendall Statistics Summary
Project: East 67th Street
Location: Odessa
Well:
Well Type:
COC:
2 5E-02 H
, o riF n9 .
E
T 1.5E-02 -
o
** 1 OF n? -
Ol
o
c
o
01 OF m •
n nF+nn .
User Name: MV
State: Texas
MW-04 Time Period: 1/31/2007 to 1/25/2013
S Consolidation Period: No Time Consolidation
TETRACHLOROETHYLENE(PCE) Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
oA' N^ r> cC>' if> ^
^ ^ O ^
-------
MAROS Mann-Kendall Statistics Summary
Project: East 67th Street User Name: MV
Location: Odessa State: Texas
Well:
Well Type:
COC:
1 2E-01 H
1 riF m .
E 8 OE-02 •
c
| 6.0E-02 -
§ 4.0E-02 -
c
o
^ o OF n? -
n nF+nn .
GW-205 Time Period: 1/31/2007 to 1/25/2013
S Consolidation Period: No Time Consolidation
TETRACHLOROETHYLENE(PCE) Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
*
4
^
•
Mann Kendall S Statistic:
-11
Confidence in Trend:
93.2%
Coefficient of Variation:
0.40
Mann Kendall
Concentration Trend: (See
Note)
PD
Data Table:
Well
GW-205
GW-205
GW-205
GW-205
GW-205
GW-205
GW-205
Well Effective Number of Number of
Type Date Constituent Result (mg/L) Flag Samples Detects
S 1/31/2007 TETRACHLOROETHY 7.0E-02 1 1
S 5/22/2007 TETRACHLOROETHY 8.7E-02 2 2
S 7/19/2007 TETRACHLOROETHY l.OE-01 1 1
S 10/28/2009 TETRACHLOROETHY 5.7E-02 1 1
S 6/16/2010 TETRACHLOROETHY 7.6E-02 1 1
S 12/15/2010 TETRACHLOROETHY 4.4E-02 1 1
S 1/25/2013 TETRACHLOROETHY 2.4E-02 1 1
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 1 of 2
C-8
-------
MAROS Mann-Kendall Statistics Summary
Project: East 67th Street User Name: MV
Location: Odessa State: Texas
Well:
Well Type:
COC:
9 OE-03 H
8.0E-03 -
j- 7 OE-03 •
E 6 OE-03 •
5 i OF m -
£5 A nF m .
'c
01 i np m .
c
o 2 OE-03 •
1 OE-03 •
n nF+nn .
MW-11 Time Period: 1/31/2007 to 1/25/2013
T Consolidation Period: No Time Consolidation
TETRACHLOROETHYLENE(PCE) Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
^^ V^ Q^* V^ ^P V^ V&-
•
*
* *
*
* •
Mann Kendall S Statistic:
3
Confidence in Trend:
61.4%
Coefficient of Variation:
0.56
Mann Kendall
Concentration Trend: (See
Note)
NT
Data Table:
Well
MW-11
MW-11
MW-11
MW-11
MW-11
MW-11
MW-11
Well Effective Number of Number of
Type Date Constituent Result (mg/L) Flag Samples Detects
T 5/22/2007 TETRACHLOROETHY 1.8E-03 1 1
T 7/19/2007 TETRACHLOROETHY 1.3E-03 2 2
T 10/28/2009 TETRACHLOROETHY 4.8E-03 1 1
T 6/16/2010 TETRACHLOROETHY 8.4E-03 1 1
T 12/15/2010 TETRACHLOROETHY 5.7E-03 2 2
T 6/29/2011 TETRACHLOROETHY 4.4E-03 1 1
T 1/25/2013 TETRACHLOROETHY 3.6E-03 1 1
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 1 of 2
C-9
-------
MAROS Mann-Kendall Statistics Summary
Project: East 67th Street
Location: Odessa
User Name: MV
State: Texas
Well: GW-22A
Well Type: T
COC: TETRACHLOROETHYLENE(PCE)
Time Period: 1/31/2007 to 1/25/2013
Consolidation Period: No Time Consolidation
Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
ion (mg
c
Ol
o
c
o
O
3.0E-02 •
2 5E-02 •
2 OE-02 •
1 EC n? -
1 np n? -
E nc n-> .
n nF+nn .
*
*
Mann Kendall S Statistic:
Confidence in Trend:
75.8%
Coefficient of Variation:
0.65
Mann Kendall
Concentration Trend: (See
Note)
NT
Data Table:
Well
GW-22A
GW-22A
GW-22A
GW-22A
GW-22A
Note: Increasing
Well
Type
T
T
T
T
T
Effective
Date
7/19/2007
10/28/2009
6/16/2010
12/15/2010
1/25/2013
Constituent Result (mg/L) Flag
TETRACHLOROETHY
TETRACHLOROETHY
TETRACHLOROETHY
TETRACHLOROETHY
TETRACHLOROETHY
(1); Probably Increasing (PI); Stable (S); Probably Decreasing
(N/A) - Due to insufficient Data
5.0E-03
7.3E-03
3.3E-02
2.9E-02
2.5E-02
(PD); Decreasing (D);
Number of
Samples
1
1
1
1
2
No Trend (NT); Not
Number of
Detects
1
1
1
1
2
Applicable
(< 4 sampling events); ND = Non-detect
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 1 of 1
C-10
-------
MAROS Mann-Kendall Statistics Summary
Project: East 67th Street
Location: Odessa
User Name: MV
State: Texas
Well: GW-24A
Well Type: S
COC: TETRACHLOROETHYLENE(PCE)
Time Period: 1/31/2007 to 1/25/2013
Consolidation Period: No Time Consolidation
Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
O)
c
01
o
c
o
O
Date
4**F 09 -
A OF 09 -
1 *»F 09 -
1 OF 09 -
9 *»F 09 -
9 OF 09 -
1.5E-02 •
1 rtF n9 .
1 OF m •
n np4-nn .
•
*
«
Mann Kendall S Statistic:
Confidence in Trend:
88.3%
Coefficient of Variation:
0.24
Mann Kendall
Concentration Trend: (See
Note)
NT
Data Table:
Well
GW-24A
GW-24A
GW-24A
GW-24A
GW-24A
Note: Increasing
Well
Type
S
S
S
S
S
Effective
Date
7/19/2007
10/28/2009
6/16/2010
12/15/2010
1/25/2013
Constituent Result (mg/L) Flag
TETRACHLOROETHY
TETRACHLOROETHY
TETRACHLOROETHY
TETRACHLOROETHY
TETRACHLOROETHY
(1); Probably Increasing (PI); Stable (S); Probably Decreasing
(N/A) - Due to insufficient Data
2.5E-02
2.7E-02
4.1E-02
4.3E-02
3.5E-02
(PD); Decreasing (D);
Number of
Samples
1
1
1
1
1
No Trend (NT); Not
Number of
Detects
1
1
1
1
1
Applicable
(< 4 sampling events); ND = Non-detect
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 1 of 1
C-11
-------
MAROS Mann-Kendall Statistics Summary
Project: East 67th Street
Location: Odessa
User Name: MV
State: Texas
Well: MW-27
Well Type: T
COC: TETRACHLOROETHYLENE(PCE)
Time Period: 1/31/2007 to 1/25/2013
Consolidation Period: No Time Consolidation
Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
Concentration (mg/L)
6.0E-02 •
5 OE-02 •
4 OE-02 •
•» OF n? -
o OF n? -
1 np rt9 .
n nF+nn .
•
•
•
•
Mann Kendall S Statistic:
-4
Confidence in Trend:
83.3%
Coefficient of Variation:
0.37
Mann Kendall
Concentration Trend: (See
Note)
Data
Note:
(N/A)
Table:
Well
MW-27
MW-27
MW-27
MW-27
Increasing
Well
Type
T
T
T
T
Effective
Date
10/28/2009
6/16/2010
12/15/2010
1/25/2013
Constituent Result (mg/L) Flag
TETRACHLOROETHY
TETRACHLOROETHY
TETRACHLOROETHY
TETRACHLOROETHY
(1); Probably Increasing (PI); Stable (S); Probably Decreasing
- Due to insufficient Data
4.3E-02
6.4E-02
3.5E-02
2.7E-02
(PD); Decreasing (D);
Number of
Samples
1
1
1
1
No Trend (NT); Not
Number of
Detects
1
1
1
1
Applicable
(< 4 sampling events); ND = Non-detect
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 1 of 1
C-12
-------
MAROS Percent of Mass by Well
Project: East 67th Street
Location: Odessa
User Name: MV
State: Texas
TETRACHLOROETHYLENE(PCE) 7/1/2013 [fb
Af\
*IU
•jr
3D
*jn
JU
•>r
ZD
•?n
zu
1 C
ID
1 n n
1U
n n
n n [
n rn „ II n II I
-i
n PI n n n „
>vy//x/>vvvv>
Well Area(ftZ) Mass(mg) Percent of Mass Percent of Area
GW-01A 47,811.89
GW-02 18,491.10
GW-03 39,463.59
GW-04 23,102.51
GW-05 39,932.90
GW-07A 29,962.05
GW-08A 43,463.68
GW-101 27,709.30
GW-19A 117,751.36
GW-205 25,201.02
GW-206 33,562.12
GW-207 137,362.71
GW-213 94,632.98
GW-21A 49,333.64
30.12 0.79 2.23
6.80 0.18 0.86
6.63 0.17 1.84
1.52 0.04 1.08
3.67 0.10 1.86
5.03 0.13 1.40
2.85 0.08 2.03
16.00 0.42 1.29
401.83 10.58 5.49
158.77 4.18 1.17
2.03 0.05 1.56
86.54 2.28 6.40
6.21 0.16 4.41
275.84 7.26 2.30
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 1 of 2
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MAROS Percent of Mass by Well
Project: East 67th Street
Location: Odessa
Well
GW-222
GW-227
GW-22A
GW-23
GW-24A
GW-27
GW-30
GW-301
GW-302
GW-304
GW-307
GW-66A
MW-02
MW-04
MW-07
MW-08
MW-09
MW-10
MW-11
MW-12
MW-13
MW-14
MW-16
MW-18
MW-21
MW-22
MW-23
MW-24
MW-27
Area (ft2)
47,110.08
64,490.01
30,585.59
29,005.26
36,302.66
51,441.48
69,535.56
39,322.03
9,092.82
91,022.56
70,818.01
14,603.64
18,241.13
16,677.10
5,584.30
7,894.68
14,735.64
40,409.69
90,667.04
29,959.11
40,732.26
106,982.39
2,200.84
16,270.02
61,188.63
30,972.97
154,329.53
37,671.84
189,349.23
2,144,977.0
Mass (mg)
7.91
3.56
202.73
191.87
329.72
13.50
10.40
12.39
0.93
5.97
8.55
11.88
4.79
15.32
1.47
1.66
161.30
47.73
85.68
54.66
2.67
28.08
0.58
4.27
44.97
20.33
166.10
2.47
1,351.95
3,797.3
User Name:
State:
Percent of Mass
0.21
0.09
5.34
5.05
8.68
0.36
0.27
0.33
0.02
0.16
0.23
0.31
0.13
0.40
0.04
0.04
4.25
1.26
2.26
1.44
0.07
0.74
0.02
0.11
1.18
0.54
4.37
0.07
35.60
100
MV
Texas
Percent of Area f ji
2.20
3.01
1.43
1.35
1.69
2.40
3.24
1.83
0.42
4.24
3.30
0.68
0.85
0.78
0.26
0.37
0.69
1.88
4.23
1.40
1.90
4.99
0.10
0.76
2.85
1.44
7.19
1.76
8.83
100 ;pj
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 2 of 2
C-14
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MAROS Spatial Moment Analysis Summary
Project: East 67th Street
Location: Odessa
Effective Date
Oth Moment
Estimated
Mass (Kg)
1st Moment (Center of
Xc (ft) Yc (ft)
Mass)
Source
Distance
User Name: MV
State: Texas
2nd Moment (Spread)
Sigma XX Sigma YY (sq
(sqft) ft)
Number of
Wells
cis-l,2-DICHLOROETHYLENE
7/1/2007
7/1/2009
7/1/2010
7/1/2011
7/1/2013
9.9E-01
8.8E-01
1.4E+00
5.2E-02
8.9E-01
1,658,974
1,659,064
1,659,021
1,659,877
1,659,077
10,663,300
10,663,470
10,663,489
10,663,523
10,663,520
522
642
607
1,446
670
101,906
93,157
73,137
23,972
93,449
44,826
65,921
46,296
86,657
58,664
36
31
29
18
35
TETRACHLOROETHYLENE(PCE)
7/1/2007
7/1/2009
7/1/2010
7/1/2011
7/1/2013
TRICHLOROETHYLENE
7/1/2007
7/1/2009
7/1/2010
7/1/2011
7/1/2013
1.6E+00
2.1E+00
2.2E+00
4.6E-01
1.4E+00
(TCE)
2.6E-01
2.9E-01
3.7E-01
5.4E-02
2.6E-01
1,659,099
1,659,160
1,659,154
1,659,476
1,659,152
1,659,165
1,659,203
1,659,167
1,659,876
1,659,252
10,663,270
10,663,418
10,663,439
10,663,570
10,663,461
10,663,273
10,663,418
10,663,458
10,663,531
10,663,461
647
722
720
1,064
723
713
764
737
1,446
821
101,490
79,853
86,295
73,391
107,497
128,376
98,252
102,916
22,143
143,904
64,664
60,912
57,725
52,091
71,264
74,021
77,920
72,140
85,402
83,574
36
33
31
22
39
36
31
29
18
35
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 1 of 2
C-15
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MAROS Spatial Moment Analysis Summary
Project: East 67th Street
Location: Odessa
User Name: MV
State: Texas
Spatial Moment Analysis Summary:
Moment Type
Oth Moment
Oth Moment
Oth Moment
First Moment
First Moment
First Moment
Second Moment X
Second Moment X
Second Moment X
Second Moment Y
Second Moment Y
Second Moment Y
Constituent
cis-l,2-DICHLOROETHYLENE
TETRACHLOROETHYLENE(P
TRICHLOROETHYLENE (TCE)
cis-l,2-DICHLOROETHYLENE
TETRACHLOROETHYLENE(P
TRICHLOROETHYLENE (TCE)
cis-l,2-DICHLOROETHYLENE
TETRACHLOROETHYLENE(P
TRICHLOROETHYLENE (TCE)
cis-l,2-DICHLOROETHYLENE
TETRACHLOROETHYLENE(P
TRICHLOROETHYLENE (TCE)
Note: The following assumptions were applied for the
Porosity: 0.25
Saturated Thickness:
Coefficient of
Variation
0.59
0.44
0.48
0.49
0.21
0.35
0.41
0.16
0.47
0.28
0.12
0.07
calculation of the
Uniform: 30 ft
Mann-Kendall S
Statistic
-2
-2
-2
6
6
6
-4
0
0
4
-2
4
Zeroth Moment:
Confidence
in Trend
59.2%
59.2%
59.2%
88.3%
88.3%
88.3%
75.8%
40.8%
40.8%
75.8%
59.2%
75.8%
Moment
Trend
S
S
S
NT
NT
NT
S
S
S
NT
S
NT
Mann-Kendall Trend test performed on all sample events for each constituent. Increasing (1); Probably Increasing (PI); Stable
(S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable (N/A)-Due to insufficient Data (< 4 sampling
events); (ND) Non Detect.
Note: The Sigma XX and Sigma YY components are estimated using the given field coordinate system and then rotated
with the estimated groundwater flow direction. Moments are not calculated for sample events with less than 6 wells.
to align
MAROS Version 3.0
Release 352, September 2012
January 2014
Wednesday, June 19, 2013
Page 2 of 2
C-16
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MAROS Well Network Uncertainty: PCE in LS1 Unit. Uncertainty is evaluated by Slope Factor within Delaunay Triangles. S =
Small uncertainty, M = Medium, L = Large. The monitoring well network recommended for East 67th Street remedy performance
monitoring does not show excess uncertainty.
Triangulation
Defaults
I
Options
Close
J K L M N O Q R
MAROS 3,0 Trianaulation Visualization
TETRACHLOROETHYLENE(PCE)
H < > H MARDS3 Data
'
TI< I
January 2014
C-17
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APPENDIX D
RECOMMENDED GROUNDWATER PERFORMANCE
MONITORING
WELL
NAME
MW-4
MW-9
MW-10
VP-01
VP-02
VP-03
VP-04
VP-05
VP-06
3 New US2
Monitoring
Wells
(NearGW-21,
GW-23, GW-
24)
5 New US2
Injection
Wells
5 New LSI
Monitoring
Wells*
(nearGW-21,
GW-23, GW-
67, GW-24,
GW-19, GW-
27)
MW-11
MW-12
MW-21
MW-22
MW-23
MW-24
MW-27
UNIT
LSI
US2
US2
US2
LSI
LSI
OBJECTIVE
Evaluate effect of
plugging GW-205 and
GW-210 on contaminant
migration from US2 to
LSI
Evaluate US2 source
extent and US2 ISB
performance
Evaluate US2 plume
extent and US2 ISB
performance
Evaluate US2 plume
extent and US2 ISB
performance
Evaluate effect of
plugging GW-205 and
GW-210 on LSI water
quality and evaluate need
for active remediation in
LSI
Evaluate need for active
remediation in LS 1
PARAMETERS AND
FREQUENCY*
VOCs quarterly for 2
years
VOCs, arsenic, iron,
manganese, TOC, and
ORP prior to ISB and
quarterly for 2 years after
injection
VOCs, arsenic, iron,
manganese, TOC, and
ORP prior to ISB and
quarterly for two years
after injection
VOCs, arsenic, iron,
manganese, TOC, and
ORP prior to ISB and
quarterly for 2 years after
injection
VOCs quarterly for 2
years
VOCs quarterly for 2
years after recommended
well plugging and
abandonment has been
conducted
ANALYSES
Trend evaluation,
mass discharge
downgradient
Compare
concentrations to
cleanup goals,
mass removal vs.
cost of remedy
Mass discharge
downgradient,
delineation of
plume in US2,
metals
concentrations
versus standards
Confirm reducing
conditions, monitor
metals mobilization
Trend evaluation,
mass discharge
downgradient
Trend evaluation,
compare
concentrations to
cleanup goals,
delineate plume
footprint
January 2014
D-l
-------
WELL
NAME
GW-01
GW-02
GW-03
GW-04
GW-05
GW-07
GW-27
GW-30
GW-64
GW-66
GW-95
GW-206
GW-207
GW-222
GW-227
GW-301
GW-302
GW-304
GW-307
MW-06
UNIT
LSI
LSI
LSI
OBJECTIVE
Evaluate LS 1 plume
migration, need for active
remediation in LSI, and
need to replace specific
water supply wells to
eliminate exposure
pathways
Evaluate LSI plume
migration, need for active
remediation in LSI, and
need to replace specific
water supply wells to
eliminate exposure
pathways
Background location
PARAMETERS AND
FREQUENCY*
VOCs quarterly for 2
years after recommended
well plugging and
abandonment has been
conducted
VOCs quarterly for 2
years after recommended
well plugging and
abandonment has been
conducted
VOCs, arsenic, iron,
manganese, TOC, and
ORP prior to ISB and
annually
ANALYSES
Compare to MCLs,
delineate plume to
below MCLs
Compare to MCLs,
delineate plume to
below MCLs
Establish
background
concentrations of
metals, confirm
delineation of
plume
* Frequency and parameters to be revisited after specified time frame
** Sample GW-21, GW-22 and GW-24 until new LSI wells are available
The monitoring network can be reduced in both well number and frequency after the 2 year remedy
performance monitoring period. If remedy installation/activation is delayed, annual monitoring is
recommended until active remedies are initiated.
January 2014
D-2
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