Pages from The Final Amended FINAL GW Monitoring Work Plan March 12 2003-Part1.pdf

AMENDED FINAL

WORK PLAN

GROUNDWATER MONITORING

BITTERROOT VALLEY SANITARY LANDFILL

RAVALLI COUNTY, MONTANA

AMENDED FINAL

WORK PLAN

GROUNDWATER MONITORING

BITTERROOT VALLEY SANITARY LANDFILL

RAVALLI COUNTY, MONTANA

Prepared for:

National Institutes of Health

Division of Safety

Environmental Protection Branch

Building 13, Room 2W64

Bethesda, Maryland 20892

Prepared by:

Maxim Technologies, Inc.®

P.O. Box 2730

2436 Dixon Avenue (59801)

Missoula, Montana 59806

December 2002 i

EXECUTIVE SUMMARY

Maxim Technologies, Inc.® (Maxim) prepared this work plan for continued groundwater monitoring at the Bitterroot Valley Sanitary Landfill facility (BVSL) in Ravalli County, Montana for the National Institutes of Health (NIH). By mutual agreement of NIH and the Montana Department of Environmental Quality (MDEQ), this work plan supersedes a former monitoring plan (Maxim 1996d) which guided groundwater monitoring between January 1997 and July 2002. Groundwater contamination from the landfill was discovered in 1987, and since 1992 the NIH has been investigating and monitoring groundwater conditions at the site. NIH has undertaken several interim remedial actions since 1993 aimed at removing the source of groundwater contamination and mitigating impacts to the groundwater resource.

Two recent documents establish the requirements for groundwater monitoring at the BVSL.

The first is a Settlement Agreement entered into in January 2001 by the United States on behalf of the NIH with the State of Montana on behalf of MDEQ. That Settlement Agreement requires NIH to monitor groundwater for potential chloroform contamination that may be emanating from BVSL. It is the intent of this work plan to provide the basis for that monitoring and to update the existing groundwater monitoring plan in acknowledgement of the agreements between NIH and MDEQ. Specific details regarding the requirements of the Settlement Agreement are provided in the specific sections of this plan that deal most directly with those requirements.

The second document that established requirements for groundwater monitoring is the MDEQ’s January 2002 Record of Decision (ROD) for the BVSL (MDEQ 2002). The MDEQ’s selected cleanup alternative includes the design and construction of a community water supply system (CWSS), implementation of institutional controls, natural attenuation of groundwater contamination, and groundwater monitoring.

In accordance with the Settlement Agreement and ROD, requirements for groundwater monitoring are in two distinct time periods: Pre-CWSS and Post-CWSS. The following summarizes the purpose and objectives for each monitoring period.

PRE-CWSS

The Pre-CWSS groundwater monitoring program is essentially similar to monitoring that has occurred since 1997. It includes semiannual monitoring of a site-wide well network and quarterly monitoring of NIH’s Phase IIA groundwater remediation system. Data generated through the implementation of the Pre-CWSS plan will be used for:

• Tracking temporal and spatial trends in groundwater flow and quality.

• Evaluating the effects of NIH's 1993-94 soil removal action and effects of NIH’s Phase IIA groundwater remediation system on groundwater flow and quality.

• Documenting volatile organic compound (VOC) water quality relative to Montana groundwater standards.

• Monitoring the effectiveness of water treatment systems on replacement domestic wells in reducing concentrations of iron and manganese at the point of use.

• Operating and maintaining of the Phase IIA groundwater treatment system.

POST-CWSS

In the Settlement Agreement it was established that NIH will, for a period of five years after the later of (a) issuance of the Certification of Completion of the CWSS or (b) the date upon which NIH terminates operation of the pump and treat system (i.e., Phase IIA groundwater remediation system), collect semiannual monitoring data from a set of 10 plume-perimeter ii wells. The approximate locations and depths of these wells are defined by the Settlement Agreement. Final locations of the wells will be dependant on an evaluation of the chloroform plume prior to CWSS construction. The triggering event to shift from Pre- to Post-CWSS monitoring will be when MDEQ issues the Certificate of Completion for the CWSS. MDEQ will be notified of the projected date when Post-CWSS monitoring will begin. Data generated through the implementation of the Post-CWSS monitoring program will be used to monitor the plume for possible expansion outside the boundaries of the CWSS.

This work plan covers field and reporting procedures for both Pre-CWSS and Post-CWSS groundwater monitoring. Presently all monitoring wells are located on private property and must be periodically accessed to take groundwater samples. In the event that access is denied to any of the wells specified in this SAP, NIH will contact MDEQ within three working days for assistance in obtaining access. If access is not reacquired before the completion of the regularly scheduled monitoring event, the well(s) in question will not be included in that event.

Key data will be posted on maps and graphed to display trends. Reports will be issued to the NIH and MDEQ Remediation Division after each monitoring event. In addition, validated monitoring data obtained from individual properties will be transmitted directly to property owners.

We have organized this work plan into sections that describe the monitoring strategy and data collection and validation procedures. The anticipated schedule and a description of the deliverables for each monitoring period (Pre-CWSS and Post-CWSS) are also presented. The final section of this plan summarizes the landfill history, environmental setting and extent of contamination. Tables and figures located throughout the work plan show monitoring locations, field and analytical requirements, and monitoring schedules. Appended to this document are supporting information including a quality assurance project plan, Maxim's health and safety plan, the project’s well inventory, standard operating procedures for field work, various field sampling forms, an example of a landowner communication report, and a work plan review signature page for Maxim employees.

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY ...................................................................................................... i

1.0 INTRODUCTION

1.1 PREVIOUS MONITORING ACTIVITIES

1.2 PURPOSE

1.3 OBJECTIVES

2.0 METHODS

2.1 PRE-CWSS GROUNDWATER SAMPLING METHODS

2.1.1 Monitoring Locations

2.1.2 Sample Designation and Documentation

2.1.3 Frequency

2.1.4 Monitoring Equipment and Sampling Procedures

2.1.5 Quality Assurance / Quality Control

2.1.6 Sample Analysis, Handling and Shipping

2.1.7 Phase IIA Remediation System Monitoring

2.2 PRE-CWSS SCHEDULE AND DELIVERABLES

2.2.1 Groundwater Monitoring Reports

2.2.2 Property Owner Data Summary Reports

2.2.3 Phase IIA Quarterly Reports

2.3 POST-CWSS GROUNDWATER SAMPLING METHODS

2.3.1 Monitoring Locations

2.3.2 Sample Designation and Documentation

2.3.3 Frequency

2.3.4 Monitoring Equipment and Sampling Procedures

2.3.5 Quality Assurance / Quality Control

2.3.6 Sample Analysis, Handling and Shipping

2.4 POST-CWSS SCHEDULE AND DELIVERABLES

2.4.1 Groundwater Monitoring Reports

2.4.2 Property Owner Data Summary Reports

3.0 SITE BACKGROUND

3.1 LANDFILL HISTORY

3.2 SITE DESCRIPTION

3.2.1 Physiography

3.2.2 Geology and Soil

3.2.3 Hydrology

3.2.4 Hydrogeologic Setting

3.3 CONTAMINANT TRANSPORT AND DISTRIBUTION

4.0 REFERENCES

TABLE OF CONTENTS, continued

LIST OF FIGURES

Figure

1 Location and Vicinity Map 2 Site Map 3 Wells to Monitor in the Shallow Portion of Unit A 4 Wells to Monitor in the Deep Portion of Unit A & Unit B 5 Wells to Monitor in Units C & D 6 Post-CWSS Monitoring Wells 7 Generalized Hydrostratigraphic Cross Section 8 Chloroform Concentration vs. Time

LIST OF TABLES

Table 1 Summary of Monitoring Locations and Frequency 2 Wells Installed Since December 1996 3 Summary of QA/QC Sampling Locations and Frequency 4 Parameter List 5 Summary of Sample Handling Procedures

LIST OF APPENDICES

APPENDIX

A Quality Assurance Project Plan B Health and Safety Plan C Project Well Inventory D Standard Operating Procedures & Chain of Custody Forms E Example of a Property Owner Data Summary Report F Work Plan Review Acknowledgement Signature Sheet G Quality Assurance Manual, Northern Analytical Laboratories

Groundwater Monitoring Work Plan, Bitterroot Valley Sanitary Landfill

1.0 INTRODUCTION

Maxim Technologies, Inc.® (Maxim) prepared this work plan for continued groundwater monitoring at the Bitterroot Valley Sanitary Landfill facility (BVSL) in Ravalli County, Montana for the National Institutes of Health (NIH). By mutual agreement of NIH and the Montana Department of Environmental Quality (MEDQ), this work plan supersedes a former monitoring plan (Maxim 1996d) that guided groundwater monitoring between January 1997 and July 2002 and is anticipated to provide guidance for all monitoring required by the Settlement Agreement.

Groundwater contamination from the landfill was discovered in 1987, and since 1992 the NIH has been investigating and monitoring groundwater conditions at the site. NIH has undertaken several interim remedial actions since 1993 aimed at removing the source of groundwater contamination and mitigating impacts to the groundwater resource.

Maxim prepared this work plan for continued groundwater monitoring at the BVSL in Ravalli County, Montana on behalf of NIH. Groundwater monitoring was authorized by the NIH according to Contract No. 263-95-C-0252 between Maxim and NIH. The BVSL site is located about one mile south of Victor, Montana (Figure 1) and covers approximately 275 acres west of the Bitterroot River (Figure 2).

Waste laboratory chemicals were disposed of at the landfill between 1981 and 1985 and groundwater contamination was discovered in 1987. NIH completed several actions including a multi-phase remedial investigation and draft final feasibility study. NIH also implemented several Interim Remedial Actions since 1993 aimed at removing the source of groundwater contamination, improving groundwater quality and mitigating impacts to the public. Results of NIH’s investigative and remedial activities are described in several reports cited in Section 5.0 by Maxim and its predecessors (Chen-Northern Inc. and Huntingdon Engineering and Environmental).

In addition to semiannual groundwater monitoring, NIH is operating, maintaining and monitoring a groundwater remediation system, and monitoring and maintaining iron/manganese filtration units on 14 replacement domestic water supplies.

This plan establishes groundwater monitoring plans for the time periods prior to and following the Community Water Supply System (CWSS) and in accordance with the Settlement Agreement. A comprehensive explanation of the time periods which each time period covers may be found in Sections 2.1 and 2.3 for the Pre- and Post- CWSS, respectively. Pre-CWSS monitoring activities involve sampling monitoring, remediation, and domestic supply wells including 19 replacement domestic wells installed by NIH between 1995 and 1999, and nine groundwater recovery/interception wells. Post-CWSS monitoring includes sampling 5 new and 5 existing monitoring wells to monitor the plume for possible expansion outside the boundaries of the CWSS. Presently all monitoring wells are located on private property and must be periodically accessed to take groundwater samples. In the event that access is denied to any of the wells specified in this SAP, NIH will contact MDEQ within three working days for assistance in obtaining access. If access is not reacquired before the completion of the regularly scheduled monitoring event, the well(s) in question will not be included in that event.

1.1 PREVIOUS MONITORING ACTIVITIES

Regular groundwater monitoring for VOCs was initiated at the BVSL in approximately 1987. In 1992, NIH expanded the BVSL monitoring program in association with a hydrogeologic characterization which involved monitoring well installation, monthly water level measurements, and quarterly groundwater sampling and analysis for a variety of inorganic and volatile organic parameters. Results of the 1992 investigation generally identified the extent and magnitude of impacts of the landfill on groundwater quality in the area downgradient of the BVSL (Chen- Northern 1993a,b).

NIH completed additional hydrogeologic and source area investigations in 1993 (Chen-Northern 1993d and 1994a). In 1993, Maxim was requested by NIH to develop a comprehensive monitoring program for the site that included accessing domestic and monitoring wells and two surface water stations on the Bitterroot River. Selected wells installed during investigations at the site were included in the program. Maxim prepared a work plan (Chen-Northern 1993e) to guide the monitoring effort that was initiated in January 1993. Monitoring was conducted on a semiannual basis in January and July 1994, and January and July 1995. Reports of these monitoring events are contained in Huntingdon (1994a, 1994b, 1995a, and 1995b) and Maxim (1995).

In 1996 the monitoring program was revised in response to results of remedial actions including: soil removal and treatment in 1993-94, Phase I groundwater recovery and treatment beginning in 1994, and the replacement of domestic water supply wells that began in 1995. In 1996 a new groundwater monitoring work plan (Maxim 1996d) was prepared to guide semiannual monitoring of selected domestic and monitoring wells. The plan included quarterly monitoring of 19 replacement domestic wells during their first two years of operation. A listing of reports documenting replacement well monitoring events between 1996 and January 2002 is presented in Maxim (2002a).

NIH completed several supplemental groundwater investigations throughout the study area between 1996 and 2001 including additional source area and plume delineation characterizations. Results of these studies are documented by Maxim (1999c, 1999f, 2000d and 2001b). Many of the wells installed during these investigations are included in groundwater monitoring program described herein.

Maxim is currently monitoring the Phase IIA groundwater remediation system on a quarterly basis in accordance with Maxim (1998b). The Phase IIA groundwater remediation was installed in 1998 and expanded in 2000 (Maxim 1999a and 2000g). Nine remediation wells are being pumped to an air-stripper where groundwater is treated and then discharged to the North Channel of Bear Creek (Bear Creek). Remediation system monitoring includes sampling individual recovery wells (semiannually) and the influent to the treatment system and the treated effluent (quarterly). Operational parameters are monitored monthly. Reports documenting Phase IIA remediation system monitoring data are listed in Maxim (2002b).

1.2 PURPOSE

The purpose of this work plan is to establish a framework for continuing groundwater monitoring at the site. Both Pre-CWSS and Post-CWSS groundwater monitoring is covered by this plan. The work plan is complimented by the Quality Assurance Project Plan (QAPP, Appendix A) and Health and Safety Plan (HSP, Appendix B). Specific purposes of the work plan are to:

• Identify stations to be monitored, specific monitoring to be performed at each station, and the frequency of monitoring;

• Standardize field methods for environmental sampling;

• Identify physical and chemical parameters that will be analyzed;

• Identify laboratory methods that will be used to analyze samples;

• Establish quality assurance and quality control protocols; and,

• Set forth the format and schedule for project deliverables.

Bitterroot Valley Sanitary Landfill

USGS 7.5' Victor Topographic Quadrangle

FIGURE 1

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William.Craig Sticky Note amended from original 2003 work plan. Tt logo. Now titled Facility Map.

1.3 OBJECTIVES

The objectives of groundwater monitoring covered by this plan differ between Pre-CWSS and Post-CWSS time periods. Objectives of the Pre-CWSS monitoring include:

• Track temporal and spatial trends in groundwater flow and quality;

• Evaluate the effects of interim remedial actions undertaken by NIH and effects of NIH’s Phase IIA groundwater remediation system on groundwater flow and quality;

• Document VOC water quality relative to Montana groundwater standards;

• Monitor the effectiveness of water treatment systems on replacement domestic wells in reducing concentrations of iron and manganese; and,

• Provide operation and maintenance of the Phase IIA groundwater treatment system.

The objective of the Post-CWSS monitoring program is to:

• Monitor the plume for possible expansion outside the boundaries of the CWSS.

2.0 METHODS

This section describes groundwater monitoring methods, schedules, and deliverables. Maxim will notify MDEQ at least 14 days before each semi-annual monitoring event. Sections 2.1 and

2.2 cover Pre-CWSS monitoring and Sections 2.3 and 2.4 cover Post-CWSS monitoring.

Included below are discussions of monitoring locations, sample designation and documentation, sampling frequency, monitoring equipment and sampling procedures, quality assurance and quality control (QA/QC), and sample analysis, handling, and shipping procedures. Appendices A through F contain supporting documentation.

Quarterly reports for Phase IIA and semiannual reports on Groundwater monitoring will be prepared and submitted to the NIH. The NIH will submit two copies of each report to the MDEQ. Individual landowner reports will be transmitted to each landowner and copied to both the NIH and the MDEQ.

2.1 PRE-CWSS GROUNDWATER SAMPLING METHODS

The following sections describe the methods, schedule, and deliverables for the Pre-CWSS monitoring program.

2.1.1 Monitoring Locations

Several types of wells will be monitored including monitoring, remediation and private (residential and commercial). The wells selected for monitoring are listed in Table 1 and include wells installed during NIH's Alternative Water Supply Project (i.e., replacement domestic wells) and during several investigations since December 1996 (Table 2). Groundwater elevations will be measured quarterly in wells located near the Phase IIA remediation system and semi-annually in all monitoring and private wells shown on Table 1. These monitoring locations are identified on Figures 3, 4, and 5, and specific information regarding each well is contained in the project’s well inventory database (Appendix C).

2.1.2 Sample Designation and Documentation

Natural water samples collected from monitoring wells, existing private wells, new replacement wells, and the Phase IIA groundwater treatment system influent and effluent will be identified according to the designation presented on Table 1 (e.g. BR-GW-36D, R-8D or D-39). In addition, quality assurance and quality control samples will be collected/prepared during each sampling event. Four types of QA/QC samples will be designated on field forms and reports as follows:

• Trip blank samples prepared by the laboratory will be designated "trip-blank". These samples will accompany sample containers to the field and will be submitted for analysis with the natural samples.

• Duplicate samples will be designated "duplicate-1”, “duplicate-2”, ect. and noted on a field sampling log when and where collected. Duplicate samples will not contain the sample designation of the natural sample.

• Field blank samples will be designated as "field-blank". A description of how, where, and when the sample was prepared will be noted on a field sampling log.

• Temperature blank samples will be designated "temp-blank" and noted on a sampling log exactly when, how and where prepared.

The date and time of sampling will be recorded on each sample label along with the monitoring station or QA/QC sample designation. Any preservative added to a sample will also be noted along with the initials of field personnel. Field crews will document sampling activities in a project field book, the monitoring well sampling schedule sheet, and on individual sampling logs

Amended from 2003 final WP. Potentiometric surface of Shallow Unit A demonstrates wells to monitor

TABLE 1

Summary of Monitoring Locations and Frequency Pre-CWSS Groundwater Monitoring Program

Total ANNUALLY SEMIANNUALLY QUARTERLY

Well Depth Sampling Fe, Mn, Colif. Depth to VOCs & Depth to VOCs &

Number Well Type (feet) Method Bacteria Water Field Param. Water Field Param.

BR-GW-2 Observation 71 Sampling Pump

BR-GW-3 Monitoring 24 NA

BR-GW-8 Monitoring 25 Sampling Pump

BR-GW-9 Monitoring 98 Sampling Pump

BR-GW-10 Monitoring 29 Sampling Pump

BR-GW-30S Monitoring 21 NA

BR-GW-31D Monitoring 90 Sampling Pump

BR-GW-32S Monitoring 19 Sampling Pump

BR-GW-33S Monitoring 20 Sampling Pump

BR-GW-34D Monitoring 78 Sampling Pump

BR-GW-35S Monitoring 19 NA

BR-GW-36D Monitoring 120 Sampling Pump

BR-GW-37S Monitoring 63 Sampling Pump

BR-GW-38D Monitoring 110 Sampling Pump

BR-GW-39S Monitoring 60 NA

BR-GW-41S Monitoring 64 NA

BR-GW-42D Monitoring 81 NA

BR-GW-43S Monitoring 25 NA

BR-GW-46S Monitoring 58 NA

BR-GW-48S Monitoring 45 Sampling Pump

BR-GW-49S Monitoring 65 NA

BR-GW-50D Monitoring 114 Sampling Pump

BR-GW-51D Monitoring 76 Sampling Pump

BR-GW-52S Monitoring 35 NA

BR-GW-53S Monitoring 49 NA

BR-GW-54D Monitoring 81 NA

BR-GW-55S Monitoring 17 NA

BR-GW-56DD Monitoring 179 Sampling Pump

BR-GW-58S Monitoring 55 Sampling Pump

BR-GW-59S Monitoring 60 NA

BR-GW-60S Monitoring 53 NA

BR-GW-61DD Monitoring 196 Sampling Pump

BR-OW-01D Monitoring 99 NA

BR-OW-02S Monitoring 39 NA

BR-GW-81S Monitoring 27 Sampling Pump

BR-GW-82D Monitoring 102 Sampling Pump

BR-GW-83D Monitoring 97 NA

BR-GW-84D Replacement 158 Well Pump

BR-GW-85 Monitoring 78 NA

BR-GW-86D Monitoring 129.5 NA

BR-GW-87S Monitoring 67.5 Sampling Pump

BR-GW-88S Monitoring 55 Sampling Pump

BR-GW-89S Monitoring 59 Sampling Pump

BR-GW-90D Monitoring 87 Sampling Pump

BR-GW-91D Monitoring 86 Sampling Pump

BR-GW-92D Monitoring 89 Sampling Pump

SA-1 Monitoring 100 NA

SA-2 Monitoring 105 NA

TABLE 1, continued Summary of Monitoring Locations and Frequency

Pre-CWSS Groundwater Monitoring Program

Total ANNUALLY SEMIANNUALLY QUARTERLY

Well Depth Sampling Fe, Mn, Colif. Depth to VOCs & Depth to VOCs & Number Well Type (feet) Method Bacteria Water Field Param. Water Field Param.

SA-3 Monitoring 106 NA SA-4 Monitoring 126 NA SA-5 Monitoring 125 NA SA-8 Monitoring 120 NA SA-9 Monitoring 89 NA SA-13 Monitoring 86 Sampling Pump SA-14 Monitoring 118 Sampling Pump SA-16 Monitoring 120 Sampling Pump SA-17 Monitoring 86 Sampling Pump P-1 Monitoring 15 NA P-2 Monitoring 20 NA P-3 Monitoring 109 NA

D-39 Observation 128 Sampling Pump D-101 Domestic 71 Well Pump

BR-GW-1 Observation 95 NA BR-GW-5 Observation 106 NA BR-GW-21 Observation ? NA

BR-GW-62DD Replacement 250 Well Pump BR-GW-63DD Replacement 249 Well Pump BR-GW-65DD Replacement 265 Well Pump BR-GW-66DD Replacement 270 Well Pump BR-GW-67DD Replacement 276 Well Pump BR-GW-68DD Replacement 270 Well Pump BR-GW-69DD Replacement 267 Well Pump BR-GW-70DD Replacement 250 Well Pump BR-GW-71DD Replacement 260 Well Pump BR-GW-72DD Replacement 273 Well Pump BR-GW-73DD Replacement 273 Well Pump BR-GW-74DD Replacement 256 Well Pump BR-GW-75DD Replacement 262 NA BR-GW-76DD Replacement 276 NA BR-GW-77DD Replacement 263 Well Pump BR-GW-78DD Replacement 270 NA BR-GW-79DD Replacement 259 NA BR-GW-80DD Replacement 260 Well Pump

R-1 Recovery 70 Well Pump R-2 Recovery 70 Well Pump R-3S Interception 39 Well Pump R-4D Interception 110 Well Pump R-5S Interception 29 Well Pump R-6D Interception 97 Well Pump R-7S Interception 30 Well Pump R-8D Interception 93 Well Pump R-9D Recovery 120.5 Well Pump INF hase IIA Influe NA Grab NA NA EFF hase IIA Efflue NA Grab NA NA

Notes:

Indicates data collection required VOCs: Volatile Organic Compounds by EPA Method 524.2 Field Param.: Field parameters of DO, ORP, Temperature, pH, SC NA: Not Applicable

TABLE 2

Wells Installed Since 1996

WELL

COMPLETION

DATE PROJECT REPORT REFERENCE

BR-GW-79DD 11/05/1997

BR-GW-80DD 08/12/1997

Alternative Water Supply Maxim 1998e

P-3 06/21/1997 R-7S 07/22/1997 R-8D 07/24/1997

Phase IIA Groundwater Remediation

Maxim 1998d

R-3S 12/11/1997 R-4D 12/05/1997 R-5S 12/12/1997 R-6D 12/15/1997

BR-GW-81S 12/17/1997

BR-GW-82D 12/03/1997

Phase IIA Groundwater Remediation

Maxim 1999a

SA-1 12/05/1998

SA-2 12/05/1998

SA-3 03/15/1999

SA-4 02/18/1999

SA-5 02/12/1999

BR-GW-83D 02/10/1999

Phase IIB Source Area Characterization

Maxim 1999c

BR-GW-84D 09/13/1999 Test Well Maxim 1999f

SA-6 10/22/1999

SA-7 10/22/1999

SA-8 10/27/1999

SA-9 10/27/1999

SA-10 11/08/1999

SA-11 11/08/1999

SA-12 11/11/1999

SA-13 11/11/1999

SA-14 11/10/1999

SA-15 11/10/1999

SA-16 11/03/1999

SA-17 11/03/1999

R-9D 01/11/2000

Expansion of Phase IIA Groundwater Remediation System

Maxim 2000g

BR-GW-85 01/07/2000

BR-GW-86D 01/07/2000

BR-GW-87S 01/13/2000

BR-GW-88S 01/14/2000

BR-GW-89S 01/17/2000

Characterization of Hydrostratigraphic Unit A Near

BVSL

Maxim 2000d

BR-GW-90D 11/13/2000

BR-GW-91D 11/14/2000

BR-GW-92D 11/16/2000

Characterization of Hydrostratigraphic Unit A East of U.S. Highway 93

Maxim 2001b

Amended from 2003 WP. Pot. Map for Deep Portion of Unit A (demonstrates wells to be monitoring in Unit A/B).

Amended from 2003 WP. Pot. Map for Unit D (demonstrates wells to be monitoring in Unit C/D).

(SOP-10, Appendix D). Examples of these field forms are provided in Appendix D. All entries will be made using permanent, indelible ink. Errors will be lined through, initialed, and corrected with a new entry.

2.1.3 Frequency

Groundwater hydrographs for wells at the site indicate seasonally high groundwater levels generally occur during early summer (June/July) and seasonally low groundwater levels occur in winter (January/February). Semi-annual sampling events at the site since January 1994 have been scheduled to coincide with these seasonal periods of high and low groundwater levels. All monitoring stations covered by this work plan will be sampled during January and July (Table 1).

The Phase IIA groundwater treatment system influent and effluent will be sampled in March and September in addition to January and July (Table 1). Water levels will also be measured quarterly in the wells listed on Table 1. Data obtained from quarterly sampling of the groundwater treatment system will be used to demonstrate the effectiveness of the air stripper at removing VOCs from groundwater.

Water samples from ports “downstream” of iron/manganese treatment units on replacement wells will be collected annually in July and analyzed for total iron and manganese and total coliform bacteria (Table 1). The purpose of annual sampling for total iron and manganese is to evaluate the effectiveness of the water treatment units in reducing total iron and manganese concentrations in water delivered by replacement wells.

2.1.4 Monitoring Equipment and Sampling Procedures

All monitoring work will be conducted under a site-specific HSP. A copy of the plan is contained in Appendix B. The HSP is intended to protect Maxim monitoring personnel from potential health and safety risks associated with the monitoring activities. The HSP describes personnel responsibilities, protective equipment, health and safety procedures and protocols, decontamination procedures, personnel training, and medical surveillance. Each Maxim employee working at the site is required to read and sign the plan.

A list of typical equipment that is needed to complete groundwater monitoring at BVSL is included in Appendix D. To the extent possible, depth to water in all wells will be measured during the same day. Measurements will be made to the nearest 0.01 foot and recorded on a field copy of the monitoring well sampling schedule sheet and on a sampling log, as appropriate (Appendix D). All water level measurements will be made from the designated, marked measuring point at the top of the well casing, on the north quadrant. The well inventory contained in Appendix C presents designated measuring points and elevations for wells. Water levels will be measured with a decontaminated electric well probe. All water level measurements will be completed in accordance with Standard Operating Procedure No. 20 (SOP-20). Appendix D contains SOPs that will be used for groundwater monitoring at the facility.

Monitoring wells will be purged of at least three borehole volumes of water prior to sampling using a submersible electric stainless steel pump and disposable tygon tubing. All sampling equipment will be decontaminated before each well is sampled in accordance with SOP-11.

Specifically, all down-hole pump equipment (pump, electrical lead, and stainless steel support wire) will be washed with hot, high pressure water, flushed with a 10% methanol in de-ionized water solution, and then given a final rinse and flush with de-ionized water. If a monitoring well will not yield three well casing volumes of water, then the well will be purged dry and sampled during water level recovery.

Temperature, pH, specific conductivity, dissolved oxygen and redox potential will be measured at least three times during well purging in accordance with SOP-07, SOP-06, SOP-05, SOP-08 and SOP-28 (Appendix D). Probes to measure these parameters will be placed in an in-line, flow-through-chamber and measurements will be recorded on sampling logs. Temperature, pH and specific conductivity shall be within ±10% on three consecutive readings before purging is considered complete.

Groundwater samples will be collected from monitoring wells after purging. Water samples will be transferred at a low pump flow rate directly to the appropriate sample container(s) to minimize air entrapment.

Water samples collected from water supply wells listed on Table 1 will be obtained in general accordance with SOP-18 (Appendix D). These wells contain their own submersible pumps and samples will be obtained from the tap nearest the well. Requirements for purging, measuring field parameters, and filling sample containers will adhere to the SOPs. Samples will be collected from sample ports after iron and manganese treatment systems installed on the replacement domestic supply wells indicated on Table 1 for analysis of total iron and manganese and total coliform bacteria.

Remediation wells R-3S through R-9D will be sampled directly from individual well sampling ports located in the remediation building on Meridian Lane (Figure 2). Wells R-1 and R-2 will be sampled from sampling ports located in the concrete vaults housing each well. Purging will not be performed prior to sampling each well if the wells have been continuously pumping. If the remediation wells have not been pumping, Maxim will follow purging procedures listed in SOP- 18 prior to sampling.

2.1.5 Quality Assurance / Quality Control

Maxim will follow a QAPP developed for the project. The QAPP is contained in Appendix A and establishes specific quality assurance and quality control policies and activities for the project.

The QAPP provides a detailed description of the QA/QC procedures to be employed during the monitoring activities. A primary objective of the QAPP is to ensure the quality of the data collected during the monitoring activities. The QAPP includes descriptions of sample custody procedures, instrument calibration, analytical procedures, corrective actions, data reduction and validation, and reporting procedures.

Field QA/QC samples will be inserted into the sample train for each sampling event and will include a trip blank and a temperature blank for each shipping cooler. For semiannual monitoring events, we will also collect field duplicate samples. Table 3 shows the number and types of QA/QC samples for the monitoring events.

Trip blank samples will be prepared in the laboratory and will consist of deionized water in 40-milliliter (ml) vials. Methods and necessary paperwork to complete QA/QC sampling are described in SOP-13 (Appendix D). The trip and temperature blanks will be shipped to the sampling office, transported to the field by the sampling crew, and returned to the laboratory along with the natural samples for analysis of VOCs. Analytical data obtained from the trip blanks will be used to determine if VOCs are introduced to natural samples during sample transport. Temperature blanks will be used to verify proper sample temperature upon receipt at the laboratory.

Field duplicate and field blank samples will be collected/prepared in the field and samples will be analyzed for the same parameters as the natural samples. Analytical data obtained from duplicate samples will be used to assess laboratory precision. Field blank samples will be prepared by pouring de-ionized water in sample vials and sampled for VOCs to verify that the rinse water does not contain contaminants. Equipment blanks will be prepared by rinsing de-ionized water over decontaminated sampling equipment and collecting the rinsate in sampling vials. Field blank samples will be analyzed along with the natural samples for VOCs. Laboratory data from the field blanks will be used to verify that the de-ionized water does not exhibit VOCs and that the decontamination procedures are adequate in removing any VOC contamination.

TABLE 3

Summary of QA/QC Sampling Locations and Frequency

PRE-CWSS POST-CWSS

ANNUALLLY SEMIANNUALLY QUARTERLY SEMIANNUALLY

Well Number

Sample Location

Sampling Method

Total Iron and Manganese & Total Coliform

VOCs & Field Param.

VOCs & Field Param.

VOCs & Field Param.

Field Duplicate

Monitoring Sampling Pump

3 1

Field Duplicate

Fe/Mn Treatment

Grab 1 (Fe and Mn) 1 (coliform)

Trip Blank QA/QC Lab Prepared

NA 2

Field Blank QA/QC Field Prepared

NA 1

Temp.

Blank

QA/QC Field Prepared

NA 3 1 1

Notes:

Field duplicate sample collection frequency based on duplicate for every 20 natural samples VOCs: Volatile Organic Compounds by EPA Method 524.2 Total iron (Fe) and manganese (Mn) by EPA Drinking Water Analysis Method 200.7 Total coliform bacteria by Standard Method 9221D Field Param.: Field parameters of DO, ORP, Temperature, pH, SC NA: Not Applicable

2.1.6 Sample Analysis, Handling and Shipping

Table 4 summarizes the suite of VOCs provided by EPA Method 524.2 (inclusive of the contaminants of concern) and includes method detection limits (MDLs) and practical quantitation limits (PQLs) for each analyte. The PQL (e.g., laboratory reporting limit) is generally five times the MDL for VOCs. All wells sampled on a semiannual frequency will be analyzed for VOCs and field parameters (Tables 1 and 4). Samples for VOC analysis will be collected in three 40 ml glass vials, filled and capped with no headspace, and preserved with hydrochloric acid to reduce the pH to less than 2 standard units (SOP-42, Appendix D).

Samples for total iron and manganese will be collected in 500 ml plastic bottles and preserved with nitric acid to a pH of less than 2 standard units. Samples for total coliform bacteria will be collected in sterile, laboratory-supplied 100 ml plastic bottles and preserved with sodium thiosulfite.

Table 5 summarizes sample handling procedures including sample volume and preservative requirements. Samples will be packaged and shipped in watertight coolers filled with ice, adequately packed to avoid damage under normal handling and shall be delivered to the laboratory so that the requested analyses can be performed within the specified allowable holding time (SOP-09; Appendix D). The laboratory will be notified at least one week prior to the time of sample collection and advised of the expected shipment date. Samples will be shipped to the laboratory for overnight delivery. Chain-of-custody forms will be filled out in the field, placed in a zip-lock bag, and taped to the upper lid of the cooler(s) along with the samples. An example chain-of-custody form is provided in Appendix D. Authorized laboratory personnel will acknowledge receipt of shipment by signing and dating the Chain-of-Custody form and returning a copy to Maxim's Project Manager.

TABLE 4

Parameter List

PARAMETER GROUP

EPA

ANALYTICAL

METHOD

METHOD

DETECTION

LIMIT

(MDL)

PRACTICAL

QUANTITATION

LIMIT (PQL)

GROUND-

WATER

STANDARD

Benzene VOC 524.2 0.10 0.5 5

Bromobenzene VOC 524.2 0.12 1 Bromochloromethane VOC 524.2 0.14 1

Bromodichloromethane VOC 524.2 0.05 0.5 6 Bromoform VOC 524.2 0.10 0.5 40

Bromomethane VOC 524.2 0.08 1 48 n-Butylbenzene VOC 524.2 0.03 1 sec-Butylbenzene VOC 524.2 0.06 1 t-Butylbenzene VOC 524.2 0.07 1

Carbon tetrachloride VOC 524.2 0.11 0.5 3 Chlorobenzene VOC 524.2 0.04 0.5 100 Chloroethane VOC 524.2 0.08 1 Chloroform VOC 524.2 0.06 0.5 60

Chloromethane VOC 524.2 0.06 1 2-Chlorotoluene VOC 524.2 0.05 1 4-Chlorotoluene VOC 524.2 0.04 1

Dibromochloromethane VOC 524.2 0.16 0.5 4.1 1,2-Dibromo-3-chloropropane VOC 524.2 2.0 5.0

1,2-Dibromoethane VOC 524.2 0.08 1 0.05 Dibromomethane VOC 524.2 0.11 1

1,2-Dichlorobenzene VOC 524.2 0.14 0.5 600 1,3-Dichlorobenzene VOC 524.2 0.06 1 400 1,4-Dichlorobenzene VOC 524.2 0.10 0.5 75

Dichlorodifluoromethane VOC 524.2 0.02 1 1,400 1,1-Dichloroethane VOC 524.2 0.04 1 1,2-Dichloroethane VOC 524.2 0.09 0.5 4 1,1-Dichloroethene VOC 524.2 0.29 0.5 7 c-1,2-Dichloroethene VOC 524.2 0.03 0.5 70 t-1,2-Dichloroethene VOC 524.2 0.09 0.5 100 1,2-Dichloropropane VOC 524.2 0.05 1 5 1,3-Dichloropropane VOC 524.2 0.06 1 2,2-Dichloropropane VOC 524.2 0.11 1 1,1-Dichloropropene VOC 524.2 0.05 1 c-1,3-Dichloropropene VOC 524.2 0.10 1 2 t-1,3-Dichloropropene VOC 524.2 0.06 1 2

Ethylbenzene VOC 524.2 0.07 0.5 700

Hexachlorobutadiene VOC 524.2 0.14 1 4.4

TABLE 4 (Con't.)

Parameter List

PARAMETER GROUP

EPA

ANALYTICAL

METHOD

METHOD

DETECTION

LIMIT

(MDL)

PRACTICAL

QUANTITATION

LIMIT (PQL)

GROUND-

WATER

STANDARD

Isopropyltoluene VOC 524.2 0.11 1

Methylene chloride VOC 524.2 0.13 2 5 Naphthalene VOC 524.2 0.09 1 28 n-Propylbenzene VOC 524.2 0.05 1 Styrene VOC 524.2 0.07 0.5 100

1,1,1,2-Tetrachloroethane VOC 524.2 0.06 1 1,1,2,2-Tetrachloroethane VOC 524.2 0.11 1 1.7

Tetrachloroethene VOC 524.2 0.10 0.5 5 Toluene VOC 524.2 0.09 0.5 1,000

1,2,3-Trichlorobenzene VOC 524.2 0.09 1 1,2,4-Trichlorobenzene VOC 524.2 0.05 0.5 70 1,1,1-Trichloroethane VOC 524.2 0.13 0.5 200 1,1,2-Trichloroethane VOC 524.2 0.11 0.5 5

Trichloroethene VOC 524.2 0.06 0.5 5 Trichlorofluoromethane VOC 524.2 0.04 1 10,000 1,2,3-Trichloropropane VOC 524.2 0.11 1 1,2,4-Trimethylbenzene VOC 524.2 0.14 1 1,3,5-Trimethylbenzene VOC 524.2 0.06 1

Vinyl chloride VOC 524.2 0.07 0.5 0.15 Total Xylenes VOC 524.2 0.08 2 10,000

Total Iron Metals 200.7 0.01 0.05 3001

Total Manganese Metals 200.7 1.00 5 502

Total Coliform Bacteria Bact. SM 9221D 1 col/100 ml 1 col/100 ml <1 col/100 ml

Notes:

All concentrations are in micrograms per liter (µg/L) except concentrations for total coliform bacteria that are in units of one coliform per 100 milliliters (ml) of water (1col/100 ml).

Total Fe and Mn and total coliform will be analyzed only during the Pre-CWSS monitoring program Water quality standards are listed from MDEQ Water Quality Standards Circular WQB-7 (September1999), unless noted Blank cell indicates WQB-7 does not have standard for that parameter

VOC = Volatile Organic Compound MDL = Method Detection Limit as defined in 40 CFR Part 136 PQL = Practical Quantitation Limit as defined in 40 CFR Part 258

1 = The concentration of iron must not reach values that interfere with the uses specified in the surface and groundwater standards (ARM 17.30.601 et seq. and 17.30.1001 et seq.). The Secondary Maximum Contaminant Level of 300 micrograms per liter which is based on aesthetic properties such as taste, odor, and staining may be considered as guidance to determine the levels that will interfere with the specified uses.

2 = The concentration of manganese must not reach values that interfere with the uses specified in the surface and groundwater standards (ARM 17.30.601 et seq. and 17.30.1001 et seq.). The Secondary Maximum Contaminant Level of 50 micrograms per liter which is based on aesthetic properties such as taste, odor, and staining may be considered as guidance to determine the levels that will interfere with the specified uses.

TABLE 5

Summary of Sample Handling Procedures

PARAMETER

GROUP

ANALYTICAL

METHOD

BOTTLE

REQUIREMENTS

SAMPLE

VOLUME

PRESERVATIVE

REQUIREMENTS

HOLDING

TIME

Volatile Organic Compounds

EPA 524.2 40ml, glass vials (3) x 40 ml

HCl < 2 pH, cool to 4 degrees C, zero headspace

14 days

Oxidation- Reduction Potential

Field Measurement

500 ml, plastic 500 ml N.A. Immediately

Dissolved Oxygen

Field Measurement

500 ml, plastic 500 ml N.A. Immediately pH Field Measurement

500 ml, plastic 500 ml N.A. Immediately

Temperature Field Measurement

500 ml, plastic 500 ml N.A. Immediately

Specific Conductance

Field Measurement

500 ml, plastic 500 ml N.A. Immediately

Total Iron and Manganese

EPA 200 Series 500 ml, plastic 500 ml HNO3 <2 pH 6 months

Total Coliform Bacteria

Standard Method 9221D

100 ml, plastic 100 ml Sodium thiosulfite 30 hours

Note:

ml = milliliters N.A. = Not applicable

2.1.7 Phase IIA Remediation System Monitoring

The Phase IIA remediation system operation, maintenance and monitoring program is described in Maxim (1998b). In addition to collecting water samples from remediation wells on a semiannual basis (described above), regular monitoring of the remediation system will be performed. Maxim will complete the following regular monthly and quarterly monitoring tasks.

Monthly

• Inspect all equipment inside remediation building for proper operation and check for plumbing leaks, water in the building sump and flow meter operation.

• Check the Bear Creek outfall and insure there are no obstructions to flow (e.g., ice, debris).

• Record all system operational parameters presented in Maxim (2001d) on field forms including water temperatures, pressures, water flow rates, air flow rates, and valve settings.

• Perform maintenance as required including lubricating the blower and cleaning the blower air intake screen.

• Prepare a list of any equipment items that need repair.

• Check and clean the Y-strainer located in the vault for well R-2, and the R-1/R-2 canister filter in the remediation building.

Quarterly

• Collect an influent and effluent water sample for VOC analyses.

• Inspect interior of the air stripper for obstructions in the air trays via access ports.

• Measure depth to water in wells listed on Table 1.

Reporting (See Section 2.2.3)

• Issue quarterly reports to NIH within approximately one month after the end of each calendar quarter. NIH will transmit two copies of each quarterly report to MDEQ.

• Present key findings from the quarter and describe methods for operational monitoring and maintenance.

• Describe any maintenance performed and present results of system operation, groundwater elevation monitoring and influent/effluent sampling.

2.2 PRE-CWSS SCHEDULE AND DELIVERABLES

Semiannual reports described below will be prepared following each January and July monitoring event to document the data and our interpretations. Data transmittal reports documenting data collected on each property within the site will also be prepared following each semiannual monitoring event and submitted to property owners (Section 2.2.2).

The Phase IIA remediation system will be monitored monthly and influent and effluent samples will be collected each quarter (January, April, July, October). Quarterly reports described in Section 2.2.3 will be prepared to document the operation and maintenance of the system.

2.2.1 Groundwater Monitoring Reports

Semiannual monitoring reports will be prepared and submitted to NIH within 60 days of each monitoring event. NIH will transmit the reports to the MDEQ’s Remediation Division. New data will be entered into our existing project databases (Maxim 2002a) and verified. VOC analytical data from the laboratory will be transferred electronically to database. Each data summary report will include the following general components:

EXECUTIVE SUMMARY AND INTRODUCTION

An executive summary presenting key findings of the recent monitoring event will be included in each report. The introductory section will discuss previous monitoring and project activities, and will introduce data contained in the report.

METHODS

This section will briefly outline methods used in collecting groundwater level and quality data.

It will also include any deviations from the work plan in data collection and the rationale for the deviations.

DATA PRESENTATION AND INTERPRETATION

This section will present results of groundwater elevation data including inferred groundwater flow directions and gradients. Potentiometric maps for the water table, the lower portion of hydrostratigraphic Unit A and for Unit D will be presented. The report will also include a discussion of the affects of Phase IIA pumping on groundwater flow.

Results of laboratory VOC analysis of groundwater samples will be presented in tabular and graphic formats. The tabular presentation will include those data qualifiers shown on page 8 of Appendix A. Isopleth maps showing an interpretation of chloroform distribution will be presented for the shallow and deep portions of Unit A. Estimates of the acreage of the plume will be included along with a listing of all exceedances of Montana Water Quality Standards for that monitoring event. Results of annual total iron and manganese and total coliform bacteria analyses will be tabulated and presented.

DATA VALIDATION

This section will describe the data validation process discussed in the QAPP (Appendix A) used to determine the adequacy and quality of laboratory data collected during the most recent monitoring event. The objective of data validation is to identify any unreliable or invalid laboratory measurements and qualify the data for interpretive use. Discussions of field QA/QC and laboratory QA/QC will be presented and any data that needed to be qualified in accordance with the QAPP will be noted.

FIGURES

A standard assortment of maps/figures will be incorporated into each semiannual monitoring report. These include a location and site map, groundwater hydrographs for wells influenced by Phase IIA system pumping, potentiometric maps, chloroform isopleth maps for hydrostratigraphic Unit A, a cross sectional diagram of the chloroform plume in Unit A, and charts showing temporal trends in VOC concentrations in various portions of the site.

TABLES

Monitoring reports will include a list of stations monitored and a summary of VOCs detected in samples relative to Montana Water Quality Standards.

REFERENCES

This section will list cited references.

APPENDICES

Each report will contain a number of appendices that document data collected during the monitoring event. These appendices will include the well inventory database, field sampling logs, the laboratory’s QA/QC review, and the water elevation, VOC, and physical parameter databases. The hydrostratigraphic terminology used for the project will also be included in an appendix to each report.

2.2.2 Property Owner Data Summary Reports

Data summary reports for individual properties located within the site will be prepared and sent to individual property owners and copied to NIH and MDEQ within 60 days of each monitoring event. Each property owner summary report will include a listing of wells that were monitored on that property and the measured depth to water in feet below the designated measuring point. Attached to each property owner report will be an analytical laboratory report for each well that was sampled on that property presenting results of VOC analyses relative to the Montana Water Quality Standards. An informational summary of the project’s groundwater monitoring program will also be attached. An example property owner summary report is included in Appendix E.

2.2.3 Phase IIA Quarterly Reports

Quarterly reports for the Phase IIA system will be issued to NIH within approximately one month after the end of each calendar quarter. NIH will transmit the reports to MDEQ’s Remediation Division. The reports will present key findings from the quarter and describe methods for operational monitoring and maintenance. A description of maintenance performed and results of system operation, groundwater elevation monitoring and influent/effluent sampling will be presented. The reports will include a variety of tables, graphs and figures that show monitoring locations, flow data and chloroform data. Supporting information will be appended to each report. Maxim will also include a calculation for the chloroform mass recovery estimate for the quarter as well as a cumulative chloroform mass recovery estimate in an appendix to each report.

2.3 POST-CWSS GROUNDWATER SAMPLING METHODS

In accordance with the Settlement Agreement, NIH will monitor the plume of contamination for five years after the later of (a) NIH’s termination of operation of the pump and treat system at the Site, or (b) the issuance of the Certification of Completion for the CWSS. The following sections describe the methods, schedule, and deliverables for the Post-CWSS monitoring program.

2.3.1 Monitoring Locations

As part of the design and construction of the CWSS, NIH or a NIH contractor shall install five new monitoring wells outside the current perimeter of the plume to monitor the plume for possible expansion outside the boundaries of the proposed CWSS. The approximate locations and depths of these wells are defined by the Settlement Agreement. Final locations of the wells will be dependant on mutual agreement between NIH and MDEQ and an evaluation of the chloroform plume at the time of well installation. New monitoring wells will be identified according to the existing well designation scheme beginning with BR-GW-93. The approximate locations of the five new wells and the five existing wells shown on Figure 6 will be monitored on a semi-annual basis.

2.3.2 Sample Designation and Documentation

Natural water samples collected from monitoring wells will be identified according to the designation presented on Figure 6. Designations for the monitoring wells not yet drilled will be established at the time of drilling.