A CDlA EPA 542-R-14-009
k ฃ ^^^j^^% Office of Solid Waste and Emergency Response
U nited States Office of Superfund Remediation and
Environmental Protection Technology Innovation
Agency
Optimization Review
Lockwood Operable Unit 1 -
Beall Source Area
Billings, Montana
www.clu-in.org/optimization I www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
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A CDlA EPA 542-R-14-009
k ฃ ^^^j^^% Office of Solid Waste and Emergency Response
U nited States Office of Superfund Remediation and
Environmental Protection Technology Innovation
Agency
OPTIMIZATION REVIEW
LOCKWOOD OPERABLE UNIT 1 - BEALL SOURCE AREA
BILLINGS, MONTANA
Report of the Optimization Review
Site Visit Conducted at Lockwood Solvent Groundwater Plume Site
FINAL REPORT
September 19, 2014
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EXECUTIVE SUMMARY
Optimization Background
The U.S. Environmental Protection Agency (EPA) defines optimization as the following:
"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 other approaches to identify opportunities for greater efficiency
and effectiveness. Contractors, states, tribes, the public, and PRPs [potentially responsible
parties] are also encouraged to put forth opportunities for the Agency to consider. "(1)
An optimization review considers the goals of the remedy, available site data, the 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 State of
Montana, the 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).
1 U.S. Environmental Protection Agency (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.
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Billings, Montana ES-1
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Site-Specific Background
The Lockwood Solvent Groundwater Plume Site (LSGPS) consists of two operable units (OUs) and is
located on the outskirts of Billings, Montana in EPA Region 8. OU1 consists of contaminated soils and a
chlorinated solvent groundwater plume associated with the Beall Source Area (Area B), and OU2 consists
of affected media associated with the Brenntag (Soco; Area A) Source Area. This optimization review
addressed remedial components planned for affected soil and groundwater in OU1. The optimization
review of remedial design (RD) considerations for OU2 is addressed under a separate optimization review
report.
Beall Trailers of Montana, Inc. (Beall) manufactured and reconditioned tank trailers for the petroleum and
asphalt industries from 1978 to 1990. Beall used steam and a solution of dissolved trichloroethene (TCE)
to clean the tank trailers in an industrial steam-cleaning bay, with wastewater subsequently discharged to
a septic system and drain field adjacent to the steam-cleaning bay. Various discharges of TCE-
contaminated water from the steam-cleaning bay have been identified as the source of contamination to
soil and groundwater in OU1.
In 1986, Lockwood Water and Sewer District (LWSD) personnel identified benzene and chlorinated
solvents in Lockwood area water supply wells, leading to a number of investigations by the Montana
Department of Environmental Quality (DEQ). In June 1998, DEQ performed an integrated site
assessment in cooperation with the EPA, which identified Beall as a potential source of TCE and TCE
degradation byproducts in the groundwater. The LSGPS was added to the National Priorities List (NPL)
in 2000 (CERCLIS ID# MT0007623052).
In 2002, the DEQ conducted a Remedial Investigation (RI) that included surface and subsurface soil
sampling, monitoring well construction and groundwater sampling, aquifer testing, surface water
sampling, sediment sampling and indoor air sampling. Based on the RI results, the EPA and DEQ
evaluated remedial alternatives as part of a Feasibility Study (FS) completed in July 2004. The LSGPS
Record of Decision (ROD) was issued in 2005. The RD process is underway at OU1 with the goal of
addressing contamination associated with the Beall Source Area.
The LSGPS was nominated for an optimization review by the EPA Office of Superfund Remediation and
Technology Innovation (OSRTI) at the request of the Region 8 Remedial Project Manager (RPM) in
September 2012. The review of design considerations for the selected remedy options for the LSGPS
OU1 is intended to optimize the remedial response to address contamination in soil and groundwater, to
achieve maximum protectiveness while improving remedy cost and energy efficiency and to minimize
time required to attain cleanup levels.
Summary of Conceptual Site Model and Key Findings
Site surface soil and shallow subsurface soils are composed of interbedded sands and gravels, silty sands
and silts in the area of OU1. Site investigation data from the RI indicate that the areas of highest
contamination are in the immediate vicinity of the steam-cleaning bay, facility piping and an oil-water
separator. TCE released from the steam-cleaning bay and associated components migrated under the
influence of gravity through the unsaturated sandy silts to the saturated zone at approximately 42 to 45
feet (ft) below ground surface. It appears that contamination was able to migrate horizontally
approximately 50 to 100 ft in the unsaturated zone. The extent of contamination in the saturated zone is
not fully understood.
Data collected during the RI indicate groundwater contamination at OU1 occurs in two lobes. The
western plume lobe (West Lobe) with high concentrations of dissolved TCE, is most likely the result of
historical groundwater flow to the west caused by the hydraulic influences of a former LWSD water
Lockwood Operable Unit 1 Beall Source Area Optimization Review Report
Billings, Montana ES-2
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supply well (closed in 1986). The north-northwestern plume lobe (North Lobe) is consistent with the
natural, regional groundwater flow direction. TCE is present in concentrations above the Maximum
Contaminant Level (MCL) of 5 micrograms per liter (ug/L) in both plume lobes. TCE is also present in
groundwater at concentrations below the MCL at locations between the two lobes, such as at monitoring
well MW-213. While c/'s-l,2-dichloroethene is detected in the plumes, both the site team and optimization
review team believe attenuation by biological degradation is not a strong process at the site.
Key findings of the optimization review team include:
Site soils are more heterogeneous than indicated in cross-sections from the RI.
The primary sources of uncertainty for the RD include the lack of understanding of the vertical
distribution of contamination, the effect of geologic heterogeneity on selected remedy options,
and the variability in groundwater flow direction.
Increased understanding of source(s), plume morphology and plume behavior may significantly
improve the effectiveness of remedy design and implementation.
The presence of the unsaturated soil contamination in relatively tight silt with a low intrinsic
permeability may create challenges for soil vapor extraction (SVE), one of the selected remedy
options. Excavation or excavation combined with SVE may provide a cost-effective and more
robust means of remediating the unsaturated soil.
Area-wide, the groundwater flow direction appears to be toward the north/northwest with fairly
flat gradients. There appears to be a component of westward groundwater flow maintaining the
West Lobe of the plume. Currently, the plumes appear stable, but additional characterization of
groundwater flow direction and gradients may provide more details on the long-term distribution
of contaminants, particularly in the area between the plume lobes.
Uncertainty about the distribution of contaminant mass in deeper silty or other low-permeability
layers may reduce the efficacy of both the RD and performance monitoring of remedies for the
source area. Matrix- or back-diffusion from silty layers may provide a long-term secondary
source of contamination to groundwater. Continued low-level discharge of mass from
downgradient secondary sources may introduce uncertainty into performance evaluation of the
source remedies.
The vertical distribution of contamination below the water table, which is currently unknown,
will affect the design and performance of the in situ bioremediation (ISB) groundwater remedy,
one of the selected remedy options.
Groundwater flows through the sand and gravel aquifer relatively quickly. The results of effective
source area remediation should become apparent at downgradient groundwater monitoring
locations within a few years of implementation (for example, by decreasing statistical
concentration trends). Depending on the concentration response in the downgradient plume,
effective source remediation may preclude installation of an additional downgradient plume
remedy. Lack of response in the downgradient plumes may indicate that an additional plume
remedy is required.
Summary of Recommendations
The following is a summary of recommendations provided for the site:
Improving effectiveness -
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Recommendations for improving remedy effectiveness include refinement of the CSM through additional
characterization to support improved design and performance monitoring of the remedies. Recommended
characterization activities include vertical characterization of soil and groundwater through deployment of
multiple passive diffusion bags (PDB) in select monitoring wells, potentially supported by in-well
borehole flow monitoring to confirm flow characteristics across the screen lengths; Membrane Interface
Probe (MIP) survey; and deployment of Bio-Trapฎ samplers to assess the microbial community.
Geologic, hydrogeologic and environmental chemistry data collected from characterization activities
should be used to create detailed cross sections and, if possible, to support 3-dimensional visualization
and analysis (3DVA) of the site.
SVE is recommended as a primary remedy option for contaminated soils in the source area (primarily for
cost reasons). However, limited soil excavation of high concentration areas with subsequent SVE may be
considered as a component of the SVE remedy to improve overall effectiveness. Along with limited
excavation, ISB amendments are recommended for application to the base of the excavation to facilitate
contact between the deeper contaminated media and the ISB treatments.
ISB remedy is recommended as a primary remedy option for the saturated source zone. Along with SVE,
and limited excavation, ISB in the source area should reduce mass discharge of contamination
downgradient.
Reducing cost -
The optimization review team compared costs associated with excavation and SVE as soil remedies.
Overall, SVE appears to be a more cost effective approach than extensive excavation and disposal. A
performance monitoring plan was developed by the optimization review team and is presented in this
report for use in evaluating SVE effectiveness to prevent operating the SVE beyond the point where it is
cost effective.
Source area performance monitoring should include groundwater monitoring in the downgradient plume.
Results of plume monitoring will indicate if additional plume remedies are required. Delaying the design
of any downgradient remedy until the effects of the source remedy are known will improve the design and
may limit the scale of the plume remedy, resulting in cost savings.
Technical improvement -
Technical improvements to the remedy include the recommendations for additional site characterization
(summarized above) and recommendations for a combination of SVE, ISB and excavation for the source
area.
Site closure -
The addition of limited soil excavation in the source area should reduce the time to site closure by
addressing soil that could be a continued source of mass to the dissolved plume. Additional site
characterization should improve the efficacy of the remedy by targeting the final remedy design to the
areas of highest contaminant mass, also reducing the time to attainment of cleanup levels.
Green remediation -
No recommendations are provided for green remediation at this time. Green remediation best
management practices and footprint analysis can be revisited after characterization activities have been
completed and the site team is developing a more targeted RD. In general, however, the additional
characterization suggested should help target the remedy to the dimensions of source soils to be
remediated and, therefore, reduce the footprint of the final remedy.
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NOTICE AND DISCLAIMER
Work described herein was performed by Tetra Tech, Inc. (Tetra Tech) for the U.S. Environmental
Protection Agency (EPA). GSI Environmental performed work under a subcontract to Tetra Tech. Work
conducted by Tetra Tech, including preparation of this report, was performed under Work Assignment 2-
58 of EPA contract EP-W-07-078 with Tetra Tech. 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 State of
Montana, EPA Region and other site stakeholders.
While certain recommendations may provide specific details to consider during implementation, these
recommendations 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 (ARARs). Further analysis of recommendations,
including review of EPA policy may be needed prior to implementation.
Lockwood Operable Unit 1 - Beall Source Area Optimization Review Report
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PREFACE
This report was prepared as part of a national strategy to expand Superfund optimization from remedial
investigation to site completion implemented by the United States Environmental Protection Agency
(EPA) Office of Superfund Remediation and Technology Innovation (OSRTI) . The project contacts are
as follows:
Organization
Key Contact
Contact Information
U.S. Environmental Protection
Agency (EPA) Office of
Superfund Remediation and
Technology Innovation
(OSRTI)
Kirby Biggs
EPA OSRTI
Technology Innovation and Field Services
Division
2777 Crystal Drive
Arlington, VA 22202
biggs.kirbv(@,epa.gov
phone: 703-823-3081
Terra Tech
(Contractor to EPA)
Jody Edwards, P.O.
Terra Tech
45610 Woodland Road, Suite 400
Sterling, VA 20166
jodv.edwards(@,tetratechcom
phone: 802-288-9485
Peter Rich, P.E.
Terra Tech
51 Franklin Street
Suite 400
Annapolis, MD 21401
peter.rich(@,tetratech.com
phone: 410 990-4607
GSI Environmental, Inc.
(Subcontractor to Terra Tech)
Mindy Vanderford, PhD.
GSI Environmental, Inc.
2211 Norfolk Street, Suite 1000
Houston, TX 77098
mvanderford(@,gsi-net.com
phone: 713-522-6300x186
2 U.S. Environmental Protection Agency (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.
Lockwood Operable Unit 1 - Beall Source Area
Billings, Montana
Optimization Review Report
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LIST OF ACRONYMS AND ABBREVIATIONS
3DVA 3-Dimensional Visualization and Analysis
(ig/kg Micrograms per Kilogram
(ig/L Micrograms per Liter
ARAR Applicable or Relevant and Appropriate Requirements
Beall Beall Trailers of Montana, Inc.
Bgs Below Ground Surface
cm2 Square Centimeters
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
cis-1,2-DCE Cis-1,2-Dichloroethene
CSM Conceptual Site Model
cVOC Chlorinated Volatile Organic Compound
DEQ Department of Environmental Quality
EPA United States Environmental Protection Agency
FS Feasibility Study
Ft Feet
FYR Five-Year Review
GAC Granular Activated Carbon
GIS Geographic Information Systems
1C Institutional Controls
ISB In Situ Bioremediation
K Hydraulic Conductivity
KR Relative Hydraulic Conductivity
LSGPS Lockwood Solvent Groundwater Plume Site
LTM Long-Term Monitoring
LTRA Long-Term Remedial Action
LWSD Lockwood Waste and Sewer District
MAROS Monitoring and Remediation Optimization System
MCL Maximum Contaminant Level
mg/kg Milligrams per Kilogram
MIP Membrane Interface Probe
MW Monitoring Well
N/A Not Applicable
NI Not Identified
NPL National Priorities List
OSRTI Office of Superfund Remediation and Technology Innovation
OSWER Office of Solid Waste and Emergency Response
OU Operable Unit
PCE Tetrachloroethene
PDB Passive Diffusion Bag
PRP Potentially Responsible Party
PWT Pacific Western Technologies, Ltd.
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QAPP Quality Assurance Project Plan
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
Trans-1,2-DCE Trans- 1,2-Dichloroethene
VI Vapor Intrusion
VOC Volatile Organic Compound
Lockwood Operable Unit 1 - Beall Source Area Optimization Review Report
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TABLE OF CONTENTS
Section Page
EXECUTIVE SUMMARY ES-1
NOTICE AND DISCLAIMER i
PREFACE ii
LIST OF ACRONYMS AND ABBREVIATIONS iii
1.0 OBJECTIVES OF OPTIMIZATION REVIEW 1
1.1 Objectives of the Remedial Design Optimization 1
1.2 Team Composition 2
1.3 Documents and Data Reviewed 3
1.4 Quality Assurance 4
2.0 CONCEPTUAL SITE MODEL 5
2.1 Site Background 5
2.2 Source 5
2.3 Soils and Unsaturated Subsurface 7
2.4 Groundwater 7
3.0 REMEDIAL ACTION OBJECTIVES AND SELECTED REMEDY OPTIONS 11
3.1 Remedial Action Objectives and Affected Media 11
3.2 Selected Remedy Options 12
4.0 FINDINGS 14
4.1 CSM Implications for Remedial Strategy 14
4.2 Data Gaps 14
4.3 Evaluation of Remedial Alternatives and Strategy 16
5.0 RECOMMENDATIONS 18
5.1 Recommendations for Phased Remedial Strategy 18
5.2 Recommendations for Resolving Vertical Extent of Contamination 19
5.3 Recommendations for Soil Remediation 20
5.4 Recommendations for Source Area Groundwater Characterization and Remediation 21
5.5 Recommendations for Remedial Performance Monitoring 22
5.6 Recommendations for Dissolved Downgradient Plume Remediation 23
5.7 Recommendations Related to Green Remediation 24
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LIST OF FIGURES
Figure Page
1 SITE MAP OF LOCKWOOD SOLVENT GROUNDWATER PLUME SITE (EPA 2005) 1
2 OU1 LITHOLOGY. (COLOR CODED DEPTH VS. SOIL TYPE FOR SOIL BORINGS IN
THE OU1 SOURCE AREA. DEPTH IS BETWEEN 0 AND 47 FT BGS.) 6
3 LSGPS OU1 TCE IN GROUNDWATER. (GROUNDWATER WELLS ARE SHOWN
WITH THE SYMBOL SIZE INDICATING THE AVERAGE TCE CONCENTRATION
2003-2012.) 8
4 LSGPS OU1 TCE CONCENTRATION TRENDS 9
LIST OF TABLES
Table Page
1 OPTIMIZATION REVIEW TEAM 2
2 SITE VISIT AND REVIEW PARTICIPANTS 3
3 CONTAMINANTS OF CONCERN AND CLEANUP LEVELS 11
4 AFFECTED OR POTENTIALLY AFFECTED MEDIA ON SITE 12
5 REMEDY OPTIONS SELECTED IN THE ROD 13
6 IDENTIFIED DATA GAPS AND RECOMMENDATIONS 15
7 RECOMMENDATIONS SUMMARY 24
8 RECOMMENDED GROUNDWATER PERFORMANCE MONITORING PROGRAM 26
Attachments
Attachment A: Optimization Review Figures
Attachment B: Supplemental Figures from Remedial Investigation
Attachment C: Monitoring and Remediation Optimization System Analysis Reports
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1.0 OBJECTIVES OF OPTIMIZATION REVIEW
1.1 Objectives of the Remedial Design Optimization
The Lockwood Solvent Groundwater Plume Site (LSGPS) occupies approximately 580 acres located on
the outskirts of Billings, Montana in EPA Region 8. The site is managed as two operable units (OUs).
OU1 consists of contaminated soils and the chlorinated solvent groundwater plume associated with the
Beall Source Area (Area B), and OU2 consists of affected media associated with the Brenntag (Soco;
Area A) Source Area (see Figure 1). Additional land is included in the greater LSGPS (Area C, see Figure
1), but this area contains no known primary sources of contamination and low-to non-detect levels of
contaminants.
Figure 1: Site Map of Lockwood Solvent Groundwater Plume Site (EPA 2005)
This optimization review addressed remedial components planned for affected soil and groundwater in
OU1. Remedial design (RD) for OU2 is addressed under a separate optimization review report.
The LSGPS was nominated for an optimization review by the United States Environmental Protection
Agency (EPA) Office of Superfund Remediation and Technology Innovation (OSRTI) at the request of
the Region 8 Remedial Project Manager (RPM) in September 2012. The review of design considerations
for the selected remedy options for the LSGPS OU1 is intended to optimize the remedial response to
address contamination in soil and groundwater to achieve maximum protectiveness while improving
remedy cost and energy efficiency and minimizing time required to attain cleanup levels.
An optimization review team (described below) was assembled and met with regulatory stakeholders and
consultants in Billings, Montana and at the site in February 2013 to review site data, remedial action
Lockwood Operable Unit 1 - Beall Source Area
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objectives (RAO) and cleanup levels, logistics and time frames to implement the remedy. This report
presents findings, conclusions and recommendations for optimization. Objectives of the RD optimization
review include:
Review of conceptual site model (CSM)
Review of RAOs
Review of selected remedy options and associated remedial components and costs
Evaluation of other potential alternative remedial components
Provision of recommendations for the remedial strategy including:
o Addressing and prioritizing data gaps in the CSM
o Recommending improvements to selected remedy option components
o Recommending consideration of other alternative remedial components
o Prioritizing and sequencing of remedial components
o Identifying decision points for contingent responses
o Performance monitoring for recommended remedies
o Remediation and data collection to support an exit strategy.
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 evaluation 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 State of Montana, the 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 review 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.
1.2 Team Composition
The LSGPS optimization review team consisted of the following individuals:
Table 1: Optimization Review Team
Name
Doug Sutton
Mindy Vanderford
Affiliation
Tetra Tech
GSI Environmental, Inc.
Phone
732-409-0344
713-522-6300
Email
doug. sutton@tetratech.com
mvanderford(ฎgsi-net.com
In addition to the optimization review team, the individuals listed below also attended the site visit or
contributed to the site data review process:
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Table 2: Site Visit and Review Participants
Name
Kirby Biggs
Tillman McAdams
Andrew Schmidt
John Podolinsky
Catherine LeCours
Roger Hoogerheide
Jim Sullivan
Affiliation
EPA OSRTI
EPA Region 8
Hydrogeologist, EPA
Region 8
Montana Department of
Environmental Quality
Pacific Western
Technologies, Ltd.
EPA Region 8
Cardno Advanced
Technologies, Inc.
Role
Optimization
Review Lead
RPMforOUl
Technical Support
State Lead for OU2
RAC Contractor for
OU1
RPM for OU2
PRP Contractor for
OU2
Email Address
biggs.kirby@epamail.epa.gov
mcadams .tillman@epa. gov
Notes: EPA OSRTI = U.S. Environmental Agency Office of Superfund Remediation Technology Innovation; RPM = Remedial
Project Manager; OU = Operable Unit; RAC = Remedial Action Contractor; PRP = potentially responsible party.
Email contact information is provided for the site managers only. Communication with other participants
can be coordinated through the site managers.
The site visit, which included the individuals above, was conducted on February 28, 2013.
1.3 Documents and Data Reviewed
The following documents were reviewed in support of the optimization review.
Final Billings LockwoodPumping Test and Groundwater Monitoring Report (MSE-HKM, Inc. -
November 1998)
Final Report VOC Groundwater Plume Delineation & Potential Source Area Assessment,
Lomond Lane Area (Lockheed Martin - November 1999)
Final Report VOC Groundwater Plume Delineation & Potential Source Area Assessment With
Soil Gas Synopsis (Lockheed Martin - November 1999)
Comprehensive Indoor Air Sampling and Analytical Results Report (Tetra Tech - October 2002)
Final Remedial Investigation Report Addendum 01 (Tetra Tech - December 2003)
Remedial Investigation Report (Tetra Tech - June 2003)
Final Feasibility Study (Tetra Tech - July 2004)
Record of Decision (EPA - August 2005)
Remedial Design Supplementary Sampling Program & Quality Assurance Project Plan, Revision
2 (Pacific Western Technologies, Ltd. (PWT) - March 2012)
PWT Notes and Calculations on Groundwater Plume Dewatering Plan (PWT - June 2012)
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EPA, 2012. Dewatering Monitoring Plan Lockwood Water and Sewer District Sewer Installation.
Helena, MT, Region 8
Remedial Design, Beall Source Area Operable Unit 1, Aquifer Testing Program, Revision 2
(PWT-July2012)
Data Trend Evaluation Technical Memorandum Remedial Design Supplemental Sampling
Program, (PWT - October 23, 2012)
Site soil and groundwater monitoring data, lithologic data and Geographic Information System
(GIS) files were received from the site contractor, PWT, in January 2013.
1.4 Quality Assurance
This optimization review used existing environmental data to interpret the CSM, evaluate potential
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 applicable, the
site QAPP was considered), the consistency of the data with other site data and the use of the data in the
optimization review. Data 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 to
improve data quality.
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2.0 CONCEPTUAL SITE MODEL
2.1 Site Background
Beall Trailers of Montana, Inc. (Beall) manufactured and reconditioned tank trailers for the petroleum and
asphalt industries from 1978 to 1990. Beall used steam and a solution of dissolved trichloroethene (TCE)
to clean the tank trailers in an industrial steam-cleaning bay, with wastewater subsequently discharged to
a septic system and drain field adjacent to the steam-cleaning bay. Beall is no longer the property owner
and the facility is inactive. However, the site is in the process of being reactivated under different
ownership. The new owners have expressed the desire to continue use of the steam-cleaning bay, without
TCE. Site remediation is currently being addressed under the Superfund program as a Fund-lead project.
In 1986, Lockwood Water and Sewer District (LWSD) personnel identified benzene and chlorinated
solvents in Lockwood area water supply wells, leading to a number of investigations by the Montana
Department of Environmental Quality (DEQ). In June 1998, DEQ performed an integrated site
assessment in cooperation with the EPA. The assessment identified Beall as a potential source of TCE
and TCE degradation byproducts in the groundwater. The investigation also identified the Brenntag West
property (formerly the Dyce Chemical property and now the Soco West property, OU2) as a potential
source of tetrachloroethene (PCE), TCE, cis-l,2-dichloroethene (cis-l,2-DCE) and vinyl chloride. In
December 2000, the EPA placed LSGPS on the National Priorities List (NPL).
Land use within and around the LSGPS is categorized as light industrial, commercial and residential. The
commercial and light industrial facilities include trucking, vehicle repair, truck tank manufacturing,
chemical repackaging, petroleum pipelines, machine shops and auto salvage. The former Comet Oil Site,
proposed for the NPL in 1988, is located on the east/northeast border of the LSGPS. The greater LSGPS
area includes the OU1 and OU2 plume areas as well as 81 commercial and light industrial businesses, an
estimated 75 residential single-family residences, two trailer parks and one apartment complex. LSGPS is
bordered by the Yellowstone River on the west and northwest; thus some wetlands and ponds are also
included in the greater LSGPS area.
In 2002, the DEQ conducted a Remedial Investigation (RI) that included surface and subsurface soil
sampling, monitoring well construction and groundwater sampling, aquifer testing, surface water
sampling, sediment sampling and indoor air sampling. Based on the RI results, the EPA and DEQ
evaluated remedial alternatives as part of a Feasibility Study (FS) completed in July 2004. The November
2004 Proposed Plan detailed the human health risks, past activities and the preferred remedial alternative
for the LSGPS. Public meetings were held and a comment period was provided for the Proposed Plan.
EPA and DEQ selected a final remedy in the 2005 LSGPS Record of Decision (ROD). The RD process is
underway at OU1 with the goal of addressing contamination associated with the Beall Source Area. In the
time period between publication of the ROD and the present, site characterization activities have
continued. Elements of the CSM presented in Section 2 are taken from the site decision documents (RI
and ROD reports) and from discussions with the site team (RPMs and contractors). The optimization
review team considered historic and more recent data, as well as site stakeholder input, to develop the
recommendations for optimizing the RD included in Section 5.
2.2 Source
Between 1978 and 1990, TCE was used as part of the steam-cleaning process for truck trailers at the Beall
facility. Based on the distribution of TCE in the subsurface, it appears that the majority of TCE was
released from the steam-cleaning bay drain and the piping to an oil-water separator. Monitoring wells
MW-200 and MW-201 are located closest to the release area. In 2002, maximum concentrations of TCE
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in groundwater at these wells were 1,867 and 1,850 micrograms per liter (|ig/L), respectively. Soil
samples collected in the unsaturated zone around the drain at the center of the steam-cleaning bay have
had detections of concentrations up to 120 milligrams per kilogram (mg/kg) in the interval from 5 to 12.2
feet (ft) below ground surface (bgs) and up to 11 mg/kg in the interval from 33.0to41.5ft bgs.
The hydrostratigraphy of the Beall Source Area consists of the following:
approximately 40 ft of silt with interbedded sand lenses
approximately 5 ft of fine sand (partially saturated)
approximately 27 ft of sand and gravel (saturated)
underlying sandstone and shale bedrock.
The water table is at approximately 42 ft bgs, with saturation at the bottom of the silt and sand unit and in
the sand and gravel unit. The soil boring logs for MW-200 and MW-201 illustrate source area
hydrostratigraphy (Attachment A). Table 4 lists the location, name and description of the affected media
on site.
There is a significant lowering of topographic relief to the north and west of the former Beall property
where the silt and sand overburden thickness decreases to approximately 20 ft. Generalized cross-sections
that illustrate the regional hydrostratigraphy are provided in Figures 3-2 through 3-5 of the RI
(Attachment A). Based on soil boring data from PWT, the formations are significantly more
heterogeneous than depicted on these figures. Figure 2 (see Attachment C for larger version) illustrates
the diversity of soil classification from bore holes in the source area (PWT, 2013) with the primary source
area to the right of the figure (SB 537 is located near MW-200). The RI states that the alluvial aquifer
pinches out to the south (upgradient) in the general area of the Lower Lockwood Irrigation Ditch as
shown on Figure 3-1 of the RI (Attachment A).
Figure 2: OU1 Lithology. (Color coded depth vs. soil type for soil borings in the OU1 source area.
Depth is between 0 and 47 ft bgs.)
Note: a larger version of this diagram is provided in Attachment A.
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2.3 Soils and Unsaturated Subsurface
Site surface soil and shallow subsurface soils are composed of interbedded sands and gravels, silty sands
and silts. TCE released from the primary source migrated under the influence of gravity through the
unsaturated sandy silts to the saturated zone at approximately 42 to 45 ft bgs. It appears that
contamination was able to spread horizontally approximately 50 to 100 ft in the unsaturated zone. Due to
soil heterogeneity, the majority of the contamination that remains appears to be in the relatively less
permeable silt layers, possibly resulting in a long-term secondary source of contamination.
Soil contamination has been evaluated by discrete soil samples collected from multiple depth intervals at
over 60 locations on the former Beall property during the 2002 RI and a 2012 design-stage investigation.
Soil contamination in the source area is generally confined to a 10,000 square ft area in the vicinity of the
steam-cleaning bay. Soil contamination appears to extend primarily to the west, north and south of the
steam-cleaning bay. Contamination does not appear to extend beyond the eastern property boundary of
the facility. Horizontally, the highest concentrations in soil have been detected under the floor of the
steam-cleaning bay. Vertically, based on the site data, soil contamination likely corresponds to the
heterogeneity of soil types, with higher concentrations located in silts rather than in higher permeable
sands.
2.4 Groundwater
Data collected during the RI indicate groundwater contamination at OU1 occurs in two lobes as shown in
Figure 3 (see Attachment C for larger version):
A western lobe (West Lobe) with high concentrations that is most likely the result of historical
groundwater flow to the west caused by the hydraulic influences of a former LWSD water supply
well (closed in 1986);
A north-northwestern lobe (North Lobe) that is consistent with the natural groundwater flow
directions illustrated in Figures 3-7 and 3-8 of the RI (Attachment A).
Figures 3-7 and 3-8 of the RI (Attachment A) depict regional groundwater flow in the Lockwood area.
Groundwater flow through much of the LSGPS is generally to the north-northwest, but has localized
westward components. Groundwater flow along the southern boundary of the alluvial aquifer, in
particular the area between monitoring wells MW-212 and MW-300, is more to the west. The site team
believes that historical pumping at a municipal water supply well located along the rail line due west and
slightly south of the OU1 source area has influenced significant contamination migration down the West
Lobe of the plume (toward MW-203 and MW-210). Pumping at the municipal well ended in 1986,
whereupon the groundwater flow appears to have returned to the natural gradient with a more north-
northwest component generating the North Lobe of the OU1 plume. Examination by the optimization
review team of the water levels on the former Beall property suggests current flow components to both
the west and north-northwest. The leading edge of the North Lobe of the plume is near the OU2 source
area, but recent data suggest the OU1 and OU2 plumes are not comingled at this time (EPA, 2012).
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Figure 3: LSGPS OU1 TCE in Groundwater. (Groundwater wells are shown with the symbol size
indicating the average TCE concentration 2003 - 2012.)
Former Steam Bay
and Drain Field
Legend
Average TCE Concentration [mg/L]
ND - 0.001
0-001 - 0.005
0 005 - 0 009
O 0009-0.100
0100-0341
LSGPS Area
OU1 Groundwater Plume:
LSGPS OU1
Figure 3 TCE in Groundwater
Billings, Montana
Groundwater monitoring has been conducted on an annual or semi-annual basis over the past 10 years,
using approximately 28 monitoring wells in the immediate area of OU1, originally installed for site
investigation and characterization. To date, wells have been sampled for characterization, delineation and
short-term monitoring to track plume behavior and evaluate risk over time in support of the ROD and RD.
The majority of the monitoring wells have long screen intervals (for example, 20 ft or greater) that extend
throughout the alluvial aquifer. According to the site team, samples are collected using a low-flow
sampling method from the center of the well screens.
Estimates of the hydraulic conductivity (K) reported from aquifer tests in the RI ranged from 10 ft per day
to over 600 ft per day. Members of the site team (PWT) conducted an aquifer test in the Beall Source
Area in 2013. Due to well construction issues, the extraction well yielded approximately 3 gallons per
minute. After three days of pumping, a change in water level of approximately 0.1 ft was noted at an
observation well approximately 15 ft from the test well. Based on these findings, the K is likely over 100
ft per day, but the data are insufficient to provide a more refined estimate. Furthermore, aquifer tests
cannot account for the short-scale differences in K that could affect contaminant fate and transport. Based
on the observed hydraulic head gradient of approximately 0.0015 ft per ft, a K of at least 100 ft per day
and an assumed effective porosity of 0.2, the transport velocity is likely over 300 ft per year (Tetra Tech
June 2003).
TCE is present in concentrations above the Maximum Contaminant Level (MCL) of 5 ng/L in both plume
lobes. TCE is also present in concentrations below the MCL at locations between the two lobes, such as at
monitoring well MW-213. At present, detected TCE concentrations remain highest in the source area
(MW-200, MW-201 and MW-203). Concentrations along the West Lobe (MW-210 and MW-212),
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remain fairly elevated 30 years after termination of pumping at the LWSD water supply wells; this
indicates to the site optimization review team that there may still be a westward flow component
influencing the plume.
Based on non-parametric Mann-Kendall Trends for TCE (2003 - 2012) illustrated for individual well
locations, TCE concentrations in the West Lobe, near the source, are still fairly elevated with stable
concentration trends (See Figure 4). Concentration stability indicates that there may be a balance between
releases from secondary sources via matrix- or back-diffusion and attenuation mechanisms such as
dilution and degradation. Individual well concentration trends in the West Lobe are stable to decreasing
(Mann-Kendall trend analysis 2003 - 2012, see Monitoring and Remediation Optimization System
(MAROS) Reports in Attachment B and Figure 4) and estimates of total dissolved mass and center of
mass are also stable (Attachment B), indicating the West Lobe plume is neither expanding nor shrinking
under current conditions.
Figure 4: LSGPS OU1 TCE Concentration Trends
Legend
Soil Boring Lgcations
Mann Kendafl Trend (TCE in Groundwater)
0 Decreasing e Non-Detect
Probably
increasing
O Stable
sing
No Trend
Insufficient Data
OU1 Groundwater
Notes:
1. Mann-Kendall trends for TCE in gn
for data collected 2003 - 2012
2. Soil boring location lithology data
jndwater shown
re illustrated on Figure 2.
MW012 Former Steam Bay
and Drain Field
LSGPS OU1
Figure 4 TCE Trends and
Soil Boring Locations
Billings, Montana
Notes: Mann-Kendall Trends: Green = Decreasing; Light Green = Probably Decreasing; Yellow = Stable; Blue = Non-detect;
Purple = No Trend
Statistical concentration trends in the North Lobe are largely stable to decreasing, as are estimates of the
total dissolved mass and center of mass for the plume (see MAROS reports Attachment B).
While cis-l,2-DCE is detected in the plumes, both the site team and optimization review team believe
attenuation by biological degradation is not a strong process at the site. Based on a likely transport
velocity of over 300 ft per year, the TCE detected in DP503, located west of the site near the on/off ramp
of Interstate 90 (1000 - 1200 ft downgradient), represents approximately four years of groundwater
contaminant flow downgradient from the Beall Source Area.
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The vertical distribution of contaminant mass below the water table is not well understood. Based on
analytical results from direct-push technology groundwater sampling, groundwater contamination
concentrations appear to be higher in the upper alluvial groundwater than in deeper groundwater in the
immediate source area. However, approximately 1,200 ft downgradient to the west, TCE concentrations
at the water table (upper alluvial groundwater) appear to be similar to TCE concentrations at the bedrock
surface (deeper groundwater). These results suggest that the primary source to groundwater
contamination is from overlying unsaturated soils and that deeper contamination is the result of vertical
migration of dissolved contamination to the saturated zone, followed by horizontal transfer with
groundwater flow. However, additional data are needed to determine the presence or absence of
secondary source material below the water table.
Plumes associated with OU1 do not discharge to surface water or sediments, and do not pose a significant
ecological risk. No significant buildings are above the source soils or high contaminant concentration
areas of the groundwater plume, so vapor intrusion (VI) is presumed not likely to be a complete exposure
pathway. There are no current water supply wells remaining in the vicinity of contamination from OU1,
therefore, there are no currently complete ingestion exposure pathways for groundwater.
The primary potentially complete exposure pathway is that of direct contact with affected soils, however,
affected soil is fenced off and institutional controls (1C) were pending at the time of the review.
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3.0 REMEDIAL ACTION OBJECTIVES
AND SELECTED REMEDY OPTIONS
3.1 Remedial Action Objectives and Affected Media
RAOs for the Site were outlined in the 2005 ROD. The following RAOs are defined for groundwater,
surface water and soil at the LSGPS:
Prevent exposure of humans to groundwater and surface water contaminants in concentrations
above regulatory standards.
Reduce contaminant concentrations in the alluvial aquifer and surface water to below regulatory
standards.
Prevent or minimize further migration of the contaminant plume.
Prevent or minimize further migration of contaminants from source materials (soil) to
groundwater.
The ROD for OU1 identifies the principal threat waste as chlorinated solvent contamination found in the
vadose zone soil and saturated soils at the former Beall property.
Table 3 outlines the groundwater cleanup standards for the site and the soil cleanup levels for the Beall
source area. The soil cleanup levels were determined from recharge and leaching modeling conducted by
the site team during the FS (Final Feasibility Study (Tetra Tech EMI - July 2004, Appendix D) to protect
groundwater from contamination leaching from soil. Table 4 summarizes the affected or potentially
affected media at the site.
Table 3: Contaminants of Concern and Cleanup Levels
Contaminant of Concern
Trichloroethene (TCE)
Tetrachloroethene (PCE)
Cis-l,2,-dichloroethene(cis-l,2-DCE)
Trans-l,2-Dichloroethene(Trans-l,2-DCE)
Vinyl chloride
Groundwater Cleanup
Standard
(ug/L)
5
5
70
100
2
Soil Cleanup Level
(^g/kg)
219
241
1,636
NI
53
Notes: ng/kg = micrograms per kilogram; \igfL = micrograms per liter; NI= Not identified.
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Table 4: Affected or Potentially Affected Media on Site
Media
Surface Soil (vadose
and saturated at depth)
Sand
Alluvial aquifer
Siltstone/sandstone
bedrock
Location
Ground surface to
35to40ftbgs
40to45ftbgs
45to70ftbgs
Below 70 ft bgs
Composition
Silt with sand lenses, highly
heterogeneous; can be
saturated below 30 ft bgs
Saturated fine to silty sand
Alluvial sand and gravel
aquifer; some cobbles
Eagle Sandstone with some
shale; groundwater in
interconnected fractures
Potential
Exposure/Migration
Pathways
Discharge to alluvial
groundwater
Direct exposure by
excavation
Discharge to alluvial
groundwater
Drinking water wells
historically located in this
unit
Transport downgradient
Not currently affected
Potential for transport and
discharge to deeper
groundwater
Notes: ft bgs = feet below ground surface.
3.2 Selected Remedy Options
The remedy options selected for OU1 are described in the 2005 ROD and summarized in Table 5. For the
Beall Source Area, the ROD specifies soil vapor extraction (SVE) as the remedy for unsaturated soils and
an enhanced in situ bioremediation (ISB) system to treat the contaminated groundwater upgradient of US
Highway 87 East (of Interstate 90) and for the leading edge of the plume. The enhanced ISB is anticipated
to include injection of a chemical reductantto stimulate anaerobic biodegradation of chlorinated volatile
organic compounds (cVOC).
The ROD recommends more detailed design studies for both the SVE and ISB components prior to
implementation. To date, no remedies have been installed, but the primary source of TCE releases, the
above-ground TCE tank in the steam-cleaning bay, has been removed and is no longer in use. A pilot test
for SVE is in the design phase.
Based on additional investigation performed during the early design stage (PWT, 2012), the site team
identified soils with an intrinsic permeability below 1* 10"10 square centimeters (cm2). As a result, the site
team has been considering excavation of contaminated soils with on-site SVE treatment or off-site
disposal as a potential alternative remedy. The feasibility of excavation may be contingent upon the
potential re-use of the steam-cleaning bay by the new property owner.
Site-wide elements of the remedy include long-term groundwater monitoring, five-year reviews (FYR)
and ICs, including restrictions on groundwater use.
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Table 5: Remedy Options Selected in the ROD
Remedy
Soil Vapor Extraction
(SVE)
In Situ Bioremediation
(ISB) Treatment
Plugging private water
supply wells and provide
alternate supply
Institutional Controls
(ICs)
Groundwater monitoring
Five-Year Reviews
Target Medium
Unsaturated
vadose zone in
source area
Groundwater
source and tail
Alluvial aquifer
Commercial
property,
affected
groundwater
Alluvial aquifer
All site media
Description/Status
Collect and treat volatile contaminants in the
vadose zone; design in progress, pilot test in design
phase
Treat soil and groundwater with amendments that
manipulate oxidation/reduction environment in
situ; amendments to be chosen based on treatability
studies, design in progress
Plug municipal and private water wells in the
LSGPS area-wide; supply of municipal water and
sewer to residences is largely complete
Implement ICs that prevent exposure to impacted
areas, restrict excavation or drilling into affected
subsurface areas and groundwater use; status
ongoing
Collection of contaminant concentration data to
assess remedy performance and progress toward
remedial goals and protectiveness; ongoing
Reports to document remedy performance and
protectiveness will be prepared in future
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4.0 FINDINGS
This section outlines the major findings of the optimization review team.
4.1 CSM Implications for Remedial Strategy
The CSM described in Section 2 has the following potential implications for a remedial strategy:
The presence of the unsaturated soil contamination in relatively tight silt with a low intrinsic
permeability may create challenges for SVE. Excavation may provide a cost-effective and more
robust means of remediating the unsaturated soil if SVE pilot testing indicates that it cannot cost-
effectively remove contaminant mass.
There is a component of westward groundwater flow maintaining the West Lobe of the plume.
Uncertainty about the distribution of contaminant mass in deeper silty or low-permeability layers
may reduce remedial efficacy. Matrix- or back-diffusion from silty layers may provide a long-
term secondary source of contamination to groundwater.
The vertical distribution of contamination below the water table, which is currently unknown,
will affect the design and performance of the ISB groundwater remedy.
Based on historical groundwater monitoring data and trend analysis, the plumes emanating from
the source appear to have stabilized and do not appear to be migrating significantly beyond the
current plume footprint.
Groundwater flows through the site relatively quickly. The results of effective source area
remediation, particularly of secondary sources, will likely become apparent at downgradient
groundwater monitoring locations within a few years of implementation.
Increased understanding of source(s), plume morphology and plume behavior may significantly
improve the effectiveness of remedy design and implementation.
4.2 Data Gaps
During the site meeting and document review several key data gaps and uncertainties in the LSGPS OU1
CSM were identified.
The primary sources of uncertainty for the RD include the lack of understanding of the vertical
distribution of contamination, the effect of geologic heterogeneity on the selected remedy options, and the
variability in groundwater flow direction. Each of these issues can be addressed through more detailed
characterization of site geology and hydrogeology, particularly as related to vertical heterogeneity.
The lack of detailed information on the vertical extent and, to a lesser degree, the horizontal extent of soil
contamination has several consequences for short- and long-term remedy design and performance
monitoring. Understanding of the vertical distribution of contamination in unsaturated zone soils would
provide an initial estimate of the total mass of contamination to be removed and would improve
placement of remedial components in areas of maximum concentration. Accurate estimation of initial
contaminant mass in soils would support remedy performance metrics assessing the extent of mass
removal.
Contaminants trapped in low permeability unconsolidated deposits are difficult to remediate, and can act
as long-term secondary sources of contamination to soil and groundwater. Remedies such as ISB and
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SVE are most effective at removing contamination from higher permeability unconsolidated deposits.
Residual pockets of high concentration contamination in low-permeability zones (such as the silts),
particularly below the water table, can act as an ongoing source of dissolved groundwater contamination
above cleanup levels. Determining the distribution of contamination in low versus high permeability
deposits, in both unsaturated and saturated zones, is critical to establishing expectations for the long-term
efficacy of the selected remedy options.
For dissolved phase contamination in groundwater, there is a general lack of understanding of the vertical
distribution of contamination within the saturated thickness at downgradient locations. The 20 ft screen
lengths introduce uncertainty into the assessment of vertical heterogeneity and the related distribution of
mass. Locating high concentration areas within the saturated zone (for example, near the top or bottom of
the aquifer) will help position remedial components for optimal efficacy.
Another source of uncertainty is the effect of variability in groundwater flow direction on the shape of the
plumes. A westerly component of groundwater flow appears to remain even after termination of pumping
at the municipal supply well to the west of the Beall Source Area. The groundwater gradient at the time of
review appeared to have a stronger northerly component, but was fairly flat, so small differences in local
gradient may impact the geometry of the plume. The long-term presence of a northward flow component
of the West Lobe could cause residual contamination to migrate north (for example, from MW212 to
MW213) into the area between the West and North Lobes increasing the contamination in that area.
Detailed information supporting predictions about the flow direction may be obtained during
characterization of vertical distribution of contamination and the distribution of lower vs. higher
permeability unconsolidated deposits.
Table 6 summarizes data gaps identified by the optimization review team and associated
recommendations to address these gaps.
Table 6: Identified Data Gaps and Recommendations
Medium
Unsaturated Soil
(Vadose)
Alluvial aquifer
Siltstone/sandstone
bedrock
Data Gap(s)
Vertical and horizontal extent of
highest contamination
Effect of heterogeneity in soil on
SVE and ISB remedies
Vertical characterization of high
mass zones
Possible presence of secondary
sources below water table
Variable groundwater flow
direction
Composition of microbial
community (to optimize ISB
remedy)
Extent of contamination
Recommendation(s)
Prepare detailed delineation of down- and cross-
gradient extent of contamination - (proposed
sampling locations are detailed in Section 5.2)
Conduct pilot testing for SVE and BioTrapsฎ
sampling for ISB (see sections 43 51 53 and 541)
Implement:
Depth discreet groundwater sampling in
existing monitoring wells with passive
diffusion bag (PDB) technology (Section
5.2.1)
Vertical profiling of soil, including relative
hydraulic conductivity (KR) and groundwater
contamination using Membrane Interface
Probe (MIP) (Section 5.2.2)
Continued area-wide synoptic groundwater
level monitoring at least annually
Sampling using Bio-Trapsฎ or similar
sampling approach for ISB (See Sections 5.2.,
5.2, 5.3 and 5.4.1)
Currently appears unaffected; continue sampling from
bedrock intervals at existing well (MW-219).
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4.3 Evaluation of Remedial Alternatives and Strategy
The optimization review team understands SVE is the primary remedial component selected for affected
soils. The optimization review team believes it is beneficial to examine other remedial components to
identify potential technical improvements or cost savings. The optimization review team identified
excavation of contaminated soil as a potential remedial component that should be considered.
Additionally, a comparison of remedial approaches may provide support for identifying contingent
alternative remedies in case the selected remedy does not perform as expected. To this end, SVE (in situ
and ex situ methods) and excavation are compared below on the basis of relative advantages and
disadvantages for addressing site contamination.
Excavation
The primary technical and logistical advantages of excavation are 1) the certainty that targeted soil will be
remediated, 2) the ability to effectively remediate contamination in low-permeability soils, and 3) the
ability to complete remediation in a timely fashion once initiated. The technical and logistical
disadvantages of this approach are 1) excavation to 40 ft bgs poses engineering challenges and requires
extensive space on site and 2) the existing steam-cleaning bay would need to be dismantled and,
potentially, reconstructed. In addition, development of a ROD amendment or other decision documents
modifying the approach outlined in the ROD will be necessary to implement excavation.
The target area for excavation should be we 11-characterized to 40 ft bgs to define all of the unsaturated
zone contamination that needs to be removed in order to avoid excavation of clean soil. The site team
may want to add some soil samples at the 40 ft bgs interval to the investigation work described in Section
5.2. For this report, the optimization review team assumes that an area of 100 ft by 100 ft centered at the
steam-cleaning bay would be excavated to a depth of 40 feet. Given the depth of the excavation, the work
will need to be designed by a professional engineer. Shoring will likely be needed to the north due to the
main building and to the south due to the road. An average slope of 1.5 to 1 (horizontal to vertical) or
more would likely be needed to the east and west for safety and to allow access of equipment. In sum,
there might be 8,000 square ft of shoring (two walls 100 ft wide and 40 ft deep) and 640,000 cubic ft of
earth moved. In this scenario, the optimization review team assumes that up to 40,000 cubic ft (10% of
the target volume) of soil might need to be disposed of at a local landfill. Based on these assumptions, the
optimization review team estimates that the cost for an excavation remedy, including planning, design,
field oversight and reporting might cost in the range of $1 million.
Once the SVE pilot test and high-density soil characterization are completed, a smaller, shallower area
may be identified to optimize the excavation area. Excavation may be combined with another remedial
approach such as ex situ SVE to further optimize the source remedy approach. A smaller and shallower
excavation will provide cost savings due to reductions in shoring requirements and overall design and
implementation efforts.
Reconstruction of the steam-cleaning bay (based on estimates for an 800 square ft car wash, Reed
Construction Data, 2013) may require an additional $300,000, bringing total costs for extensive
excavation to approximately $1.5M, 30% of which are associated with shoring. This approach includes
the risk that costs would be significantly higher if more soil requires disposal or if affected soil must be
disposed of at a hazardous waste landfill. This risk could not be mitigated once the excavation is begun.
The estimated cost does not include a ROD modification or other decision documents that must be
developed to support the change in remedial strategy.
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SVE
The primary technical and logistical advantages of SVE are 1) the steam-cleaning bay does not need to be
moved or demolished, and 2) the target treatment volume does not need to be as precisely defined. In
addition, decision documents do not need to be modified. The technical and logistical disadvantages of
this approach are that 1) there is less certainty with SVE than with excavation that soil cleanup levels will
be achieved, 2) SVE will likely need to continue for two or more years, and 3) there are challenges in
removing contaminant mass from low porosity materials.
The optimization review team assumes that soil vapors will primarily transport through poorly sorted
sand lenses and layers within the more prevalent silt (silty gravel [GM], poorly graded gravel [GP], well-
graded gravel, fine to coarse gravel [GW] and well-graded sand, fine to coarse sand [SW] lithology
shown in Figure 2). Absent additional information from an SVE pilot test, the optimization review team
assumes vapor extraction would occur from three separate depth intervals from wells with an approximate
10 ft radius of influence. Based on these assumptions, and on current site understanding, approximately
30 extraction locations would be used with extraction occurring from separate extraction wells at the
following depth intervals: 0 to 15 ft bgs, 15 to 30 ft bgs, and 30 ft bgs to the water table.
Vapor extraction is expected to occur for up to two years with off-gas treatment using vapor phase
granular activated carbon (GAC). Based on these assumptions and on current site understanding, the
optimization review team estimates that the cost for design and construction would be approximately
$600,000 and the cost for two years of operation and maintenance would be approximately $200,000 for a
total estimated cost of remedy of approximately $800,000. Prior to implementation, an SVE pilot test at
the three intervals noted above would need to be conducted to provide more information regarding flow
rates and approximate radius of influence at each interval. The pilot test might cost an additional $30,000,
assuming the wells installed for the test would be also used in the final remedy. Depending on
performance of the SVE, additional years of operation may be necessary. The primary remedial risk is
that contamination will remain in low-porosity strata.
The costs for excavation are somewhat higher; however, the uncertainty in the performance and duration
of the SVE system is much greater. Construction time frames for both remedial approaches are similar;
however, SVE operations will continue beyond the time required for excavation. Between the two
primary options under consideration, the optimization review team favors the SVE approach, or a
combination of SVE and targeted excavation, assuming the SVE pilot testing is successful. SVE is a
lower cost option, and is more compatible with property redevelopment. More detailed recommendations
for the remedy components are presented in Section 5.3 through 5.6.
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5.0 RECOMMENDATIONS
Several recommendations are provided in this section related to remedy effectiveness, cost control,
technical improvement and site closure strategy. Note that while the recommendations 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 QAPPs.
Recommendations provided below are focused on resolving uncertainty with regard to the CSM. General
recommendations on remedial strategy and decision points have been developed based on data collected
to date. However, specific recommendations for RD must be made after data gaps in the extent and
magnitude of contamination have been addressed.
Cost estimates provided herein have levels of certainty comparable to those typically prepared for
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) FS reports (-30%
/ +50%), and these cost estimates have been prepared in a manner generally consistent with EPA 540-R-
00-002, A Guide to Developing and Documenting Cost Estimates During the Feasibility Study, July,
2000. The costs presented do not include potential costs associated with community involvement
activities that may be conducted prior to field activities or modification of decision documents. The
estimated costs of these recommendations are summarized in Table 7.
5.1 Recommendations for Phased Remedial Strategy
A phased remedial approach is recommended for OU1. Optimization review team recommendations for
the Site RD include source treatment by SVE, with possible excavation in high concentration areas where
lithology limits the efficacy of SVE. Source treatment is anticipated to reduce volatile organic compound
(VOC) discharge to the West and North Lobes, resulting in decreasing concentration trends and plume
footprints.
The following is the recommended sequence for implementing the recommendations summarized in
Table 6, and explained in detail in Sections 5.2 through 5.5:
Address data gaps identified in Section 4.2 and Table 6 and discussed in Section 5.2 below.
Re-evaluate remedial strategy and technology options, as needed, based on increased site
understanding.
Modify the relevant decision documents as necessary to accommodate recommended changes in
remedial strategy.
Design and implement the remedy to address areas of highest contaminant mass. Future remedy
performance may be assessed by comparing the mass of contamination removed over time to
initial estimates of total contaminant mass.
Consider including soil excavation, if SVE pilot testing indicates that mass will not be removed
from less permeable soils or if SVE does not meet cost or schedule goals. The time and efficacy
benefits (complete source removal and easier ISB amendment injection) of excavation may
outweigh the added cost of demolishing and rebuilding the steam-cleaning bay. The benefits of
excavation could exceed the long-term downside of a slower or less effective SVE remedy,
especially if excavation could reduce the scale of any downgradient plume remedy. Excavation
could be used in combination with SVE to target shallower contamination from tighter formations
once high density site characterization has been performed. A deep excavation project requires
Lockwood Operable Unit 1 - Beall Source Area Optimization Review Report
Billings, Montana 18
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more management, health & safety and community involvement efforts and presents greater
short-term risks.
Consider adding ISB amendment using injection wells at the northern and western property
boundaries (this could be augmented or replaced with ISB amendment at the base of the
excavation if excavation is implemented).
Conduct performance monitoring for the source remedy for three to five years after
implementation.
Delay implementation of any remedy at the leading edge of the groundwater plumes until three to
five years of source area remedy performance data have been collected and analyzed. Given the
high rate of groundwater flow, the success of the source remedy should be apparent in
downgradient wells relatively rapidly. Decreasing concentration trends and reduced plume
footprints may indicate that a downgradient remedy is not required.
5.2 Recommendations for Resolving Vertical Extent of Contamination
Uncertainty regarding the vertical extent of contamination
and heterogeneity within the source area, and the West
and North Lobes of the plume is the primary data gap
limiting design of an optimized remedy for OU1.
OU1 monitoring wells have long screened intervals (20
ft). The relatively high concentrations in two source area
monitoring wells (MW-200 and MW-201) suggest that
the other wells may display vertical heterogeneity in
concentrations and may not be sampled from the correct
interval to accurately characterize maximum contaminant
concentrations and to delineate the plume. The
optimization review team recommends reviewing well
sampling techniques and optimizing sample collection to
accurately characterize the saturated intervals with
highest concentration.
Benefits of Implementing Section 5.2
Recommendations
Accurately identify saturated intervals
with the highest contaminant mass.
Provide a better estimate of total
dissolved mass to be treated.
Optimize groundwater monitoring to
track changes in the plume and
remedy performance.
Reduce uncertainty about location
and extent of contaminant mass.
Accurate assessment of the location and magnitude of
contaminant mass in the dissolved phase will guide development and implementation of the selected
groundwater remedy option as well as assessment of the remedy's efficacy. The goal of the
recommendations below is to outline the general saturated target treatment zones.
Recommendation 5.2.1: The optimization review team suggests sampling with multiple passive diffusion
bags (PDBs) in existing long-screen-interval wells to provide greater vertical characterization at multiple
intervals at key wells such as MW-200, MW-201, MW-203 to MW-207 and MW-210 to MW-214. PDBs
may be deployed in wells used to define the plume such as MW-213. PDBs are often deployed in 2 ft
intervals within each well. Selection of final low-flow sampling locations may be aided by in-well
borehole flow monitoring to confirm flow characteristics across the screen lengths.
Sampling results will help better characterize the water quality within the West and North Lobe plumes.
The sampling intervals for the long-term monitoring (LTM) program should be modified accordingly,
based on the results. Monitoring intervals of high contaminant mass will provide more accurate
assessment of source remedy performance and total mass destruction and recovery. The optimization
review team recommends using existing and new data to prepare highly detailed cross-sections and maps
Lockwood Operable Unit 1 - Beall Source Area
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19
Optimization Review Report
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of high concentration areas and heterogeneity within saturated units to target remediation in areas of
highest contaminant mass.
The optimization review team estimates that the cost of sampling with PDBs at the specified wells will be
approximately $20,000 for one event. This cost includes an addendum to the QAPP and field sampling
plan for the PDBs, purchase of the PDBs, deployment of three PDBs per well, retrieval of the PDBs,
laboratory analysis and preliminary data interpretation.
Recommendation 5.2.2: The site team should also consider using a Membrane Interface Probe (MIP) or
depth-discrete groundwater sampling from the capillary fringe to bedrock in the source area to refine the
target treatment zone. Hydraulic profiling, performed separately or in combination with the MIP or depth-
discrete groundwater sampling, can also be conducted to better understand the vertical distribution of K.
Areas of high K function to transport the majority of mass, while areas of low K store and slowly release
contaminant mass. By identifying areas of transport vs. storage, remedies can be targeted to precise
locations to treat or contain mass. As a result, the optimization review team suggests that up to 20
hydraulic profiling locations are appropriate.
The additional source area characterization work using hydraulic profiling and MIP or depth-discrete
sampling for up to 20 locations should cost approximately $45,000, including an addendum to the QAPP,
field sampling and preliminary data interpretation.
Recommendation 5.2.3: If the implemented remedy (excavation, SVE or both) does not achieve the
applicable remediation goals or demonstrable decreases in concentration in the downgradient plume, the
optimization review team recommends the site team consider using 3-dimensional visualization and
analysis (3DVA) methods to support source area groundwater characterization, source(s) targeting, as
applicable, RD and remedy performance monitoring.
The use of 3DVA would support an integrated analysis of source location(s); plume morphology; and
plume behavior as related to site geology (bedrock and unconsolidated overburden visualized in terms of
relative hydraulic conductivity [KR]), groundwater contaminant chemistry, and temporal changes in water
table elevations. Integrated analysis of these data will provide enhanced understanding of plume
morphology and behavior and enable estimation of contaminant mass and volume. This information
would provide a more refined basis to scope and design additional remedial strategies and components.
3DVA could also support remediation performance monitoring via application to subsequent groundwater
monitoring data sets, including demonstration of reductions in plume area mass and volume. The cost of
the initial 3DVA effort is anticipated to be in the range of $25,000 to $50,000, dependent upon data
quantity and organization. The cost of each subsequent groundwater monitoring update would be on the
order of $5,000.
5.3
Recommendations for Soil Remediation
Details on the relative technical merits of excavation
vs. SVE remedies for soil are discussed in Section
4.0. Recommendations for soil remediation follow.
Recommendation 5.3: Between the two primary
remedies being considered, the optimization review
team favors the SVE remedial approach or a
combination of SVE and excavation depending on
the results of the SVE pilot test. Excavation may be
considered a contingent response if SVE is not
effective for highly contaminated, low-porosity soils
Benefits of Implementing Section 5.3
Recommendations
SVE is recommended as a cost-effective,
low-risk approach.
Excavation or SVE with excavation is
recommended as a contingent remedy if
the pilot study and site characterization
indicate that SVE will not be effective as a
stand-alone remedy.
Lockwood Operable Unit 1 - Beall Source Area
Billings, Montana
20
Optimization Review Report
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in the source area. Limited excavation of high concentration shallow soils followed by on-site SVE may
be an effective way to target contaminant sources, without having to modify decision documents.
Overall, SVE costs are lower than excavation, and would not require modification of decision documents
as a selected remedy option. SVE is more compatible with property re-use. Although, the optimization
review team believes the SVE remedy will require more time to meet remedial goals, this is not a major
concern, as no major exposure pathways are open.
SVE (or SVE/excavation) should be performed prior to ISB treatments in groundwater. Rapid
remediation of residual soil sources could have a beneficial effect on remediation of groundwater by
cutting off the source of contaminant transfer to groundwater. The velocity of groundwater in the
saturated zone (300 ft per year) is fairly high, so remedial effects should be seen at downgradient
locations within two years.
The cost of the excavation remedy (assuming an excavation measuring 100 ft by 100 ft by 40 ft), without
rebuilding the steam-cleaning bay or modifying the ROD is in the range of $ 1 million, whereas the cost of
design, implementation and operation of SVE with vapor phase GAC treatment for two years is
approximately $800,000. An approach including SVE and small-scale excavation followed by SVE
would have an approximate cost range of $800,000 to $1 million. If SVE pilot tests are not successful, the
optimization review team recommends preparation of more detailed cost assessments including
excavation, after consultation with the new owners of the property to determine if demolition of the
steam-cleaning bay is a possibility.
5.4
Recommendations for Source Area Groundwater Characterization and Remediation
Before a source area groundwater remedy can be
designed, additional information is needed to
determine the distribution of mass both horizontally
and vertically below the water table. Depending on
the results of the characterization, remediation may
be needed in the capillary fringe, upper portion of
the unconsolidated saturated zone (including finer
sands) and or middle to lower portion of the
unconsolidated saturated zone (sand and gravel). The
scope and cost will vary significantly with the
volume to be treated. The optimization review team
offers the following approaches to remediate these
intervals. The approaches can be modified as needed
once more information is available. It is
recommended that ISB should follow the SVE
remedy (Recommendation 5.2 above).
Recommendation 5.4.1: As an initial measure, the site team can install Bio-Trapsฎ or a similar
technology in MW-200 to evaluate the microbial community at the site and determine if bioaugmentation
(addition of microbes) will be appropriate.
Recommendation 5.4.2: If the soil remedy includes excavation, ISB amendments may be added to the
base of the excavation to stimulate biodegradation of contaminants. This approach would improve
contaminant degradation in the capillary fringe of the aquifer. Emulsified vegetable oil might be applied
as a 5% solution to the base of the excavation followed by an approximately equal volume of water. The
cost of treatment would depend on the size of the excavation.
Benefits of Implementing Section 5.4
Recommendations
Characterize microbial community to
optimize choice of ISB strategy.
Source area ISB may dramatically reduce
mass flux to leading edge of plumes.
If excavation is included as part of the soil
remedy, ISB amendments can be added to
the base of the excavation to stimulate
degradation of remaining contamination,
to improve remedy efficiency.
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Optimization Review Report
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Recommendation 5.4.3: Application of emulsified vegetable oil, potentially with bioaugmentation would
be appropriate through injection wells in the source area. Given the volumes of water needed to disperse
the vegetable oil throughout the target area, extracted groundwater would be a reasonable source of water
for blending and injection of the emulsified vegetable oil. Three, 6-inch extraction wells could be
installed along the western and northwestern property boundaries to provide groundwater for the injection
program. Injection could occur through six injection locations distributed from the vicinity of the steam-
cleaning bay to the western property boundary.
Depending on the distribution of contaminant mass, two injection wells may be needed per location so
that emulsified vegetable oil can be delivered effectively to the shallow, finer-grained material and
deeper, coarser-grained material as needed. Injection should occur at the highest practical injection rate
for timely delivery and a large radius of influence. Assuming contaminant mass is distributed such that
remediation is needed throughout the unconsolidated aquifer, the optimization review team assumes that
each injection location might receive approximately 30,000 pounds of emulsified vegetable oil delivered
as a 3% solution (approximately 120,000 gallons of water) followed by an additional 160,000 gallons of
chase water. The injections should be distributed evenly between the two injection intervals. Injection
could occur simultaneously at three wells. After injections through the injection wells has been
completed, injection of the same emulsified vegetable oil water combination used at each injection
location should be conducted at the western and northwestern extraction wells using extracted water from
the third extraction well.
The optimization review team anticipates that the design, implementation, and reporting of this injection
event (including well installation) might cost up to $ 1.2 million. A repeat event for the same volume,
which would likely be needed, would cost approximately $1 million because design, planning and well
drilling would have already occurred. The cost for this remedial approach can be substantially reduced if
remediation is not required from the water table to bedrock throughout the target treatment area.
Additional costs would be incurred for performance monitoring as described in the following section.
5.5 Recommendations for Remedial Performance Monitoring
Historically, over 28 groundwater wells have been
installed in LSGPS Area A for characterization of
. , . , . , , . f .1 Recommendations
contaminant distribution. Based on data trom these
locations, contamination is believed to occur in two lobes . Remedy performance can be
- one fairly high concentration lobe emanating from the
source and extending to the west and a second, more
dilute lobe extending north/northwest.
,. , . . ., . , - remedy performance to stakeholders.
Remedial performance monitoring will be required tor
groundwater for all of the selected remedy options,
including SVE, excavation or ISB.
Benefits of Implementing Section 5.5
evaluated more effectively.
Quantitative metrics demonstrate
Remedy performance monitoring
can prevent operating remedies past
n j ^- ซ ซ 7 A i- j their effective life span.
Recommendation 5.5.1: A preliminary remedy
performance monitoring matrix is included as Table 8. A
total of 55 groundwater samples per year are recommended for the three to five years of active source
remediation. After completion of the remedy performance monitoring period, the groundwater monitoring
network can be reduced.
Recommended groundwater monitoring wells are listed for monitoring the remedy and plume spread for
the source area, the West and North Lobe plumes and the edges of the plume. Sampling frequencies are
Lockwood Operable Unit 1 - Beall Source Area Optimization Review Report
Billings, Montana 22
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recommended for each well group as well as potential data analysis techniques to support each
monitoring objective.
After the multi-level PDB sampling recommended in Section 5.2 is complete, sampling should be
conducted with low-flow sampling from the interval with the highest concentration indicated from the
PDB sampling. Selection of final low-flow sampling locations may be aided by in-well borehole flow
monitoring to confirm flow characteristics across the screen lengths. Samples should be analyzed for
typical field stabilization parameters (including oxidation reduction potential, turbidity and pH), ferrous
iron, nitrate, sulfate, and dissolved organic carbon, alkalinity and VOCs. During the ISB remedy, metals
should be included in the sampling program to ensure that oxidation/reduction manipulation does not
mobilize constituents such as arsenic and manganese. Inorganic sampling may be performed using low-
flow techniques.
Additional data analyses to evaluate remedy performance may include mass flux estimates, and estimates
and trends for total dissolved mass in the plume. All area wells should be monitored at least once during a
FYR cycle. Data should be evaluated routinely to determine if a follow-up source area ISB injection
event is required and if the dilute lobes of the plume are being restored in a timely manner. The sampling
frequency can be revisited after three years of sampling.
Particular attention should be paid to future sampling results from MW-208, which showed non-detect
results through 2010 with one detection of TCE in 2012. The detection in 2012 may be an artifact (no
subsequent sample was available to confirm the detection) or it may indicate the North Lobe plume is
migrating to the north/northeast. In addition, well MW-213 should be sampled periodically to detect any
potential northward migration of the West Lobe resulting from the northerly component of groundwater
flow.
Recommendation 5.5.2: Based on a spatial analysis of the monitoring network using the MAROS
software, an additional groundwater monitoring well would be beneficial in the area of the North Lobe
plume just west/southwest of MW-208 and north of MW-214. It is unclear if some of the wells not
sampled in 2012 are still functional. If wells have been plugged or are not functional, additional wells
may be required to demonstrate remedy performance or containment of the plume.
Recommendation 5.5.3: The sum of mass removed can be compared with estimates of total source area
mass to assess progress toward remedial goals. In addition, remedy performance monitoring for the SVE
system should include monitoring total contaminant mass removed by the SVE relative to energy and
maintenance costs. The SVE system is preliminarily scoped to operate for two to three years. If the cost of
operation exceeds the benefits derived from SVE operation, consider termination, contingency remedies
or optimization of SVE operation. The cost of remedy performance monitoring and reporting for the SVE
is anticipated to be $2,000.
5.6 Recommendations for Dissolved Downgradient Plume Remediation
Currently, cessation of groundwater extraction for municipal supplies and natural attenuation processes
appear to have stabilized and controlled the further migration of OU 1 plumes. In addition, groundwater
flows quickly at the site. The optimization review team finds it likely that quantifiable indications of
performance of source area remediation may be realized at downgradient locations (at monitoring wells
near Interstate 90) in less than three years.
Recommendation 5.6: Delay the decision on whether to implement any active remedy for the
downgradient, leading edge of the groundwater plume until the effects of aggressive source treatment
have been evaluated. Monitor the downgradient portion of the plume for three to five years after source
area remedies have been implemented. Groundwater samples should be collected from groundwater
Lockwood Operable Unit 1 - Beall Source Area Optimization Review Report
Billings, Montana 23
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intervals identified during the vertical characterization to have the highest contaminant concentrations.
Aggressive source area treatment along with natural attenuation processes is anticipated to reduce the
contaminant mass downgradient. Implementation of the source remedies may reduce the need or reduce
the scale of active remediation in the downgradient plume.
Benefits of Implementing Section 5.6
Recommendations
Source area treatment may
eliminate the need for
downgradient remedies.
The performance monitoring discussed in Section 5.5.3 will
provide a good indication of source remedy performance
between the source area and Interstate 90. The monitoring
wells downgradient of Interstate 90 with historical TCE
concentrations above MCLs can be monitored semi-
annually for five years to determine the effect of source area
remediation on these portions of the plume. Trend and
simple statistical analyses of downgradient sampling can be
used to determine if an additional downgradient remedy is appropriate. If time-series data indicate
deceasing concentration trends at individual wells and a reduction in total dissolved mass in the
downgradient plume after source area remedies have been installed, consider eliminating any active
remediation for the downgradient plume from the RD. The optimization review team would not
recommend the use of ISB to address concentrations below 10 (ig/L. Application of ISB remedies are
both ineffective and cost-prohibitive on a cost per mass basis for low concentrations.
5.7 Recommendations Related to Green Remediation
No recommendations are provided for green remediation at this time. Green remediation best
management practices and footprint analysis can be revisited after characterization activities have been
completed and the site team is developing a more targeted RD. In general, the additional characterization
suggested should help target the volume to be remediated and, therefore, reduce the footprint of the final
remedy.
The recommended remedy performance monitoring plan should help reduce the likelihood that the
remedies will be run longer than is beneficial. Conversely, underperforming remedies can be modified or
replaced earlier in the remediation process, thus saving costly time and material expenditures.
Table 7: Recommendations Summary
Recommendation
5.2.1 Groundwater sampling using PDBs
for vertical delineation of contaminants
5.2.2 MIP survey or depth-discrete
groundwater sampling from capillary
fringe to bedrock in the source area
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Recommendation
5.2.3 SDVAto support source area
groundwater characterization, source(s)
targeting, as applicable, remedy design
and remedy performance monitoring
5.3 SVE for source soils with possible
addition of excavation
5.4.1 Bio-Trapฎ samplers to characterize
microbial community
5.4.2 ISB remedy at base of excavation
5.4.3 ISB remedy for saturated zone
5.5.1 Remedy performance monitoring
for groundwater
5.5.2 Additional monitoring location in
North Lobe of groundwater plume
5.5.3 Performance monitoring of SVE
system
5.6 Monitor downgradient groundwater
for response prior to implementation of
any downgradient plume remedy
Effectiveness
+
+
+
Cost Reduction
Technical
Improvement
+
+
+
+
Site Closure
+
+
+
Environmental
Footprint Reduction
Estimated Capital
Cost
$25,000 - $50,000
(dependent on data
quantity and
organization.)
$5,000 (per each
subsequent
sampling update.)
$800,000 -$1M
$3,000
(dependent on size
of excavation)
$1,200,000
$50,000
$5,000
$2,000
(no cost above
performance
monitoring
program)
ซ
3
a
<
_c
OK
g ~
ซ VI
JS 0
u u
N/A
N/A
N/A
N/A
N/A
N/A
Notes: MIP = membrane interface probe; SVE = soil vapor extraction;
diffusion bag; 3DVA = 3-dimensional visualization and analysis; N/A
ISB = in situ bioremediation; PDB = passive
= not applicable.
Lockwood Operable Unit 1 - Beall Source Area
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Optimization Review Report
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Table 8: Recommended Groundwater Performance Monitoring Program
Well Name
MW-200
MW-201
MW-012
MW-204
MW-205
MW202
MW-206
MW-207
MW-217
MW-214
Additional Well
(N of MW-214,
SW of MW-208)
MW108
MW109
MW208
MW215
MW216
MW218
MW203
MW210
MW212
MW300
MW301
MW023
MW211
MW213
MW215
MW302
MW303
MW-209
MW-219
SVE extraction
wells (vapor)
Unit
Source Area
North Lobe
North Lobe
Edges
West Lobe
West Lobe
Edges
Redundant
Source area
Objective
Evaluate response
to source
treatment
Remedy
Performance
Delineate and
evaluate plume
migration
Remedy
Performance
Delineate and
evaluate plume
migration
Parameters &
Frequency
VOCs quarterly for two
years following source
treatment
(metals if ISB
implemented) semi-
annually after remedies
VOCs semi-annually
(metals and
geochemical indicators
during ISB treatment)
VOCs annually during
active remediation, once
every five years during
LTRA
VOCs semi-annually
(metals and
geochemical indicators
during ISB treatment)
VOCs annually during
active remediation, once
every five years during
LTRA
Analyses
Concentration
trend evaluation,
mass discharge
downgradient,
mass removal vs.
cost of remedy
Concentration
trend evaluation,
mass discharge
downgradient,
mass removal vs.
cost of remedy
Compare to
detection limits
and cleanup
standards
Monitor for plume
expansion
Concentration
trend evaluation,
mass discharge
downgradient,
mass removal vs.
cost of remedy
Compare to
detection limits
and cleanup
standards
Monitor for plume
expansion
Do not monitor in near term
Mass removal
Photoionization detector
monthly and VOCs
quarterly from key wells
for comparison
Mass removal rate
Notes: MW = monitoring well; SVE = soil vapor extraction; VOCs = volatile organic compounds; LTRA = long
term remedial action; ISB = in situ bioremediation.
Lockwood Operable Unit 1 - Beall Source Area
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26
Optimization Review Report
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ATTACHMENT A
OPTIMIZATION REVIEW FIGURES
-------
Legend
JK - Recirculation Extraction Well (Enhanced Bioremediation)
A - Recirculation Injection Well (Enhanced Bioremediation)
- Treatment Barrier
- Injection Well Rows (Enhanced Bioremediation)
- Culvert
- Site Boundary
- Area Delineation
lllllllllllllllllllllll - Railroad
^ ^ - Building
I| - Ponds
- River
- Wetlands
- Concentration of PCE Exceeds MCL in April 2003
- Concentration of TCE Exceeds MCL in April 2003
- Groundwater Contamination Above Remediation Goals
Note: All Locations Approximate
650
SCALE IN FEET -1 inch = 650 feet
650
LOCKWOOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 10
GROUNDWATER REMEDY COMPONENTS
TetraTech EM Inc.
-------
ft bus
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
42
43
44
45
46
47
47.5
SP/SM/SW
SP/SM/SW
SP/SM/SW
NR
NR
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
NR
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
NR
NR
NR
NR
NR
SP/SM/SW
NR
NR
NR
NR
SP/SM/SW
^^m
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
NR
NR
40 SP/SM/SW
41 SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
TD
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
NR
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
GW
NR
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
sc
SP/SM/SW
NR
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
GP
GP
TD
SB502
SP/SM/SW
SP/SM/SW
SP/SM/SW with
clay
SP/SM/SW
NR
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
GP
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
NR
NR
NR
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
NR
NR
NR
NR
NR
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
SP/SM/SW
refusal
GP
GP
GW/SP
SP
SP
SP (sat @ 38')
NR
TD
TD = Total Depth
Silty gravels, silty
GM/SM sands
Well-graded
gravel, poorly-
iV/SP graded sands
Silty gravels, silty
sands
SP
SM
SP
NR
NR
NR
NR
SP/SM
SP/SM
NR
SP
GW
SP
NR
NR
SP
SP
SP
NR
NR
SP
GW
NR
NR
NR
SP
SP
NR
NR
NR
SP
SP
SP
NR
NR
SP
SP/SM
NR
NR
NR
SP
SP
SP/SM
SM
NR
GW/SP
SP
SP
SP
NR
SP
SP
NR
NR
NR
SP
SP
SP
SP
NR
SP
SP
GW/SP
NR
NR
SP
SP
NR
NR
NR
SP
SP
SP
NR
NR
SP
SP
SP
SP/SM
NR
SM
SP/SM
SP/SM
NR
NR
SP(sat@40.7') SP/SM (sat @ 40.3') SP(sat@40.8)
SP SP/SM SP/SM
GW
NR
NR
TD
GW
NR
NR
TD
SP/SM
SP/SM
GW/SP
TD
I Well-graded
| gravel
E<
g
Poorly-graded
gravel
Silty gravels,
well-graded
GM/SW sand
GW/SP
SP
SP
SP
NR
SP
SP
SP
NR
NR
SP
SP
SP
SP
NR
NR
SP
SP
^^H"'
NR
SP
SP
SP
NR
NR
SP
SP
SP
SP/SM
NR
SP
SP
SP/SM
NR
NR
SP
SP
SP
SP/SM
NR
SP
SP(sat@41.4')
NR
NR
NR
TD
Clayey sands,
sand -clay
GW/SI
SP
SP
SP
NR
SP
SP
NR
NR
SP
SP
SP
NR
NR
SP
SP
GW
NR
NR
G
SP
NR
NR
SP
SP
SP
NR
NR
SP
SP
NR
NR
NR
SP
SP
NR
NR
NR
jrL
;w
GW(sat@41')
NR
TD
SP
SP
SP
SP
NR
SP
SP
SP
SP
NR
NR
SP
SP
SP
NR
SP/SM
SP/SM
SP/SM
NR
NR
SP
SP
SP/SM
NR
NR
SP
SP
SP
NR
NR
NR
NR
NR
NR
NR
SP/SM
SP/SM
SP/SM
NR
NR
SP
SP
SP/SM
NR (sat @ 43.5')
NR
TD
SP
SP
SP
SP
NR
SP
SP
NR
NR
NR
SP
SP
SP
NR
NR
SP
SP
SP
NR
NR
NR
NR
NR
NR
NR
SP
SP
NR
NR
NR
SP
SP
SP/SM
NR
NR
NR
NR
NR
NR
NR
SP (sat @41.6')
SP/SM
SP/SM
NR
NR
TD
SM/ML
NR
NR
SW
SW
SM/ML
SM/ML
NR
SW
SM
SW
NR
NR
SM/SP
SM/SP
SM/SP
NR
NR
SW/GM
NR
NR
NR
NR
SW/GM
NR
NR
NR
NR
SM/ML
SM/ML
SM/MSP
SM/ML
NR
SM/ML
SM/ML
GW/SM
NR
GM/SM
SM
NR
NR
NR
GM/SM
SM/SP
SM/SP
SM/SP
SM/SP
SM
SM
SM
SM
NR
SM/ML
SM/ML
SM
ML
NR
SM
SM
SM/ML
SM
SM/ML
SM/ML
NR
SM/ML
SM/ML
ML
ML
ML
SP/SM (sat (3 40.8')
ML
SM
SM/ML (sat @
42.5')
I SM/SP
SM/SP
TD
SM/ML
ML/SM
SP
TD
Poorly-graded
SP/SM sand, silty sand
SW
Well-graded
sands
Sand/Silty
sand/gravely
SP/SM/SW sands
Poorly-graded
SP sand
SM Silty sands
Silty sand,
SM/ML inorganic silts
Silty sand,
gravelly sands
Silts, poorly
I graded sands
SM/SW
NR
Inorganic silts
Poorly -graded
sands,
inorganic silts
Not Recorded
Figure 2: OU1 Lithology. Color coded depth vs. soil type for soil borings in the OU1 source area. Depth is between 0 and 47 ft. (Adapted From PWT, 2013)
-------
Mwnn
Historic
GWFlow
*.u . V ^=^/
|MW012| V-
\ Former Steam Bay
OKIS^f r^V'OIKI ~If\lf4
in F/e/cf
LSGPS OU1
Figure 3 TCE in Groundwater
Scale [FT]
0 150 300
0.009-0.100
0.100-0.841
OU1 Groundwater Plumes
Billings, Montana
Legend
Average TCE Concentration [mg/L]
ND-0.001
0.001-0.005
0.005 - 0.009
-------
W310
MW207
MW303
GWFlow
MW212
Historic
GWFlow
MW012
Former Steam Bay
and Drain Field
Legend
ฎ Soil Boring Locations
Mann Kendall Trend (TCE in Groundwater)
O Decreasing * Non-Detect
_ Probably
0 Decreasing No Trend
O Stable Insufficient Data
Increasing
LSGPSArea
OU1 Groundwater
Plumes
Scale [FT]
0 110 220
Notes:
1. Mann-Kendall trends for TCE in groundwater shown
for data collected 2003 - 2012.
2. Soil boring location lithology data are illustrated on Figure 2.
LSGPS OU1
Figure 4 TCE Trends and
Soil Boring Locations
Billings, Montana
-------
ATTACHMENT B
SUPPLEMENTAL FIGURES FROM REMEDIAL INVESTIGATION
REPORT
-------
Attachment A
Figures Excerpted from Site Documents
Log of Borehole MW-200
Log of Borehole MW-201
Figures from RI Report
Figure 3-1
Figure 3-2
Figure 3-3
Figure 3-4
Figure 3-5
Figure 3-6
Figure 3-7
Figure 3-8
-------
LOCKWOOD SOLVENT LOG OF BOREHOLE
/JJAA JjPt GROUND WA TER PLUME SITE
Borehole/Well ID: MW200
YFLLOI/I/9TOA7F COUNTY
^^^^^^
Elevation (+/- AMSL)
3152.5
3151.0-j
3150.0-:
3149.0-;
3148.0-:
3147.0-;
3146.0-j
3145.0-:
3144.0-j
3143.0-:
3142,0":
3141.0-:
3140.0-1
3139.0-j
3138.0-:
3137.0-j
3136.0-:
3135.0-:
3134.0-j
3133.0-1
Depth (n bgs)
Lithologic Symbol/
ฐ=ป
i-EiS
-'&
T'W
5ip
6^|il
7^ ' '
s-E'-
~ iW>
^n
10^
11^'. .
^Z^
1^ _ !
13-E-'
14i
is-E?;^
le^feS
17:B
1 ( _ S .';
18T^|i
= S
20-
Lithologic Description
S1
1
u
&
Ground Surface
||! Grave/
งtil
1
^ A/o Recovery
i,
|;j&; Sand
l^ijii Brown fine with silt to no staining and no odors
!:.;"";
Silt
Brown with moderate fine sand and minor scattered fine-angular gravel, no
staining and no odors
ijjz No Recovery
Silt
Brown silt with moderate clay grading to fine-graded sandy silt grading to fine-
graded sand with some silt, no staining and no odors.
'/%$ NO Recovery
Silt
Brown with mnor fine sand and minor clay, no staining and no odors
^^ No Recovery
}?m Sand
';$ฃ? Brown fine sand with some silt, no staining and no odors
4m. No Recovery
i:;-:{| Sand
;.;:;;ฃ;; Brown fine with variable silt, trace of scattered subrounded gravel, no staining
;;;]'': and no odors
;^jg No Recovery
'.
Headspace PID
Reading
4.4
0.7
11.6
2.4
2.9
1.1
1.5
O ra
0) m
o-c
ii
V) Q.
o n
(0(0
MW200SB001
Monitoring Well
Completion
DRILLING DATE: 7/23-24/02 BOREHOLE DIAMETER (in.): 8.25
DRILLING METHOD: HSA WELL CASING DIAMETER (in.): 2
BOREHOLE DEPTH (ft bgs): 67.6 TOC ELEVATION (ft AMSL): 3152.46 F^T T CIA I
TOTAL WELL DEPTH (ft btoc): 67.6 GROUND ELEVATION (ft AMSL): 3152.47 U0 3 6 "
LOGGED BY: Randy Laskowski DRILLING CO.: O'Keefe 7 Wes( 6(n Avenue Suite 612
CLIENT: MDEQ WATER LEVEL (ft btoc): 42.4 Helena Montana
PROJECT NO.: S1176-10RIRPRT GROUNDWATER ELEV (ft AMSL).: 3110.06 (406)442 5588
-------
LOCKWOOD SOLVENT
GROUNDWATER PLUME SITE
YELLOWSTONE COUNTY
MONTANA
LOG OF BOREHOLE
Borehole/Well ID: MW200
(0
s
i.
c
o
>
HI
3132.0-;
3131,0-;
3130.0-;
3129.0-:
3128.0-:
3127.0-:
3126.0-:
3125.0-:
3124.0-;
3123.0-;
3122.0-j
3121.0-j
3120.0-j
3119.0-:
3117.0-
I
3115.0-
~
3114.0-
:
3113.0-
:-
O)
Si
ฃ
^
5.
Q
22 i
23^
24 ~_
25 i
26^
27 T
28^
29^
30^
31 i
34^
35 T
36-
_
37^
I
38-
I
39-
~
40-
o
E
(0
o ^
o* a
f C
.*; a
!
. ' . .
.
m
ซ
^
ซ
?^
^
^
Lithologic Description
i
Sand
Interbedded layers of silty fine-graded sand to silt with clay, no staining and no
: odors
Sand
Brown fine-graded silty sand with scattered silt and clay lenses, no staining and
no odors, damp
$; No Samples
^
% Silty Sand
:;;.; Brown fine silty with scattered silt and clay lenses, no staining or odors, damp
P A/o Samples
\
Silt
Brown with minor clay and fine sand, no staining or odors
^ No Samples
1
n
i
i
a
a
0)
TI "5
(0 (0
d) o
ID:
2.3
3.7
8.9
3 n
.2 ai
Is
(0 a.
= E
o n
(0(0
0)
g c
0 ^
~ i"
O o
s o
1
E
~
E
i
DRILLING DATE: 7/23-24/02 BOREHOLE DIAMETER (in.): 8.25
DRILLING METHOD: HSA WELL CASING DIAMETER (in.): 2
BOREHOLE DEPTH (ft bgs): 67.6 TOC ELEVATION (ft AMSL): 3152.46 F^T T CH* 1
TOTAL WELL DEPTH (ft btoc): 67.6 GROUND ELEVATION (ft AMSL): 3152.47 Utf ** 6
LOGGED BY: Randy Laskowski DRILLING CO.: O'Keefe 7 Wes( 6(n Avenue Suite 612
CLIENT: MDEQ WATER LEVEL (ft btoc): 42.4 He|eng Mon(gng
PROJECT NO.: S1176-10RIRPRT GROUNDWATER ELEV (ft AMSL).: 3110.06 (406)442 5588
-------
LOCKWOOD SOLVENT
GROUNDWATER PLUME SITE
YELLOWSTONE COUNTY
MONTANA
LOG OF BOREHOLE
Borehole/Well ID: MW200
(0
s
Bฃ
i.
c
o
+J
ra
>
tu
3112.0-j
:
3111.0-i
3110.0-E
~
3109.0-:
3108.0-E
-
3107.0-:
3106.0-:
:
3105.0-i
:
3104.0-;
'.
3103.0-;
I
3102.0-j
:
3101.0-j
3100.0-j
:
3099.0-:
:
3098.0-:
3097.0-;
-
3096.0-;
I
3095.0-j
"
3094.0-j
:
3093.0^
-
O)
&
ฃ
f
S.
3
;
41^
I
43-;
A A ~
44 _
45 -_
47 T
I
48 T
I
49^
~
50^
~
51 -E
;
;
53 -_
~
54^
55 -_
~
56^
I
57^
I
58-;
I
59^
-
60-
o
1
(0
>i
O GS
>
ฃ O
.t; a)
IJDi
'mmy'
'SM
:-:^o:-i !?!;':
^^^
iiงi
ฃO6:-:jj-i
^p^:!j
:^'^>;:-:-
&/J^'&:E
^E=^J
|-Qp<$
?i^'^l
fStง:|
^drSi:!:
BSl
iBl
gO.a-;ij-i
?ฃง?ง;!
9k^::;(
n
'ijLJQ-.ij'j:
M
H'Sm'i
:i&ggj:t
J^fe^
|Q:?^|
;J*wi(
^Oa^-j
^/TvS^^
Lithologic Description
Sand
Brown very moist fine with silt grading to wet fine-graded sand and silt, sand
content increasing with depth, no odors, no staining
A/o Samples
Sandy Gravel
a
a
0)
1 =
(/) .=
^ ^
CO CO
0) 0)
XK
6.2
3 n
ll
15
(0 a.
= E
o n
(0(0
MW200SB002
0)
|i
E
.i "5.
= E
l<5
=
|
5
^
|
E
=
1
E
E
E
=
=
=
=
=
1
E
E
=
E
E
E
DRILLING DATE: 7/23-24/02 BOREHOLE DIAMETER (in.): 8.25
DRILLING METHOD: HSA WELL CASING DIAMETER (in.): 2
BOREHOLE DEPTH (ft bgs): 67.6 TOC ELEVATION (ft AMSL): 3152.46 F^T T CH* 1
TOTAL WELL DEPTH (ft btoc): 67.6 GROUND ELEVATION (ft AMSL): 3152.47 Utf ** 6
LOGGED BY: Randy Laskowski DRILLING CO.: O'Keefe 7 Wes( 6(n Avenue Suite 612
CLIENT: MDEQ WATER LEVEL (ft btoc): 42.4 Helena Montana
PROJECT NO.: S1176-10RIRPRT GROUNDWATER ELEV (ft AMSL).: 3110.06 (406)442 5588
-------
LOCKWOOD SOLVENT
GROUNDWATER PLUME SITE
YELLOWSTONE COUNTY
MONTANA
LOG OF BOREHOLE
Borehole/Well ID: MW200
(0
s
eS
Elevation (+/-
3092.0-j
:
3091 .0-j
~
3090.0-:
I
3089.0-:
I
3088.0-:
3087.0-:
3086.0-:
3085.0-:
3084.0-;
'.
3083.0-:
I
3082.0-j
:
3081 .0-j
-
3080.0-j
-
3079.0-:
-
3078.0-:
-
3077.0-.
-
3076.0-;
I
3075.0-j
"
3074.0-j
:
3073.0^
:-
O)
.a
ฃ
f
3
;
61 -:
I
62-;
I
63^
~
64^
I
65 -_
67-
68 T
I
69^
~
70^
~
71 1
-
72~.
-
73 -_
~
74^
~
75 -i
~
76^
~
77^
I
78-;
I
79 -_
~
80-
o
E
Lithologic Sy
Recovery
mp
^06:^^
?&$^-.
ifjrtp
a>j-^:t
''Q&^^ft
bQ.VM
W$$%t
fSt^l
nil
Lithologic Description
Bedrock
End of Log
a
Headspace PI
Reading
3 n
11
(0 Q.
o n
(0(0
0)
Monitoring W
Completion
;;; E ;;;
::: =::::
: : : = : : : :
::: E::::
III ill!
: : : ~ : : :
: : : = : : : :
::; Eiiii
::: =:i:i
\\\ =i:ii
- - -|^^|
;;;V;;;
DRILLING DATE: 7/23-24/02 BOREHOLE DIAMETER (in.): 8.25
DRILLING METHOD: HSA WELL CASING DIAMETER (in.): 2
BOREHOLE DEPTH (ft bgs): 67.6 TOC ELEVATION (ft AMSL): 3152.46 F^T T CH* 1
TOTAL WELL DEPTH (ft btoc): 67.6 GROUND ELEVATION (ft AMSL): 3152.47 Utf ** 6
LOGGED BY: Randy Laskowski DRILLING CO.: O'Keefe 7 Wes( 6(n Avenue Suite 612
CLIENT: MDEQ WATER LEVEL (ft btoc): 42.4 Helena Montana
PROJECT NO.: S1176-10RIRPRT GROUNDWATER ELEV (ft AMSL).: 3110.06 (406)442 5588
-------
ฉLOCKWOOD SOLVENT LOG OF BOREHOLE
GROUNDWATER PLUME SITE
Borehole/Well ID: M W20 1
VPI 1 OI/I/QTOA/P POIIA/TV
i c,ii\jvv*j i ly/vc i^u/t/iv f F
MOJVTOAM
Elevation (+/- AMSL)
3152.6
3151 .0";
3150.0-
3149.0-:
3148.0-j
3147.0-
3146.0-1
3145.0-:
3144.0";
3143.0-:
3142.0-:
3141.G-;
314Q.O-:
3139.0-j
3138.0-:
3137.0-:
3136.0-:
3135.0-:
3134.0-j
3133.0-:
Depth (n bgs)
Lithologic Symbol/
;i
^P
_ : :
si-' -
_ : :
- ;-
6^|&l
7-i 11;
8^l;li
Q " ^1-
10 _ :X.;K
11^;;ง|
12i '-
13-1-
14 _ :" :
15-E-" "
16^.-' -
M-_ ' .
1ST
ly _;.,
20 -^i)|;
Lithologic Description
ฃ*
1
o
&
Ground Surface
งง A/o Samples
m
il Grave/
|| - ^^Gravel ^/
Silt
Brown silt with minor clay, grades at depth to silt with some fine-graded sand, no
t:., odors and no staining
Silt
:.3# ^^tirown silt with tine-graded sand to thin gravel at about b teet ^/
0; Sand
;-:;i; ^v staining /
ill Sand
.:"!ซ Sand and fine to medium gravel, subrounded, minor silt with no odors and no
TTTFT --sustaining ^-
ง\ Silt /
:^f \ Sand /
fi^ii \Sand and gravel at the top 1 inch of split spoon /
\ Sand /
\ Fine sand with silt, no staining or odors /
Si7*
Silt and fine-graded sand, only small amount in split spoon recovered not enough
N. for a sample. '
Silt
Silt and fine sand with minor scattered pebbles grades to fine silty sand at depth,
no staining or odors
Silt
Brown silt with some clay which changes to silt with minor sand which grades to
fine sand at bottom of spilt spoon
Headspace PID
Reading
145
64
245
19
2.5
0.7
2.5
8.1
3 "5
o> i
Q.=
ง1
V) a.
o n
(0(0
MW201SB001
Monitoring Well
Completion
!
DRILLING DATE: 6/25/02 BOREHOLE DIAMETER (in.): 8.25
DRILLING METHOD: HSA WELL CASING DIAMETER (in.): 2.0
BOREHOLE DEPTH (ft bgs): 69 TOC ELEVATION (ft AMSL): 3152.24 F^T T CH* 1
TOTAL WELL DEPTH (ft btoc): 67.5 GROUND ELEVATION (ft AMSL): 3152.57 Utf ** 6
LOGGED BY: Randy Laskowski DRILLING CO.: Maxim 7 Wes( 6(n Avenue Suite 612
CLIENT: MDEQ WATER LEVEL (ft btoc): 42.1 (10/28/02) Helena Montana
PROJECT NO.: S1176-10RIRPRT GROUNDWATER ELEV (ft AMSL).: 3110.14 (406)442-5588
-------
LOCKWOOD SOLVENT
GROUNDWATER PLUME SITE
YELLOWSTONE COUNTY
MONTANA
LOG OF BOREHOLE
Borehole/Well ID: M W201
Elevation (+/- AMSL)
3132.0-:
3131.0-
3130.0-:
3129.0-;
3128.0-j
3127.0-:
3126.0-:
3125.0-:
3124.0-:
3123.0-j
3122.0-j
3121.0-
3120.0-:
3119.0-:
3118.0-
3117.0-1
3116.0-:
31150-
311.4.0-:
311,3,0':
Depth (n bgs)
Lithologic Symbol/
21 ^ilf
22-E '.
23-;
z4 _ : :
25 ~= :
26-E -
27-E '.
28-E "
so-:'
31-E/
32-E '
33-E
o4 _
35 T
36
37^ '. '
38^r'J':
39-:--
40-?; |)|:
Lithologic Description
ฃ*
1
u
&
;ฃf Sand
'kg; Brown fine sand with silt which changes to silt with minor fine sand at bottom of
- *.. split spoon no staining or odors
Silt
Brown silt with minor clay and variable fine sand, fine sand content increases
with depth, not staining or odors
Silt
Brown silt with minor clay and variable fine sand, no staining or odors
Silt
Brown silt with minor clay interbedded with fine sand with some silt, layers 2-3
inches thick, soft and moist with no staining or odors
Silt
Same as above with increasing fine sand towards bottom, not staining or odors
Silt
. Same as above, interbedded silt and fine sand layers, bottom 3 inches very moist
and soft, no staining or odors
: sat
^^Brown very moist to wet 5 inches of silt with fine sand /
Clay
\Silt /
\Softer moist silt with fine-graded sand for bottom 3 inches, no staining or odors /
":ASI" /I
\\Brownsiltchangingtofine-gradedsandwithvariablesiltneartop //
HA Sand /I
\ \One cm layer of coarser oxidized sand and trace of fine gravel at 37.5 / 11
Headspace PID
Reading
34.5
37.7
26.3
29.1
38.6
24.6
6.8
14.7
3 ซ
o> i
o-c
ง1
V) Q.
o n
(0(0
MW201SB002
Monitoring Well
Completion
i
1
=
=
1
1
=
=
DRILLING DATE: 6/25/02 BOREHOLE DIAMETER (in.): 8.25
DRILLING METHOD: HSA WELL CASING DIAMETER (in.): 2.0
BOREHOLE DEPTH (ft bgs): 69 TOC ELEVATION (ft AMSL): 3152.24 F^T T CH* 1
TOTAL WELL DEPTH (ft btoc): 67.5 GROUND ELEVATION (ft AMSL): 3152.57 Utf ** 6
LOGGED BY: Randy Laskowski DRILLING CO.: Maxim 7 Wes( 6(n Avenue Suite 612
CLIENT: MDEQ WATER LEVEL (ft btoc): 42.1 (10/28/02) Helena Montana
PROJECT NO.: S1176-10RIRPRT GROUNDWATER ELEV (ft AMSL).: 3110.14 (406)442-5588
-------
LOCKWOOD SOLVENT
GROUNDWATER PLUME SITE
YELLOWSTONE COUNTY
MONTANA
LOG OF BOREHOLE
Borehole/Well ID: M W201
Elevation (+/- AMSL)
3112.0":
3111.Q-;
3110.0-;
3109.0-:
3108.0-j
3107.0-:
3106.0-:
3105.0-:
3104.0-:
3103.0-j
3102.0-j
3101.0-;
3100.0-:
3099.0-:
3098.0-
3097.0-:
3096.0-:
3095.0-;
3094.0-:
3093.0-j
(/)
O)
.a
ฃ
f
3
41-1
42 -;
43-;
44-
45.
47 T
48 -E
50^
b1
52 "I
53 T
o4 _
55 T
56-
57^
58^
59-
60-
Lithologic Symbol/
Recovery
1.'!\^l "::'*^<*J
v^-?!: 'py^v
.;:^^!: 'i^^v
I
Hi
|9ง^|
^1
1
;:^x:i-;.\r^;:
1
Mis
ซ%
Lithologic Description
\\S"' //
\ \Brown silt changing to fine-graded sand with variable silt near top / /
\\SI" It
\\ \Brown silt / //
\\Sand I
\ \Fine-graded sand with silt / /
V \Clay I 1
\ \Clay with silt / /
\ Sand /
\ Brown fine-graded sand with silt changing to very moist (almost wet), soft with /
\ \silt and fine-graded sand / /
\ Sand /
\ Brown fine-graded sand with variable silt becoming wet at 44 feet /
A/o Samples
Sand with Gravel
Brown medium-graded sand with abundant fine to medium rounded to subrounded
gravel, no staining or odors
A/o Samples
Sandy Gravel
\ Brown medium-graded sand with abundant fine to medium rounded to subrounded /
\gravel, no staining or odors /
A/o Samples
Sandy Gravel
Headspace PID
Reading
9.8
11.5
1.9
0.5
0.1
3 n
o> i
Q.=
ง1
V) Q.
o n
(0(0
MW201SB003
Monitoring Well
Completion
^
=
=
=
ti
^
^
=
=
^
^
=
^
I
=
|
=
^
=
^
=
=
=
=
E
=
E
=
=
~
=
E
>
=
=
=
: : : :
DRILLING DATE: 6/25/02 BOREHOLE DIAMETER (in.): 8.25
DRILLING METHOD: HSA WELL CASING DIAMETER (in.): 2.0
BOREHOLE DEPTH (ft bgs): 69 TOC ELEVATION (ft AMSL): 3152.24 F^T T CH* 1
TOTAL WELL DEPTH (ft btoc): 67.5 GROUND ELEVATION (ft AMSL): 3152.57 Utf ** 6
LOGGED BY: Randy Laskowski DRILLING CO.: Maxim 7 Wes( 6(n Avenue Suite 612
CLIENT: MDEQ WATER LEVEL (ft btoc): 42.1 (10/28/02) Helena Montana
PROJECT NO.: S1176-10RIRPRT GROUNDWATER ELEV (ft AMSL).: 3110.14 (406)442-5588
-------
LOCKWOOD SOLVENT
GROUNDWATER PLUME SITE
YELLOWSTONE COUNTY
MONTANA
LOG OF BOREHOLE
Borehole/Well ID: M W201
Elevation (+/- AMSL)
3092.0-:
3091 .0-;
3090.0-;
3089.0-:
3088.0 .
3087.0-:
3086.0-:
3085.0-:
3084.0-:
3083.0-j
3082.0-j
3081 .0-;
3080.0-:
3079.0-:
3078.0-:
3077.0-:
3076.0-:
3075.0-;
3074.0-:
3073.0-j
(/)
O)
.a
ฃ
f
&
61 T
62-_
63^
b4 _
65 ~_
66 T
CT7
68 T
69-
70^
71 -E
72^
73 T
74^
75 T
76^
77^
78^
79 T
80-
Lithologic Symbol/
Recovery
^
:v;.;.:';.-y:.\:^v
%
Lithologic Description
A/o Samples
Gravelly Sand
\ Medium to coarse sand with some fine to medium graded gravel, more sand than /
\gravel no staining and no odors /
No Samples
Bedrock
End of Log
Headspace PID
Reading
0.3
3 ซ
o> i
o-c
ง1
V) Q.
o n
(0(0
MW201SB004
Monitoring Well
Completion
: : : '.'.'.:
::: =::::
... ...
: : : : : : :
... _ . . . .
;;; s|||;
... ....
: : : E : : : :
... . . . .
;;; =;;;;
::: =::::
... ....
::! =::::
::: =::::
: : : : : : :
: :: = : :: :
... '.'.'.'
;;:M;;:
DRILLING DATE: 6/25/02 BOREHOLE DIAMETER (in.): 8.25
DRILLING METHOD: HSA WELL CASING DIAMETER (in.): 2.0
BOREHOLE DEPTH (ft bgs): 69 TOC ELEVATION (ft AMSL): 3152.24 F^T T CH* 1
TOTAL WELL DEPTH (ft btoc): 67.5 GROUND ELEVATION (ft AMSL): 3152.57 Utf ** 6
LOGGED BY: Randy Laskowski DRILLING CO.: Maxim 7 Wes( 6(n Avenue Suite 612
CLIENT: MDEQ WATER LEVEL (ft btoc): 42.1 (10/28/02) Helena Montana
PROJECT NO.: S1176-10RIRPRT GROUNDWATER ELEV (ft AMSL).: 3110.14 (406)442-5588
-------
MW120
RECENT FLOODPLAIN
RECENT COLLUVIAL
DEPOSITS
MW108 V*IW003
Auto Storage Yard RW006
ID
UPPER ALLUVIAL
TERRACE
MW013AL MW040
Estimated Extent
I 'of Alluvial Aquifer /
MWOJ6-
Fig3-1_GeomorphicFeats.mxd RSR 2/20/03 S1176-10RIRPRT
Legend
Well Locations
Roads
Ditches
Railroad
Fence Line
Culvert
Area Delineations
Site Boundary
Alluvial Aquifer Extent
Terrace Boundaries
Buildings
I7 __ J River Islands
River
Wetlands
Recent Colluvial Fan Deposit
650
LOCKWDOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 3-1
GEOMORPHIC FEATURES
iTetraTech EM Inc.
-------
A- - Monitoring Well Locations
Cross Section Line
- Culvert
- Site Boundary
- Area Delineation
iiiiiiiiiiiiiiiiiiiini - Railroad
- Building
- Ponds
- River
- Wetlands
SCALE IN FEET -1 inch = 650 feet
LOCKWOOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 3-2
GEOLOGIC CROSS SECTION
PLAN MAP
Tetra Tech EM Inc
-------
A
NORTHWEST
3,150-
3,145-E-
3,140-E-
3,135-E-
3,130-E-
3,125
3,120
3,115-E-
3,110-E-
3,105-E-
3,100-E-
3,095
3,090
3,085
3,080
3,075
3,070
3,065
3,060
3,055
3,050
3,045
3,040
3,035 -E-
3,030
A1
SOUTHEAST
MW219
-3,150
-3,145
-3,140
-3,135
3,130
3,125
3,120
3,115
3,110
3,105
3,100
3,095
3,090
3,085
3,080
3,075
3,070
3,065
3,060
3,055
3,050
3,045
3,040
3,035
3,030
LOCKWOOD SOLVENT GROUNDWATER PLUME SITE
CROSS SECTION A-A' - LOCATOR MAP
Legend
MW - Monitoring Well Locations
TD - Total Depth
BGS - Below Ground Surface
& - Groundwater Level
- Silty Clay / Silt / Fine Sand
CSS3 - Gravels With Sand
| | - Bedrock
Elevations Listed In Feet Above Mean Sea Level
Well Detail
Riser
Screened Interval
325
325
650
I
SCALE IN FEET -1 inch = 325 feet
VERTICAL SCALE EXAGGERATED 15X
LOCKWOOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 3-3
GEOLOGIC CROSS SECTION
A-A'
Tetra Tech EM Inc.
-------
Legend
MW - Monitoring Well Locations
TD - Total Depth
BGS - Below Ground Surface
_Y_ - Groundwater Level
- Silty Clay / Silt / Fine Sand
CSS3 - Gravels With Sand
| | - Bedrock
Elevations Listed In Feet Above Mean Sea Level
LOCKWOOD SOLVENT GROUNDWATER PLUME SITE
CROSS SECTION B-B' - LOCATOR MAP
i
Well Detail
Riser
Screened Interval
325
325
650
I
SCALE IN FEET -1 inch = 325 feet
VERTICAL SCALE EXAGGERATED 15X
LOCKWOOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 3-4
GEOLOGIC CROSS SECTION
B-B1
Tetra Tech EM Inc.
-------
c
SOUTHWEST
3,100-
3,0955
3,090 5
3,085 5
3,0805
3,075 5
3,070 5
3,0655
3,060 5
3,0555
3,050 5
3,045 5
3,040-
MW304
MW117
C1
NORTHEAST
-3,100
53,095
5 3,090
E- 3,085
53,080
5 3,075
f-3,070
5-3,065
5 3,060
5-3,055
53,050
5 3,045
-3,040
Legend
MW - Monitoring Well Locations
TD - Total Depth
BGS - Below Ground Surface
_Y_ - Groundwater Level
- Silty Clay / Silt / Fine Sand
CSS3 - Gravels With Sand
| | - Bedrock
Elevations Listed In Feet Above Mean Sea Level
LOCKWOOD SOLVENT GROUNDWATER PLUME SITE
CROSS SECTION C-C' - LOCATOR MAP
i
Well Detail
Riser
Screened Interval
325
325
SCALE IN FEET -1 inch = 325 feet
VERTICAL SCALE EXAGGERATED 15X
650
I
LOCKWOOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 3-5
GEOLOGIC CROSS SECTION
C-C'
Tetra Tech EM Inc.
-------
Estimated Extent \
i'of Alluvial Aquifer /
650
Legend
Well Location
"v" with Bedrock Elevation
Roads
... Ditches
' ' Railroad
-X- -X- Fence Line
> < Culvert
^^^^ Area Delineations
ซ Site Boundary
Ten Foot Bedrock Elevational Contours
4 1 Inferred
- Aquifer Extent
Buildings
17 j River Islands
Wetlands
Bedrock Elevations.mxd RSR 11/25/02 S1176-10RIRPRT
LOCKWDOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 3-6
TOP OF BEDROCK STRUCTURE MAP
Tetra Tech EM Inc.
-------
MW21'4A
3108 98^ RflYTFPI MIHARnlM RD
Estimated Extent of
Alluvial Aquifer
August_Waterlevel_51503.mxd RSR 5/15/03 S1176-10RIRPRT
Legend
A MW202 Monitoring Well Location
3110'7 with August Water Level (above mean sea level)
Roads
... Ditches
Railroad
-X- -X- Fence Line
) < Culvert
^^^^ Area Delineations
Site Boundary
^^-^ Groundwater Flow Streamline
- Aquifer Extent
Five Foot Water Table Contours
4 1 Inferred
Buildings
!7 J River Islands
I River
I:.-'.'.V::-':'J Wetlands
650
LOCKWDOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 3-7
AUGUST 28,2002
ALLUVIAL AQUIFER WATER LEVELS
lletra Tech EM Inc.
-------
IVIVVIUZ J^ป IVIVVIU^
3092.86 V" \3093.6
nm/w-inn *
MW202 Monitoring Well Location
with October Water Level (above mean sea level)
Roads
Ditches
Railroad
Fence Line
Culvert
Area Delineations
Site Boundary
Groundwater Flow Streamline
Aquifer Extent
Five Foot Bedrock Water Table Contours
Inferred
Buildings
River Islands
River
l:.:.V-'::-:'-l Wetlands
LOCKWDOD SOLVENT GROUNDWATER PLUME SITE
BILLINGS, MONTANA
FIGURE 3-8
OCTOBER 28, 2002
ALLUVIAL AQUIFER WATER LEVELS
Tetra Tech EM Inc.
Odober_Waterlevel_051503.mxd RSR 5/15/03 S1176-10RIRPRT
-------
ATTACHMENT C
MONITORING AND REMEDIATION OPTIMIZATION SYSTEM
ANALYSIS REPORTS
-------
Attachment B
MAROS Software Reports
West Lobe of Plume
Mann-Kendall Individual Well Trend Analysis
Individual Well Summary
MK TCE Trend Well MW-212
MK TCE Trend Well MW-213
First Moment - Total Dissolved Mass in West Lobe
Percent Mass by Well - West Lobe
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
Time Period: 4/25/2003 to 5/4/2012
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
Coefficient
of Variation
Mann-
Kendall
Statistic
Confidence
in Trend
All
Samples
"ND" ?
Concentration
Trend
cis-l,2-DICHLOROETHYLENE
MW012
MW023
MW200
MW201
MW202
MW203
MW204
MW210
MW211
MW212
MW213
MW215
MW219
MW300
MW301
MW302
MW303
T
T
S
S
S
S
S
T
T
T
T
T
S
T
T
T
T
7
7
7
7
5
7
7
8
7
7
7
4
7
7
8
4
4
7
5
7
7
2
7
7
8
1
7
2
4
7
7
8
3
2
0.59
0.44
0.68
0.59
0.69
0.68
0.93
1.27
0.33
0.54
0.31
0.21
0.30
0.89
0.45
0.54
0.20
-11
-16
-3
-5
1
-3
-7
-10
-2
-17
-7
-4
-3
-17
-10
2
1
93.2%
99.0%
61.4%
71.9%
50.0%
61.4%
80.9%
86.2%
55.7%
99.5%
80.9%
83.3%
61.4%
99.5%
86.2%
62.5%
50.0%
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
PD
D
S
S
NT
S
S
NT
S
D
S
S
S
D
S
NT
NT
TRICHLOROETHYLENE (TCE)
MW012
MW023
MW200
MW201
MW202
MW203
MW204
MW210
T
T
S
S
S
S
S
T
7
7
7
7
5
7
7
8
7
7
7
7
3
7
7
8
0.34
0.40
0.60
0.43
1.03
0.69
0.59
0.97
-1
-20
-7
-1
1
9
-5
-8
50.0%
100.0%
80.9%
50.0%
50.0%
88.1%
71.9%
80.1%
No
No
No
No
No
No
No
No
S
D
S
S
NT
NT
S
S
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
TRICHLOROETHYLENE (TCE)
Well
Number Number Mann-
Source/ of of Coefficient Kendall
Tail Samples Detects of Variation Statistic
All
Confidence Samples Concentration
in Trend "ND" ? Trend
MW211
MW212
MW213
MW215
MW219
MW300
MW301
MW302
MW303
T
T
T
T
S
T
T
T
T
7
7
7
4
7
7
8
4
4
4
7
6
4
2
7
8
3
4
1.11
0.33
0.58
0.26
1.88
0.72
0.26
0.65
0.26
-14
-9
9
-6
-3
-21
-1
2
-2
97.5%
88.1%
88.1%
95.8%
61.4%
100.0%
50.0%
62.5%
62.5%
No
No
No
No
No
No
No
No
No
D
S
NT
D
NT
D
S
NT
S
Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not
Applicable (N/A)-Due to insufficient Data (< 4 sampling events); Source/Tail (S/T)
The Number of Samples and Number of Detects shown above are post-consolidation values.
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 2 of 2
-------
MAROS Individual Well Summary Report
Project: Lockwood User Name: MV
Location: OU1 State: Montana
coc
Priority
COC for
Well?
Detection
Frequency
Recent
Sample
Above Goal?
MK
Trend
cov
95% UCL
Outlier
Distribution
Assumption
Attained Cleanup?
Normal
Lognormal
MW012
DCE12C
TCE
NO
NO
100%
100%
NO
YES
PD
S
0.56
0.30
0.0823
0.0251
NO
NO
Normal
Normal
NO
NO
NO
NO
MW023
DCE12C
TCE
MW200
DCE12C
TCE
YES
YES
NO
YES
75%
100%
89 %
89 %
NO
NO
YES
YES
D
D
S
S
0.77
0.35
0.73
0.63
0.0006
0.0020
0.2147
0.7387
NO
NO
YES
NO
Normal
Normal
Normal
Normal
YES
YES
NO
NO
NO
NO
NO
NO
MW201
DCE12C
TCE
NO
YES
100%
100%
YES
YES
S
S
0.56
0.37
0.8952
1.1748
NO
NO
Normal
Normal
NO
NO
NO
NO
MW202
DCE12C
TCE
NO
NO
40%
60%
NO
NO
NT
NT
1.84
1.07
0.0008
0.0046
NO
NO
Lognormal
Normal
YES
NO
NO
NO
MW203
DCE12C
TCE
NO
YES
100%
100%
YES
YES
S
NT
0.59
0.51
0.1700
0.1328
NO
NO
Normal
Normal
NO
NO
NO
NO
MW204
DCE12C
TCE
NO
NO
100%
100%
NO
YES
S
S
1.09
0.57
0.0889
0.0504
NO
NO
Normal
Normal
NO
NO
NO
NO
MW210
DCE12C
TCE
NO
YES
100%
100%
NO
YES
NT
S
1.27
0.94
0.0520
0.0562
YES
YES
Lognormal
No distribution
YES
NO
NO
NO
MW211
DCE12C
TCE
NO
NO
14%
57%
NO
NO
S
D
0.00
1.30
0.0004
0.0020
YES
YES
No distribution
Lognormal
YES
YES
YES
NO
MW212
DCE12C
NO
100%
NO
D
0.55
0.0447
NO
Normal
YES
NO
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 2
-------
MAROS Individual Well Summary Report
Project: Lockwood User Name: MV
Location: OU1 State: Montana
coc
TCE
Priority
COC for
Well?
NO
Detection
Frequency
100%
Recent
Sample
Above Goal?
YES
MK
Trend
S
cov
0.33
95% UCL
0.0508
Outlier
NO
Distribution
Assumption
Normal
Attained Cleanup?
Normal
NO
Lognormal
NO
MW213
DCE12C
TCE
NO
NO
29 %
86%
NO
NO
S
NT
0.71
0.59
0.0003
0.0026
YES
NO
No distribution
Normal
YES
YES
NO
NO
MW215
DCE12C
TCE
NO
YES
100%
100%
NO
NO
S
D
0.21
0.24
0.0009
0.0044
NO
NO
Normal
Normal
NO
NO
NO
NO
MW219
DCE12C
TCE
NO
NO
100%
38%
NO
NO
S
NT
0.28
1.91
0.0017
0.0053
NO
YES
Normal
No distribution
YES
NO
NO
NO
MW300
DCE12C
TCE
MW301
DCE12C
TCE
NO
YES
NO
NO
100%
100%
100%
100%
NO
NO
NO
YES
D
D
S
S
0.81
0.52
0.45
0.23
0.0111
0.0130
0.0084
0.0073
YES
YES
NO
NO
Normal
Normal
Normal
Normal
YES
NO
YES
NO
NO
NO
YES
NO
MW302
DCE12C
TCE
NO
YES
75%
75%
NO
NO
NT
NT
0.79
0.81
0.0014
0.0012
NO
NO
Normal
Normal
NO
NO
NO
NO
MW303
DCE12C
TCE
NO
YES
50%
100%
NO
NO
NT
S
0.93
0.17
0.0004
0.0028
YES
NO
Normal
Normal
NO
NO
NO
NO
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood User Name: MV
Location: OU1 State: Montana
Well:
Well Type:
COC:
6 OE-02 -
1 OF n? -
E 4 OE-02
c
ฃ 3.0E-02 -
TO
ง 2.0E-02 -
c
o
u 1 OE-02
MW212 Time Period: 4/25/2003 to 5/4/2012
T Consolidation Period: No Time Consolidation
TRICHLOROETHYLENE (TCE) Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
<^' xปc^ <ฃ'
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood User Name: MV
Location: OU1 State: Montana
Well:
Well Type:
COC:
3 5E-03 H
3.0E-03 -
'S) O ซJF ffl .
c o OF m -
CO
c
-------
MAROS Zeroth Moment Analysis
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
Change in Dissolved Mass Over Time
COC: TRICHLOROETHYLENE (TCE)
3.0&-00
__ 2.0&-00 -
O)
"^ 1.5&-00
ro
S 1.0&-00
5.0E-01
Date
Porosity: 0.25
Saturated Thickness:
Uniform: 20ft
Mann-Kendall S Statistic:
-7
Confidence in Trend:
80.9%
Coefficient of Variation:
0.29
Zeroth Moment Trend:
S
Data Table:
Effective Date
4/25/2003
10/24/2003
4/23/2004
4/6/2006
10/8/2009
4/15/2010
5/4/2012
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Estimated Mass (Kg)
1.6E+00
1.8E+00
2.6E+00
1.6E+00
1.2E+00
1.3E+00
1.4E+00
Number of Wells
17
17
17
15
14
14
13
Note: 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. Moments are not calculated for sample events with less
than 6 wells.
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 1
-------
MAROS Percent of Mass by Well
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
TRICHLOROETHYLENE (TCE) 5/4/2012
35
15
10
5
0
n
Well
MW012
MW023
MW200
MW201
MW202
MW203
MW204
MW210
MW211
MW212
MW213
MW215
MW219
MW300
Area (ft2)
14,753.22
216,010.67
11,506.42
15,777.81
5,323.42
81,636.18
39,572.27
157,876.03
99,453.77
285,878.17
275,239.50
184,512.72
38,141.88
164,041.73
Mass (mg)
49.05
37.80
594.02
2,291.73
0.23
1,714.36
133.89
469.68
4.35
2,076.19
105.97
77.50
1.67
28.71
Percent of Mass
0.64
0.49
7.72
29.78
0.00
22.28
1.74
6.10
0.06
26.98
1.38
1.01
0.02
0.37
Percent of Area
0.80
11.70
0.62
0.85
0.29
4.42
2.14
8.55
5.39
15.48
14.91
9.99
2.07
8.88
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 2
-------
MAROS Percent of Mass by Well
Project: Lockwood
Location: OU1
Well
MW301
MW302
MW303
User Name: MV
State: Montana
Area (ft2)
55,389.88
70,769.42
130,503.24
1,846,386.3
Mass (mg)
74.64
12.38
22.84
7,695.0
Percent of Mass
0.97
0.16
0.30
100
Percent of Area
3.00
3.83
7.07
100
rfb
A
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 2 of 2
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Attachment B
MAROS Software Reports
North Lobe of Plume
Mann-Kendall Individual Well Trend Analysis
Individual Well Summary
MK TCE Trend Well MW-207
MK TCE Trend Well MW-208
MK TCE Trend Well MW-217
First Moment - Total Dissolved Mass in West Lobe
Percent Mass by Well - West Lobe
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
Time Period: 4/25/2003 to 5/4/2012
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
Coefficient
of Variation
Mann-
Kendall
Statistic
Confidence
in Trend
All
Samples
"ND" ?
Concentration
Trend
cis-l,2-DICHLOROETHYLENE
MW012
MW108
MW109
MW200
MW201
MW202
MW204
MW205
MW206
MW207
MW208
MW209
MW214
MW216
MW217
MW218
MW219
S
T
T
S
S
S
S
S
S
T
T
T
T
T
T
T
S
7
6
6
7
7
5
7
7
7
7
7
4
7
8
7
4
7
7
5
6
7
7
2
7
7
6
7
0
0
2
5
6
0
7
0.59
0.36
0.22
0.68
0.59
0.69
0.93
1.05
0.44
0.55
0.00
0.00
0.33
0.39
0.46
0.00
0.30
-11
-15
-13
-3
-5
1
-7
-3
5
-17
0
0
-5
-25
-19
0
-3
93.2%
99.9%
99.2%
61.4%
71.9%
50.0%
80.9%
61.4%
71.9%
99.5%
43.7%
37.5%
71.9%
100.0%
99.9%
37.5%
61.4%
No
No
No
No
No
No
No
No
No
No
Yes
Yes
No
No
No
Yes
No
PD
D
D
S
S
NT
S
NT
NT
D
ND
ND
S
D
D
ND
S
TRICHLOROETHYLENE (TCE)
MW012
MW108
MW109
MW200
MW201
MW202
MW204
MW205
S
T
T
S
S
S
S
S
7
6
6
7
7
5
7
7
7
6
6
7
7
3
7
7
0.34
0.18
0.27
0.60
0.43
1.03
0.59
0.58
-1
-12
-11
-7
-1
1
-5
7
50.0%
98.2%
97.2%
80.9%
50.0%
50.0%
71.9%
80.9%
No
No
No
No
No
No
No
No
S
D
D
S
S
NT
S
NT
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
TRICHLOROETHYLENE (TCE)
Well
Number Number Mann-
Source/ of of Coefficient Kendall
Tail Samples Detects of Variation Statistic
All
Confidence Samples Concentration
in Trend "ND" ? Trend
MW206
MW207
MW208
MW209
MW214
MW216
MW217
MW218
MW219
S
T
T
T
T
T
T
T
S
7
7
7
4
7
8
7
4
7
7
7
1
0
7
8
7
0
2
0.54
0.51
1.77
0.00
0.60
0.26
0.29
0.00
1.88
3
-17
6
0
-17
-20
-17
0
-3
61.4%
99.5%
76.4%
37.5%
99.5%
99.3%
99.5%
37.5%
61.4%
No
No
No
Yes
No
No
No
Yes
No
NT
D
NT
ND
D
D
D
ND
NT
Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not
Applicable (N/A)-Due to insufficient Data (< 4 sampling events); Source/Tail (S/T)
The Number of Samples and Number of Detects shown above are post-consolidation values.
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 2 of 2
-------
MAROS Individual Well Summary Report
Project: Lockwood User Name: MV
Location: OU1 State: Montana
coc
Priority
COC for
Well?
Detection
Frequency
Recent
Sample
Above Goal?
MK
Trend
cov
95% UCL
Outlier
Distribution
Assumption
Attained Cleanup?
Normal
Lognormal
MW012
DCE12C
TCE
NO
NO
100%
100%
NO
YES
PD
S
0.56
0.30
0.0823
0.0251
NO
NO
Normal
Normal
NO
NO
NO
NO
MW108
DCE12C
TCE
MW109
DCE12C
TCE
NO
YES
NO
YES
88%
100%
100%
100%
NO
NO
NO
YES
D
D
D
D
0.38
0.18
0.22
0.26
0.0005
0.0028
0.0010
0.0106
NO
NO
NO
NO
No distribution
No distribution
No distribution
No distribution
YES
YES
YES
NO
NO
YES
YES
NO
MW200
DCE12C
TCE
NO
YES
89 %
89 %
YES
YES
S
S
0.73
0.63
0.2147
0.7387
YES
NO
Normal
Normal
NO
NO
NO
NO
MW201
DCE12C
TCE
NO
YES
100%
100%
YES
YES
S
S
0.56
0.37
0.8952
1.1748
NO
NO
Normal
Normal
NO
NO
NO
NO
MW202
DCE12C
TCE
NO
NO
40%
60%
NO
NO
NT
NT
1.84
1.07
0.0008
0.0046
NO
NO
Lognormal
Normal
YES
NO
NO
NO
MW204
DCE12C
TCE
NO
NO
100%
100%
NO
YES
S
S
1.09
0.57
0.0889
0.0504
NO
NO
Normal
Normal
NO
NO
NO
NO
MW205
DCE12C
TCE
NO
NO
100%
100%
NO
NO
NT
NT
1.13
0.54
0.0091
0.0108
NO
NO
Lognormal
Normal
YES
NO
NO
NO
MW206
DCE12C
TCE
NO
NO
78%
100%
NO
YES
NT
NT
0.60
0.52
0.0014
0.0094
NO
NO
Normal
Normal
YES
NO
NO
NO
MW207
DCE12C
NO
100%
NO
D
0.55
0.0010
NO
Normal
YES
NO
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 2
-------
MAROS Individual Well Summary Report
Project: Lockwood User Name: MV
Location: OU1 State: Montana
coc
TCE
Priority
COC for
Well?
NO
Detection
Frequency
100%
Recent
Sample
Above Goal?
YES
MK
Trend
D
cov
0.48
95% UCL
0.0159
Outlier
NO
Distribution
Assumption
Normal
Attained Cleanup?
Normal
NO
Lognormal
NO
MW208
DCE12C
TCE
NO
NO
0%
22%
NO
NO
ND
NT
0.00
1.91
0.0003
0.0020
NO
YES
No distribution
No distribution
YES
NO
YES
NO
MW209
DCE12C
TCE
NO
NO
0%
0%
NO
NO
ND
ND
0.00
0.00
0.0003
0.0003
NO
NO
Normal
Normal
NO
NO
NO
NO
MW214
DCE12C
TCE
NO
NO
29%
100%
NO
NO
S
D
2.24
0.57
0.0004
0.0057
NO
NO
No distribution
Normal
YES
NO
YES
NO
MW216
DCE12C
TCE
MW217
DCE12C
TCE
NO
NO
NO
NO
56%
100%
86%
100%
NO
NO
NO
YES
D
D
D
D
0.97
0.21
0.57
0.28
0.0004
0.0038
0.0012
0.0142
NO
NO
NO
NO
Normal
Normal
Normal
Normal
YES
YES
YES
NO
YES
YES
NO
NO
MW218
DCE12C
TCE
NO
NO
0%
0%
NO
NO
ND
ND
0.00
0.00
0.0003
0.0003
NO
NO
Normal
Normal
NO
NO
NO
NO
MW219
DCE12C
TCE
NO
NO
100%
38%
NO
NO
S
NT
0.28
1.91
0.0017
0.0053
NO
YES
Normal
No distribution
YES
NO
NO
NO
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 2 of 2
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood User Name: MV
Location: OU1 State: Montana
Well: MW207 Time Period: 4/25/2003 to 5/4/2012
Well Type: T Consolidation Period: No Time Consolidation
COC: TRICHLOROETHYLENE (TCE) Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
<^' xปc^ <ฃ'
1 op n? .
. 1 RF rt9 .
O) 1 AC no .
' 1 9F 09 .
o
~ 1 OF 09 -
TO
*- Q OF n? *
01
o *
OA OF m
n nF+nn
Mann Kendall S Statistic:
-17
Confidence in Trend:
99.5%
Coefficient of Variation:
0.51
Mann Kendall
Concentration Trend: (See
Note)
D
Data Table:
Well Effective Number of Number of
Well Type Date Constituent Result (mg/L) Flag Samples Detects
MW207 T 4/25/2003 TRICHLOROETHYLEN 1.7E-02 2 2
MW207 T 10/24/2003 TRICHLOROETHYLEN 1.9E-02 2 2
MW207 T 4/23/2004 TRICHLOROETHYLEN 1.3E-02 2 2
MW207 T 4/6/2006 TRICHLOROETHYLEN 8.1E-03 2 2
MW207 T 10/8/2009 TRICHLOROETHYLEN 6.3E-03 2 2
MW207 T 4/15/2010 TRICHLOROETHYLEN 6.9E-03 2 2
MW207 T 5/4/2012 TRICHLOROETHYLEN 5.2E-03 2 2
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
Well: MW208 Time Period: 4/25/2003 to 5/4/2012
Well Type: T Consolidation Period: No Time Consolidation
COC: TRICHLOROETHYLENE (TCE) Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
<ฃ' xป.cK s^
^j< O ^*^ ^*^ O ^*^ ^
1 nnnnn
'Si 1 nnF m
o
f3 1 nnF n9 .
'c
Ol
o
c
.9 1 nnF m .
1 nnF n4
*
Mann Kendall S Statistic:
6
Confidence in Trend:
76.4%
Coefficient of Variation:
1.77
Mann Kendall
Concentration Trend: (See
Note)
NT
Data Table:
Well Effective Number of Number of
Well Type Date Constituent Result (mg/L) Flag Samples Detects
MW208 T 4/25/2003 TRICHLOROETHYLEN 2.5E-04 ND 2 0
MW208 T 10/24/2003 TRICHLOROETHYLEN 2.5E-04 ND 2 0
MW208 T 4/23/2004 TRICHLOROETHYLEN 2.5E-04 ND 2 0
MW208 T 4/6/2006 TRICHLOROETHYLEN 2.5E-04 ND 2 0
MW208 T 10/8/2009 TRICHLOROETHYLEN 2.5E-04 ND 2 0
MW208 T 4/15/2010 TRICHLOROETHYLEN 2.5E-04 ND 2 0
MW208 T 5/4/2012 TRICHLOROETHYLEN 3.8E-03 6 4
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 2
-------
MAROS Mann-Kendall Statistics Summary
Project: Lockwood User Name: MV
Location: OU1 State: Montana
Well:
Well Type:
COC:
1 8E-02 H
1 cc n? -
j- 1 4E-02
E 1 2E-02
5 1 OF n? -
ฃ5 ft nF m .
'c
01 c np nt .
c
o 4 QE-03
2 OE-03
MW217 Time Period: 4/25/2003 to 5/4/2012
T Consolidation Period: No Time Consolidation
TRICHLOROETHYLENE (TCE) Duplicate Consolidation: Median
Consolidation Type: Average
ND Values: 1/2 Detection Limit
J Flag Values: Actual Value
Date
<^' xปc^ <ฃ'
-------
MAROS Zeroth Moment Analysis
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
Change in Dissolved Mass Over Time
COC: TRICHLOROETHYLENE (TCE)
1.8E+00
1.6&-00 -
in
ra
1.2E+00
1.0E+00
8.0E-01
6.0E-01
4.0E-01
2.0E-01 -
Date
Porosity: 0.25
Saturated Thickness:
Uniform: 20ft
Mann-Kendall S Statistic:
-17
Confidence in Trend:
99.5%
Coefficient of Variation:
0.34
Zeroth Moment Trend:
D
Data Table:
Effective Date
4/25/2003
10/24/2003
4/23/2004
4/6/2006
10/8/2009
4/15/2010
5/4/2012
Constituent
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
TRICHLOROETHYLENE (TCE)
Estimated Mass (Kg)
1.4E+00
1.7E+00
1.6E+00
1.1E+00
9.5E-01
7.8E-01
7.0E-01
Number of Wells
17
17
17
15
14
14
13
Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT); Not Applicable
(N/A) - Due to insufficient Data (< 4 sampling events); ND = Non-detect. Moments are not calculated for sample events with less
than 6 wells.
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 1
-------
MAROS Percent of Mass by Well
Project: Lockwood
Location: OU1
User Name: MV
State: Montana
TRICHLOROETHYLENE (TCE) 5/4/2012 [fb
en
DU
in
JU
1 n
1U
i i
Well
MW012
MW108
MW109
MW200
MW201
MW202
MW204
MW205
MW206
MW207
MW208
MW209
MW214
MW216
n
H n n rn ^
**x^ ^v^ ^x^ '"'X^ **x^ '"'X^ '"'X^ '"'X^ '"'X^ **x^ '"'X^ '"'X^ '"'X^ '"'X^
^ ^^ ^^ ^^ ^^ ^"ป ^^ ^^ ^^ ^^ ^"ป ^^ ^^ ^^
Area(ftZ) Mass(mg) Percent of Mass Percent of Area
6,385.80 21.23 0.50 0.32
77,681.29 13.59 0.32 3.89
120,906.33 21.16 0.50 6.06
39,780.50 2,053.67 48.68 1.99
5,224.56 758.87 17.99 0.26
12,009.56 0.53 0.01 0.60
5,124.44 17.34 0.41 0.26
6,360.51 5.51 0.13 0.32
119,262.25 181.58 4.30 5.98
255,650.96 232.64 5.51 12.81
294,617.24 196.78 4.66 14.76
39,980.62 7.00 0.17 2.00
305,541.69 74.86 1.77 15.31
137,792.31 72.34 1.71 6.90
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 1 of 2
-------
MAROS Percent of Mass by Well
Project: Lockwood
Location: OU1
Well
MW217
MW218
MW219
User Name: MV
State: Montana
Area (ft2)
412,048.05
107,471.19
49,956.96
1,995,794.3
Mass (mg)
540.81
18.81
2.19
4,218.9
Percent of Mass
12.82
0.45
0.05
100
Percent of Area
20.65
5.38
2.50
100
rfb
A
MAROS Version 3.0
Release 352, September 2012
Thursday, November 14, 2013
Page 2 of 2
------- |