744 Heartland Trail (53717-1934)PO Box 8923 (53708-8923)Madison, WlTelephone (608)831-4444Fax (608)831-3334

EPA Region 6 Records Ctr.

3014M

Workplan forMonitored Natural AttenuationEngineering Demonstration

Revision 1

Lemberger Landfill andLemberger Transport and Recycling SiteTown of Franklin, Wisconsin

April 2006

Prepared for

Lemberger Site Remediation Group

Jamnes WedekindSfenior Project Hydrogeologist

CA-Lo

Eric Gredell, P.E.Project Manager

RMT^^^^mm^m •>

RMT, Inc. I Lemberger Site Remediation GroupFinal - Revision 1/•\WPMSN\P/T\00-Q3454\46\R00034 5448-OflJ.DOC

S 2006 RMT. Inc.All R!$Ms Refen'eii

Table of Contents1. Introduction 1

1.1 Background 11.2 Purpose and Scope 3

2. Overview of Monitored Natural Attenuation Engineering Demonstration Project 4

2.1 Project Objectives 42.2 Key Components of the Project 42.3 Project Duration 52.4 Community Outreach Plan 72.5 Other Site Investigations and Activities 7

3. Protocol for Evaluating Natural Attenuation 8

3.1 USEPA's Protocol 83.2 Lines of Evidence 93.3 Opportunities and Challenges of the Lemberger Site 10

4. Project Details 13

4.1 Monitoring Well Network 134.2 Assessing VOC Source Zone Effects 144.3 Groundwater Monitoring Program 16

4.3.1 Natural Attenuation Parameters 164.3.2 Baseline and Background Conditions 204.3.3 Sample Collection Methods and Equipment 214.3.4 Scope of Demonstration Monitoring Program 224.3.5 Analytical Procedures and Schedule 24

4.4 Data Quality Assurance and Quality Control 254.5 Lemberger Landfill Operations and General Site Maintenance 254.6 Maintenance of the Existing Pump-and-Treat System 254.7 WPDES Requirements 26

RMT, Inc. I Lemberger Site Remediation Group i

/.\wpMSN\p(T\oo-a3454\46\ROoa34s*46-oo3DOC 4/12/06 Final - Revision I April 2006

4.8 Contingency Provisions 264.8.1 Increased Sampling Frequency for Residential Wells 264.8.2 Increased Sampling Frequency for Sentinel Wells 264.8.3 Quick Turnaround Time for Residential and Sentinel Well Samples 274.8.4 Prompt Review and Reporting of Residential and Sentinel Well

Sample Results 274.8.5 Maintenance of Pump-and-Treat System in "Ready-to-Operate" Condition 274.8.6 Interim Progress Reports and Data Transmittals 27

5. Data Evaluation, Reporting, and Post-Project Status of Pump-and-Treat System 28

5.1 Interim Progress Reporting 285.1.1 Data Transmittals 285.1.2 Semiannual Status Reports 28

5.2 Overall Project Evaluation Report 295.2.1 Data Evaluation Methods 295.2.2 Report Contents 29

5.3 Annual O&M Progress Reports 305.4 Pump-and-Treat System Status 30

6. References 31

List of Tables

Table 1

Table 2

Table 3

Table 4

Table 5

Table 6

Table 7

Monitored Natural Attenuation Parameters, Analytical Methods, andReporting LimitsCurrently Approved Groundwater Monitoring Program - Well GroupDesignationsCurrently Approved Groundwater Monitoring Program - GroundwaterSampling FrequencyGroundwater Monitoring Program for MNA Demonstration Project -Proposed Sampling Schedule (Project Years 1 and 2)Water Sample Containers, Preservatives, and Holding Times for MonitoredNatural Attenuation ParametersProposed Monitoring Program for Groundwater Treatment SystemDischarge to the Branch River During Quarterly Functionality TestsElements of a Performance Monitoring Report for Monitored NaturalAttenuation (Excerpt from [USEPA, 2004])

RMT, Inc. I Lemberger Site Remediation GroupI:\WPMSN\PIT\00-03454\f6\R000345446-003 DOC 4/12/06

11

Final - Revision 1 April 2006

List of Figures

Figure 1 Site Plan

List of Appendices

Appendix A Low-Flow Sampling MethodsAppendix B Manufacturer's Information for Low-Flow Purging/Sampling Pump

RMT, Inc. I Lemberger Site Remediation Group iii/ \wpMSN\p/T\oMU<54\4«\Roaw45«6-oa3.DOc 4/12/06 Final - Revision 1 April 2006

Section 1Introduction

1.1 BackgroundThe groundwater extraction and treatment (pump-and-treat) system selected by the UnitedStates Environmental Protection Agency (USEPA) in the 1991 Record of Decision forremediation of groundwater at the Lemberger site began operation on 17 March 1997, and hasremained in operation since that time. Initial evaluations of the groundwater remediationeffectiveness of the pump-and-treat system performed in 1998 through 2000 determined that theoriginal extraction well system was not capturing the full extent of the volatile organiccompound (VOC) plume. In response to these findings, the groundwater flow modeldeveloped for the site, which has been calibrated to observed site conditions, was used toevaluate optional approaches and to develop recommendations for upgrading the originalextraction well system, to attempt to achieve the VOC plume capture effectiveness envisionedin the 1991 Record of Decision.

The recommended improvements to the extraction well system were approved by USEPA, andthe design and construction of the upgraded system was completed in 2001. Four newextraction wells began operation in December 2001. Unlike the intended purpose of the sixoriginal extraction wells, these four additional extraction wells were installed at locations thatwere intended to intercept and extract VOC-contaminated groundwater primarily near theLemberger Transport and Recycling (LTR) landfill site, where VOC sources present in thefractured bedrock beneath the landfill continue to generate a VOC plume in the bedrockaquifer.

After operation of the upgraded extraction well system for 2 years, the monitoring dataindicated limited to no improvement in groundwater quality attributable to operation of thefour additional extraction wells installed in 2001. At the request of the Lemberger SiteRemediation Group (LSRG), RMT, Inc. (RMT), performed a technical assessment of theeffectiveness of the extraction well system in meeting the groundwater remediation objectivesand performance expectations. The data, findings, and conclusions of that technical assessmentwere provided in the report titled "Assessment of Remedial Action Effectiveness, LembergerLandfill and Lemberger Transport and Recycling Sites, Town of Franklin, Wisconsin, RMT, Inc.,June 2004" (the 2004 Report) submitted to USEPA and the Wisconsin Department of NaturalResources (WDNR) in June 2004. Key conclusions of the 2004 Report were that approximately5 percent of the total dissolved VOC mass that originates from VOC sources remaining in the

RMT, Inc. I Lemberger Site Remediation Group 1i \wpMSN\PiT\oo-o34S4\46\RiM0345446-eo3.DOC 4/W06 Final - Revision 3 April 2006

bedrock aquifer beneath the LTR landfill is being captured by the extraction well system; thatapproximately 90 percent of the VOC mass is being degraded by naturally occurring, primarilybiological, processes; and that the remaining 5 percent of the VOC mass originating at theLTR landfill remains in the groundwater at very low VOC concentrations at the downgradienttermination of the far-field plume, where the groundwater discharges to surface water.

On the basis of the 2004 Report, RMT, on behalf of the LSRG, submitted a letter to USEPA andWDNR on 9 February 2005, requesting USEPA's approval to perform a full-scale engineeringdemonstration project of natural attenuation processes for remediation of the VOC plume at thesite. The purpose of the proposed demonstration project is to define, and if practical, toquantify, the nature and effectiveness of the natural attenuation processes occurring at the site.The 9 February request letter also indicated that if the findings and conclusions of the projectdemonstrate the sufficiency and protectiveness of natural attenuation processes, the LSRGwould then request a formal change of the groundwater remedial action from the current use ofpump-and-treat technology, to the use of monitored natural attenuation (MNA) as theappropriate long-term remedial alternative for the site.

In a 26 April 2005 letter to the LSRG's common counsel, Doug Clark of Foley & Lardner, USEPAconcluded that there is sufficient justification to perform the requested natural attenuationdemonstration project. USEPA also indicated that a workplan for the demonstration projectshould be prepared and submitted to USEPA and WDNR for review. A Workplan forMonitored Natural Attenuation Engineering Demonstration Project (the original Workplan)was prepared and submitted to USEPA and WDNR by RMT, on behalf of the LSRG, in August2005. Review comments on the original Workplan were provided in a letter from WDNR toDoug Clark of Foley & Lardner dated 31 October 2005, and in a letter from USEPA to DougClark dated 1 December 2005. Responses to these review comments on the original Workplanwere sent to USEPA and WDNR by RMT, on behalf of the LSRG, with a letter dated10 February 2006. This Revision 1 of the Workplan has been prepared to address the agencies'review comments on the original Workplan, as clarified in the responses to the commentssubmitted by RMT on 10 February 2006, and to address additional comments provided in aletter from USEPA to Doug Clark dated 23 March 2006.

In addition to the Revision 1 Workplan, USEPA has required the submittal of an addendum tothe currently approved Quality Assurance Project Plan (QAPP), for review and approval byUSEPA. The QAPP Addendum is to address the quality control and quality assurance detailsassociated with implementing the MNA demonstration project. A QAPP Addendum has beenprepared and is being submitted to the agencies concurrently with this Revision 1 Workplan.

RMT, Inc. I Lemberger Site Remediation Group 2i.\wpMSN\p;T\oo-o3454\46\RoooM5«6-oQ3Doc 4/U/06 Final - Revision 1 April 2006

1.2 Purpose and ScopeThe purpose of this workplan (Revision 1) is to provide details for implementation of thenatural attenuation demonstration project and evaluation of the project results. The scope ofthis workplan includes an overview of the objectives and key components of the demonstrationproject; a summary of USEPA's recommended protocol for evaluating natural attenuation atremediation sites; implementation details, with emphasis on the proposed groundwatermonitoring program to provide the data needed to meet the project objectives; and a descriptionof the methods that will be used for evaluating and reporting the project results.

RMT, Inc. I Lemberger Site Remediation GroupI \WPMSN\PIT\00-03454\46\ROO0315446-OO3 DOC 4/12/06 Final - Revision 1 April 2006

Section 2Overview of Monitored

Natural AttenuationEngineering Demonstration Project

2.1 Project ObjectivesThe primary objectives of the MNA demonstration project at the Lemberger site are as follows:

• To determine whether existing natural attenuation processes will maintain the currentacceptable level of protectiveness of human health and the environment at the site

• To confirm that the existing pump-and-treat system provides only limited effectiveness incapturing the VOC plume

• To perform a full-scale site demonstration to identify the chemical, biological, and physicalprocesses that are providing the natural attenuation of VOCs in the groundwater plume

• To determine the relative effectiveness of the natural attenuation processes over the extentof the contaminated groundwater areas

• To obtain data to evaluate natural attenuation at the site consistent with current guidancedocuments prepared by USEPA and WDNR, as well as with the large volume of technicalliterature available on this subject

• To gather the information necessary to provide the technical basis to support a change ofthe groundwater remedial action from the current use of pump-and-treat technology, to theuse of monitored natural attenuation, as appropriate

2.2 Key Components of the ProjectThe demonstration project will include the following key components or features, which aredescribed in further detail in the following sections of the workplan:

• Shutting down the existing groundwater extraction wells and treatment system for theduration of the project, and maintaining the system in stand-by or ready-to-operatecondition throughout the project

• Sampling monitoring wells for the primary groundwater contaminants (VOCs, metals, andSVOCs), per the currently approved monitoring program, with increased samplingfrequency for certain wells and groundwater contaminants

RMT, Inc. I Lemberger Site Remediation Group 4

/:\wi>MSN\PiT\oo-n3454\46\Ro<xa45446-oo3DOC 4/12/06 Final - Revision 1 April 2006

• Sampling monitoring wells for site-specific "MNA parameters," as identified in USEPA andWDNR guidance documents

• Establishing baseline conditions for groundwater quality and groundwater flow prior tothe start of the demonstration project, including the MNA parameters

• Increasing the sampling frequency of Group II residential wells to quarterly for the firstyear of the project, and to semiannually during the second year

• Increasing the sampling frequency for all eight sentinel monitoring wells to quarterlythroughout the project

• Providing 1-week laboratory turnaround time for groundwater samples from all residentialwells and sentinel monitoring wells

• Providing expedited notifications and data rransmittals to USEPA and WDNR if there areany validated detections of VOCs in any residential wells, or statistically significantincreases of any VOCs in any sentinel monitoring wells

• Providing semiannual status reports and a final project evaluation report to USEPA andWDNR

2.3 Project DurationThe proposed duration of the fieldwork phase of the demonstration project is 24 months. Thefieldwork phase of the project would start on the day that the pump-and-treat system isshutdown, and would end on the same date 24 months later, at which time the final evaluationphase of the project would begin.

The extensive groundwater monitoring program over the past 9 years of operation of the pump-and-treat system has shown that seasonal variability in groundwater recharge causes small butimportant shifts in both contaminant concentrations and groundwater flow patterns at severalmonitoring wells across the site. The groundwater flow system is expected to reach near-equilibrium conditions under naturally occurring influences (i.e., nonstressed conditions)within a few days after shutdown of the pump-and-treat system and startup of thedemonstration project. Therefore, the seasonal effects on groundwater quality and flow undernatural conditions are expected to be observable soon after startup of the demonstration project.A duration of 24 months is proposed for the demonstration project to provide data forverification of the seasonal effects and other naturally occurring processes on both groundwaterquality and flow, without the influence of groundwater extraction.

Advective mass transport, dispersion, sorption, biodegradation, and diffusion are the primaryprocesses governing the movement of dissolved VOCs throughout the groundwater plume.The calibrated groundwater flow model indicates that the average groundwater flow velocities

RMT, Inc. I Lemberger Site Remediation Group 5i\wpMSN\PiT\oo-o}4S4\4t\Rooo34544(,-oo3DOC 4/12/06 Final - Revision I April 2006

in the bedrock aquifer are approximately 1 to 2 feet per day over most of the area, but increaseto approximately 4 feet per day near the Branch River. Small-scale heterogeneities are evidentin the aquifer, and groundwater velocities will be lower than the aforementioned averagevelocities in the rock matrix or higher in fractures. However, these zones of lower and highergroundwater velocities are not believed to have a substantial effect on mass transport, based onthe calibrated model, measured heads, and observed contaminant concentrations.

Although the groundwater model indicates that biodegradation is significantly attenuating theVOC plume, the very conservative assumption was made in preparing this workplan that noprocesses other than advection and dispersion affect the mass transport of contaminants in thegroundwater (e.g., no contaminant retardation or loss due to adsorption, volatilization,diffusion, or biodegradation). On the basis of that conservative assumption, the contaminantsthat were present in the bedrock aquifer at the immediate northern edge of the LTR landfill atthe start of the demonstration project would be expected to migrate laterally approximately1,000 feet from the landfill perimeter within the 24-month project duration. The area within1,000 feet downgradient (north) of the northern perimeter of the LTR landfill (see site map onFigure 1) would encompass the following monitoring and residential wells: RM-7S, RM-7D,RM-7XD, RM-209D, RM-303D, RM-8D, GR-25, GR-26, and one new monitoring well (RM-213D)located between the LTR and the LL landfills, which was constructed in September 2005 duringthe LTR site bedrock investigation. Given that there are small-scale fractures present withhigher groundwater velocity, it is possible that some contaminants could migrate farther withina 24-month period, encompassing an estimated zone of up to 2,000 feet downgradient of thenorthern perimeter of the LTR landfill. Additional monitoring wells and residential wellswithin this zone include the following: RM-211D, RM-3I, RM-3D, RM-208S, RM-208I, RM-208D,RM-302S, GR-27, GR-60R, and a new monitoring well located near the southern perimeter of theLL site (RM-214D), which was installed in September 2005.

Monitoring of groundwater downgradient of the far-field extraction wells will also beconducted, and will include monitoring wells and residential wells in an approximate 2,000-footzone through which the groundwater is expected to flow within a 24-month period. Thefollowing monitoring wells are located within 2,000 feet downgradient of extraction wellEW-7D: RM-208S, RM-208I, RM-208D, RM-207S, RM-206S, RM-301S, RM-5S, RM-5I, RM-5D,RM-103S, and RM-103D. The following additional monitoring wells are located within2,000 feet downgradient of extraction well EW-2D: RM-212I and RM-212D. The followingmonitoring wells and residential wells are located within 2,000 feet downgradient of extractionwells EW-4I, EW-4D, and EW-3D: RM-203I, RM-203D, GR-62, GR-8, and GR-9.

In summary, the potential effects of migration of contaminants past the inactive extraction wellsduring the 24-month demonstration period will be monitored by approximately three dozen

RMT, Inc. I Lemberger Site Remediation Group 6

/ \wPMSN\PiT\oo-o3454\46\Roao45446-oo3Doc 4/72/w Final - Revision 1 April 2006

monitoring wells and residential wells that are located within a 2,000-foot zone downgradientof the extraction wells. The large number of monitoring wells and residential wells locatedwithin a 24-month time-of-travel zone of the extraction wells will provide substantial capabilityto detect and quantify changes that might occur due to the shutdown of the extraction wells.Sampling and analysis of the contaminant concentrations in this extensive downgradientnetwork (as well as numerous additional monitoring wells that are farther from the extractionwells) will allow for comparison to historical trends of contaminant concentrations in themonitoring wells and residential wells, which will allow for identification of significant changesin concentrations, if any, as a result of the extraction system shutdown.

2.4 Community Outreach PlanOn 28 March 2006, USEPA sent letters to 23 property owners and current residents near the site,whose residential wells are currently sampled as part of the groundwater monitoring program,informing them of USEPA's approval of the upcoming MNA demonstration project. Inaddition, USEPA will prepare an Explanation of Significant Differences (ESD) that describes thepurpose, objectives, and selected details for performing the MNA demonstration project, andwill make the ESD available for public review in the information repositories for the Lembergersite that are maintained in the local community.

2.5 Other Site Investigations and ActivitiesIn addition to the MNA demonstration project, the LSRG has proceeded with other initiativesthat are intended to complement the objectives of the demonstration project. One of thoseinitiatives is a bedrock investigation, i.e., a fieldwork drilling and testing program that wasperformed in the summer of 2005, to investigate the characteristics of the fractured bedrock inthe vicinity of the LTR landfill, following a workplan approved by USEPA and WDNR. Thedata that have been developed from this investigation will support the objectives of the MNAdemonstration project by substantiating the conclusions of the groundwater plume modelingpresented in the 2004 Report regarding the bedrock aquifer, by verifying the geologic andhydrogeologic conditions in the area between the LTR and LL sites. In addition, thedrilling/testing program included the installation of two new monitoring wells (RM-213D andRM-214D) in the area between the landfills, which will provide valuable information on theVOC plume response and natural attenuation effectiveness, as determined from groundwatersampling of the new wells prior to and throughout the MNA demonstration project.

RMT, Inc. I Lemberger Site Remediation Group 7

i:\wpMSN\PiT\oo-o345i\46\Rono345446-oo3DOC tiuio6 Final - Revision 1 April 2006

Section 3Protocol for Evaluating

Natural Attenuation

3.1 USEPA's ProtocolUSEPA has defined the process and technical protocol for the use and demonstration of MNAat remediation sites, and for evaluation of the processes responsible for natural attenuation andtheir expected effectiveness in remediating impacted groundwater resources to achieve site-specific standards (USEPA, 1998) (USEPA, 1999) (USEPA, 2004). Several states, includingWisconsin (WDNR, 2003), have developed their own guidance on characterizing andmonitoring sites where MNA is being considered as part of an overall remediation approach.These state guidance documents, including the WDNR's guidance, generally conform toUSEPA's guidance and protocols. USEPA's Technical Protocol for Evaluating NaturalAttenuation of Chlorinated Solvents in Ground Water (USEPA, 1998) defines the key steps forevaluating natural attenuation, as listed below. Several of these steps have already beencompleted for the Lemberger site.

Step 1: Develop a preliminary conceptual model of contaminant sources and behavior at the site.

Step 2: Apply a detailed screening process (defined in the guidance) to assess the potential for

natural attenuation.

Step 3: If the screening process suggests that natural attenuation is potentially appropriate,perform additional site characterization to further evaluate natural attenuation.

Step 4: Refine the conceptual model based on site data, and make pre-modeling calculationsof contaminant behavior.

Step 5: Simulate natural attenuation effects using a solute fate-and-transport model.

Step 6: Complete a receptor exposure pathways analysis.

Step 7: Evaluate the need for supplemental source control measures.

Step 8: Prepare a long-term monitoring plan.

Step 9: Present the findings of the natural attenuation evaluation.

RMT, Inc. I Lemberger Site Remediation Croup 8/ :\wpMSN\PiT\oo-03454\46\R<xx>}45446-oo3.DOC i/u/06 Final - Re vision 1 April 2006

USEPA guidance documents (USEPA, 2004) also suggest the following representativetechniques for demonstrating the effectiveness of MNA, with respect to the remedial objectivesidentified for a site:

1. Demonstrate that natural attenuation is occurring according to expectations.

2. Detect changes in environmental conditions (e.g., hydrogeologic, geochemical,microbiological, or other changes) that may reduce the efficacy of the natural attenuationprocesses.

3. Identify any potentially toxic and/or mobile transformation products.

4. Verify that the plume(s) is not expanding downgradient, laterally, or vertically.

5. Verify no unacceptable impact to downgradient receptors.

6. Detect new releases of contaminants to the environment that could impact the effectivenessof the natural attenuation remedy.

7. Demonstrate the efficacy of institutional controls that were put in place to protect potentialreceptors.

8. Verify attainment of remediation objectives.

The proposed MNA demonstration project described in this workplan generally follows thesteps in the MNA demonstration protocol noted above, and will provide the data needed foruse of USEPA's suggested MNA demonstration techniques as listed above.

3.2 Lines of EvidenceUSEPA has identified (USEPA, 1999) the following three lines of evidence that can be used toestimate natural attenuation of chlorinated VOCs:

1. Historical groundwater and/or soil chemistry data that demonstrate a clear and meaningfultrend of decreasing contaminant mass and/or concentration over time at appropriatemonitoring or sampling points

2. Hydrogeologic and geochemical data that can be used to demonstrate indirectly [originalemphasis] the type(s) of natural attenuation processes active at the site, and the rate atwhich such processes will reduce contaminant concentrations to required levels

3. Data from field or microcosm studies (conducted in or with actual contaminated sitemedia) which directly [original emphasis] demonstrate the occurrence of a particularnatural attenuation process at the site and its ability to degrade the contaminants of concern(typically used to demonstrate biological degradation processes only)

RMT, Inc. I Lemberger Site Remediation Group 9i•\wpMSN\PiT\oo-tB454\46\Rooo34S446-oo3DOC 4iuio6 Final - Revision 1 April 2006

USEPA provides the following guidance on expectations for demonstrating these lines ofevidence:

"Unless EPA or the overseeing regulatory authority determines that historicaldata (#1 above) are of sufficient quality and duration to support a decision touse MNA, data characterizing the nature and rates of natural attenuationprocesses at the site (#2 above) should be provided. Where the latter are alsoinadequate or inconclusive, data from microcosm studies (#3 above) may alsobe necessary." (USEPA, 1999)

The MNA demonstration project described in this workplan is designed to provide the datanecessary to evaluate MNA according to the initial two lines of evidence defined by USEPA.Sampling and testing to follow the third line of evidence (laboratory microbiological ormicrocosm testing) is not expected to yield worthwhile or conclusive results regarding theattenuation processes or rates occurring at this site, primarily due to the severe difficultiesassociated with attempting to apply such techniques to groundwater contamination in fracturedrock conditions.

3.3 Opportunities and Challenges of the Lemberger SiteSeveral of the steps in USEPA's natural attenuation evaluation protocol, as listed above, havebeen completed for the Lemberger site. The site provides several unique opportunities forcompleting the remaining steps in evaluating the suitability of MNA as an appropriateremediation approach, compared with the conditions and circumstances at most other siteswhere MNA has been evaluated. Most importantly, the conditions at the Lemberger site arestable and fully protective of human health and the environment, as shown from the results ofextensive monitoring of site conditions for over 9 years.

The groundwater flow model developed for the site, which is calibrated to observed siteconditions, indicates that the groundwater quality that has been monitored for the last 9 yearshas resulted primarily from the effects of natural attenuation processes, with very limitedinfluence from operation of the groundwater extraction well system (RMT, 2004). Therefore,the results of natural attenuation have, in effect, already been observed and demonstrated forseveral years. Extensive measures have also been completed to control the remainingcontaminant sources, through completion of the landfill closure construction requirements forboth the LTR and the LL sites. Such fortuitous conditions for formalizing the remaining steps inthe protocol for evaluating natural attenuation are present at few other sites.

As included with the project objectives listed in Subsection 2.1, the primary tasks remaining todemonstrate that MNA is an appropriate approach for groundwater remediation are to confirm

RMT, Inc. I Lemberger Site Remediation Group 10; \wpMSN\prnoo-o3454\46\Rooo345446-oo3DOC 4/12/06 Final - Revision 1 April 2006

that the groundwater model accurately predicts the VOC plume response, and that the site willcontinue to be protective of human health and the environment, in the absence of groundwaterpumping. Secondary objectives of the demonstration project include the collection of additionaltypes of groundwater data to obtain a better understanding of the natural processes that areaffecting the observed groundwater quality across the site, to confirm that the conditionsnecessary for natural attenuation to continue are present at the site, as required by USEPA'sprotocol.

However, the unique conditions at the Lemberger site are also expected to present challenges inapplying several of USEPA's recommended methods for performing quantitative technicalassessments using the additional diagnostic data that will be obtained from the MNAdemonstration project. MNA guidance documents of both USEPA (USEPA, 1998)(USEPA, 2004) and WDNR (WDNR, 2003) acknowledge the difficulties in attempting to applythe conventional quantification techniques for MNA evaluation to sites with complex fracturedbedrock conditions, such as the Lemberger site. Several of the analytical techniques forattempting to quantify parameters such as rates of degradation or loss-of-mass for specificVOCs require relatively accurate identification of the VOC plume "centerline" or "core," withdata on VOC concentrations at several locations and depths for a substantial distance along theplume centerline, originating at the VOC source or "head-end" of the plume, as well as acrossseveral "transects" perpendicular to the plume centerline. The complex and highlyheterogeneous groundwater flow patterns in the fractured bedrock at the Lemberger site wouldmake it highly difficult, if not impossible, to characterize the groundwater quality sufficiently toallow worthwhile application of such analysis techniques. The characteristics of the VOCsource zones in the bedrock beneath the LTR landfill, i.e., sources present over an area ofseveral acres, would further complicate attempts to apply the plume "centerline and transects"analytical methods.

The low VOC concentrations (generally within federal drinking water standards) over most ofthe plume extent also make it challenging to calculate accurate degradation rate constants toquantify natural attenuation effects. Contaminant concentrations should vary betweenmonitoring locations by a minimum of one order of magnitude to produce valid calculations ofdegradation rates (USEPA, 1998). At the LTR landfill, concentrations of TCE and relatedcompounds decrease by an order of magnitude within approximately 1,000 feet downgradientof the landfill perimeter, potentially allowing for reasonable estimates of degradation rates to becalculated. Farther downgradient, concentrations decrease more slowly, to about the limits ofdetection. The existing groundwater contaminant transport model has been calibrated to theobserved distribution of TCE concentrations, and despite the low concentrations, the model hasincorporated degradation rate constants mat allow it to simulate the observed patterns ofconcentrations reasonably well. Additional points of calibration will be available from the data

RMT, Inc. I Lemberger Site Remediation Group 11i \wpMSN\PiT\oo-ta454\46\Rmo34S446-oo3.DOC 4/12/06 Final - Revision \ April 2006

provided by the two new monitoring wells installed in September 2005. Analysis of theconcentration data with the existing contaminant transport model will refine estimates of thedegradation rate constants. These methods are consistent with recommended proceduresoutlined in USEPA's guidance document for evaluating natural attenuation of chlorinatedsolvents in groundwater (USEPA, 1999).

Although challenges in applying quantitative MNA evaluation techniques, such as those notedabove, are expected to be encountered during the evaluation phase at the conclusion of thedemonstration project, the types of data needed to attempt such evaluations will be collected, asdescribed in this workplan.

RMT, Inc. I Lemberger Site Remediation Group 12i:\wpMSN\PiT\oo-o3454\4t\Roon)f5446-oo3DOC 4mio6 Final - Revision 3 April 2006

Section 4Project Details

4.1 Monitoring Well NetworkThe existing monitoring well network at the Lemberger site has been designed to ensure thatthe protectiveness as well as the effectiveness of the ground water remedial action can beadequately monitored. The locations, design, depths, and construction of the 51 monitoringwells that comprise the existing well network have been accepted by both USEPA and WDNRwith the agencies' approval of the original Operation & Maintenance (O&M) Plan in 1996, andwith approval of monitoring wells that have been added to the network since that time. Theexisting monitoring well network provides the data needed to meet all of the currently definedgroundwater monitoring objectives, and the well network will also provide the data needed tomeet the objectives of the upcoming MNA engineering demonstration project. As noted above,as part of concurrent investigations of the bedrock characteristics near the LTR landfill, two newbedrock monitoring wells (RM-213D and RM-214D) installed in 2005 will also assist inevaluating the natural attenuation processes that are occurring in the vicinity of the LTR and LLsites. The locations of those wells are illustrated on Figure 1.

All of the site monitoring wells will be sampled for specific "MNA parameters" during thedemonstration project, as described further in Subsection 4.3. Monitoring wells have beeninstalled over the years to monitor the nature and extent of groundwater contamination. Themonitoring network includes wells that define the limits of contamination. Though no wells arelocated within the known source area directly beneath the LTR Landfill, the existing wellnetwork includes wells located in the core and extending to the fringes of the VOC plume, andbeyond the plume boundaries. These wells are adequately positioned for monitoring the MNAdemonstration as well. The following list indicates portions of the plume that are monitored byvarious wells:

• Upgradient: RM-11D, RM-102D, RM-205I, and RM-205D.

• Plume core: RM-303D, RM-209D, RM-7S, RM-7D, RM-7XD, EW-1D, EW-6D, EW-8D, andEW-9D.

• Plume fringes: RM-8B, RM304D, RM-305D, RM-208S, RM-208I, RM-208D, RM-206S,RM-207S, RM-3I, RM-3D, RM-5S, RM-5I, RM-5D, MW-15R, MW-14R, RM-302S, RM-103S,RM-103I, RM-103D, RM-204I, RM-204D, RM-2I, RM-2D, RM-210I, RM-210D, RM-301I,RM-301D, RM-301S, RM-302S, RM-101I, and RM-101D,

RMT, Inc. I Lemberger Site Remediation Group 13i \wpMSN\Pir\oo-n3454\46\Ronn34&446-oo3 DOC tm/ot Final - Revision 1 April 2006

• Outside the plume (sidegradient and downgradient): RM-201I, RM-201D, RM-212I,RM-212D, RM-202I, RM-202D, RM-1I, RM-1D, RM-10D, RM-4S, and RM-4D.

4.2 Assessing VOC Source Zone EffectsThe current conceptual model of the LTR site (RMT, 2004) includes the widespread presence ofpotentially significant quantities of VOC source mass within the water-saturated fracturedbedrock beneath the LTR landfill. However, the concentrations of TCE, PCE, and other"parent" VOCs observed in monitoring wells along the northern (downgradient) edge of theLTR landfill are orders of magnitude below levels that are considered to be indicative of theproximity of VOC source mass in the form of dense nonaqueous-phase liquid (DNAPL). Theobserved concentrations are also consistent with the current conceptual model, which includesthe diffusion of the DNAPL source mass into the bulk rock matrix within a relatively short timeafter the source materials were originally disposed in the landfill.

Current conceptual models of DNAPL behavior as well as direct observations at manychlorinated solvent sites indicate that concentrations of a dissolved VOC in groundwater as lowas 1% of the aqueous solubility of the pure-phase VOC infer the presence of a DNAPL source(Pankow, 1996). Dissolved VOC concentrations in the immediate vicinity of a DNAPL sourcewould be expected to be significantly higher, often in the range of 10% to 15% of the pure-phasesolubility, with concentrations approaching the pure-phase solubility observed at some sites.The generally accepted "field" solubility of pure-phase TCE is 1,100 mg/L- Therefore, dissolvedTCE concentrations in the range of 11,000 Hg/L (1% of 1,100 mg/L) or higher would be expectedto be present at some locations in and near the VOC source zones beneath the LTR landfill, ifthere were DNAPL pools or lenses present in substantial quantities. If however, the DNAPLhas migrated into fractures, groundwater may contact the DNAPL only around the edges of theDNAPL, yielding relatively lower concentrations of TCE (and related compounds) than if theDNAPL were present in pores throughout the permeable zone. In addition, since much of theTCE has diffused into the matrix of the bedrock, as is expected to have occurred fairly rapidly,the slow back-diffusion out of the matrix will continue for many years and will yield muchlower concentrations of TCE than the concentrations that might be expected if pools of DNAPLwere present (Pankow and Cherry, 1996; Parker et al., 2004). This conceptual model of thesource zone, with DNAPL migrating into the fractures soon after disposal, diffusing (wholly orin part) into the matrix, and then slowly back-diffusing out of the matrix, would be consistentwith relatively low observed concentrations that occur immediately downgradient of the sourcezones at the LTR landfill. The highest historical TCE concentration observed in any of themonitoring wells along the northern edge of the LTR landfill is only 130 (Jg/L in well RM-303D.The calibrated groundwater flow model for the site uses an estimated average "source term"dissolved TCE concentration of 150 ug/L to represent the groundwater quality within theestimated VOC source zones beneath the LTR landfill, which is consistent with the lower

RMT, Inc. I Lemberger Site Remediation Group 14i \\vpMSN\PiT\oo-ro454\46\Knoo345446-oo3.DOC 4/12/06 Final - Revision 1 April 2006

concentrations expected with back-diffusion of VOCs from the matrix. The bedrockinvestigation that was performed at the site included collection of samples of the solid rockmatrix from borehole locations within the VOC plume near the LTR landfill. The rock sampleswere analyzed for the key VOCs observed in groundwater near the LTR, to attempt to confirmand quantify the diffusion of the VOCs into the rock matrix, as described in the currentconceptual model of the VOC source zones beneath the LTR landfill.

There is a substantial body of evidence that biodegradah'on of chlorinated solvent constituentsis occurring downgradient of the source area. Elevated concentrations of 1,2-DCE (the initialbiological breakdown product of TCE) and both 1,1-DCA and chloroethane (sequentialbiological breakdown products of 1,1,1-TCA) are consistently observed in all of the monitoringand extraction wells located along the northern perimeter of the LTR landfill. This is a strongindication that biological reductive dechlorination of PCE and TCE is occurring. Theoccurrence of active biodegradation of the VOC source mass beneath the LTR is consistent withthe current conceptual model of the conditions at the LTR (RMT, 2004), given the known natureof the wastes disposed in the landfill. It is likely that a variety of biodegradable organiccompounds that originated from the wastes disposed during active landfilling operationsmigrated downward into the fractured bedrock with, or independently of, the organic solvents.If present, those organic compounds would provide the food (electron donor) materialnecessary to support the activity of microorganisms that are known to degrade the parentsolvent VOCs such as PCE and TCE, resulting in the breakdown products that have beenconsistently observed for several years in groundwater immediately downgradient of the LTRlandfill. The consistent presence of significant concentrations of 1,1-DCE in all of themonitoring wells along the northern LTR perimeter also indicates that 1,1,1-TCA is beingattenuated by naturally occurring abiotic processes (dehydrohalogenation).

As noted in Subsection 2.1, objectives of the MNA demonstration project include identificationof the specific chemical, physical, and biological processes that are attenuating the VOC plumethat emerges from beneath the LTR landfill. A detailed understanding of the degradationprocesses occurring directly within the widespread VOC source zones in the saturated fracturedbedrock beneath the LTR landfill, or within the landfill waste, or within the unsaturatedgranular deposits and bedrock beneath the landfill, is extremely difficult to obtain, is notnecessary to meet the project objectives, and is not an essential component of USEPA or WDNRprotocols for performing MNA evaluations. Monitoring of groundwater quality forcontaminants of concern as well as for the MNA parameters both upgradient of the LTR (wellsRM-102D, RM-11D, RM-205I, and RM-205D) and immediately downgradient of the LTR (wellsRM-303D, RM-209D, RM-7D, and RM-7XD) will provide the data needed to identify theattenuation processes at work within the VOC source zones. Evaluation of the plume responseimmediately sidegradient of the VOC source zones under natural groundwater flow conditions

RMT, Inc. I Lemberger Site Remediation Group 15l:\WPMSN\PIT\00-03454\46\R000345446-003DOC 4IU/U6 Final - Revision 1 April 2006

will also be well-defined during the project by the data obtained from the monitoring wells onthe eastern (RM-304D) and western (RM-306D, RM-307D, and RM-308D) perimeter of the LTR.

The collection of samples of waste materials from the LTR landfill for analysis of organic carboncontent, microbial activity, or physical characteristics such as teachability would be appropriateand useful for the MNA demonstration only if there was a known, or likely, transport processoccurring within the landfill that results in the continued leaching of significant amounts ofdissolved substances (contaminants of concern or other innocuous substances) from the landfillwaste, and migration of those substances downward into the fractured bedrock into the zoneswhere VOC source mass is diffused into the rock matrix. There is presently no known or likelytransport process of this type occurring at the LTR. The design and construction of the landfillcap at the LTR, and the drum removal action that preceded the cap construction, were intendedto prevent, to the greatest practical extent, this type of transport process from occurring.USEPA has determined that the objectives of the cap construction and drum removal have beenmet, as indicated by their approval of the "no further action" Record of Decision for OperableUnit 2 in 1994, by their approval of the cap constructed in 1996, and by statements in the firstFive-Year Review Report: "The landfill cover systems have been effective in isolating wastesand preventing infiltration of rainwater into landfill wastes which could cause contaminantmigration to ground water." This finding by USEPA is consistent with the observedgroundwater VOC concentrations since the LTR landfill cap was constructed in 1996, with thecurrent conceptual model of the VOC source conditions at the LTR landfill, and with thecalibrated groundwater flow model for the site. Information that would be obtained fromfurther characterization and analysis of the LTR wastes is not necessary to properly evaluate thefeasibility, protectiveness, or effectiveness of MNA as an alternative to the existing pump-and-treat system, for remediation of the groundwater VOC plume.

4.3 Groundwater Monitoring Program

4.3.1 Natural Attenuation Parameters

Evaluation of the occurrence and effectiveness of various natural attenuation processesrequires characterization of the groundwater for certain parameters that are notanalyzed as part of the currently approved monitoring program for the Lemberger site.A list of the commonly defined "MNA parameters" associated with degradation ofchlorinated VOCs that will be analyzed for groundwater samples collected during thedemonstration project is included in Table 1. The MNA parameters are also listedbelow, with a brief explanation of the purpose or use of each parameter (USEPA, 1998).

RMT, Inc. I Lemberger Site Remediation Group 16/ \wpMSN\p;T\oo-03454\46\R<»0345«6-oa3DOC 4/12/06 Final - Revision 1 April 2006

Carbon Dioxide

The presence of carbon dioxide indicates that microbial processes are active.However, carbon dioxide is difficult to use as a monitoring parameter since it isproduced under both aerobic and anaerobic conditions.

Dissolved Oxygen

Dissolved oxygen (DO) is the most thermodynamically favored electronacceptor used by microorganisms for the degradation of organic carbon.Anaerobic bacteria responsible for reductive dechlorination of TCE and otherVOCs cannot function at DO concentrations greater than approximately0.5 mg/L.

Nitrate

After dissolved oxygen has been depleted in the groundwater, nitrate may beused as a preferential electron acceptor for anaerobic biodegradation of VOCsand other organic carbon via denirrification.

Nitrite

As an intermediate in the denitrification process described above, depletion ofnitrite can also indicate anaerobic dehalogenation.

Sulfate

After dissolved oxygen and nitrate have been depleted, sulfate may also beused as an electron acceptor for anaerobic degradation. This process is termed"sulfate reduction" and results in the production of sulfide. Concentrations ofsulfate greater than 20 mg/L may cause competitive exclusion of reductivedechlorination of TCE.

Iron (ID

In some cases, iron (HI) is used as an electron acceptor during anaerobicbiodegradation of organic carbon. During this process, iron (III) is reduced toiron (II), which may remain soluble in groundwater. Increases in iron (II)concentrations may thus be used as an indicator of anaerobic degradation ofVOCs.

RMT, Inc. I Lcmberger Site Remediation Group 17

i:\wpMSN\pfr\oo-03454\46\Roon345446-oo3 DOC I/mot Final - Revision 1 April 2006

AlkalinityThere is a positive correlation between locations of microbial activity andincreased alkalinity in groundwater. Increases in alkalinity result from theproduction of carbon dioxide during use of VOCs and other organic carbon formicrobial metabolism. The carbon dioxide dissolves in groundwater, whichmay result in measurable increases in bicarbonate alkalinity at typicalgroundwater pH levels, compared with the groundwater alkalinity insubsurface zones where biodegradation of VOCs is not occurring.

MethaneMethane production (methanogenesis) generally occurs after oxygen, nitrate,and sulfate have been depleted from the groundwater. The presence ofmethane in groundwater is indicative of the activity of methanogenic bacteria,and the presence of strongly reducing conditions.

Oxidation-Reduction Potential (ORP)The ORP of groundwater is an indicator of the relative tendency of the water toaccept or transfer electrons. Oxidation-reduction reactions in groundwatercontaining organic compounds are usually biologically mediated; therefore, thegroundwater ORP depends upon and influences rates of biodegradarion.Knowledge of the groundwater ORP is also important because some biologicalprocesses occur only within a specific range of ORP conditions.

pH, Temperature, and ConductivityThe pH of groundwater has an effect on the presence and activity of microbialpopulations, especially for methanogens. Microorganisms capable ofdegrading TCE and other chlorinated VOCs generally prefer pH values rangingfrom 6 to 8.

Groundwater temperature directly affects the solubility of dissolved gases andother geochemical species. The temperature also affects the metabolic activityof bacteria.

The electrical conductivity of groundwater is directly related to theconcentration of ions in solution. Conductivity increases as ion concentrationincreases, and the ionic strength is affected by microbial activity.

RMT, Inc. I Lemberger Site Remediation Group 18i:\wpMSN\PiT\oo-oa4S4\46\xooo345446-oca DOC 4/12/06 Final - Revision 1 April 2006

Chloride

During biodegradation of dissolved chlorinated hydrocarbons such as TCE,and abiotic chemical reactions involving other chlorinated VOCs, chloride isreleased into the groundwater. This may result in measurable increases inchloride concentration in the groundwater in locations where degradation ofhigh concentrations of chlorinated VOCs is occurring, relative to backgroundconcentrations.

Ethane and Ethene

If present in the groundwater, dissolved ethane and ethene gases wouldindicate that the biodegradation of TCE and other chlorinated VOCs hadprogressed all the way to these innocuous end products. Conversely, however,the absence of detectable concentrations of these gases would not necessarilyindicate that biodegradation of TCE was not occurring, due to the highvolatility and biodegradability of these compounds.

Total Dissolved Solids

Total dissolved solids is a general water quality parameter that assists indetermining that a sample is of a similar source as other waters (especially inenvironments with conduit flow) and establishes the quality of the sample.

Total Organic Carbon (TOC) and Total Inorganic Carbon (TIC)

TOC concentrations are used to "classify" the contaminant plume and todetermine whether anaerobic reductive dechlorination would be possible in theabsence of anthropogenic sources of dissolved carbon. Changes in TICconcentration in groundwater have been found to be a good measure ofdissolved carbon dioxide, which is an end product of microbial degradation oforganic compounds, and is therefore an indicator of the biological activitywithin an aquifer.

Manganese

Similar to iron (III), naturally occurring manganese (IV) in the aquifer matrixmaterial may be chemically reduced and become dissolved in the groundwaterdue to anaerobic biodegradation of VOCs.

As described in the USEPA guidance documents (USEPA, 1998)(USEPA, 2004), theMNA parameters listed above will be used to assist in evaluating, primarily in aqualitative manner, whether specific naturally occurring biological and chemical

RMT, Inc. I Lemberger Site Remediation Group 19

/:\wpMSN\PiT\oo-o3454\46\Rooo3t5446-oo3Doc 4/12/06 Final - Revision 1 April 2006

processes that are known to be capable of degradation of chlorinated VOCs areoccurring in the groundwater across the Lemberger site. However, the groundwaterconstituents that will be monitored most closely during the project are the primarychemicals-of-concern at the site, i.e., the VOCs, to evaluate, and potentially quantify, theoccurrence and effectiveness of natural attenuation processes.

4.3.2 Baseline and Background Conditions

Baseline Conditions

Baseline conditions for groundwater flow and chemical characteristics will bemeasured prior to start of the MNA demonstration project. A round ofgroundwater level measurements will be collected from all monitoring wells atthe site within 3 to 4 days prior to shutdown of the extraction well system andstartup of the demonstration project.

A round of groundwater sampling for all MNA parameters (per Table 1) fromall site monitoring wells will be performed no more than 6 weeks prior to thestart of the demonstration project. The baseline conditions for the regularlymonitored constituents in monitoring wells (VOCs, SVOCs, metals,pesticides/PCBs, cyanide, and standard indicator parameters), and inresidential wells (VOCs), have been thoroughly established from monitoringover the last 9 years. A comprehensive round of groundwater sampling fromall site monitoring wells, extraction wells, and residential wells was performedin April 2005, in support of the Five-Year Review Report currently beingprepared by the agencies. The recent laboratory results and field-measuredparameters from the April 2005 groundwater sampling round, supplementedby the prior 8 years of monitoring data, adequately define the baselinegroundwater quality conditions needed to support the MNA demonstrationproject objectives.

Background Conditions

Background conditions for groundwater quality will be determined fromevaluation of all monitoring data after completion of the project. In the contextof the MNA demonstration project, background conditions will be consideredto exist at any monitoring wells where no site-related VOCs are detected.Several monitoring wells, in various locations across the site, have historicallyshown no VOC detections for several years. Specifically, wells RM-11D,RM-102D, RM-205I, and RM-205D, have been chosen as background wells forthe MNA demonstration. These wells were chosen because they are adjacent to

RMT, Inc. I Lemberger Site Remediation Group 20

i:\wpMSN\PiT\on-o$454\46\Rotx>345446-oo3DOC 4/12/06 Final - Revision 1 April 2006

the site and hydrologically upgradient, and in addition, they show no evidenceof VOCs and should represent the ambient geochemical environment of thearea. It is expected that these wells will provide data on the naturalbackground groundwater quality, particularly for the MNA parameters, atseveral locations on the periphery of the VOC plume, that will be useful forinterpreting the overall effectiveness of the natural attenuation processes.

4.3.3 Sample Collection Methods and Equipment

Representative groundwater samples for analysis of several of the MNA parameters,especially dissolved oxygen, ORP, and iron (II), cannot be collected using the wellpurging and sampling method specified in the currently approved Operation &Maintenance Plan, i.e., use of a standard bailer. Therefore, the use of low-flow purgingand sampling methods for collection of all monitoring well samples is proposed,including samples for the non-MNA parameters under the currently approvedmonitoring program (VOCs, SVOCs, metals, PCBs, and cyanide). These methods willallow production of accurate results for all groundwater analyses, including the MNAparameters, without compromising the comparability of the MNA demonstrationproject data and the historical groundwater monitoring data.

Sampling procedures will be performed in substantial agreement with the standardoperating procedure (SOP) for low-flow sampling methods included in Appendix A.Redox potential and turbidity will be monitored at the beginning and the end ofpurging, using a turbidity meter and a redox electrode, with a flow-through cell.Temperature, pH, dissolved oxygen, and specific conductivity will be measured duringpurging of the wells prior to sampling. These parameters will also be measured using aWTW Measurement Systems, Inc., MultiLine P3 meter and a flow-through cell. Thisinstrument is capable of utilizing multiple analytical sondes or probes; therefore, theoperation, maintenance, and calibration of the instrument is relatively detailed.Sampling personnel will have the training and experience necessary to properly use theequipment. An equipment manual that addresses items such as calibration will beavailable to the field sampling crew at the time of sampling. After collection ofgroundwater samples for laboratory analysis, field analyses for CO2, ferrous iron, andalkalinity will be performed using Hach field kits or equivalent. SOPs for these methodsare provided with the individual kits from Hach. The usefulness of sampling andanalysis for sulfide was considered. Due to the known presence of significant ferrousiron concentrations in the site groundwater, sulfide is not expected to be found abovedetection limits owing to likely precipitation with ferrous iron. Therefore, sulfide hasbeen omitted from the list of MNA parameters included in Table 1.

RMT, Inc. I Lemberger Site Remediation Group 21i:\wpMSN\PiT\oo-o3in\46\Rooo345Hk-oo3 DOC 4/12/06 Final - Revision I April 2006

Groundwater for purging and sampling will be drawn from the monitoring wells usinga QED™ micropurge bladder pump (or equivalent) that is capable of producing low-flow purging and sampling rates, as described in the manufacturer's information inAppendix B. The pump operates by compressed air that will be supplied from acompressor powered from a portable 12 VDC battery. The pump includes a removablePTFE bladder. One pump bladder, with plastic tubing for the air supply and waterdischarge, will be dedicated to each monitoring well at the site, for reuse each time awell is sampled. The stainless-steel pump housing will be decontaminated by washingwith Alconox soap or equivalent and rinsing with distilled water between wells.Decontamination wastewater will be collected and transferred into the existingcollection tanks for the Lemberger Landfill site "leachate." Following decontaminationof the pump, rinsate blanks will be collected for laboratory analysis at the frequencynoted in the QAPP Addendum for the MNA demonstration project.

4.3.4 Scope of Demonstration Monitoring Program

Groundwater Elevations

Tracking of changes in groundwater flow patterns across the site without thehydraulic influence of the extraction well system operation is an importantcomponent of the project. Groundwater elevations throughout the site areexpected to recover to naturally occurring levels within a few days after shut-down of the extraction well system. To evaluate the short-term response of theaquifer, the groundwater recovery rate will be monitored in each extractionwell and the immediately adjacent monitoring wells, as each extraction well istaken off line. Water levels will be measured at each of the wells listed belowprior to shutting down the pumps. The wells will then be shut downsequentially with water levels collected at approximate 1-minute intervals inthe extraction well for a period of 10 minutes. Water level measurements willalso be collected in the nearby monitoring wells, and then in the extraction well.Water levels will then be taken again 10 minutes later. If water levels appear tohave recovered (stabilized) in any well, water level measurements will cease. Ifwater levels continue to show a demonstrable rise, water level measurementswill continue on an hourly basis until three consecutive measurements arewithin 0.1 ft of the previous measurement, or after 5 hours.

Groundwater recovery rate data will be collected at the following wells:

• Extraction Wells - EW-6D, EW-8D, and EW-9D; Monitoring Wells -RM-303D and RM-209D

RMT, Inc. I Lemberger Site Remediation Group 22

i \wpMSN\PiT\oo-ous4\i6\Rooo345446-txa DOC 4m/o6 Final - Revision 1 April 2006

• Extraction Well - EW-1D; Monitoring Wells - OW-101A, OW101B, RM-7S,RM-7D, RM-7-XD

• Extraction Well - EW-2D; Monitoring Wells - OW-102D, OW-102B, RM-211D

• Extraction Well - EW-7D (there are no appropriate nearby monitoringwells from which to measure water levels)

• Extraction Wells - EW-4D and EW-4I; Monitoring Wells - OW-104A, OW-104B, OW-104C, OW-104D, OW-104E, OW-104F, OW-104G, OW-104H

• Extraction Well - EW-3D; Monitoring Wells - OW-103A and OW-104B

Groundwater level measurements will also be recorded at all site monitoringwells and in the idle extraction wells during each groundwater sampling event,even when an individual sampling round does not include all of the sitemonitoring wells, as discussed below. All water level measurements will becompleted before collection of any groundwater samples during each samplinground, to minimize the effects of time-dependent factors such as barometricpressure fluctuations.

Groundwater Sampling

Groundwater sampling to be performed during the MNA demonstrationproject will incorporate the sampling required under the currently approvedgroundwater monitoring program, and additional sampling included for theMNA demonstration project. The well group designations and the samplingfrequency under the currently approved program are summarized in Tables 2and 3, respectively. The proposed sampling program for the 24-month MNAdemonstration project is summarized in Table 4. As shown in Table 4, theMNA parameters will be analyzed for all monitoring well sampling eventsthroughout the demonstration project. The extraction wells and thegroundwater collection sumps will not be sampled during the project, becausethe water quality in the idle wells and sumps would not be representative ofthe actual groundwater quality in the bedrock or perched aquifers. The typesof sample containers, preservatives, and holding times for the MNA parametersare shown in Table 5.

As shown in Table 4, four additional rounds of sampling from ResidentialGroup II have been included during the 2-year project. Three of thoseadditional rounds will be performed during the first year of the project, so allwells in both Residential Groups I and II will be sampled for VOCs on a

RMT, Inc. I Lemberger Site Remediation Group 23i-\wpMSN\Pir\oo-a34S4\46\ROoo345446-o(o DOC 4/12/06 Final - Revision I April 2006

quarterly basis during the first year. One additional sampling round forResidential Group II is proposed for the second year of the project. In addition,all of the eight monitoring wells designated by USEPA as sentinel wells will besampled for VOCs, at a minimum, on a quarterly basis throughout thedemonstration project, coinciding with the sampling schedule for theresidential wells.

If a fully validated VOC detection occurs in a residential well that has nevershown a VOC detection, the well will be resampled. Any fully validated VOCdetection in a sample from a residential well that has previously had VOCdetections will be resampled if the detection is greater than three standarddeviations above the mean concentration (99% upper confidence interval) fromthat particular well.

At the conclusion of the MNA demonstration project, the groundwatermonitoring program summarized in Table 4 will continue to be performed untileither (a) the pump-and-treat system is turned back on, in which case thecurrently approved (pre-MNA demonstration project) monitoring program willbe followed, or (b) the LSRG and USEPA, in consultation with WDNR, agree toan alternative monitoring program. Low-flow sampling methods used in thedemonstration study will be retained as a standard sampling method formonitoring wells after completion of the demonstration project.

4.3.5 Analytical Procedures and Schedule

The laboratory turnaround time for all groundwater samples from residential wells andthe sentinel monitoring wells will be 7 work days. Standard turnaround time(approximately 3 to 4 weeks) for samples from all other wells will be provided.

Samples collected throughout the MNA demonstration project will be analyzed by theUSEPA-approved laboratory for the Lemberger site, Pace Analytical Services, Inc. Forthe MNA parameters, the laboratory will follow analytical procedures detailed inUSEPA-approved methods and in the laboratory's standard operating procedures(SOPs). Analytical methods for all analyses other than the MNA parameters willconform to the currently approved QAPP. Samples will be analyzed for the constituentsnoted in Table 1. Analytical methods to be used for the MNA parameters, with theexpected reporting limits for each parameter, are also identified in Table 1.

RMT, Inc. I Lemberger Site Remediation Group 24i:\wpMSN\PiT\oo-o3454\46\Rooous446-oo3DOC 4/12/06 Final - Revision 1 April 2006

4.4 Data Quality Assurance and Quality ControlQuality control samples will be collected in accordance with the currently approved QAPP,including one field blank per sampling round, one trip blank per cooler shipment, and oneduplicate sample per every 20 primary samples sent to the laboratory.

4.5 Lemberger Landfill Operations and General Site MaintenanceOperation, maintenance, and monitoring of the existing leachate withdrawal (LW) wells andoff-site disposal of the collected leachate (groundwater inside the slurry wall) from theLemberger Landfill site will continue throughout the MNA demonstration project, or until thetarget groundwater head level has been achieved. Other site tasks will include all of the currentgeneral maintenance, monitoring, and oversight tasks required by the approved O&M Plan,although the extent of the tasks will be somewhat reduced due to the shutdown of theextraction wells and groundwater treatment system. The site operator's responsibilities willalso include performing the expanded groundwater sampling program during the project, andensuring that the pump-and-treat system equipment remains in fully functional conditionthroughout the project, as discussed further in the next subsection.

4.6 Maintenance of the Existing Pump-and-Treat SystemThe startup (Day 1) of the MNA demonstration project will be defined by the shutdown of theexisting groundwater extraction wells, the groundwater collection sumps, and the groundwatertreatment system. These systems will remain shutdown for the duration of the project. Allequipment will remain, and will be maintained, in fully functional condition, i.e., no equipmentcomponents will be dismantled or removed from the facilities or from the site. Themaintenance objective will be to keep all equipment and associated instrumentation, controls,and auxiliary components in "ready-to-operate" condition, so any portion or all of theequipment could be restarted quickly, if necessary, in response to previously definedcontingency plans or other unforeseen factors. Electrical service to all equipment will bemaintained throughout the project.

Soon after initial shutdown of the extraction wells, the groundwater treatment system (airstripping units) will be cleaned. Pipelines will be drained, equipment will be lubricated,temporary insulation and/or covers will be installed, painting will be performed, etc., tofacilitate maintenance during the expected shutdown period. Equipment components will beprepared for extended shutdown according to manufacturers' recommendations.

To ensure that the pump-and-treat system remains functional throughout the project, all systemcomponents will be operated briefly on a quarterly basis, at a minimum. Certain equipmentcomponents (e.g., the air compressor used for wells EW-6D, -8D, and -9D) may be test-run

RMT, Inc. I Lemberger Site Remediation Group 25r\wpMSN\pfT\oo-o3454\46\Rooo345446-oa3.DOC 4/12/06 Final - Revision 1 April 2006

more frequently, if recommended by the manufacturer. For each quarterly test, each extractionwell will be operated for a short rime, to confirm that the well pump functions and that thepumping rate is comparable to pre-shutdown rates. The run-time for each well will be limited,to minimize hydraulic disturbance to the aquifer. The groundwater collection sump pumps willalso be test-run. During each quarterly test of the extraction wells' operation, one or more of thethree air stripping unit trains will be operated to treat the groundwater, as dictated by the totalgroundwater flowrate through the treatment units. Problems or discrepancies that may beobserved during any of the quarterly functionality tests will be promptly communicated to anddiscussed with USEPA and WDNR, to determine an appropriate response action.

4.7 WPDES RequirementsAs required by the Wisconsin Pollutant Discharge Elimination System (WPDES) SubstantiveRequirements Document issued for the treated groundwater discharge to the Branch River,written notification regarding the planned shutdown of the groundwater treatment system andcessation of the continuous discharge to the river is to be provided to WDNR. The proposedmonitoring program for the brief discharge of treated groundwater to the river during thequarterly functionality tests of the pump-and-treat system (as described in Subsection 4.6) issummarized in Table 6.

4.8 Contingency ProvisionsThe approach for the MNA demonstration project includes several provisions to addresspotential contingencies that may be encountered during the project. These provisions havebeen designed to ensure that site conditions remain fully protective of human health and theenvironment throughout the project, and that appropriate and timely data and information onthe project and site status are provided to USEPA and WDNR to allow the agencies to properlymonitor the project and to take corrective actions if necessary. These contingency provisions aresummarized below.

4.8.1 Increased Sampling Frequency for Residential Wells

Water supply wells in Residential Group I will be sampled on a quarterly basis forVOCs throughout the project. Residential Group II wells will be sampled on a quarterlybasis for VOCs during the initial year of the project, and will be sampled semiannuallyfor VOCs during the second year of the project.

4.8.2 Increased Sampling Frequency for Sentinel Wells

All 8 of the monitoring wells designated as sentinel wells by USEPA will be sampled ona quarterly basis throughout the project, on the same schedule with the residential wells.

RMT, Inc. I Lemberger Site Remediation Group 264/12/06 Final - Revision 1 April 2006

4.8.3 Quick Turnaround Time for Residential and Sentinel Well Samples

Laboratory turnaround time of 7 work days will be provided for all residential andsentinel well samples.

4.8.4 Prompt Review and Reporting of Residential and Sentinel Well SampleResults

RMT will review the laboratory reports for residential and sentinel wells upon receipt.If any detectable VOC concentrations are reported in a residential well sample, the datawill be validated and the results will be communicated via e-mail to USEPA and WDNRas soon as practicable. RMT will then contact USEPA and WDNR project managers bytelephone to discuss the laboratory results and appropriate response actions. The VOCresults from each round of groundwater sampling of the sentinel wells will be validatedand evaluated by comparing these data to pre-shutdown historical data for each well. A95% confidence interval statistical method (Gilbert, 1987) will be used to characterize thepre-shutdown data. The results will also be added to the graphs of the historicalconcentration vs. time plots for various VOCs, as the results are received. If the analysisshows that the most recent VOC sampling results from any sentinel well are outside(greater than) the 95 percent confidence limit of the mean pre-shutdown value for anindividual VOC, RMT will promptly provide the results to USEPA and WDNR viae-mail, and will contact the USEPA and WDNR project managers by telephone todiscuss the results and appropriate response actions.

4.8.5 Maintenance of Pump-and-Treat System in "Ready-to-Operate"Condition

As described in Subsection 4.6, all components of the groundwater extraction well andtreatment system (the pump-and-treat system) will be maintained to facilitate rapid re-start of the system at any time, if USEPA determines that such action is necessary.

4.8.6 Interim Progress Reports and Data Transmittals

As described in Subsection 5.1, technical observations of the MNA demonstrationperformance will be provided to the agencies semiannually during the project. Inaddition, data transmittals, similar in format and content to the transmittals that arecurrently provided, will be provided on a quarterly basis for the monitoring well sampleresults. Validated laboratory results for residential well samples will be sent to USEPAwithin approximately 6 weeks after receipt of the laboratory reports.

RMT, Inc. I Lemberger Site Remediation Group 27i \wpMSN\PiT\oo-Q3i54\46\RoxH45446-oo3 DOC 4/12/06 Final - Revision I April 2006

Section 5Data Evaluation, Reporting, and Post-

Project Status of Pump-and-Treat System

5.1 Interim Progress Reporting

5.1.1 Data Transmittals

Quarterly Data Transmittals containing the validated laboratory results and qualitycontrol (QC) descriptions for all groundwater samples collected during each calendarquarter will continue to be provided to USEPA and WDNR, following the currentformat for these transmittals.

Copies of laboratory reports and summary tables of the validated results for residentialwell samples will continue to be provided to USEPA and WDNR for each samplinground identified in Table 4. If expedited reporting of specific residential well sampleresults is provided due to any VOC detections, as described in Subsection 4.8, copies ofthe laboratory report(s) will also be transmitted to the agencies when the e-mailnotifications of the detections are sent. Similarly, if expedited reporting of specificsentinel well sample results is provided due to a statistically significant increase inconcentration of a contaminant(s), copies of the laboratory report(s) will also betransmitted to the agencies when the e-mail notifications of the detections are sent.

5.1.2 Semiannual Status Reports

Three semiannual evaluation reports will be provided to USEPA and WDNR for theinitial 18 months of the project. Each report will include summaries of the cumulativemonitoring data collected during the demonstration project, with summaries of the pre-demonstration project data, to assist in evaluating effects of the pump-and-treat shut-down on groundwater quality. The reports will also include initial interpretations of theeffects of natural attenuation processes, from a review of the MNA parameter data.Data interpretation may include plots of changes in groundwater chemicalcharacteristics in terms of molar fractions of the parent VOC compounds to the daughtercompounds, if such analysis methods are found to be practical and informative. Figuresshowing groundwater flow gradient contours and isoconcenrration plots for selectedkey parameters of interest will be included. Evaluations of the data using the

RMT, Inc. I Lemberger Site Remediation Group 28/:\wpMSN\p;T\oo-o3454V46\Rooa345«6-oa3 DOC 4/12/os Final - Revision 1 April 2006

groundwater flow model or calculations of contaminant degradation rates, etc., will notbe performed for the semiannual reports.

In each semiannual report, the VOC concentrations in the monitoring wells closest to theBranch River (RM-212, RM-202, RM-2, and RM-203) will be evaluated to determine if themost recent VOC results from any of these wells are outside (greater than) the 95 percentconfidence limit of the mean pre-shutdown value for an individual VOC. If a VOCconcentration is found to be increasing, using this evaluation method, the status reportwill present the findings and the supporting data, and will include a recommendationregarding whether sampling of the Branch River water and/or river sediment should beadded to the monitoring program for the remainder of the demonstration project.

5.2 Overall Project Evaluation Report

5.2.1 Data Evaluation Methods

At the conclusion of the MNA demonstration project, the monitoring data will beevaluated using methods as described in USEPA's Technical Protocol for EvaluatingNatural Attenuation of Chlorinated Solvents in Ground Water (USEPA, 1998), and asdescribed in other technical references and regulatory guidance documents (USEPA,2002) (WDNR, 2003). As described in Subsection 3.3, the quantitative methods foranalysis of the effects of natural attenuation processes will be applied to thedemonstration project data to the extent feasible, given the physical complexities andlimitations of the Lemberger site.

5.2.2 Report Contents

At the conclusion of the field-phase of the MNA demonstration project, a report will beprepared that includes summaries of the monitoring and measurement data from theproject; technical evaluations of the data supported by tables, figures, graphs, statisticalassessments, and groundwater modeling results (if appropriate, and after discussionwith the agencies regarding the need to revise the current computer model); andconclusions regarding the effectiveness and protectiveness of MNA as the long-termremedial action for groundwater at the site. The report contents will generally includethe "elements of a performance monitoring report" as defined in USEPA's guidancedocument "Performance Monitoring of MNA Remedies for VOCs in Ground Water"(USEPA, 2004). These suggested report elements are shown in an excerpt from theguidance document provided in Table 7. Although the report contents will generallyfollow the guidance document suggestions, the report will be organized and will containinformation specific to the particular conditions and circumstances at the Lemberger

RMT, Inc. I Lemberger Site Remediation Croup 29i:\wpMSN\PiT-oo-o34S4\4t\Rouo45446-oo3.DOC 4m/06 Final - Revision 1 April 2006

site. The report will be submitted within 120 days after the receipt of the final laboratoryanalytical results.

5.3 Annual O&M Progress ReportsDuring the MNA demonstration project, O&M Progress Reports will continue to be issued onan annual basis, per the current reporting cycle, covering each 12-month period from Julythrough June of the following year. Because comprehensive groundwater monitoring data forthe overall site will be reported to USEPA and WDNR on a semiannual basis during the MNAdemonstration project, this information will not be repeated in the O&M Progress Reportsissued during the demonstration project. The contents of the O&M Progress Reports willinclude all of the information on the site O&M status that has been reported in previous reports,except groundwater monitoring data will be omitted. After completion of the MNAdemonstration project, the contents of subsequent annual O&M Progress Reports will return tothe pre-demonstration project format.

5.4 Pump-and-Treat System StatusIf the MNA demonstration project continues for the full planned duration of the project, thepump-and-treat system will remain shutdown during the data evaluation and reportpreparation phase following completion of the project, until a final decision regarding arevision of the groundwater remedial action requirements for the site is made by USEPA.

RMT, Inc. I Lemberger Site Remediation Croup 30i:\wpMSN\PiT\oo-o34S4\46\Rooto45446-oo3DOC 4/12/06 Final - Revision 1 April 2006

Section 6References

Gilbert, R. 1987. Statistical methods for environmental pollution monitoring. New York:Van Nostrand Reinhold Co.

Pankow, James F. and John A. Cherry. 1996. Dense chlorinated solvents and otherDNAPLs in groundwater. Portland, Oregon: Waterloo Press. 1996.

Parker, B., J. Cherry, and S. Chapman. 2004. Field study of TCE diffusion profiles belowDNAPL to assess aquitard integrity. /. Contaminant Hydrology. Vol. 74, pp. 197-230.

RMT. 2004. Assessment of remedial action effectiveness, Lemberger Landfill andLemberger Transport and Recycling Sites, Town of Franklin, Wisconsin. RMT, Inc.June 2004.

USEPA. 1998. Technical protocol for evaluating natural attenuation of chlorinated solventsin groundwater. United States Environmental Protection Agency. Office of Researchand Development. EPA/600/R-98/128. September 1998.

USEPA. 1999. Use of monitored natural attenuation at Superfund, RCRA CorrectiveAction, and underground storage tank sites. United States Environmental ProtectionAgency. Office of Solid Waste and Emergency Response, Directive No. 9200.4-17P.21 April 1999.

USEPA. 2002. Calculation and use of first-order rate constants for monitored naturalattenuation studies. National Risk Management Research Laboratory. Ground WaterIssue. EPA/540/S-02/500. November 2002.

USEPA. 2004. Performance monitoring of MNA remedies for VOCs in ground water.United States Environmental Protection Agency. National Risk Management ResearchLaboratory, Office of Research and Development. EPA/600/R-04/027. April 2004.

WDNR. 2003. Understanding chlorinated hydrocarbon behavior in groundwater:investigation, assessment, and limitations of monitored natural attenuation. WisconsinDepartment of Natural Resources. RR-699. April 2003.

RMT, Inc. I Lemberger Site Remediation Group 31i:\wpMSN\PiT\oo-o34S4\46\Rooo34S446-uo3.DOC 4/U/06 Final - Revision 1 April 2006

Table 1Monitored Natural Attenuation Parameters, Analytical Methods, and Reporting Limits

GROUNDWATERPARAMETER

Alkalinity (total)

Carbon dioxide

Dissolved oxygen

Iron (II)

Oxidation-reduction potential

PH

Specificconductivity

Temperature

Turbidity

Alkalinity (total)

Chloride

Ethane

Ethene

Manganese

Methane

Nitrate

Nitrite

PH

Sulfate

Temperature

Total inorganiccarbon

FIELD ORLABORATORY

Field

Field

Field

Field

Field

Field

Field

Field

Field

Laboratory

Laboratory

Laboratory

Laboratory

Laboratory

Laboratory

Laboratory

Laboratory

Laboratory

Laboratory

Laboratory

Laboratory

METHOD

Hach kit

Hachkit

360.1")

8146 WAH

Standardmethods'7'

150.K')

120.10)

-

SM 2130B

2320BP)

300.00

M8015BP)

M8015BP)

6020P)

M8015BP)

300.00

300.0

150.10

300.00

-

415.20

EQUIPMENT

Hach kit

Hack kit

Probe

Hach kit

Electrode

Electrode

Electricalconductivity

meter

Probe

Meter

Per method

Per method

Per method

Per method

Per method

Per method

Per method

Per method

Electrode

Per method

Thermometer

Per method

LIMIT OFDETECTION

CLOD)

10 mg/L asCaCCb«>

1.25 mg/L

0.1 mg/L<5>

0.1 mg/L

N/A

N/A

N/A

N/A

NA

3.7 mg/L

0.88 mg/L

1.6(ag/L

1.4 mg/L

0.4pg/L

2ug/L

0.078 mg/L

0.46 mg/L

N/A

0.83 mg/L

N/A

0.80 mg/L

LIMIT OFQUANTITATION

<LOQ)

N/A

25 mg/L

N/A

N/A

N/A

0.1 standardunits

1 (^mho/cm

0.1 °C

1NTU

10 mg/L

5.0 mg/L

lOfjg/L

10 mg/L

2.0ng/L

10 Mg/L

0.40 mg/L

0.10 mg/L

0.1 standardunits

4.0 mg/L

0.1°C

2.0 mg/L

RMT, Inc. I Lemberger Site Remediation Groupl:\WPMSN\PIT\0043454\46\R00034544t-003.DOC 4/12/06 Final - Revision 1 April 2006

Table 1 (continued)Monitored Natural Attenuation Parameters, Analytical Methods, and Reporting Limits

GROUNDWATERPARAMETER

Total organiccarbon

FIELD ORLABORATORY

Laboratory

METHOD

415.2(D

EQUIPMENT

Per method

LIMIT OFDETECTION

(LOD)

0.80 mg/L

LIMIT OFQUANTTTATION

<LOQ)

2.0 mg/L

Notes:(') USEPA 600/4-79-020; Methods for Chemical Analysis of Water and Waste.<3> Standard Methods for the Examination of Water and Wastewater, 19th Edition, 1995.<3> SW-846, Test Methods for Evaluating Solid Waste, Physical and Chemical Methods, USEPA, 3"> Edition, 1986.<«> Based on Hach Method 8203 digital titration.<s> Based on typical field meter and dissolved oxygen probe with a resolution of 0.01 mg/L and used under normal field operating

conditions.

N/A - Not applicable.

RMT, Inc. I Lemberger Site Remediation Group

l:\WPMSN\Prr\00-034S4\46\R000345446-003.DOC 4/12/06 Final - Revision 1 April 2006

Table 2Currently Approved Groundwater Monitoring Program - Well Group Designations

Lemberger Site

IA

RM-7DRM-7XDRM-8D

RM-209DRM-303DRM-306DRM-307D

RM-213D<«>RM-214DW

IB

EW-1DEW-3DEW-4IEW-4DEW-6DEW-7DEW-8DEW-9D

RM-203DWRM-210CX')RM-212IWRM-212DO)

HA

RM-2I

RM-3D<3>

RM-5S<3>

RM-5I<3>RM-5DWRM-10DRM-101IRM-101DRM-IOSSWRM-103DP)

RM-204IRM-204D

RM-208CX3)RM-304DRM-305DRM-308D

WW.LSBCT

' "."IB* 'I:.' '-

EW-6SRM-2DO>

RM-203I<W>RM-210IO)

I K ' - \ ; • • • ' • ' " : . • • • ' - . . • : •intA

RM-3I<3>RM-4D

RM-7S<3)RM-11DRM-102DRM-201IRM-201DRM-202IRM-202DRM-206SP)RM-207SP)RM-208SP)RM-208K3)RM-301S<3)RM-302SW

' .' • . '.. HlB • " "••• •

GWC-1GWC-2GWC-3

RM-211DCX3)

• ,/,'-• -iy'; .' :; •'-RM-4S

RM-205IP)

RM-205EK3)

METALSBACKGROUND

:••-"-' vinsa. :>

(2)

RESIDEmULJ":eapa*i:-?<

GR-13GR-26GR-27GR-31GR-41

GR-60R

R^TOBKHAL

GR-8GR-9

GR-10GR-11GR-12GR-14GR-15GR-16GR-17GR-24GR-25GR-30GR-33GR-62GR-63GR-64GR-65

Notes:O Sentinel well.m The previous metals background well (RM-9D) and RM-103I were abandoned during the LTR site bedrock investigation drilling program in summer 2005.(3) Well will be sampled and analyzed quarterly for VOCs and metals with the Group LA of wells, during the 24-month MNA demonstration period.<«) Well constructed in September 2005 during the LTR site bedrock investigation.

Final - Revision 1 April 2006l:\WPMSN\PJT\00-034S4\46\R000345446-003.DOC

Table 3Currently Approved Groundwater Monitoring Program - Groundwater Sampling Frequency

Lemberger Sites

WELL GROUP

IA

IB

IIA

IIB

niAnmIV

Metals Background Well

Residential Group I

Residential Group II

VOOANDMETALS

Quarter

Quarter

Semiannual

Semiannual

Annual

Annual

5 years

-

-

svoo,PEST./PCB*, CN

5 years

Annual

5 years

Annual

5 years

Annual

5 years

-

-

WATER LEVEL

Month

Month

Month

Month

Month

Month

Month

Month

-

--

VOCsONLY

-

-

-

-

-

-

-

-

Quarter

Annual

METALS ONLY

~

-

-

~

-

-

-

Annual

-

--

Final - Revision 1 April 2006l:\WPMSN\PJT\aHO4S4\4t\KUXI34S44t-003.DOC

Table 4Groundwater Monitoring Program for MNA Demonstration Project - Proposed Sampling Schedule (Project Years 1 and 2)

Lemberger Sites

WELLGROUP

IA

IB (Note 1)

EA

HB(Note2)

raA

fflB (Note 2)

IV

MetalsBackgroundWell (Note 3)ResidentialGroup IResidentialCroup n

PROJECT YEAR 1

MONTH NUMBER1 2

V&M(MNA)V&M

(MNA)

(V)

(V)

V

(V)

3 4 5V&M

(MNA)V&M

(MNA)

V&M(MNA)V&M

(MNA)

(V)

V

V

6 7 8V&M

(MNA)V&MS/P/C

(MNA)

(V)

V&M(MNA)V&MS/P/C

(MNA)(V)

(MNA)

V

(V)

9 10 11V&M

(MNA)V&M

(MNA)

V&M(MNA)V&MS/P/C

(MNA)

(V)

V

(V)

12

PROJECT YEAR 2

MONTH NUMBER1 2

V&M(MNA)V&M

(MNA)

(V)

(V)

V

3 4 5V&M

(MNA)V&M

(MNA)

V&M(MNA)V&M

(MNA)

(V)

V

V

6 7 8V&M

(MNA)V&MS/P/C

(MNA)

(V)

V&M(MNA)V&MS/P/C

(MNA)(V)

(MNA)

V

9 10 11V&M

(MNA)V&M

(MNA)

V&M(MNA)V&MS/P/C

(MNA)

(V)

V

(V)

12

Abbreviations:V&M - volatile organic compounds and metals.S/P/C » semivolan'Ie organic compounds, pesticides/PCBs, and cyanide.

MNA - monitored natural attenuation parameters.V = volatile organic compounds only.

Notes:1. Sampling of extraction wells is not included; however, groundwater elevation will be measured at each extraction well during each monitoring round.2. Groundwater collection (GWC) sumps, including EW-6S, will not be sampled.3. This well (RM-9D) was abandoned during the bedrock investigation drilling program in summer 2005.4. Abbreviations shown in bold font in parentheses are analyses added to the currently approved monitoring program, for the MNA demonstration project. Abbreviations in nonbold font without

parentheses are analyses required by the currently approved monitoring program.5. The two monitoring wells that were constructed in September 2005 as part of the LTR bedrock investigation (RM-213D and RM-214D) will be sampled with Well Group LA.

Final - Revision 1 April 2006l:\WPMSN\PJT\00-034S4\46\RIXKa4S446-003.DOC

Table 5Water Sample Containers, Preservatives, and Holding Times for Monitored Natural Attenuation Parameters

PARAMETER

Alkalinity, sulfate

Methane, ethane, and ethene

Nitrate+Nitrite Nitrogen

Temperature, EH, pH, specificconductivity, dissolved oxygen,ferrous iron, ORP, alkalinity(field)

Manganese

Total organic carbon, totalinorganic carbon

CONTAINER

1 x 250 mL high-densitypolyethylene bottle<3>

3 x 40 mL VOA vials withTeflon* septum*2'

1 x 250 mL high-densitypolyethylene bottle<3>

1 x 250 mL high-densitypolyethylene bottle<3>

2 x 60 mL glass bottles

MINIMUM SAMPLEVOLUME

120 mL

1 x 40 mL VOA vial

75 mL

50 mL

Bottles must befilled

FIELD PRESERVATIONMETHOD

Cool to 4°C

Cool to 4°C, add HC1 to pH< 2; protect from light

Cool to 4°C, add H2SO4 topH<2

Cool to 4°C, add HNCb top H < 2

Cool to 4°C, no headspace,add FLSCu to pH < 2

HOLDING TIME*"

14 days (alkalinity)28 days (sulfate)

7 days if unpreserved;14 days if preserved

(sample should remainon-site less than 24 hours)

28 days

Immediately after samplecollection

6 months

28 days

Notes:'•' Starting from time of sample collection.<2> Collect three extra containers for MS/MSD samples.(3) Collect one extra container for sample spike and duplicate analyses.

Final - Revision 1 April 2006l:\WPMSN\PJT\00-034St\46\W0034S446-003.DOC

Table 6Proposed Monitoring Program for

Groundwater Treatment System Discharge to the Branch RiverDuring Quarterly Functionality Tests

PROPOSED MONITORINGPARAMETERS'"®

Treatment system influent None

Treatment system effluent Flowrate

Discharge duration (minutes)

VOCsW

Metals'3)

Cyanide<3>

pH

TSS

Notes<"> All samples will be grab samples collected just prior to shutdown of the groundwater treatment

system during each quarterly functionality test<2> Monitoring data will be reported using the WDNR's Discharge Monitoring Report format.

Specific analytes will be per the current Substantive WPDES Permit Requirements (last modification1 January 2006), including mercury.

(3)

RMT, Inc. I Lemberger Site Remediation Groupl:\WPMSN\PIT\00-03454\46\R00034544t-003.DOC 4IUI06 Final - Revision 1 April 2006

Table 7Elements of a Performance Monitoring Report for Monitored Natural Attenuation

(Excerpt from [USEPA, 2004])

Elements of a Performance Monitoring Report

Summary of Data Interpretations and Recommendation!Q Brief description of siteQ Remedial goalsQ Narrative summary of new data and their interpretationQ Recommended actions

Background and Site DescriptionThe following Information typically would be discussed or incorporated by reference:Q Site setting, history, characteristicsQ Remedial goalsQ Past and present remedial activities, and any Institutional controlsQ Map and cross-sectional views Illustrating geologic and hydrogeologlc setting of the site. Including controls on

ground-water flow at the regional scale and site scale

Monitoring Network and ScheduleQ List and maps of monitoring locations for each sampled medium and each major hydrogeologlc unitQ Description and construction details for each monitoring pointQ Monitoring schedule specifying monitoring parameters, analytical methods, and sampling frequency for each

monitoring locationQ Data Quality Objectives (DQOs) to be met

Evaluation of New DataQ Detailed discussion of new results and evaluationsQ Data in tables and electronic filesQ Potentiometric surface maps for each hydrostratlgraphic unitQ Hydrographs of ground-water elevations for key wells In each hydrostratigraphic unit and surface-water

monitoring pointsQ Contaminant data posted and contoured on maps for each media and major hydrogeologic unitQ Hydrochemlcal cross sections along and perpendicular to ground-water flow directions depicting contaminants,

monitoring points,and hydrogeologyQ Geochemlcal data posted and contoured on maps for each major hydrogeologlc unitQ Cross sections depicting geochemlcal data, monitoring points, and hydrogeologyQ Comparison of the new data with previous data and established performance criteriaQ Results of statistical comparisonsQ Discussion of trends and the relation of any trends to remedial goalsQ Assessment of measurement variability from analysis of QA/QC dataQ Observed changes In land use

Evaluation of Institutional Controls (ICs)Q Description of ICs that are In place with appropriate verificationQ Evaluation of the effectiveness of ICsQ Discussion of any pending changes in property ownershipQ Observed changes in land or resource uses

MM Conceptual Site Model EvaluationQ Evaluation of the conceptual site model incorporating any new data and data trendsQ Discussion of consistency of previous conceptual site model with new dataQ Suspected sources for continued ground-water contamination (e.g., number, location(s), characteristics of

sources)Q Trends In contaminant and geochemistry valuesQ Discussion of any observed changes in site hydrology (eg., water elevations, ground-water velocities)O Discussion of refinements/modifications to conceptual site modelO Consistency of current data with previous predictionsQ Discussion of changes in land use and potential effects on the conceptual model

Recommendations (as warranted)Q Recommended changes in monitoring locationsQ Recommended changes In monitoring frequenciesQ Recommended changes in sampling methodsQ Recommended changes in analysesQ Discussion of new data in relation to performance criteria previously established to trigger implementation of a

contingency remedyQ Discussion of changes In land use and potential effects on site remedies, and remedy protectiveness for human

and ecological receptors -Q Recommended remedy modifications {e.g., additional source removal actions)Q Recommendations for starting verification monitoring, or terminating performance monitoringQ Rationale for recommended changes

Qc30mC/)

1

x

SDMS US EPA Region V Imagery Insert Form

Some images in this document may be illegible or unavailable in SDMS.

Please see reason(s) indicated below:

Illegible due to bad source documents. Image(s) in SDMS is equivalent to hard copy.

Specify Type of Document(s) / Comments:

Includes ___ COLOR or RESOLUTION variations.

Unless otherwise noted, these pages are available in monochrome. The source document page(s) is

more legible than the images. The original document is available for viewing at the Superfund

Records Center.

Specify Type of Document(s) / Comments:

Confidential Business Information (CBI).

This document contains highly sensitive information. Due to confidentiality, materials with such

information are not available in SDMS. You may contact the EPA Superfund Records Manager if you

wish to view this document.

Specify Type of Document(s) / Comments:

Unscannable Material:

Oversized __x__ or ___ Format.

Due to certain scanning equipment capability limitations, the document page(s) is not available in

SDMS. Specify Type of Document(s) / Comments:

Document is available at the EPA Region 5 Records Center.

Specify Type of Document(s) / Comments:

FIGURE 1 – SITE PLAN

Appendix ALow-Flow Sampling Methods

RMT, Inc. I Lemberger Site Remediation Groupi:\wpMSN\pfnoo-034S4\4f\Ktxxa45t46-oa3.DOC Final - Revision 1 April 2006

Low-Flow Sampling Methods

IntroductionThis appendix summarizes methods that will be used to collect representative groundwatersamples for chemical analysis. Equipment and techniques that will be followed to purge and toobtain samples are discussed in detail. This section includes excerpts from the WisconsinDepartment of Natural Resources Groundwater Sampling Desk Reference, WDNRPUBL-DG-03796 (September 1996), that deal specifically with low-flow sampling methods.

Wells That Do NOT Purge DryThis section applies to wells that take less than -1 hour for the water level in the well torecover (or nearly so) after being purged using high-volume purging methods.

The following purging and sampling procedures will be used for wells that do not purge dry.The first procedure listed will consistently yield the highest level of data quality. The lastprocedure listed may yield a lower level of data quality:

A. Low-flow purging < 1 L/min (0.26 gpm), low-flow sampling < 300 mL/min (0.3 L/minor 0.1 gpm) and the monitoring of indicator parameters for stability in a closed flow-through cell.

To obtain the highest-quality, most representative, and consistent groundwater qualitymeasurements and analytical data, purge the well at an average rate of 1 liter/minute(L/min) or less, sample at an average rate of 300 mL/min (0.3 L/min) or less, and monitorindicator parameters in a closed flow-through cell until they become stable.

Purging and sampling rates should be at or less than the natural flow conditions existingin the aquifer at the well location. This is accomplished by controlling the purgingflowrate to obtain a minimal drawdown rate of the groundwater head level. The waterlevel in the well should be stabilized before the flowrate is decreased to 300 mL/min orless to commence sampling. While maintaining a sampling flowrate of 300 mL/min orless, the water level should be stable or preferably recovering as samples are collected.This minimizes the possibility that stagnant water remaining above the pump may beremoved with the water collected for samples.

Do not reduce the pump's flowrate by using valves. The resulting pressure drop acrossthe valve (also known as an "orifice effect") can alter sensitive samples, usually bydegassing.

RMT, Inc. I Lemberger Site Remediation Group

i \wpMSN\PiT\co-03454\46\Rooo3i54i6-oo3 DOC 1 Final - Revision 1 April 2006

Purge the well until at least three consecutive readings, spaced -2 minutes or -0.5 wellvolumes or more apart, are within the following indicator parameter ranges:

Dissolved oxygen +0.2 mg/L

Specific conductivity +5.0 umhos/cm for values < 1,000 umhos/cm+10.0 umhos/cm for values > 1,000 umhos/cm

pH +0.1 pH units

Temperature 0.1 °C

Turbidity < 5 NTUs (Required if metals samples will not be filtered.Recommended if sorptive compounds or elements arecollected. Optional, but recommended, if other compoundsor elements are collected.)

EH (optional) +30 mV

Stable dissolved oxygen, specific conductivity, and turbidity readings are considered themost reliable parameters for indicating that stagnant water within the well has beenreplaced by groundwater from the aquifer. The + ranges and indicator parameters usedmay be adjusted to reflect site-specific data, geochemistry, and hydrogeologicconditions.

Turbidity stabilization and NTU readings below 5 are required if metals samples willnot be filtered. Low turbidity readings (i.e., < 5 NTUs), when measured using low-flowpumping techniques, should represent colloids and particulates that are mobile ingroundwater under natural flow conditions. Turbidity stabilization should also bemonitored when collecting sorptive, hydrophobic, or high octanol-water partitioncoefficient (Kow) compounds or elements.

On Purge the well until the readings for each indicator parameter listed above varywithin + 10 percent, over three or more consecutive readings spaced ~2 minutes or-0.5 well volumes or more apart.

Collect samples from the pump's discharge line before the water enters the flow-throughcell. Air pockets in the flow-through cell and probes inserted into the flow-through cellcan degrade sample water quality. Either disconnect the sample tubing from the flow-through cell before collecting samples, or connect a "tee" junction with an on/offsampling valve between the well and the flow-through cell to collect samples.

RMT, Inc. I Lemberger Site Remediation Croup

i; \WPMSN \rvr\oo-OM54\46\RoooM5446-oo3 DOC 2 Final - Revision 1 April 2006 £-•

Low-flow purging/sampling may not be necessary or may be impractical under thefollowing circumstances:

A well purges dry before indicator parameters stabilize.

Parameters are not affected by aeration, agitation, or the gain or loss of dissolvedgases (and subsequent changes in sample pH, etc.).

- Data quality objectives for a project do not require the level of accuracy andstringency inherent in low-flow purging/sampling methods.

An alternative purging and sampling technique has been proven to meet the dataquality objectives for the project.

- The procedures are extremely burdensome and time consuming.

B. Purging FOUR well volumes and then sampling with a low-flow pump.

You may use this method when stabilization of the indicator parameters is not achievedin a reasonable amount of time (2 hours). As with the low-flow purging and samplingtechnique, the purging and sampling rates should also be kept low and should notexceed the natural flow conditions of the aquifer, if possible. The sampling flowrateshould be less than the purging flowrate.

Wells That Purge DryThis section applies to wells that take ~1 or more hours to recover (or nearly so) after they havebeen purged dry (or nearly so).

Ideally, wells should be sampled and purged at flowrates at or less than the natural flowconditions in the aquifer at the well location. Drawdown and turbidity during purging andsampling should be minimal; however, for wells that recover slowly, attaining little drawdownand low turbidity may be nearly impossible. Nevertheless, slowly-recovering wells should bepurged and sampled with minimal disturbance to the water and fine particulate matter in andaround the well and to obtain samples with the lowest possible turbidity and degree ofoxygenation.

For slowly-recovering wells that purge dry, bail or pump the well dry, or nearly so, and allow itto recover at least once before collecting samples. If time permits, purge the well a second time.If recovery permits, collect samples from the well within 24 hours of the final purging.

When collecting sensitive samples such as VOCs and metals, the following procedure shouldyield samples with the highest data quality. Purge the well dry, or nearly so, using a very lowpurging rate (< 300 mL/min or 0.1 gpm). Allow the well to recover, or nearly so, at least oncebefore collecting samples. If time permits, purge the well a second time and collect sampleswithin 24 hours. Low-flow pumping should minimize the disturbance of fine particulate matter

RMT, Inc. I Lemberger Site Remediation Group

i\wpMSN\Pir\oo-03454't46\Rooo345446-oo3DOC 3 Final - Revision 1 April 2006 T

in and around the well during purging and sampling, and therefore should minimize sampleturbidity.

Sample CollectionDuring sampling, the primary objectives and considerations include minimizing sampledisturbance, avoiding sample exposure to air and extraneous sources of potentialcontamination, and preserving sample integrity throughout the collection process.

Collect sample parameters in the following order:

1. Volatile organic compounds (VOCs)

2. Non-filtered, non-preserved (e.g., sulfate, chromium VI, mercury, semi- and non-volatiles,pesticides, PCBs)

3. Non-filtered, preserved (e.g., nitrogen series [ammonia, nitrate, nitrite, etc.], phenolics, totalphosphorus, total metals, cyanide, total organic carbon)

4. Filtered, non-preserved (e.g., dissolved chromium VI)

5. Filtered, preserved immediately (e.g., dissolved metals)

6. Miscellaneous parameters

7. Unfiltered samples for in-field water quality measurements (alkalinity, iron [II], carbondioxide)

Collect sulfate samples before sulfuric acid-preserved samples (e.g., nitrogen series). Collectnitrogen series samples before nitric acid-preserved samples (e.g., boron, dissolved metals).This will prevent accidental contamination of a sample with a preservative intended for anothersample (e.g., sulfuric acid preservation contaminating an unpreserved sulfate sample).

Before opening and filling sample containers, check the sampling area for potential sources ofextraneous contamination. Make sure the area around the well is clean and that contaminatedequipment is kept away from the well. Protect the samples from airborne contaminants such asengine exhaust, blowing dust, and organic fumes (e.g., gas cans); sample upwind of thesecontaminants or remove them before sampling. Choose gloves appropriate for thecontaminants that are known or suspected to be present. Use new, clean gloves for each well,or if it is suspected that gloves have become contaminated. Do not attempt to decontaminate orreuse gloves; use disposables.

Do not open sample containers until it is time to fill them. Immediately after filling a samplecontainer, add any required preservative (unless added previously) —filter first, ifrequired—replace the cap, label the container, and place the sample on ice in a cooler.Following these procedures will help minimize sample turbulence, agitation, volatilization,degassing, atmospheric exposure, biodegradation, exposure to extraneous contaminationsources, and heating of samples.

RMT, Inc. I Lemberger Site Remediation Group .

i \WPMSN\P/T\00-03454\46\Rooo34S446-oo3 DOC 4 Final - Revision 1 April 2006 Lf'jlJ

Appendix BManufacturer's Information for

Low-Flow Purging/Sampling Pump

RMT, Inc. I Lemberger Site Remediation Groupi:\wpMSN\PiT\oo-03454\46\Rfmi345i4t-oo3DOC Final - Revision 1 April 2006

Portable MicroPurge®Sampling Equipment

Catalog

T R E N T

SI K\ ICI S

QED ENVIRONMENTAL SYSTEMS

Sample Pro The first portable MicroPurge*pumps for low-flow sampling.

2 SIZES:1-3/4" for 2" & Larger Wells3/4" for Direct Push Wells

The all-new Sample Pro Portable MicroPurge Pumps are the firstpumps developed specifically to bring the advantages of low-

flow sampling to sites requiring portable pumps.

Reliable low flow rates and fast, simple cleaningSample Pro Pumps

are not only able todeliver consistent low-flow rates, they areeasy to disassemblewithout tools, simpleto clean, and trulyfield rugged.

The pumps are avail-innovative design and precision machining make thepumps reliable and easy to disassemble.

able in two sizes: 1-3/4" diameter for conventional monitoringwells, and 3/4" diameter for direct push and small diameter wells,piezometers, and specialty installations.

The easiest-to-use portable field pump everSample Pro reliability, ease of use, and low mainte-

nance make sampling more economical. The bayonet-type, 1/4 turn twist-open design makes it easy to removethe pull-off, disposable bladder in seconds. The compactunits fit in a 5 gallon bucket for pumping and cleaning.

Under typical field conditions, a Sample Pro pumpcan be completely disassembled, decontaminated, andfitted with a new bladder in 5 to 10 minutes. Tubingreplacement is just as easy, if your sampling protocolrequires it. Before you know it, you'll be ready to move

on to the next well.Unlike other portable pumps, they are cool-running

and can be operated by a lightweight backpack con-troller. There are no high speed rotating parts, no sam-ple and motor heating, no bulky, noisy generators. There

is nothing in a Sample Pro pump that will burn up orseize — you will never have a destructive failure. If a

pump gets silted up, just take it apart and rinse it out.

The only pumpsavailable withthese 3 majorinnovations forportable low-flow sampling.

IEasy, rapiddisassembly

— 1/4 turn, notools

~l Pull-off.bladder

for fastreplacement

' No-fitting,push-in

From QED,the originatorsof MicroPurgelow-flowequipment andWell Wizard ,the most widelyused samplingpumps.

Visit www.micropurge.comyour source for the latest in

low-flow technology.

TQED ENVIRONMENTAL SYSTEMS

The most reliable pump ever engineered for portable sampling

Sample Pro innovations don'tstop there. Both pumps are

available with "no fitting" push-inheads that are perfect for applica-tions where the tubing is discardedfrequently. The 1-3/4" pump alsohas optional compression fittings

for conventional tubing attach-ment. Both options provide highpull-out strength; a cable eye isalso included for applicationswhere a support cable is desired.

Sample Pro value and rugged, all-stainless construction will stand up

to tough portable use. The simpleyet effective design avoids the highmaintenance expenses and destruc-tive failure modes of other pumps.

How they workSqueeze type bladder pumps are

supported by years of independentresearch that shows they provideunaltered samples for even themost sensitive parameters.

Water enters the pump throughthe inlet in the upper, head section,then flows down into the bladder.The high inlet helps prevent clog-ging if the pump is accidentally low-ered into a sediment-filled sump.

Compressed gas squeezes theoutside of the quick-change, one-piece bladder to force liquid out ofthe pump; there is no gas contactwith the pumped water inside thebladder.

Check valves with stainless steelseats and Teflon check balls arelocated at the inlet and outlet. Areplaceable inlet screen is provid-ed for wells with high solids levels

Sample Prof 1V Pump

2o

a: 40°0

"• ix

\%

%

•\**

'••.>*̂• *.

\:;•-.;--W\^* '

C 50 100 150Pump Depth (FT)

to help ensure proper sealing ofthe check valves. Each Sample ProPump is shipped in a heavy-dutytube with rubber end caps to helpkeep the pump clean and protect-ed between uses.

The pump is disassembled by a1/4 turn of the cap and body; nospecial tools are needed. The blad-der pulls off for replacement. Bothcheck valves are press-in, pull-outdesign, and use the same sizeTeflon check ball.

SAMPLE PRO 1-3/4" PUMP SPECIFICATIONS

MODEL NUMBERSPump Only KitMP-SP-4P (1/4" discharge, push-in fittings) MP-SPK-4PMP-SP-4C (1/4" discharge, compression fittings) MP-SPK-4CMP-SP-6P (3/8" discharge, push-in fittings) MP-SPK-6PMP-SP-4C (3/8" discharge, compression fittings) MP-SPK-6C

MATERIALSBody: 303 Stainless SteelInlet & Discharge Housing: 303 Stainless SteelBladder: Polyethylene or Teflon®O-rings: Viton®Teflon is a registered IrademarK ot E I DuPonl Cc. Vilon is a registered trademark of DuPoit Dow Elastomers

DIMENSIONSDiameter: 1.75"(44.5 mm)Length:

Weight:

14.75" (37.5 cm) w/ push-in fittings;16.5" (41.9 cm) w/ compression fittings;12.12" (30.8 cm) bottom of pump to centerline of inlet4.25 Ibs. (1.93 kg)

Pump Volume: Milliliters100

Liters.100

Gallons.026

Ounces3.34

FITTINGSStainless Steel Compression or Push-in TypeAir: 1/4' (6.4 mm) O.D., 3/16" (4.7 mm) I.D.Discharge: 3/8" (9.5 mm) O.D., 1/4" (6.4 mm) I.D. or

1/4" (9.5 mm) O.D., 3/16" (6.4 mm) I.D.

PERFORMANCEMaximum Lift: 250 Feet (76 m)Flow Rates: [1/4"(6.4 mm) x 1/4" (6.4 mm) O.D. tubing]

1.2 liters/min 6 25 ft. (7.6 m) [10 ft. (3 m) submergence]400 ml/min. <S 150 ft. (45.6 m) |10 ft. (3 m) submergence]

Sampling Consultant's KitThe Sample Pro 1-3/4" Pump is

also offered in this exclusive kit,which holds accessories and sup-plies in a rugged case that alsocarries and protects the pump.

The kit includes all supplies,accessories, and replacement partsnecessary to sample 10 wells,packed in a 9x9x20" heavy-dutystructural foam tool box for easyportability on-site.

Portable Equipment Catalog

With Easy to Use MicroPurge® basics1

Control and Power Supplies IftltHMfl

Only Sample Pro Pumps are engi-neered specifically to be

compatible with the new generationof MicroPurge basics control andpower equipment. This is the mostadvanced low flow sampling pumpcontrol system in the industry. You willenjoy the advantage of many exclusivecapabilities, including the Purge Scan™stabilization indicator, AutomaticDrawdown Control, and unparalleledportability for easy well access.

Simple pump control for flawless low flow operationSample Pro Pump users are raving about how easily and reliably these

pumps and controllers sample at low flow rates, when other pump sys-tems falter.

The pumps deliver a steady flow at any rate, even the lowest, with sim-ple up/down arrow key adjustments on the compact, easy-to-use con-trollers. Once flow rate settings for a well have been optimized, takenote of the I.D. setting for one-touch recall during later sampling events.

Versatile power options for every well on your siteMicroPurge basics pneumatic power supplies make it a breeze to oper-

ate your Sample Pro pumps, even at remote wells.Compact, full-powered compressors are available with optional 200

foot hose reels and cart kits to extend your reach beyond where a pickuptruck can drive. Lightweight 12 VDC electronic compressors, ultralightCO2 bottles, and regulators that let you use your own gas cylinders com-plete the system.

PORTABLE SAMPLING PACKAGES

Simplest portable package Backpack power package

Easy up/down arrowkey flow rate adjust-ment

One-touch recall ofpreviously optimizedflow rate settings

Purge Scan™ stabiliza-tion indicator

Automatic DrawdownControl

The only controllerwith a self-containedgas supply

Direct push package

This combination sticks to the essen-tials for portable sampling of conven-tional drilled wells (2" dia. and larger).• 1-3/4" Sample Pro Pump• Sampling Consultant's Kit:

Rugged toolbox w/ bladders, o-rings,check balls, tubing cutter, and more

• 250' reel of 1/4x1/4" bonded twinpolyethylene tubing

• MP10 Controller

On-board compressed gas supply forultimate portability and easy access toany well, no matter how remote.• 1-3/4" Sample Pro Pump• Sampling Consultant's Kit:

Rugged toolbox w/ bladders, o-rings,check balls, tubing cutter, and more

• 250' reel of 1/4x1/4" bonded twinpolyethylene tubing

• MP15 Controller

When you're sampling direct pushwells (3/4" up), piezometers, and spe-cialty wells, this is what you need.• 3/4" Sample Pro Pump• Sampling Consultant's Kit:

Rugged toolbox w/ bladders, o-rings,check balls, tubing cutter, and more

• 250' reels of 1/4 &1/8" single polyeth-ylene tubing

« MP10 Controller

TQED ENVIRONMENTAL SYSTEMS