54
8 k_> eder associates Madison. Wl Ann Arbor, Ml Augusta. GA consulting engineers, p. c. FEDERAL EXPRESS July 6, 1992 File #497-14 Ms. Linda Nachowicz Environmental Scientist Waste Management Division Michigan/Wisconsin Branch USEPA Region V 77 West Jackson-HSRW6J Chicago, IL 60604 Dear Ms. Nachowicz: Enclosed are two copies of the Final Design Package Report for On- site Groundwater at the National Presto Industries, Inc. site, Eau Claire, Wisconsin. There were no revisions to the original set of design drawings submitted in April 1992. Please advise if you have any questions. Very truly yours, EDER ASSOCIATES CONSULTING ENGINEERS, P.C. William M. Warren Vice President WMW:sld Enclosures cc: M. Gifford, USEPA (w/1 enc.) J. Boettcher, WDNR (w/2 enc.) D. Hantz, WDNR (w/1 enc.) J. Lemcke, WDNR (w/1 enc.) Om Pat«l, Weston (w/1 enc.) R. Nauman, NPI (w/1 enc.) D. Manning, ACOE (w/1 enc.) L. Eder, EA (w/1 enc.) #L0701.1n 315 W. HURON STREET. SUITE 24O. ANN ARBOR. MICHIGAN 481O3 (313) 663-2144 FAX Q13) 747-653O

8k > eder associates consulting engineers, p. c. · e eder associates ^OFFICES: c ri ust Va"rNY Madison. Wl consulting engineers, p. c. July 6, 1992 File 1497-14 Ms. Linda Nachowicz

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8k_>

eder associates Madison. WlAnn Arbor, MlAugusta. GAconsulting engineers, p. c.

FEDERAL EXPRESS

July 6, 1992File #497-14

Ms. Linda NachowiczEnvironmental ScientistWaste Management DivisionMichigan/Wisconsin Branch

USEPA Region V77 West Jackson-HSRW6JChicago, IL 60604

Dear Ms. Nachowicz:

Enclosed are two copies of the Final Design Package Report for On-site Groundwater at the National Presto Industries, Inc. site, EauClaire, Wisconsin. There were no revisions to the original set ofdesign drawings submitted in April 1992.

Please advise if you have any questions.

Very truly yours,

EDER ASSOCIATES CONSULTING ENGINEERS, P.C.

William M. WarrenVice President

WMW:sld

Enclosures

cc: M. Gifford, USEPA (w/1 enc.)J. Boettcher, WDNR (w/2 enc.)D. Hantz, WDNR (w/1 enc.)J. Lemcke, WDNR (w/1 enc.)Om Pat«l, Weston (w/1 enc.)R. Nauman, NPI (w/1 enc.)D. Manning, ACOE (w/1 enc.)L. Eder, EA (w/1 enc.)

#L0701.1n

315 W. HURON STREET. SUITE 24O. ANN ARBOR. MICHIGAN 481O3 • (313) 663-2144 • FAX Q13) 747-653O

7INALINTERIM REMEDIAL DESIGN PACKAGE

ON-SITE GROUNDWATERFOR

NATIONAL PRESTO INDUSTRIES, INC. SITEEAU CLAIRE, WISCONSIN

eder associatesconsulting engineers, p.c

•d«r cusockrtM consulting •ngin««o, p.c.

NATIONAL PRESTO INDUSTRIES, INC. SITEEAD CLAIRE, WISCONSIN

FXH&LINTERIM REMEDIAL DESIGN PACKAGE

ON-SITE GROUNDWATERFOR

NATIONAL PRESTO INDUSTRIES, INC. SITEEAU CLAIRE, WISCONSIN

PROJECT §497-14JULY 1992

EDER ASSOCIATESCONSULTING ENGINEERS, P.C.

Ann Arbor, MichiganLocust Valley, New York

Madison, WisconsinAugusta, Georgia

gt\«it««\49714\r*port«\irdp 070392

•ctor onockitM consulting «ngin««fs, p.c.

TABU ?F CONTENTSPage

LETTER OF TRANSMITTAL1 . 0 INTRODUCTION 1

1.1 Description of the Interim Action 3

2.0 SCOPE OF WORK 13

3.0 PERFORMANCE GOALS AND STANDARDS 163.1 Groundvater Modeling of Capture Zones 16

3.1.1 Water Table Maps 173.1.2 Melby Road Pumping Test 233.1.3 Groundwater Modeling - CAPTURE 24

3.2 Cascade Aerator Efficiency 30

4.0 LONG-TERM MONITORING PLAN 354.1 Measure Performance of Treatment System 354.2 Verification of VOC Plume Capture 40

4.2.1 Melby Road Disposal Area 404.2.2 Southwest Corner of NPI Site 424.2.3 Sampling Frequency Rationale 44

4.3 Treatment System Modifications 444.4 Monitor Compliance with WPDES Permit 464.5 Reporting Requirements 46

4.5.1 Implementation Workplan 464.5.2 Construction Report 464.5.3 Progress Reports 47

LIST OF APPENDICES

Appendix A - City of Eau Claire Letter - March 26, 1992Appendix B - Pumping Test Results - Melby Road Disposal Area

(Existing Wells)Appendix C - Specifications for Remedial Design, Interim Action,

On-aite Groundwater

•dor associates consulting •nginoon, p.c.

TftBIJi 9* CONTENTS CONTINUED

T.TST Off APPENDICES CONTINUED

Appendix D - "Capture-Zone Type Curves: A Tool for AquiferCleanup1*

Appendix E - Results of On-site Sever EvaluationAppendix F - Interim Action Monitoring Well Installation ProceduresAppendix G - WDNR Letter - WPDES Monitoring Requirements

No. Description page1 Summary of Results for Detected VOCs and MCLs 62 VOC Estimates for Combined Effluent from

Cascade Aerators 343 List of USEPA Method 8010/8020 VOCs and

Detection Limits (ng/l) 37

4 Long-Term Monitoring Activities and Schedulefor First Year 38

LIST OP FIGURES

No. Description Page

1 VOC Plumes - Melby Road Disposal Area 42 VOC Plume - Southwest Corner 53 Water Table Map - May 9, 1991 - Southwest Comer 184 Water Table Map - April 1, 1992 - Southwest Corner 195 Water Table Map - August 3, 1989 - Melby Road Disposal

Area 206 Water Table Map - May 9, 1991, Melby Road Disposal Area 217 Water Table Map - April 1, 1992 - Melby Road Disposal

Area 228 Computer Predicted Capture Zone - Melby Road Disposal

Area 26

•cfer associate* consulting engineers, p.c.

TftBLE 9P COMTEMTS COHTIKUED

FIGURE

No. Description

9 VOC Plumes and Predicted Capture Zone - Melby RoadDisposal Area 27

10 Computer Predicted Capture Zone - Southwest Corner 2811 VOC Plume and Predicted Capture Zone - Southwest

Corner 29

e OFFICES:

eder associates ^criust Va"rNY

Madison. Wl

consulting engineers, p. c.

July 6, 1992File 1497-14

Ms. Linda NachowiczEnvironmental ScientistWaste Management DivisionMichigan/Wisconsin Branch

USEPA Region V77 West Jackson-HSRW6JChicago, IL 60604

Re: National Presto Industries, Inc. site

Dear Ms. Nachowicz:

Enclosed are two copies of the Final Design Package Report for On-site Groundwater at the National Presto Industries, site, EauClaire, Wisconsin. This report has been revised to addresscomments from Mr. Mike Gifford (USEPA) dated June 10, 1992 and Mr.Jim Boettcher (WDNR) dated June 5, 1992. All comments have beenincorporated with the exception of identifying the full list ofparameters for the WPDES permit. These parameters have not beenfinalized by WDNR; however, this information will be forwarded toUSEPA and WDNR upon finalization.

Please advise if you have any questions or comments.

Very truly yours,

EDER ASSOCIATES CONSULTING ENGINEERS, P.C.

William M. Warrenvice President

WMW:sld

#L0701.1n

315 W. HURON STREET, SUITE 24O. ANN ARBOR. MICHIGAN 481O3 • (313) 663-2144 • FAX (313) 747-653O

•Q9T QMOCIOtQS COftSUnfflQ OnQIIMWSf p.C

INTERIM REMEDIAL DESIGN PACKAGEON-SITE GROUNDWATER

NATIONAL PRESTO INDUSTRIES, INC. SITEEAU CLAIRE, WISCONSIN

1.0 INTRODUCTION

A Record of Decision (ROD) was signed by the U.S.Environmental Protection Agency (USEPA) on September 30, 1991,which documented the selected interim action alternative for on-site contaminated groundwater at the National Presto Industries,Inc. (NPI) site in Eau Claire, Wisconsin. The State of WisconsinDepartment of Natural Resources (WDNR) concurred with the selectedalternative in a letter dated September 26, 1991.

The Interim Remedial Design Package (Design Package) consistsof this report, engineering drawings, and specifications. Therequirements for the Design Package were set forth in the February21, 1992, Modification to the Administrative Order by Consent forthe Remedial Investigation/Feasibility Study (RI/FS) made effectiveon July 8, 1986.

As stated in the modification to the order, the Design Packagerequirements are:

1) Design specifications of groundwater extraction wells andmonitoring wells, sufficient to meet or exceed theperformance goals and standards of the ROD, to beinstalled in the southwestern portion of the site(groundwater extraction wells shall comply with ChapterNR 112, WAG, which establishes uniform and minimumstandards for the construction and maintenance of highcapacity water systems and approval is required from theWDNR private water supply section to construct andoperate the extraction wells).

III

•dor associates consulting engineers, p.c.

2) Design specifications and locations of the independentcascade aeration units for the Melby Road Disposal area(which has extraction wells in place) and in thesouthwest corner, each comprising a nine-foot concretestep structure.I

3) All necessary design components of 1) and 2) above,I including a) groundwater pumps; b) piping between the

respective extraction wells, cascade aeration units andI on-site storm sewers; c) electrical, instrumentation and

control requirements; and, d) identification of the storm

I sewer outfall location on the Chippewa River for thedischarge of treated groundwater.

I 4) Detailed discussion of a long-term monitoring program toa) measure performance of the groundwater extraction and

I treatment; b) verify completeness of contaminant plumecapture; c) determine the need for any additional

I treatment of extracted groundwater beyond cascadeaeration; and, d) monitor compliance with WisconsinPollutant Discharge Elimination System (WPDES) permitrequirements for the discharge of treated groundwater tothe Chippewa River.

5) The monitoring program shall be designed such that whenimplemented, it is capable of demonstrating theeffectiveness of the groundwater extraction system incontaining groundwater contamination plumes emanating atthe Melby Road Disposal Area and the southwestern portionof the Site. Discussions shall also include a detailedproposal for the number of locations of additionalgroundwater monitoring wells at the Melby Road DisposalArea and the southwestern portion of the Site, and thegroundwater sampling and analysis program that identifiesproposed sampling points (groundwater and treatment

•d*r ossocicrt** consuMng •ngirn ri, p.e.

influent and effluent), frequency of sampling and ananalytical parameter list.

1.1 Description of the Interim Action

The remedy selected by the USEPA and WDNR consists of plumecontainment at the Melby Road Disposal Area (Figure 1) and thesouthwest corner of the site, which is the area downgradient ofLagoon No. 1 and Ditch No. 3 (Figure 2). The on-site VOC plumes ingroundwater at these locations contain VOCs (Table 1) in excess ofthe Federal Maximum Contaminant Levels (MCLs) for TCE (southwestcorner) and PCE, TCA and 1,1 DCE (Melby Road Disposal Area). TheMCLs for these VOCs are the same as the Wisconsin NR 140Enforcement Standards. The on-site VOC plumes at each location areshown on Figure l and 2. The VOC plumes have been estimated basedon the presence of 1 Mg/1 or more of a VOC in a monitoring well.The concentrations shown on Figures 1 and 2 are the highestdetected at each monitoring well. The detection limit (0.2 Mg/1)for each VOC is shown on Figures 1 and 2. Additional monitoringwells will be installed in each area as a part of the InterimAction. Sampling of the new wells will provide additional VOCplume mapping data. The new VOC plume data will be used to updateFigures 1 and 2 which are based on Eder Associates' currentestimates of the VOC plumes. The two plumes extend off-site, whichwill be addressed in the NPI site Feasibility Study report.

The interim action at the Melby Road Disposal Area and thesouthwest corner consists primarily of two groundwater extractionwells at each location. The locations and pumping rates of theextraction wells are based on groundwater modeling, which isdiscussed in Section 3.1 of this report. The groundwater capturepredictions made by the model will be confirmed by aquifer pumpingtests and water level measurements. Extracted groundwater from thetwo locations will be piped to their respective cascade aeratorslocated near the existing NPI storm sewer as shown on Design

IIIIIIIIIIIIIIIII•

II

&m

PLUME 4:::::::::::::::.(TC£)

Eittnatod Extuntof VOC P/umr

1/510/12

NPI Property i*»MenHartnf HWI W/Numlnr *Highlit TCE/rCt/PCF Cannntratlonat Clnlfd dW (DttfcUon Limn - 0.2ug/l)

200'I

MS49714YEW-1 €) Extraction MW/ tf/Humbfr

VQC ?],TJMPS

MBBY ROAD DISPOSAL AREA*^gfcNATIONAL PRESTO INDUSTRIES. INC. SfTt_____ EAU OAmg. vacuum___;• ;....

i,.^»v

IIIIIIIIIIIpIIIIIII

•d«r OModcrtm consulting «ngin««rs> p.e.

NATIONAL PRESTO INDUSTRIES, INC SITEEAU CLAIRE. WISCONSIN

TABLE 1

SUMMARY OF RESULTS FOR DETgCTED<1) VOCs (uq/I]|ANDMCLa

I. Melbv Road Disposal Area • Continued

Well No.

MW-14

MW-15

MW-20A

MW-20B

MW-32A

MW-32B

MCL»;ij

;'•/ D#»&

10/88

10/88

10/88

5/90

4/91

10/88

5/90

4/91

7/89

5/90

4/91

7/89

5/90

4/91

TCE ;

_

-

1.1

1.1

0.5

0.4

0.5

0.7

0.6

-

felliib?|:;;;.;::;;*;i>

:; PC£i

1.9

4.0

1.5

0.5

0.7

3.0

1.0

-

0.4

0.4

0.5

1.0

1.0

09»ip»p.*::. ;;x5--;-::.8.U.;

• 1,1,1 -TCA^

83.0

130.0

83J

33.0

42J

130J

9ao63J

22.0

41.0

36J

55.0

57^>

42J^m*&&$£i ::•; :i;:-V:2UO.U ••.

"•1.1 -OCAS

81.0

75.0

32.0

5.0

10.0

63.0

16.0

20.0

3J

6.0

13.0

16.0

1&0

13.0

f 1,1 -DCE_

-

3.65

2.0

2.0

4.6J

4.0

2.0

1.0

2.0

2.0

3.0

2.0

2.0

liSlill

1.2-DC£«

_

3.7

1.5

0.2

OJ2J

2.6

0.5

0.5

0.1J

0.3

0.4

0.7

0.8

0.4

lifdS 7,0trana 100.0

Benzen*-

-—

_

;::..:::;:: :-:;:.:5;0-

•d«r associates consulting engineer*, p.e.

NATIONAL PRESTO INDUSTRIES. INC SITEEAU CLAIRE. WISCONSIN

TABLE 1 CONTINUED

SUMMARY OF RESULTS FOR DgTEC1'ED<1> VOCaANDMCLs

Well No.MW-5A

MW-5B

MW-6

MW-8

MW-9A

MW-9B

MCLs

-'''VDattfer

1/88

10/88

5/90

4/91

1/88

10/88

5/90

4/91

1/88

10/88

5/90

4/91

10/88

5/90

10/88

5/90

10/88

5/90: . '':•: , . ;:-:-:x: ':' -:";

•• -TCE:;'->0.8

1.0

1.0 J

-

0.6 J

-

-

-

-

-

-

-

0.2J

•yigiQ:

:':-: PCe^(6^

9.6

10.0

10.0

0.4

12.0

0.7

-

-

-

-

0.14J

-

te';;.5;o';:'-.-.;: •' '.-.•_.•:• • ' ' :

:'i

;:sl;1,1^TCA :

300.0

400.0

510.0

460.0J

16.0

19.0

410.0

34.0

14.0

24.0

19.0

12J

0.7J

55.0

56.0

7.5

4.0

:;;|;--ir';;::2oao:

't-i-odii120.0

210.0

180.0

220.0J

0.6

1.7

150.0

&0

-

U

3

-

-

-

0^6

-.

r.,:ii

lt.1-OCEi

3.1

5.6

5.0

3,0

0.6

5.0

0.5

0.3

1.2

0.8

0.3

2.0

1.0

2.0

1.0

0.2J

j|t ff|£o;::

;t;2-DCE«

4.0

8.3

6.0

3.0

-

10.0

0.3

_

-

-

-

-.

-

_

||i;:ds 7,o;;trans 100.0

Benzene-

-_.

..

-

. —

-

-

^; • 5.0

•d«r associate* consulting •ngirwcn, p.c.

NATIONAL PRESTO INDUSTRIES. INC SITEEAU CLAIRE, WISCONSIN

TABLE 1 (CONTINUED)SUMMARY QP RESULTS FOR DETECTED<1) VOCs

ANDMCLaI. Southwest Comer

WeU NarMW-4A

MW-48

MW-10A

MW-10B

MW-11A

MW-11B

MW-23A

.;::-;Mcul£

Data

1/8810/88

5/90

4/91

6/90

4/91

10/87

1/88

10/88

4/91

12/91

10/87

1/88

10/88

4/91

12/91

1/88

10/88

4/91

1/88

10/88

4/91

10/88: v: '.;.,: ••.:Ss;:'S:::-:

: <:;••.: :-:.:;;;:g.;:;j:;;.:y

TCE-

-

-

-

0.7

-

_

-

-

_

_

-

-

,.

-

0.87

1.0

-

-

-

0.97;l; 5&

PCS

-

-

-

-

0.2J

0.5

-

0.1J

-

-.

-

*•

-

-

0.43

0.5

-

-

-

;;.?•:' •y->::;;4;:Y:'..:i*:

^ 1,1,1-TCA

-

-

0.2J

24.0

34.0

3A)

3.0

4.7

5.0

9.0

-

-

-

29.0

91.0

13OO

0^7

_

2.3

lii;200.o:]:m:^-m

1.1-OCA

-

-

7.0

9.0

3.7J

3.0

5.2

6.0

8.0

-

1.8

9.4

7.0

-

.

1

?-VI.HDCE':----

0.2J

-

-

-

-.

_

_

-

0.5

0.4

-

-

•ill

1,2-DCE®

-

-.

-

-

-

_

-

-

?lp;'v 'ds70";r!trw»100.0

Benzene_

-

-

-

-

-

-

-

-

-

-

5.0

onodcrt** consulting engineers, p.e.

II. Southwest Comer

NATIONAL PRESTO INDUSTRIES, INC. SITE

EAU CLAIRE, WISCONSIN

TABLE 1 (CONTINUED)

SUMMARY OF RESULTS FOR DgTgCTED<1) VOCs faANDMCLa

Well No.

MW-23B

MW-34A

MW-34B

RW-2A

RW-2B

RW-2C

MCLS'il: ;

Date

5/90

4/91

10/88

5/90

4/91

6/90

4/91

12/91

6/90

4/91

12/91

7/89

5/90

4/91

7/89

5/90

4/91

7/89

5/90

4/91- . . *; ""• :>:'£r:'; :^^mm:

'' '•:': : . :" : : ' ; ••:': :¥::?-;V'

TCE

2.0

3.0

1

3.0

3.0

49.0

30.0

51.0

9.0

1.0

0.9

3.0

3.0

3J

5.0

4.0

4.0

6.0

6.0

6.0

:s-%Jt

PCE

OJ3

0.4

0.29

0.6

0.4

0.6

1.0

2J

0.1J

OJJ

.08J

-.

^J

-

_

.

_

_

.3

s.:--^ai

f'i.t,1-TCAv-

49.0

43.0

9^

57.0

40.0

6.0

8.0

10.0

1.0

1.0

0.8J

1.0

0.8

03

1.0

1.0

1.0

2.0

2.0

2.0

^S^maf

|:-;:1,1-6CA:;

5.0

5.0

6.4

8.0

5.0

2.0

5.0

10J

OJ

1J)

1.0

-

-

-

-

.5J

05

05

: i,i-ocE1.0

0.9

2.0

0.8

_

_

_

_

1.0_

-

_

-

.06J

.U_

:£xi-: •'••:. -^ • • ••

1,2-OCEO

_

_

_

0.3

0.2S

_

_

_

-

..

_

-

;:;:;:ffi;v-dr70trans 100.0

Benzene_

_

-

_

_

-

2J

-

-

5.0

III

g:\sites\497i 4\rpts\tablei

Note:

J - Estimated vatae (QA/QC criteria not within control limits).- - Not detected

Footnotes:(1) No other VOCs were detected in any sampling rounds." Total cts and trans.

IIIIIIIIIIIIIIIIIII

•d«r associates consulting engineers, p.c.

Drawing No. l. Following treatment for voc reduction in thecascade aerator, the water will be discharged to the city of EauClaire stora sewer system at the intersection of Hallie Lane andLocust Lane. This part of the City storm sewer systea dischargesto the Chippewa River at an outfall located west of theintersection of Riverview Drive and Marquette Street/Welsh Drive.The discharge will be permitted by a WPDES permit and monitoredaccording to the permit conditions.

At the Melby Road Disposal Area, the extraction well systemconsists of two five-inch diameter wells (MW-14 and MW-15) whichwere installed in 1987. These wells (renumbered EW-1 and EW-2)were equipped with pumps in July 1991. Each extraction well andassociated valves and meters will be enclosed by a pump house.Upon implementation of the interim action, EW-l and EW-2 will eachpump at 90 gpm and discharge into a 4-inch diameter pipe. Therecovered groundwater will be piped to a cascade aerator (DesignDrawing No. 1) located near the existing NPI storm sewer. Thetreated groundwater will discharge to the NPI storm sewer and flowinto the City of Eau Claire storm sewer at the intersection ofHallie Lane and Locust Lane.

Two 6-inch diameter extraction wells (numbered EW-3 and EW-4)will be installed at the southwest corner as shown on DesignDrawing No. 1. Each extraction well and associated valves andmeters will be enclosed by a pump house. The wells are locateddowngradient of Lagoon No. 1 and Ditch No. 3 and are intended tocontain the VOC plume in that area. The recovered groundwater willbe pumped to a cascade aerator which will discharge the treatedgroundwater to the same NPI storm sewer receiving treatedgroundwater from EW-1 and EW-2. This flow, combined with the flowfrom the cascade aerator serving EW-1 and EW-2, will discharge tothe City of Eau Claire storm sewer system at the intersection ofHallie Lane and Locust Lane.

10

tctor associate consulting «ngin««rs, p.e.

Recovered and treated groundwater discharged to the city stormsewer will flow to the city outfall located west of theintersection of Riverview Drive and Marquette Street/Welsh Drive.The city engineer, Brian Amundson, was consulted on storm sewercapacities during a meeting with EA staff on December 6, 1991. Theflow from the NPI recovery system will be low (less than 1 cfs) butprecautions will be taken to prevent any potential overflow problemcaused by the small reduction in pipe capacity resulting from NPI' sdischarge. A flow control device will be installed in the citystorm sewer pipe downstream of the Eddy Lane/Abby Hill intersectionshown on Design Drawing No. 1. This device consists of a floatlevel in the pipe which will transmit a radio signal to a controlswitch on the recovery well pumps. Any significant rise in thewater level in the pipe will activate the control switch and turnoff the recovery wells. The extraction wells will also beautomatically turned on when the water level in the pipe recedes.The initial increment of water level rise in the storm sewer pipeat 50% of the pipe capacity. This level was established inconsultation with Eau Claire Public Works Director, Mr. WilliamBittner, on June 18, 1992. This setting is conservative and willbe monitored during the Interim Action. Appendix A contains aletter from the City of Eau Claire expressing the City's commitmentto cooperate with NPI. The operating time logs (chart recorder)and water level measurements in monitoring wells near extractionwells will be used to determine if the recovery systems areeffectively containing the plumes. This data will be submitted toUSEPA and WDNR in the Interim Action Progress reports andsummarized in an annual report for the first three years of systemoperation. If the effectiveness of the plume containment systemsis significantly compromised by the on-off cycling of the pumps,system modifications will be evaluated and implemented to ensureproper system operation. A significant compromise of the system ispreliminarily defined as any pumping interruption longer than sixhours which occurs at a frequency of more than once during a threeday period.

11

I «d«r associate* consulting «ngin««n, p.e.

The discharge of the treated recovered groundwater will be

( permitted and monitored according to the terms of a WPDES permit.The permit application is currently being reviewed by WDNR.Preliminary requirements for the WPDES are discussed in Section

| 4.0. Data collected during the aquifer pumping test and upon fullimplementation of this interim action shall demonstrate that the

I groundwater extraction and treatment systems at the Melby RoadDisposal Area and the southwestern portion of the site fully

I capture the VOC plumes, thus preventing the off-site movement ofcontaminated groundwater from the respective source areas. It

( shall further be demonstrated that the level of treatment ofextracted groundwater is sufficient to comply with the standards inthe WPDES permit issued for the discharge of treated groundwater to

I the Chippewa River. Upon completion and evaluation of the aquiferpumping tests and ongoing evaluation of the groundwater extraction

I and treatment system; USEPA, in consultation with WDNR, willdetermine if additional extraction wells are required or if

• additional treatment of groundwater is required prior to discharge• to the Chippewa River.

IIIIIII

12

I

I

•ctor associates consulting •ngirwwr*, p.c.

2.0 SCOPE OF WORK

The design package include* the following components:

1) Installation of two 6-inch diameter extraction wells (EW-3 and EW-4) in the southwest corner of the NPI site.

2) Installation of submersible pumps in EW-3 and EW-4capable of producing up to 150 gpm each on a continuousbasis from each well.

3) All necessary electrical service and connections tooperate EW-1, 2, 3 and 4. Pumps have been installed inEW-l and EW-2.

4) Flow meters and an operating-time recorder to measureflow and any down time due to city storm sewer capacity.

5) Installation of PVC piping from each pumping location totheir respective connection locations at the existing NPIstorm sewers.

6) Installation of cascade aerators near the point whererecovered groundwater from each extraction well locationwill discharge to the NPI storm sewer. Installation ofall connecting piping from the cascade aerator to the NPIstorm sewers.

7) Necessary repairs will be made to the receiving portionof the NPI sewers to maintain the integrity of the sewersystem and minimize the potential for loss of treatedgroundwater to subsoils prior to discharge to theChippewa River. A TV survey was conducted in lateJanuary 1992 and the report is included as Appendix E inthe Design Package. Appendix E also discussed the

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edor associates consulting cngineon, p.c.

results of the sever evaluation and identifies thoseareas of the storm sewer where repairs are required.These repairs will be made during the construction of theRemedial Action.

8) WPDES Permit application for discharge to the ChippewaRiver.

9) Installation of flow monitoring device in the city stormsewer and radio relay system to turn off extraction wellsduring high flow conditions and turn them on again whenthe storm sewer water level recedes. A high flowcondition is defined as 50% of storm sewer pipe capacityat the flow monitoring station in the city storm sewer.

10) Installation of monitoring wells required to demonstrateeffective capture of the VOC plume at each location andto monitor VOC concentrations downgradient of theextraction wells.

11) Perform pumping tests at the Melby Road Disposal Area andthe southwest corner of the NPI site immediately uponimplementation of the interim action to confirm thecontainment system effectiveness.

12) Implementation of a long-term monitoring plan.

The design specifications for the components listed above areprovided in Appendix C. The installation of monitoring wells isalso described in Appendix F. Design drawings accompany thisreport that illustrate the design details and layout of the designpackage components. A QAPP and Health and Safety Plan will besubmitted to the USEPA prior to Interim Action implementation in anImplementation Workplan.

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Th« long-torn monitoring plan is presented in Section 4.0 ofthis report.

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PERFORMANCE GOALS AND STANDARDS

The performance goals and standards used for this DesignPacJca

I• Package can be summarized as follows:

1) Prevention of future off-site migration of contaminatedgroundwater at the Melby Road Disposal Area and thesouthwest corner of the NPI site as an interim action.

2) Improve off-site groundwater quality by means of plumecontainment to the extent that a significant riskreduction and restoration will occur in the aquiferdowngradient of the recovery systems.

3) Accomplish Items 2 and 3, above, during the completion ofon-site source remediation and, eventually, incorporatethis interim action into the final site remediation plan.

4) Collect data during the interim action that will beuseful in the selection of the final remedial action atthe NPI site including on-site source areas and off-sitegroundwater. Groundwater data collected during theinterim action will be used to support the selection ofa final remedy for contaminated groundwater.

Pumping extraction wells at the Melby Road Disposal Area andthe southwest corner will attain the performance goals andstandards of this interim remedial action. The following sectiondescribes the results of aquifer pumping tests at the Melby RoadDisposal Area and the use of groundwater modelling to predict thecapture zones.

3.1 Groundwater Modelling of Capture Zones

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3.1.1 Waller Table Mane

Water table naps for the two interim action areas arepresented on Figures 3 through 7. The groundwater flow directionin the southwest corner is generally toward the northwest with amore westerly flow component at the KPI western property line andin the extreme southwest corner of the site. Water table maps forMay 9, 1991 and April 1, 1992, (Figures 3 and 4, respectively) showonly slight differences in flow directions in the southwest cornerduring 1991 and 1992. MW-10A is screened in the sandstone bedrockbecause the overlying alluvial sand and gravel does not containgroundwater at this location. The sandstone is deeper to the westand north of MW-10A and monitoring wells MW-4A, 34A, 39A, 23A, 11A,and RW-2A are screened in the saturated sand and gravel overlyingthe sandstone bedrock. The sandstone bedrock slope is about 10percent in the west, northwest and north directions in thesouthwest corner. The spacing of the water table contours shown onFigures 3 and 4 reflect the transition from groundwater occurrencein bedrock to sand and gravel. The water table contours are moreclosely spaced in the vicinity of MW-10A,B and are much furtherapart at the proposed locations of extraction wells EW-3 and EW-4.Narrower water table contour spacing indicates the lowerpermeability and the greater hydraulic gradient required to movewater through the sandstone. Conversely, the wider spacing of thewater table contours at the proposed locations of extraction wellsEW-3 and EW-4 indicate higher permeability and the lower hydraulicgradient required to move water through the sand and gravelaquifer.

Water table maps for the Melby Road Disposal Area arepresented on Figures 5, 6 and 7 for August 3, 1989, May 9, 1991 andApril 1, 1992, respectively. This disposal area is located justeast of a groundwater divide that is generally oriented in anorthwest direction at the NPI site and is shown on Figures 5, 6and 7. The position of the groundwater divide shifts in response

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•d«r anoctotm aomuMJtn tn^nttn,

HW-4A.B 9 Manltortnt MM8aS.lt

Wbtff Lf¥f/

835 ——— *attr nth Omter

MW-34A.B S /'

E MAP-MAY $SOUTHWEST CORNER-NPI SITE

NATIONAL PRESTO INDUSTRIES. INC.EAU CLAHC. MSCONW ;

•dw onociotn coniutUng »ngln»«fi. p.c.TOURE 4

t

HW-4A.B9825.46 W/Humbtr an*

Waitr Lwtl

ew-3 f) Extraction HW Location

826 ——— NWw Tot* Contour

—— GrvunOwotur FlewOncthn

(1) Fftt AbWf MSL

j^-— Ut^JI &WF 4V0TT. ffWP OIn Sonttstonf

SOO"

MS49714R

WATER TABJj; MAP-APRIL 1. 1992SOUTHWEST CORNER-NPI SITE

NATIONAL PRESTO INDUSTRIES, INC. SITE JCAU CLAIME. MSCONSM

IIIIIIIIIIIIII!•IIIII

oraoclatM consulting «njk!••'•. p.c.FIGURE 9

- — — ———— NPI Property Lint

UW-5A.B $ Monitoring Well W/Number824.55 and Water L»<n/ Elevation (1)

rw-i O extraction We/I W/Numbar

——825—— *<>*"• Toblf Contour W/tltvothn (1)

^————— Groundmatrr Flow Direction

(1) reel Above USL

— —— Groundmter Divide

MAP- AUGUST 3. 1989

MS497US

MELBY ROAD DISPOSAL AREANATIONAL PRESTO INDUSTRIES, INC.

EAUCUMKE. HSCONSNSITE

•dv onectetM consultingMW-J2A.B 9

825.31

LEQBONPI Property Unt Tab1* Contour W/Elevathn (1)

Groundwoter Flow Direction

fat Above MSL

Groundwoter Divide

UW-SA.B826.2J

Monitoring Will W/Numberand Water Level Elevation (1)

Extraction Will W/Numbfr MELBY ROAD DISPOSAL AREANATIONAL PRESTO INDUSTRIES, INC.

EAU CLAJHfc

MW-32A.B W825.54 '

X «MV-9A.B .826.38 /

MV-ISAJ828.45

Water Table Contour W/Devation (1)

Groundmter Flow Direction

Feet Above USL

Groundwater Divide

NPI Property Lint

Monitoring Well W/Numb«rand Water Lent Elevation (1)

UW-5A.B826.53 WATER TABL,fl

—— MELBY ROAD ^NATIONAL PRESTO INDUSTRO, WC. 8

EAU CL*«E.

Extraction Well W/Number

•ctor oscockrtw consulting «ngin««re, p.c.

to water-table changes. Comparing the August 1989 nap with the May1991 map, the higher water levels in May resulted in thegroundwater divide moving to the south in the vicinity of MW-20A,B.The changes in the location of the groundwater divide result in themovement of VOCs, primarily TCA, to MW-20A,B. The three watertable maps show that groundwater flow at the Melby Road DisposalArea is generally to the northwest. During lower water levelperiods such as in August, monitoring wells 9A,B are more directlydowngradient than during higher water level periods, such as May.

The water table maps for the Melby Road Disposal Area indicatethat the groundwater flow direction at this location is toward theextraction wells EW-1 and EW-2. The maps indicate no significantseasonal changes in the water table which would cause a groundwaterflow direction change at the Melby Road Disposal Area itself.

The water table maps for the southwest corner indicate thatthe groundwater flow at the NPI property line is to the west andnorthwest. Groundwater at MW-34A,B also has a seasonal westerlyflow as shown on the April 1, 1992, water table map. As a resultthe VOC plume becomes much wider downgradient of Lagoon No. 1.Therefore, the most efficient location for the pumping wells iscloser to Lagoon No. l and at a pumping rate high enough to capturethe plume width. The pumping rates at EW-3 and Hf-4 have b«*Bpreliminarily estimated 4«i the OtfTtJM arouwtwmter mod« whichpredicts capture cents that could be created at various pumpingrates (see Section 3.1.3).

3.1.2 Melby Road Pmapino: Test

Extraction wells EW-1 and EN-2 were tested in July 1991 toprovide data on the permeability of the sand and gravel aquifer atthe Melby Road Disposal Area. The test results are presented inAppendix C. The test was limited to 6 hours because the combinedpumpage of the two wells could only be discharged to the sanitary

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sewer between midnight and 6 a.m. However, the results could beused to estimate the permeability and area of pumpage inducedchanges in groundwater flow direction at the end of six hours. Thepermeability (k) for the sand and gravel aquifer is 267 ft./daywhich provides a transmissivity (T) of about 60,000 gpd/ft. At theend of six hours of simultaneous pumpage, drawdown was observed atobservation wells 100 feet east of EW-1 and 100 feet west of EW-2.This capture zone was 400 feet wide and apparently expanding at theend of the six hour test.

The estimated permeability of 267 ft./day is consistent withthe range of permeabilities for a sand and gravel aquifer. Thesand and gravel aquifer in the southwest corner consists of thesame type of materials that characterize the Melby Road Disposalarea. Therefore, the same value for permeability is applicable topreliminary estimates of capture zone widths at the Melby RoadDisposal Area and the southwest corner. Groundwater modeling wasused to determine the locations for extraction wells EW-3 and EW-4in the southwest corner. A 24-hour aquifer pumping test will beperformed upon implementation of the interim action to verify thecapture zones. Any adjustments in pumping rates or extraction welllocations, including the need for additional extraction wells, asdeemed necessary by the USEPA will be made based on the pumpingtest results.

3.1.3 Groundwater Modeling - CAPTURE

The computer program used to predict capture zones created bythe extraction wells is known as CAPTURE. The model provides arelatively simple tool for determining groundwater flow pathscaused by the pumpage of up to 20 extraction wells. The programuses an analytical method for mapping steady state flow in aconfined isotropic aquifer with a uniform regional hydraulicgradient. CAPTURE is commonly used for unconfined (water table)aquifers when the amount of drawdown is small in relation to the

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saturated thickness. The model may also be used where the resultsof pumping tests indicate agreement with model predictions. Basedon the pumping test results at the Melby Road Disposal area, theCAPTURE model is appropriate because there was only 2.5 feet ofdrawdown compared to 30 feet of saturated thickness and the capturezone measured was spreading at the end of the six hour test when itwas at least 400 feet wide.

Appendix 0 contains an article entitled, "Capture-Zone TypeCurves: A Tool for Aquifer Cleanup", which provides a discussionof the CAPTURE model and mathematical parameters.

Figure 8 shows the output for CAPTURE modeling of the HelbyRoad Disposal Area extraction wells EW-1 and EW-2. The parametersused for the model are shown on Figure 8. The predicted capturezone width of 1000 feet is also shown on Figure 9 which also showsthe estimated VOC plume. The TCE and TCA values plotted on Figure9 are the highest historical analytical results at each monitoringwell.

Figure 10 shows the output for CAPTURE modeling of thesouthwest corner extraction wells EW-3 and EW-4. The parametersused for the model are also shown on Figure 11. The predictedcapture zone width is about 800 feet. The difference in thecapture zone widths at the Melby Road Disposal Area and thesouthwest corner is due to the different hydraulic gradients. Ahigher hydraulic gradient results in a narrower capture zone width.The capture zones shown on Figures 9 and 11 are plotted at thewidest portion of the captured segment of groundwater flow and alsoshow the predicted downgradient extent of the capture zone.

Figure 11 shows the predicted capture zone and demonstratesthat the extraction wells should capture the VOC plume in thevicinity of Lagoon No. 1 and Ditch No. 3. Extraction wells EW-3and EW-4 have been designed as 6-inch diameter wells with a

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Modeling Parameters*• - 267ft/doyI - .OOJ

0 - WOgp/n (CW-t)lOOgpm (EW-2)

NPI Property Lint

Hontlorlhg W*ll W/Humbtr

Extraction Wdl N/Humber

Hydrautk Conduct/vfty! - Hydraulic Crodlml

0 « Pumping Kate ofErtroct/on Well MELBY ROAD

NATIONAL PRESEAU

eaer onodotM coneuMnq unttnttrt.TOURE *

9 UW-32AIQ0.7/57/1.0

:.. . . . . . PLUME 4:

PLUME J(TCA)

• PredictedDowrtgrodlentCapture Zone

,K.MW-20AJQ1.1/I JO/3.0 UW-69

ND/24/ND

Estimated Extentof VOC Plume

NPI Property UneMonitoring Well W/Number *Highest TCE/TCA/PCE Concentrationat Circled Well

UW-3&B 91/510/12

Extraction Well W/kumber

IIIIIIIIIIIIIIIIIII

anoelotes ceniulUng tngkiMra. p.cTFIGURE 10

——————— - NPI Preptrty Um

MW-4A.B9 UcnHartig MWW/Humbtr

ExtncHen KM Locution

* - 3f7n/dayI - .0OI0 - lOOgpm (EW-3)

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MS49714X

rnMPUTER PRgljJgTED CAPTURE ZONESOUTHWEST CORNER-NPI SITE ,..*

NATIONAL PRESTO INDUSTRIES. INC. SITE__________EAU OJK- M8COM8M_______ ....^.....

«d«r associates consulting •ngin««n, p.e.

submersible pump capable of producing 150 gpm. An aquifer pumpingtest will be conducted upon implementation of the interim action,in conjunction with the long-term monitoring program, to verify theeffectiveness of the extraction well system in meeting theperformance standards. The aquifer pumping test will also aid indetermining the final number of extraction wells required toprovide plume containment in the southwestern portion of the site.In the event that the pumping test for these extraction wellsindicates insufficient plume containment at 100 gpm, the test wouldbe rerun at 150 gpm per well.

The presence of the lower permeability sandstone upgradient ofthe proposed locations of extraction wells EW-3 and EW-4 shouldresult in a larger capture zone in the southwest corner once thesewells are pumping. The groundwater flowing toward the extractionwells, under the influence of pumpage induced changes ingroundwater flow directions, will tend to be from the sand andgravel aquifer at side and downgradient locations. Upgradientgroundwater in the sandstone will move toward EW-3 and EW-4 but notat a rate fast enough to supply the pumpage rate. Therefore, thecapture zone will extend into the side and downgradient areas tosupply the pumping wells from the higher permeability sand andgravel deposits in those areas.

The attainment of performance goals and standards for plumecontainment and prevention of off-site groundwater degradation willbe demonstrated as described in the Long-Term Monitoring Plan(Section 4.0) .

3.2 Cascade Aerator Efficiency

The removal efficiency of the cascade aerator was estimated bycomparing it to a surface aerator, recognizing that the mostsignificant difference between the two is how the air and water aremixed. The cascade aerator mixes through gravity while a surface

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aerator use* mechanical agitation. The VOC removal achieved bycascade aeration through mixing and agitation created by waterfalling against a hard surface is the equivalent of the waterstream directed into the air by the surface aerator pump. Thepower generated by the cascading water can be calculated and theVOC removal rate projected through the same relationship betweensurface aerator horsepower and VOC removal.

The mixing energy can be calculated based on the dynamic headof the falling water:

QxSGxH3960

Where: WHP » water horsepowerQ - flow rate (gpm)SG - specific gravity of water (1)H * dynamic head (ft)

Once the horsepower of the falling water is known, thefollowing equation for a surface aerator can be used to determinethe voc removal efficiency for the cascade:

Ci - Co _ 454 x T x SOR x HP x a x 8<r-30)Ce Q x C,

Where: Q - flow rate (m3/hr)Ci * influent concentrationCe * effluent concentrationSOR - standard oxygen transfer rate (2.5 Ibs O2/HP hrf * oxygen transfer rate proportionately

coefficient, (0.52 for TCE)

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actor associate* consulting engineers, p.c.

a * relative rate of oxygen transfer as compared toclean water (.85 for groundwater)

0 » temperature correction constant (1.024)T » temperature of the water

Using this approach and a maximum flow rate of 200 gpm, a ninefoot high cascade would have a removal efficiency of 35% with agroundwater temperature of 20*c. If the water temperature is near10*C, the removal efficiency is estimated at 30%. Groundwatertemperature at the NPI site has been measured at 10°C in Decemberand 13°C in July. The outside air temperature should not have asignificant effect on the groundwater temperature since thedetention time in the cascade aerator is less than 30 seconds.

The estimated removal efficiencies were also calculated usingthe National Council for Air and Stream Improvements (NACI)mathematical model (Technical Bulletin No. 511) which simulates theremoval of organic compounds in treatment plant processes. Thepredicted removal efficiencies were comparable and ranged from 33-28% at groundwater temperatures of 20* and 10*C respectively.

The concentration of VOCs in the combined effluent from thecascade aerators at each interim action area can be estimated usingpreliminary predictions of VOC concentrations groundwater pumpedfrom the extraction wells. Actual concentrations will bedetermined by monitoring data after the interim action has beenimplemented.

Water samples were collected from EW-1 during the July 1991pumping tests at the Melby Road Disposal Area and analyzed forVOCs. These VOC results are used to estimate influent VOCconcentrations at the Melby Road cascade aerators and are shown inTable 2.

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The influent concentrations at the southwest corner cascadeaerators can be estimated using VOC data for monitoring wellslocated within the predicted capture zone of EW-3 and EW-4.Monitoring wells MW-4B and MW-34A are both screened in the sand andgravel aquifer and their historical VOC data can be used toestimate VOC concentrations at EW-4 and EW-3, respectively. VOCdata from MW-10A, B can not used because these wells are screenedin the sandstone bedrock.

VOC concentrations can be estimated for EW-3 and EW-4 based onthe assumption that VOC concentrations at EW-3 will be similar toVOC concentrations at MW-34A, and VOC concentrations at EW-4 willbe similar to VOC concentrations at MW-4B. This assumption is madesolely on the basis of proximity of each of these monitoring wellsto the respective extraction wells. By combining the predicted VOCconcentration at each extraction well on an equal mixture basis,VOC concentrations in the southwest corner cascade aerator can bepredicted and are shown in Table 2.

The predicted VOC concentrations in the water that will bedischarged to the City of Eau Claire storm sewer are also presentedin Table 2. The predicted VOC concentrations can be calculated bycombining the 180 gpm effluent from the Melby Road cascade aeratorand 200 gpm from the southwest corner cascade aerator assuming thelowest estimated efficiency in each cascade aerator - 30 percent.

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NATIONAL PRESTO INDUSTRIES, INC. SITEEAU CLAIRE, WISCONSIN

TABLE 2

VOC ESTIMATES (ue/D FOR COMBINEDEFFLUENT PROM CASCADE

VOC

1,1,1 TrichloroethaneTrichloroetheneTetrachloroethene1,1 Dichloroethene

INFLUENT

A

160031

B

2022.7.05

(30% Removal)A

11202.1.7

B

1415.4.5.04

608.11.3.4

NOTES: A - Melby Road Disposal Area - VOC data for influentfrom July 1991 pumping test sample analysis.

B - Southwest Corner VOC estimates calculated asfollows:

100 gpa (Ave. VOC at MW-34A) + 100 gpm (Ave. VOC atMW-4B) - 200 gpm at influent VOC concentration

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4.0 LONG-TERM MONITORING PLAN

Item 4 of the modification to the Administrative Orderrequires that a detailed Long-Term Monitoring Plan be included inthe Design Package to address the following items at the Nelby RoadDisposal Area and the Southwest corner of the NPI site:

1. Measure performance of the groundwater extraction andtreatment system.

2. A detailed proposal for the number of additionalmonitoring wells, and a groundwater sampling and analysisprogram that indicates proposed sampling points(groundwater and treatment influent and effluent),frequency of sampling and an analytical parameter list.

3. Determine the need for any additional treatment ofextracted groundwater beyond cascade aeration.

4. Monitor compliance with WPDES permit requirements for thedischarge of treated groundwater to the Chippewa River.

The purpose of this section is to provide a detaileddescription of the long-term monitoring plan that will fulfill therequirements of the four items listed above.

4.1 Measure Performance of Treatment System

The monitoring plan for measuring the performance of thegroundwater treatment system consists of VOC analysis of samples ofthe cascade aerator influent and effluent. The performance of thegroundwater extraction wells will be measured based on water levelmeasurements and analysis of samples from monitoring wells for VOCswhich is described in Section 4.2.

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Water samples for VOC analysis will be collected at eachextraction well (influent) and froa the NPI storm sewer (effluent)just downstream of each cascade aerator as shown on Design DrawingNo. 1. Samples from extraction wells (influent) will be collectedat the well head sampling point indicated on Design Drawing No. 3.The sampling procedures will be specified in the Quality AssuranceProject Plan (QAPP) to be submitted with the Implementation WorkPlan. The QAPP will also specify sampling procedures for theeffluent (WPDES compliance) collected from the NPI storm sewerdownstream of the cascade aerators. The location of this effluentsampling point is shown on Design Drawing No. 1. The samplingparameters for WPDES compliance would initially consist of VOCs,and permit required analyses which have not been finalized by WDNR.These additional analyses will be submitted to USEPA and WDNR as anaddendum for the Design Package. These samples would be analyzedby a Wisconsin certified laboratory.

Water samples for WPDES compliance (for parameters to bespecified) will be collected during the full scale pumping testsprior to implementation and during the interim action. Theanalytical results for the pumping test water samples will besubmitted to USEPA and WDNR in the Construction Report. Assumingthat the WPDES permit compliance limits are achieved, the samplingparameters and frequency will be established according to the WPDESpermit.

The sampling schedule for the first year of the interim actionis shown in Table 4. Any future modifications in the monitoringprogram proposed by NPI shall be approved by USEPA, andconsultation with WDNR, prior to implementation.

The removal efficiency during the winter months will beclosely monitored. If monitoring indicates that the VOC removalefficiency of the cascade aeration system decreases to less than 25percent, modifications shall be made to the treatment system toincrease the removal efficiency to no less than 25 percent. The

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NATIONAL PRESTO INOUSTRICS. INC. SITEEAU CLAIRE, WISCONSIN

TABLES

LIST OF USEPA METHOD 8010/8020 VOCaAND DETECTION LIMITS

DETECTIONLIMIT

Benzene 0.2Bromoform 2.0Bromomethane 4.0Carbon Tetrachloride 0.5Chlorobenzene 2.0Chloroethane 2.02-ChtoroethyMnyl Ether 5.0Chloroform 0.5Chloromethane 2.0Chlorocflbrofnomethane 0.51,3-Ofchtorobenzene 1.01.3-Dichlorobenzene 1.01.4-Oicnlorobenzene 0.5Bromodchloromethane 0.51,1 -Otehtoroethane 0.51,2-Olchloroethane 0.51,1 -Olchloroethytene 0.41,2-Oichloroethyiene 1.0Methylene ChtorkJe 2.51,2-Dichloropropane 0.5ds-1,3-Oichloropropane 2.0trans-1,3-Dichloropropane 0.5Ethylbenzene 1.01,1,2,2-Tetracnloroethane 1.0Tetrachtoroethylene 0.5Toluene 0.51,1,1 -Trtchloroethane 0.51,1,2-Trichloroethane 0.5Trichtoroethylene 0.5Vinyl Chloride 0.2Trichlorofluoromethane 1.0Dicrtlorodffluorornethane 2.0m&p-Xylene 1.0o-Xylene 1.01,1,2-Trtchtorotrifluoroethane 1.0

NATIONAL PRESTO INDUSTRIES, INC. SITEEAU CLAIRE, WISCONSIN

TABLE 4

LONG-TERM MONITORING ACTIVITIESAND SCHEDULE FOR FIRST YEAR '

SAMPLE LOCATIONSAND PARAMETERS

INTERIM ACTION ACTIVITY

FULL-SCALE PUMPINGTEST (24 HOUR!

GROUNDWATER ON-SITE EFFLUENTMONITORING MONITORING

WPDESCOMPLIANCE

1) Extraction Wells (EWl-4)VOCS

WPDES Parameters

Water Levels2) Monitoring Wells &

Cascade AeratorsA) Mefcy Road

•VOCs at MW-9A.B: 64A.B65A.B

•VOCsalMW-5A,B;6.62A.B; 63A.B; 66A.B

•Water Levels at MW-5A.B;6; 9A.B; 62A.B; 63A.B;64A.B; 65A.B; 66A.B

'Cascade Aerator No. 1VOCs (effluent)

Per WPDES Permit

Per WPDES PermitPer Test Procedures

Per Test Procedures

Per WPDES Permit

Weekly-Monthly

Weekly-Monthly

Monthly

Monthly

2)

Weekly-Monthly

Weekly/Monthly

1

•pn

NATIONAL PRESTO INDUSTRIES, INC. SITEEAU CLAIRE, WISCONSIN

TABLE 4 (Continued)

LONG-TERM MONITORING ACTIVITIESAND SCHEDULE FOR FIRST YEAR

i)

SAMPLE LOCATIONSAND PARAMETERS

INTERIM ACTION ACTIVITY

FULL-SCALE PUMPINGTEST (24 HOUR)

GROUNDWATER ON-SITE EFFLUENTMONITORING MONITORING

WPDESCOMPLIANCE

B) Southwest Corner

*VOCsatMW-23A.B;39A.B;68A.B;60A.B

Monthly

•VOCs at MW-4A.B; 10A.B;34A.B; 67A.B; 70A.B71A.B

•Water Levels at MW-4A.B;10A.B;11A,B;23A.B;67A.B; 68A.B; 69A.B;70A.B; 71A.B

•Cascade AeratorNo. 2 VOCs (effluent)

9) Effluent Monitoring LocationWPOES Parameters

Per Test Procedures

Per WPDES Permit

Monthly

Weekly-Monthly

Weekly/Monthly ,Per WPDES Perm!

1) Subject to request for revision based on first 6 months of data. Any future modifications in the monitoring programproposed by NPI shad be approved by USEPA, In consuttallon with WDNR, prior to implementation.

2) Once a week for the first four weeks of operation, then monthly.

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design of any required modification would be submitted to USEPA forapproval as an addendum to the Design Package.

The influent and effluent sampling schedule will be maintainedduring the interim action period. The final site remediation planwill contain provisions for continued sampling as related to theachievement of groundwater clean-up goals.

4.2 Verification of VOC PlijiB? Capture

4.2.1 Melby Road Disposal Area.

Plume capture at the Helby Road Disposal Area will beaccomplished by pumping extraction wells to modify groundwater flowdirections within the plume. The locations of the two extractionwells at the Melby Road Disposal Area were determined based on thelocation of the two trenches containing spent forge compound, andVOC data from monitoring wells MW-5A,B, MW-6, MW-7 and off-sitewells MW-9A,B. Sampling of the extraction wells EW-1 and EW-2(previously numbered MW-14 and MW-15) was also used to map the VOCplume. The sampling of all monitoring wells at and near the MelbyRoad Disposal Area indicates that MW-5A,B are located in the zoneof highest VOCs within the plume. Pumpage of EW-1 and EW-2 willcontain the plume and prevent its off-site migration.

Five additional monitoring well clusters will be installed toverify VOC plume containment at the Melby Road Disposal Area andestablish a database to support the selection of a final remedy forcontaminated groundwater. The locations of the additionalmonitoring well clusters are shown on Design Drawing No. 1. Thetwo sidegradient monitoring well clusters (MW-62A,B and MW-63A,B)are located 100 feet east and west of EW-1 and EW-2, respectively.These locations were based on the July 1991 pumping tests andgroundwater capture modeling which indicated water table drawdownshould occur at these distances. The width of the aquifer

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I monitored will be sufficient to verify plume containment.Monitoring well cluster 64A, B will be installed downgradient of the

I extraction wells. MW-64A,B was located based on a northwest* groundwater flow direction indicated by repetitive water level

( measurements between 1987 and 1991. The water table maps indicatesome variation in flow direction between west and north.Monitoring well clusters MW-65A,B and MW-66A,B will be installed to

I monitor groundwater flow toward the west from the Melby RoadDisposal Area. Groundwater in this area can flow to the west under

I the influence of the buried valley as indicated by the presence ofVOCs at MW-20A,B. With the addition of MW-64A,B, 65A,B, and 66A,B

I there will be four downgradient monitoring well cluster locations• (MW-64A,B; MW-65A,B; MW-66A,B: and MW-9A,B) to monitor the

reduction in off-site VOC concentrations in groundwater resultingfrom the interim action. Monitoring well installation will complywith the NPI RI/FS site QAPP and NR-141. To establish baseline VOClevels, all new monitoring wells will be sampled prior to theaquifer pumping test and implementation of the Interim Action.

III Verification of plume capture at the Melby Road Disposal Area

( will be determined by water table mapping using water levelelevation data from recovery wells EW-l and EW-2; and monitoringwells MW-5A,B; MW-6; MH-9A,B; MH-62A,B; MW-63A,B; MW-64A,B; MW-

I 65A,B; and MW-66A,B. Water table maps will be prepared based onweekly water level measurements made during the first four weeks of

I full scale operation and submitted to USEPA in the ConstructionReport. Continued VOC plume containment during seasonal changes in

I the water table will be verified by monthly measurements made atthe time of the treatment system performance sampling during the

I first year. Any decrease in water level measurement frequencywould be based on the first year of data. Future water levelmeasurements will be scheduled, when possible, to coincide with the

I recovery system performance sampling. Groundwater flow directionmaps will be prepared for water table monitoring wells (A-prafix)

I and lower aquifer monitoring wells (B-prefix).

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Plume containment at the Melby Road Disposal Area will also beverified by sampling, and VOC analysis, of monitoring wells MW-5A,B; MW-9A,B; MW-62A,B; MW-63A,B; MW-64A,B; MW-65A,B; and MW-66A,B. The sampling and analytical procedures will be specified inthe QAPP to be submitted as part of the Implementation Workplan.Off-site downgradient monitoring wells MW-9A,B;MW-64A,B; and MW-65A,B; will be sampled for VOCs on a monthly basis in order tomeasure the reduction in VOCs in off-site groundwater resultingfrom the interim action. On-site monitoring wells MW-5A,B; MW-6;MW-62A,B; MW-63A,B; and MW-66A,B will be sampled for VOCs on amonthly schedule. After the first six months, the samplingschedule for these monitoring wells will be evaluated as describedin Section 4.2.3. The final sampling schedule, including number ofmonitoring wells, frequency of sampling and analytical parametersshall be approved by USEPA, in consultation with WDNR, prior toimplementation.

4.2.2 Southwest Corner of NPI Site

Plume containment at the southwest corner of the NPI site willbe verified using the same methodologies described for the MelbyRoad Disposal Area. Pumpage of EW-3 and EW-4 at a projected rate of100 gpm, each, will modify groundwater flow directions in thevicinity of the extraction wells and is intended to result in VOCplume containment. The locations of EW-3 and EW-4 were determinedbased on: 1) the location of Lagoon No. 1 and Ditch No. 3; 2) VOCdata from on-site monitoring well clusters (MW-4A,B, MW-10A,B, MW-11A,B and MW-34A,B and downgradient monitoring well clusters MW-23A,B, MW-39A,B and RW-2A,B,C; and, 3) water table maps preparedfrom water level measurements between 1987 and 1991.

Five additional monitoring well clusters will be installed inthe southwest corner of the NPI site to verify plume containment.Each monitoring well cluster will be installed similar to existingmonitoring well MW-4A,B. Monitoring well installation procedures

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I are described in Appendix F. These additional monitoring wellclusters identified as MW-67A,B; MW-68A,B;MW-69A,B; MH-70A,B and

I MW-71A,B are shown on Design Drawing No. 1. Existing wells MW-4A,B, MW-34A,B, MW-39A,B, MW-23A,B and RW-2A,B,C will be used along

( with the additional monitoring well clusters to verify that theplume is being contained in the southwest corner of the NPI site.

I Plume containment will be verified by groundwater flow mappingusing data from monitoring wells MW-4A,B; MW10A,B; MW-11A,B; MW-

I 23A,B; MW-34A,B; MW-39A,B; MW-67A,B; MW-68A,B; MW-69A,B; MW-70A,Band MW-71A,B. The current groundwater flow direction in the

I southwest corner of the NPI site is to the northwest. Pumpage ofthe extraction wells will result in mappable changes in the

I groundwater flow direction. Groundwater flow maps will be preparedfor the upper (A suffixed wells) and lower (B suffixed wells)portions of the sand and gravel aquifer during the interim action.

I During the first four weeks of full scale recovery systemoperation, water level measurements will be made on a weekly

I schedule at the time of influent and effluent sampling of thecascade aerators. Groundwater flow maps prepared for this period

I will be submitted to USEPA in the Construction Report. ContinuedVOC containment will be verified during seasonal changes in the

I water table by monthly measurements made at the time of theI recovery system performance sampling during the first year. Any

decrease in water level measurement frequency would be based on theI first 6 months of data. Future water level measurements will be

scheduled, when possible, to coincide with the recovery systemI performance sampling.

I Plume containment will also be verified by sampling monitoringI wells MW-4A,B; MW-10A,B; MW-23A,B; MW-34A,B; MW-39A,B; MW-67A,B;

MW-68A,B; MW-69A,B; MW~70A,B; and MW-71A,B. These groundwaterI samples will be analyzed for VOCs by Hazelton Laboratories

pursuant to the QAPP which will be submitted as part of theImplementation Workplan. Property line monitoring wells MW-23A,B;

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MW-39A,B; MW-68A,B; and MW-69A,B will be sampled on a monthly basisin order to measure the reduction in VOCs in off-site groundvaterresulting from the interim action. On-site monitoring wells MW-4A,B; MW-10A,B; MW-34A,B; MW-67A,B; MW-70A,B and MW-71A,B will besampled for VOC analysis on a monthly basis. After the first sixmonths, the sampling schedule for these wells will be evaluated asdescribed in Section 4.2.3. The final sampling schedule, includingnumber of monitoring wells, frequency of sampling and analyticalparameters shall be approved by the USEPA, in consultation withWDNR, prior to implementation. The sampling procedures will bespecified in a QAPP submitted with the Implementation Workplan.

4.2.3 Sampling Frequency Rationale

Upon implementation of the Interim Action, the monitoringwells at the southwest corner and the Melby Road Disposal Area willbe monitored monthly in order to accurately plot the rate ofdecrease in VOCs in groundwater. The monthly monitoring isproposed in order to reduce the possibility of using data outliersas a representative concentration in groundwater. Data outliersmay be in the form of quality control problems or small transientvariations in VOC concentrations in groundwater. The overall trendof remediation can be more easily evaluated with the monthlysampling data.

The sampling schedule will be evaluated after six months ofdata collection. A change to a quarterly sampling schedule for allor selected monitoring wells may be appropriate at that time. Anyfuture modifications in the monitoring program proposed by NPIshall be approved by USEPA, in consultation with WDNR, prior toimplementation.

4.3 Treatment System Modifications

Monitoring data from the cascade aerator influent and effluent

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will be used to determine: l) the removal efficiency of cascadeaeration; and, 2) if treatment system modifications are required tomeet permit limits or maintain a removal efficiency for VOCs of noless than 25 percent. Cascade aerator influent and effluentmonitoring data will also measure removal efficiency and anyseasonal variations that may occur.

Influent and effluent samples will be collected during thefull scale pumping tests conducted prior to implementation of theinterim action. These samples will be collected during the 24-hourpumping tests at the Melby Road Disposal Area and the southwestcorner of the NPI site. Water samples will be collected after 12hours and 24 hours of pumping at each extraction well anddownstream of the cascade aerator at the locations shown on DesignDrawing no. 1. These water samples will be analyzed for VOCs,polynuclear aromatic hydrocarbons (PNAs), and Target Analyte List(TAL) metals. The analyses will be performed by a Wisconsincertified laboratories using USEPA SW-846 Methods Chloride andhardness samples will also be collected at the time of VOC and PNAsampling and analyzed using WDNR approved methods for the WPDESpermit application. All laboratory SOWs will be included in theQAPP submitted as part of the Implementation WorJcplan.

Analytical results from samples collected during the 24-hourtest will be used to determine the need for treatment systemmodification prior to implementing the interim action. Theseresults will be submitted to USEPA in the Construction Report alongwith recommendations for treatment system modifications, ifrequired.

During full-scale operation, monitoring data for compliancewith the WPDES permit will also be used to evaluate the need fortreatment system modification.

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4.4 Monitor Compliance with WPDES Permit

The WPDES permit application is being reviewed by WDNR.Following the WDNR chemical specific review, the WDNR willdetermine permit limits and requirements for aquatic life toxicitytesting. The WDNR letter of December 6, 1991, (Appendix G) , statedthat the compliance monitoring plans may be established accordingto two choices requiring either aquatic life toxicity testing witha reduced monitoring frequency or a more rigorous monitoringfrequency without the aquatic life toxicity testing.

A plan to monitor compliance with the WPDES permit will besubmitted as an addendum to the Design Package, once WDNR completestheir review.

4.5 Reporting Requirements

After USEPA and WDNR review and approval of the DesignPackage, it would be appropriate to implement reportingrequirements listed in the following sections.

4.5.1 Implementation Workplan

This document would consist of a plan to implement the interimaction including schedules and progress reports. It would alsoinclude a QAPP and HASP for construction activities and long-termmonitoring.

4.5.2 Construction Report

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construction report would document and certify that the interimaction was installed as designed and is capable of meeting theperformance goals and standards. It would also contain anyrecommendations for modifications to meet the performance goal andstandards or WPDES permit conditions.

4.5.3 Progress Reports

Monthly progress reports would be submitted to USZPA startingone month from the approval date of the Design Package. Theprogress reports would contain a discussion of the work performedduring the previous month, results of analyses, problemsencountered and work scheduled for the next month. It would alsocontain reports of milestone events such as at the end of the firstyear of operation and any recommendations to revise the frequencyof data collection.

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