Stages of Site Investigation

CHAPTER 5 - CONDUCTING THE INITIAL SITE INVESTIGATION
hen the information gathered during the background investigation

suggests that hazardous substances may be present on the site, an
investigation must be performed to determine whether and to what
extent the site is contaminated, and to identify exposure pathways that may
require assessment and remediation. This phase begins with a comprehensive
planning process that requires the participation of technical staff from various
disciplines. The process concludes with an evaluation of presumptive remedies
after completion of the initial site investigation. The data gathered during the
initial site investigation may show that a certain presumptive remedy is
appropriate and may be cost effective.
The initial investigation, as outlined in this chapter, begins with the development
of a conceptual model, followed by site screening and systematic planning process
to determine the scope of work which may include geophysical or remote sensing
surveys, soil borings, and monitoring well placement. The planning process
requires the participation of technical staff with various disciplines and expertises
(e.g., statistician, risk assessor, hydrologist, etc.) The strategy is to adequately
characterize the composition of the waste material and sample potentiallyimpacted media in order to evaluate the typical exposure pathways associated
with dump sites. Examples of this strategy are: 1.) leachate, if observed or
detected, should be sampled, 2.) a geophysical survey is recommended for sites
where waste burial histories are unknown or where site boundaries are unclear,
and 3.) monitoring wells are drilled and screened in strategic locations to learn
whether groundwater exists, and if so, in which direction it is flowing.
The seven basic parts of an initial site investigation are:
1. systematic, comprehensive project planning to establish the scope of work;
2. evaluating information obtained during the preliminary investigation and
site visit;
3. site screening;
4. conducting an intrusive investigation to evaluate whether hazardous substances are present;
5. evaluating exposure pathways for the hazardous substances that are
detected;
6. evaluating whether hazardous substances are detected at concentrations
that exceed the applicable clean-up criteria; and
7. evaluating whether further site investigation is necessary.
Guidelines for Closure of

Abandoned Dump Sites
Rouge River National Wet Weather

Demonstration Project
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I:rouge2:dumps:dumpdoc:chap5a.wpd
5.1
EVALUATION OF INFORMATION GATHERED DURING THE BACKGROUND INVESTIGATION

The information and data collected during the background investigation should
be carefully reviewed, focusing on the potential for undetected environmental
contamination on or migrating from the property. Conclusions drawn at this point
will form the basis for investigating these conditions and identifying the potential
human health or environmental risks. These conclusions are then summarized
in a conceptual site model (CSM), one form of which consists of an illustrated
overview of the site dynamics.
5.2 CONCEPTUAL SITE MODEL
The CSM is a depiction of a site that illustrates suspected sources and types of
hazardous substances present, contaminant release and transport mechanisms,
affected media, exposure points, exposure routes, primary receptors, and
secondary receptors. Generally, a CSM is based on evaluation of the existing data
and information and is developed before any field activities are conducted. The
CSM can be used as a tool to identify and/or possibly eliminate certain hazardous
substances or exposure pathways from further consideration. For example, if it
is known that volatile organic compounds (VOCs) are not present at the site, it can
be assumed that inhalation of VOCs is not an exposure pathway. Typical CSMs
include the following:
! Suspected sources, types, and estimated quantities of contaminants
present,
! Geologic/hydrogeologic environment at and around the source area,
! Contaminant release, transport and fate mechanisms,
! Rate of contaminant release and transport,
! Affected media,
! Known and potential routes of migration,
! Extent of contamination.
! Known and potential human and environmental receptors,
! Potential for hot spots.
The CSM should be revised and updated as investigations reveal new information
and data about a site. Assumptions or hypotheses presented by the CSM are
tested, refined, and modified throughout the site investigation. The development
and use of a CSM typically includes the following steps:
1. Collection of Existing Site Data and Information - Site data and information
includes, but is not limited to, site sampling data, historical records, aerial
photographs, maps, and observations from the site visit.
2. Organization and Evaluation of Existing Site Data - If there is sufficient
existing data, perform a preliminary evaluation of potential exposure
pathways and receptors.

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3. Prepare a Preliminary Diagram of the CSM - Prepare an illustration of the

site conditions, including source areas, exposure pathways, and potential
receptors. An example of a CSM diagram is shown on Figure. 5-1.
A more sophisticated form of CSM is a flow chart that shows all the same
parameters as in the schematic diagram but also includes a listing of receptor
populations, all pathways of exposure, whether or not each pathway is complete,
and which pathways are included in the site risk assessment. This format allows
changes in the CSM to be easily made and identified.
The CSM can be used to focus attention on the hazardous substances or areas of
concern that pose the greatest risk, and to help identify and evaluate preliminary
remedial action alternatives. In addition, the CSM is an internal part of the
decision-making process in choosing the appropriate elements of a presumptive
remedy.
5.3 SITE SCREENING
Site screening can be defined as utilizing investigative tools and instrumentation
that minimize disturbance to the site (i.e, are non-intrusive) to gather preliminary
information on whether hazardous substances are present on the site. Site
screening is conducted to identify areas of potential contamination, qualitatively
define the areal extent of fill or hazardous substances, identify potential transport
and exposure mechanisms, as well as areas which may require further
investigation.
Field screening also is an effective and economical tool for generating site data.
With the constraint of a limited sampling budget, field analytical screening, with
laboratory confirmation of the screening results, can produce a more
comprehensive analytical database at lower cost than by using offsite laboratory
analysis. Field Screening is typically done in the following manner:
5.3.1 SELECT SCREENING INSTRUMENTATION
Field screening instruments provide real-time or immediate reading capabilities.
These screening instruments can typically detect the presence of contaminants (if
present at high enough concentration) and narrow the possible groups or classes
of chemicals for laboratory analysis. Once an area of concern is identified using
field screening techniques, a subset of samples can be sent for laboratory analysis
to verify the screening results. When using field screening methods and
instruments, it is crucial to follow standard operating procedures, including
instrument calibration, performance checks, and record keeping. Table 5.1 lists
many of the common field screening instruments, their application, and
advantages and disadvantages.


5-3
5-4
Table 5.1
Field Screening Instruments
INSTRUMENT
APPLICABILITY
ADVANTAGES
DISADVANTAGES
Flame Ionization
Detector (FID)
Detects organic
gases and vapor in
air, soil, and waste;
useful in
determining areas of
concern
Widely used and

available; can be used
for total detectable
gases and vapors, or in
a gas chromatograph
(GC) mode for a specific
compound; can be
used in humid and cold
weather; direct reading
Used for organic vapors only;

detection is non-specific in the
survey mode; requires experience
to operate (especially in the GC
mode); detects in the ppm range
Photo Ionization
Detector (PID)
Detects organic and

some inorganic
gases and vapor in
air, soil, and waste;
useful in
determining areas of
concern
Widely used and

available; direct
reading; detects some
inorganic compounds
Detection is non-specific;
requires experience; not effective
in humid or cold weather;
affected by electrical sources;
does not respond to methane;
depends on lamp eV; does not
respond to any compound with a
higher ionization potential than
its probe (probes with varying
ionization potentials are
available); detects in the ppm
range
Portable Gas
Chromatograph
(GC)
Detects organic
gases and vapor in
air, soil, and waste
New portable GCs are

much like the PID but
can also give
compound specific
concentrations of
organic vapors
immediately;
immediate results; can
detect below 1 ppm for
some compounds; data
can be downloaded
directly from the
instrument into a
computer; effective in
high humidity
Requires specific modules for

various compounds or to work in
PID mode, therefore, the user
must have an idea what to screen
in advance; not effective at low
temperatures; data tabulation
requires some experience
X-Ray
Fluorescence
(XRF)
Field detection of
arsenic, antimony,
barium, cadmium,
chromium, copper,
iron, lead, mercury,
nickel, selenium,
and zinc
Rapid analysis of
metals; user can
analyze an unlimited
number of samples to
generate data of known
quality (with lab
confirmation) meeting
QA level 2; can use a
generic calibration
model for locating
points for further lab
analysis
Requires experience; 10 samples

must be analyzed in lab for QA
level 2; site-specific calibration
curve is needed; results can vary
in heterogeneous samples; soil
cover of 0.5 cm may mask a hot
spot; soil moisture affects result;
high detection limits, in the ppm
range; not widely available.


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INSTRUMENT
APPLICABILITY
ADVANTAGES
DISADVANTAGES
Field Detection
Kits
Detects specific
compounds, or
specific properties,
in soil, waste, and
water (e.g., PCB or
pesticide kits; Haz
Cat kits for
examining
parameters such as
reactivity, pH,
flashpoint,
ammonium,
chlorine, cyanide,
sulfides)
Rapid results; easy to

use with some training;
low cost; kits may be
customized to user
needs; semiquantitative
Limited number of kit types

available; interference by other
chemicals; colorimetric
interpretation is needed;
detection level dependent upon
type of kit used; soil moisture can
affect results; some tests require
experience to interpret results
Real-time Aerosol
Monitor
(RAM)/mini RAM
Real-time detection
of particulate matter
in air
Not much experience

needed to use; can
detect dusts, fumes,
smoke, fogs, etc., gives
direct reading
Cannot detect specific

compounds
Detector Tubes
Qualitative air
monitoring for
specific vapors
Easy to operate;
available for many
different compounds;
gives direct reading of
vapor concentration;
widely available
Must have specific tubes

available (must know what you
are monitoring for ahead of time);
some tubes are cross sensitive
(e.g., HCL tube may detect CL or
NO2); detection time is slow;
there is no advance warning
when vapor is present; accuracy
is + 20%
Monitor Gas
Monitor
Detection of various
specific gases (e.g.,
H2S, HCN, NO2 )
Needs no experience;
passive; simple
audible alarm if
concentrations of the
gas rises above TLV;
widely available
Certain monitors may be cross

sensitive to other gases (e.g., the
HCN monitor is cross sensitive to
H2S, HCl, and Cl2)
Radiation Meter
Detection of alpha,
beta, and gamma
radiation
Allows immediate
detection of radioactive
materials; direct
reading; widely
available; needs little
experience to operate;
audible detection mode
Most probes cannot distinguish

between beta and gamma
radiation; many detectors may
detect beta and gamma, but not
alpha (even if alpha is present);
must have specific probe for
alpha; must be lab calibrated;
requires experience to interpret
results.
Combo meter
(CGI, O2, H2S)
Detection of
combustible gas
(CGI), O2, and H2S,
in air
Fully automatic; 3-way

audible alarm; can give
TWA for H2S; direct
reading; widely
available; needs little
experience to operate
Used mainly for health and safety

purposes and not
environmental screening,
however, the ability to monitor
H2S is useful.


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INSTRUMENT
APPLICABILITY
ADVANTAGES
DISADVANTAGES
Mercury Vapor
Analyzer
Analysis of mercury
vapor in air
Direct reading with

real-time concentration
levels
For vapors only; instrument

probe cannot come in contact
with dust or liquid; requires
experience to operate; not readily
available
Conductivity
Meter
Screening of
groundwater
Immediate detection of
potentially-impacted
groundwater; high
conductivity is an
indication of possible
contamination
Not definitive; not compound

specific
High volume air

sampling pumps
Used to determine
particulate and/or
VOC type, size, and
quantity
Sample media available

for many different
compounds and
particulates
Requires experience; offsite

laboratory analysis must be used
for channel testing
Personal air
sampling
VOC and particulate

sampling for worker
exposure and
contaminant
specification
Many sampling
scenarios for VOC and
particulates
Requires training for use; off-site

laboratory analysis must be used
for chemical testing
Notes:
H2S=hydrogen sulfide
HCN=hydrogen cyanide
NO2=nitrogen dioxide
HCl=hydrogen chloride
Cl2=chlorine gas
O2=oxygen
TLV=threshold limit value
TWA=time weighted average
5.3.2 SELECT THE SCREENING LOCATIONS

The selection of screening locations should be based on the results of the
information investigation and the site visit. Examples of areas that warrant site
screening are: 1.) locations where wastes were buried; 2.) areas where there is
evidence of stressed vegetation; 3.) leachate seeps; 4.) points where there is evidence
of material spillage; 5.) areas with little or no site cover; and 6) areas with animal
burrows.
5.3.3 ANALYZE SELECTED SAMPLES AT AN OFFSITE LAB
Samples from known or suspected source areas should be submitted to an offsite
laboratory for full chemical characterization.
The results will enable the
investigation team to evaluate potential contaminants at their method detection
limits (MDLs), and confine future sampling and analysis to those substances that
are detected above the MDLs. It is important to ensure that laboratory data in all
phases of the investigation are of sufficient quality to allow the drawing of
conclusions regarding future investigation and eventual closure. In Michigan, the
MDEQ has provided guidance on MDLs in Operational Memorandum #6.

5-7
Away from source areas, a limited number of indicator parameters may be selected
for analysis (e.g., lead, PAHs) based on the suspected hazardous substances.
Although approved sampling and laboratory methods must be used for all offsite
laboratory analysis, this approach will result in significant cost savings over a full
chemical analysis of each sample.
The USEPA recommends analysis of at least 10% of the screening samples at an
offsite laboratory to evaluate MDLs and the potential bias of screening methods
(USEPA, 1991). The samples chosen for analysis should be representative of
locations at which hazardous substances were detected by the field screening
instruments. If no contaminants were detected by the field screening instruments,
the samples submitted for laboratory analysis should be a random selection of
several media.
To meet screening objectives, USEPA quality assurance/quality control (QA/QC)
objective level 1 (QA1) is appropriate (USEPA, 1991). The QA1 objective applies
when a large amount of data are needed quickly and relatively inexpensively, or
when preliminary screening data is not required to be chemical or concentration
specific. QA1 requirements are used with data from field analytical screening
methods to prepare a quick, preliminary assessment of site contamination.
Examples of QA1 objectives include:
!
!
!
!
determining physical and/or chemical properties of samples;

determining the extent and degree of contamination;
conducting a preliminary health and safety assessment; and
determining waste compatibility.
The Quality Assurance requirements for QA1 are:

! Sample documentation (e.g., chain-of-custody form)
! Instrument calibration data or a performance check of a test method
! Determination of detection limits, if appropriate
5.4
CONDUCTING THE INITIAL INVESTIGATION
5.4.1 DETERMINING THE SCOPE OF THE INVESTIGATION

The objective of the initial investigation is to detect hazardous substances, if they
are present, at a level of confidence sufficient to evaluate all suspect areas and
potential exposure pathways. At this point in the process, all available information
and data should be reviewed and evaluated for the purpose of developing an
investigative approach and a scope of work for this phase of the project. If
necessary, an additional site visit may be conducted to verify potential data gaps
and refine the proposed scope of work.

5-8
The scope of work should define the methods that will be used to conduct the
investigation (a geophysical survey, leachate sampling, test pits, soil borings,
monitoring wells, etc.); the media that will be sampled (soil, groundwater, sediment);
the sampling locations and quantities; and the analytical parameters for laboratory
analysis. Detailed information on the application of these technologies is provided
in subsequent parts of this chapter.
5.4.2 PREPARATION OF A WORK PLAN DOCUMENT
A formal work plan document should be developed and should include: 1.) the
scope of the investigation; 2.) investigation methods; 3.) sampling locations; 4.)
analytical parameters; 5.) quality assurance procedures, 6.) a cost estimate; 7.) the
project schedule; and 8.) project deliverables.
The work plan document should identify field and management personnel, and their
duties and responsibilities. However, it should be remembered that, while it is
essential to have a well-defined plan, a good scope of work is flexible and may be
revised during the investigation, if appropriate.
5.4.3 PREPARATION FOR INITIAL SITE INVESTIGATION
Prior to conducting the site investigation, several preparatory steps, discussed
below, must be undertaken. They are essential to the success of the investigation
and should be considered carefully before commencing field activities.
5.4.3.1 Obtaining Site Access
In order to conduct field activities, it will be necessary to obtain site access from all
affected property owners. This may include adjacent property owners, if access to
the site affects adjacent sites. Due to potential legal issues, it is recommended that
written permission be obtained from each affected property owner. An example of
a typical access agreement is presented in Appendix C.
5.4.3.2 Obtaining Utility Clearance
The locations of aboveground and underground utility corridors should be
determined using several sources of information.
These sources can be
summarized as follows:
! Site Inspection: Visual inspection of the site may reveal sewer lines and other
buried utilities, and above ground power lines that may interfere with field
activities (i.e., drill rig)
! Utility Companies: Water, electric, and gas companies will provide detailed
information on locations of buried utilities.
! Current Site Owner(s): Blueprints or other detailed site diagrams, current
and historical, may be available from the current site owner(s).
! Miss Dig Utility Alert: In Michigan, a utility locating service known as Miss
Dig Utility Alert (800-482-7171) will mark all the known utility lines for a site.

5-9
Similar services are available in other states.

5.4.3.3 Field Preparation And Mobilization
Proper field preparation is essential to the success of a field investigation. Field
preparation activities include equipment testing, calibration and decontamination
and acquiring and organizing sampling and testing equipment (i.e., tools, laboratory
bottles, meters, protective clothing). In addition, prior arrangements should be
made for disposal of investigation-derived waste.
5.4.3.4 Preparation of an Investigation Schedule
A project schedule should be developed that includes the time required for each
work activity. A detailed schedule of the investigation activities can potentially
avoid unnecessary delays by identifying interdependent work tasks. Typically, the
site manager needs a detailed project schedule for purposes such as site planning,
development, health and safety, or regulatory requirements.
The project manager should carefully schedule field activities to ensure that all
subcontractors are well informed of their responsibilities, and to avoid delays
and/or potential conflicts. In addition, the project manager should provide any
required notification of field activities to regulatory agencies or other interested
parties.
5.4.3.5 Preparation of a Health & Safety Plan
Any project involving field work for which the likelihood exists that a worker will
come in contact with hazardous substances or conditions, will require preparation
of a site-specific health and safety plan (HASP). The purpose of the HASP is to
provide information for site workers about the physical and chemical hazards that
may be encountered at the site. The HASP describes the health and safety guidelines for the protection of on-site personnel, visitors, and the general public. The
document should contain the following information:
!
!
!
!
!
!
!
!
!
!
!
!
Summaries of the site background and scope of work.

A list of the key personnel working at the site.
Identification of personnel directly responsible for site health and safety.
An analysis of safety and health risks for each task.
Data sheets describing the potential chemical hazards.
A description of personal protective equipment and medical monitoring
requirements.
Activities and corresponding level of protection.
Air monitoring requirements and action levels.
Site control, decontamination, and disposal.
Delineation of work zones (i.e., hot zone).
Hazard communication.
Procedures for emergencies, accidents, and injuries.


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!
!
!
!
Emergency response contingency plan.

SOPs for any site monitoring, protective equipment, etc.
Site maps to the nearest hospital.
List of emergency contacts.
An outline of a typical HASP is located in Appendix D. Federal Occupational Safety

and Health Administration (OSHA) standards (29CFR 1910 and 1926) dictate the
specific policies and procedures to be implemented at a site. In Indiana, Michigan,
and Minnesota, state OSHA regulations may apply.
5.4.3.6
Preparation of a Field Sampling & Analysis Plan with Standard

Operating Procedures and a Quality Assurance Project Plan
The field activities and laboratory procedures for site investigation must be
documented in the form of written standard operating procedures (SOPs). Typically
SOPs are included as attachments to a field sampling and analysis plan (FSP), and
include field sampling procedures, sample handling and preparation, and sample
analysis. The USEPA has made several types of SOPs available electronically on the
Internet at www.ERT.org. From the site homepage, click on products, the on the
link for Compendium of ERT Standard Operating Procedures. This will lead to a
list of SOPs which can be downloaded or in some cases mailed after finalizing a
request. The SOPs available at this site include the following:
!
!
!
!
!
!
!
!
!
Surface water sampling

Sediment sampling
Toxicity testing
Waste sampling
Field analysis
Groundwater sampling
Soil sampling
Air sampling
Biota assessment
Laboratory SOPs are obtained from the laboratory selected to perform the analysis,
and usually are based on published procedures from sources such as USEPA or the
American Society for Testing and Materials (ASTM).
In addition, a Quality Assurance Project Plan (QAPP) should be prepared and
approved prior to the start of field investigation activities. The QAPP summarizes
the project objectives and outlines the data quality objectives for the investigation.
An example outline of a QAPP is included in Appendix E.
5.4.3.7 Preparation of a Cost Estimate
Using the scope of work, a detailed cost estimate should be prepared. The cost
estimate provides information for the site manager to prepare budgets and cost
control procedures. A detailed cost estimate should include costs for the following

5-11
items:
!
!
!
!
!
!
Development of a site-specific work plan

Field preparation and mobilization activities
Field activities (i.e., labor, equipment, travel)
Laboratory testing
Laboratory and field data review analysis and
Preparation of required report(s)
An example of a cost estimate is included in Appendix F.

5.5 CONDUCTING THE INITIAL SITE INVESTIGATION
The field investigation will be conducted according to the methods and procedures
outlined in the work plan. However, as additional site information and data are
collected, the project manager and other technical staff should continually evaluate
the appropriateness of the scope of work with respect to the objectives of the
investigation. The scope of work may be reduced or expanded based upon the
evaluation of site data. If the scope of work needs revision, the project manager
should submit the revised scope of work and cost estimate to the site manager.
5.6 INVESTIGATION METHODS
The next several sections of this chapter describe in detail the methods that are
typically used to perform the site investigation. The specific sampling design or
combination of designs should be chosen so that risk assessment information will
be provided for all receptor populations. Thoroughness at the outset may reduce
the need for additional sampling. Preliminary or background data will likely be
useful in directing both the CSM and the sampling strategy.
5.6.1 STATISTICAL METHODS
Statistical methods are widely employed to evaluate sites of environmental
contamination and may be useful at several stages of the investigation of an
abandoned dumpsite:
!
!
!
!
determining appropriate sampling locations;

evaluating and organizing data;
establishing confidence in data; and
evaluating the appropriateness of a proposed investigation or closure of a
site.
This section focuses specifically on the use of statistical methods in the selection
of sampling locations from which the samples will be subjected to trace chemical
analysis. The choice of the most appropriate sampling approach is important; the
methods
include judgmental, random, stratified random, systematic grid,
systematic random, search, and transect sampling. A sampling plan may combine

5-12
two or more of these approaches. Table 5.2 summarizes several types of statistical
sampling designs.
This section is not intended to be an exhaustive treatment of this exceedingly
complex topic. Many important areas have not been included, namely determining
the number of sampling locations, specifying the specific location of samples, and
procedures for detecting outliers. During the planning stage of an investigation it
is crucial to involve a qualified statistician so that appropriate statistical methods
are selected.
5.6.1.1 Judgmental Sampling
Judgmental sampling is the subjective selection of sampling locations at a site and
is typically based on: 1.) historical information; 2.) visual inspection; and 3.) the
professional judgement of the sampling team. Judgmental sampling is conducted
to identify contaminants present at areas having the highest concentrations (i.e.,
worst-case conditions). It has no randomization associated with the sampling
strategy, precluding any statistical interpretation of the sampling results.
5.6.1.2 Random Sampling
Random sampling is the arbitrary collection of samples within defined boundaries
of the area of concern. Random sample locations are selected using a random
procedure (e.g., using a random number table). The arbitrary selection of sampling
points requires each sampling point to be selected independent of the location of all
other points, and results in all locations within the area of concern having an equal
chance of being selected. This randomization is necessary in order to maintain
statistical validity.


5-13
Table 5.2
Summary of Sampling Designs
TYPE OF SAMPLING
DESIGN
CONDITIONS WHEN THE SAMPLING

DESIGN IS USEFUL
Haphazard sampling
A very homogeneous population over time and space is

essential if unbiased estimates of population parameters
are needed. This method of selection is not recommended
due to difficulty in verifying this assumption
Judgmental sampling
The target population should be clearly defined,

homogeneous, and completely assessable so that sample
selection bias is not a problem. Specific environmental
samples are selected for their unique value and interest
rather than for making inferences to a wider population.
Stratified random sampling
Useful when a heterogeneous population can be broken

down into sampling parts that are internally homogeneous.
Multistage sampling
Needed when measurements are made on subsamples or

aliquots of the field sample.
Cluster sampling
Useful when population units cluster together (schools of

fish, clumps of plants, etc.) and every unit in each
randomly selected cluster can be measured.
Systematic sampling
Usually the method of choice when estimating trends or

patterns of contamination over space. Also useful for
estimating the mean when trends and patterns in
concentrations are not present or they are known a
priority, or when strictly random methods are impractical.
Search sampling
Useful when historical information and site knowledge of

prior samples indicate where the object of the search
may be found.
Because most approaches assume that the site is homogeneous with respect to the
parameters being evaluated (i.e., the contamination does not contain major patterns
or trends) other methods must be considered. The higher the degree of
heterogeneity, the less the random sampling approach will adequately characterize
true conditions at the site. Therefore, since hazardous waste sites are very rarely
homogeneous, other statistical sampling approaches may provide more suitable
means of subdividing the site into homogeneous areas, and thus would be more
appropriate than random sampling. Figure 5.2 presents an example of a random
sampling design.


5-14
Figure 5-2 Random Sampling Design Example
5.6.1.3 Stratified Random Sampling

Stratified random sampling often relies on historical information, prior analytical
results, or field screening data to divide the sampling area into smaller areas, called
strata. Each strata is more homogenous than the site is as a whole. Strata can be
defined by various criteria, including sampling depth, contaminant concentration
levels, and contaminant source areas. The placement of sampling locations within
each of these strata is conducted using random selection procedures. Stratified
random sampling imparts some control on the sampling scheme, but allows for
random sampling within each stratum.
Different sampling approaches may also be selected to address the different strata
at the site. Stratified random sampling is a useful and flexible approach for
estimating the pollutant concentration within each depth interval or area of
concern. Stratified judgmental sampling is another approach for dividing the
sampling area into smaller stratified areas.
Typically, sample depths are based on:
!
!
!
!
field screening results;

the presence of a permeable zone such as a sand lens;
the location of the base of fill material; and
the location just above the saturated or impermeable zone.


5-15
Figure 5.3 shows an example of a stratified random sampling design.

Figure 5.3 Stratified Random Sampling
Design Example
5.6.1.4 Systematic Grid Sampling

Systematic grid sampling involves subdividing the area of concern by using a
square or triangular grid and collecting samples from the nodes (intersection of the
grid lines or center of cell). The method starts with the selection of the origin and
direction for placement of the grid using an initial random point.
From that point, a coordinate axis and grid is constructed over the entire site. The
distance between sampling locations in the systematic grid is determined by the size
of the area to be sampled and the number of samples to be collected.
Systematic grid sampling is often used to delineate the extent of contamination and
to define contaminant concentration gradients. Figure 5-4 presents an example of
a systematic grid sampling design.


5-16
Figure 5-4
Systematic Grid Sampling Design Example
5.6.1.5 Systematic Random Sampling

Systematic random sampling is a flexible approach, useful for estimating the
average pollutant concentration within grid cells. Systematic random sampling is
conducted by subdividing the area of concern using a square or triangular grid,
then collecting samples from within each cell using random selection procedures.
Systematic random sampling allows for the isolation of cells that may require
additional sampling and analysis. Figure 5-5 presents an example of a systematic
random sampling design.
5.6.1.6
Figure 5.5 Systematic Random Sampling Design Example

Search Sampling


5-17
Search sampling utilizes either a systematic grid or systematic random sampling

approach to search for areas where hazardous substance(s) exceed applicable clean
up standards (i.e., hot spots). The number of samples and the grid spacing are
determined on the basis of the acceptable level of error (i.e., the probability of
missing a hot spot).
Search sampling requires that assumptions be made about the size, shape, and
depth of the hot spots. The smaller and/or narrower the hot spots are, the smaller
the grid spacing must be in order to locate them. Also, the smaller the acceptable
error of missing hot spots is, the smaller the grid spacing must be. This, in effect,
means collecting more samples.
Once grid spacing has been selected, the probability of locating a hot spot can be
determined. Using a systematic grid approach, Table 5.3 lists approximate
probabilities of missing an elliptical hot spot based on the grid method chosen and
the dimensions of the hot spot. The lengths of the long and short axes (L and S) are
represented as a percentage of the grid spacing chosen.
A triangular grid method consistently shows lower probabilities of missing a hot
spot in comparison to the block grid method. Table 5.3 can be used in two ways.
First, if the acceptable probability of missing a hot spot is known, then the size of
the hot spot which can be located at that probability level can be determined.
Second, if the approximate size of the hot spot is known, the probability of locating
it can be determined.
Examples of these two scenarios are presented below.


5-18
Table 5.3 Probability of Missing an Elliptical Hot Spot
Length of Long Axis as a Percentqge of Grid Spac8ing
Length of Short Axis as a Percentage of Grid Spacing

10%
10%
0.97
20%
0.95
30%
0.92
40%
0.88
50%
0.85
20%
30%
40%
50%
60%
70%
80%
90%
100%
0.95
0.88
0.92
0.85
0.83
0.87
0.78
0.75
0.85
0.80
0.71
0.77
80%
0.75
0.62
90%
0.72
100%
0.70
0.55
0.45
0.56
0.35
0.54
0.75
0.72
0.45
0.66
0.0
0.0
0.21
0.0
0.0
0.06
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.04
0.0
0.0
0.0
0.08
0.18
0.0
0.03
0.0
0.1.0
0.24
0.37
0.07
0.12
0.08
0.06
0.03
0.0
0.30
0.45
0.15
0.29
0.50
0.08
0.12
0.18
0.32
0.51
0.21
0.27
0.27
0.38
0.54
0.41
0.38
0.44
0.58
0.77
0.50
0.54
0.63
0.80
70%
0.66
0.65
0.69
0.82
60%
0.72
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
From tables in: Gilbert, 1987

L = length of long axis
BLOCK GRID
S
S=length of short axis
0.97
0.95
TRIANGULAR GRID
Example 1: Suppose the block grid method is chosen with a grid spacing of 25
feet. The decision maker is willing to accept a 5 percent chance of missing an
elliptical hot spot. Using Table 5.3, there would be a 95 percent probability of
locating an elliptical hot spot with L equal to 80 percent of the grid spacing chosen
and S equal to 50 percent of the grid spacing chosen. Therefore, the smallest
elliptical hot spot which can be located would have a long axis L= 0.80 x 25ft = 20ft,
and a short axis S = 0.50 x 25ft. = 12.5ft.
Example 2: If 1.) a triangular grid with a 25 foot grid spacing is chosen, 2.) the
approximate shape of the hot spot is known, 3.) L is approximately 15 feet or 60
percent of the grid spacing and 4.) S is approximately 10 feet or 40 percent of the
grid spacing, then, there is approximately a 15 percent chance of missing a hot spot
of this size and shape. Figure 5-6 presents an example of a search sampling design.


5-19
Figure 5-6
Search Sampling Design Example
5.6.1.7 Transect Sampling

Transect sampling involves establishing one or more transect lines across the
surface of a site. Transect sampling is conducted by collecting samples at regular
intervals along the transect lines at the surface and/or at one or more given depths.
The length of the transect line and the number of samples to be collected determine
the spacing between sampling points along the transect. Multiple transect lines
may be parallel or non-parallel to one another. If the lines are parallel, the
sampling objective is similar to systematic grid sampling. A primary benefit of
transect sampling over systematic grid sampling is the ease of establishing and
relocating individual transect lines versus an entire grid.
Transect sampling is often used to delineate the extent of contamination and to
define contaminant concentration gradients. It is also used, to a lesser extent, in
developing a sampling approach for selecting composite samples. For example, a
transect sampling approach might be used to characterize a linear feature such as
a drainage ditch. A transect line is run down the center of the ditch, along its full
length. Sample aliquots are collected at regular intervals along the transect line
and are then composited. Figure 5-7 presents an example of a transect sampling
design.


5-20
Figure 5-7
Transect Sampling Design Example
5.6.1.8 Comparison of Statistical Sampling Approaches

Table 5.4 summarizes the various statistical sampling methods and ranks the
approaches from most to least suitable, based on the sampling objective. The table
is intended to provide general guidelines, but the approach can vary based on sitespecific conditions.
Table 5.4
Comparison of Representative Sampling Approaches
SAMPLING APPROACH
SAMPLING
OBJECTIVE
JUDGMENTAL RANDOM
STRATIFIED
RANDOM
SYSTEMATIC SYSTEMATIC SEARCH TRANSECT

GRID
RANDOM
IDENTIFY
SOURCES
2A
DELINEATE THE
EXTENT OF
CONTAMINATION
2B
CONFIRM
CLEANUP
1C
1D
Notes:
1--Preferred Approach
A--Should be used with field analytical screening
2--Acceptable Approach
B--Preferred only where known trends are present
3--Moderately Acceptable Approach C--Allows for statistical support of clean up verification if sampling over entire site
4--Least Acceptable Approach
D--May be effective with composting technique if site is presumed to be clean


5-21
5.7
THE GEOPHYSICAL SURVEY
Geophysical surveys include a wide range of physical measurements and can
assist in: 1.) defining hydrogeologic conditions; 2.) selecting sampling locations;
3.) identifying the locations of buried waste and underground storage tanks; 4.)
estimating quantities of waste; and 5.) tracing conductive plumes (Benson et. al.
1988). The methods are non-invasive and usually lead to increased project
efficiency and cost effectiveness. These physical measurements are based on the
physics of electromagnetic fields, electric current flow, magnetics, seismic wave
propagation, gravitational attraction, and radioactive properties.
! Natural Site Conditions - Terrain and ground cover will influence the rate
of collection and geophysical sampling locations. In some instances, grid
lines will need to be physically cleared before the survey can commence.
Soil type(s) and depths to groundwater need to be considered when selecting
the appropriate geophysical method. Drilling records will aid in interpreting
the survey results.
! Cultural Features - Cultural features (i.e., fencing, power lines, and surface
metal) can create undesirable noise (i.e., interference) in the geophysical
measurements. These cultural features can interfere with electric,
electromagnetic, and magnetic measurements. Vibrations from busy
roadways, industrial complexes, or mining operations can also interfere
with seismic data collection. The presence of these features should be
considered when assessing the viability of data collection.
! Survey Objectives - The objectives of the geophysical survey should be
clearly defined and may include: 1.) defining hydrogeologic conditions, 2.)
defining the extent of fill, 3.) locating buried metallic objects (i.e., drums or
underground storage tanks), or 4.) locating trenches. Defining the
objectives of the survey is vital to a properly designed survey.
! Waste Type(s) - Waste or fill material present in the survey area will
influence selection of the geophysical method. Some waste types may not
be detected by the proposed geophysical method. Other waste types can
interfere with the assessment of hydrogeologic conditions at the site.
! Survey Grid Size and Positioning - The survey grid must be accurately
laid out and linked to permanent features so that locations of interest or
concern can be relocated after the survey has been completed. The line and
station spacing of the grid will depend on the target size, estimated depth
of buried material, contrast in physical properties between the target and
host material, and the selected geophysical method. The orientation of the
survey grid relative to the target should also be considered.


5-22
I:rouge2:dumps:dumpdoc:chap5b.wpd
! Cost Effectiveness - Geophysical surveys may not be cost-effective in all

investigations of abandoned dump sites. Experienced and knowledgeable
members of the investigation team should evaluate the appropriate
approach for each site.
5.7.1 GEOPHYSICAL SURVEY METHODS
This section contains descriptions of five commonly used geophysical methods for
the investigation of potentially contaminated sites: electromagnetic, magnetics,
ground penetrating radar, DC resistivity, and seismic. Table 5.5 contains a
comparison of these five geophysical survey methods. In some instances, other
less common geophysical methods may be more appropriate for investigating site
conditions, and the lack of mention of these other methods in this guideline
should not necessarily exclude them from consideration.
5.7.1.1 Electromagnetics (EM)
EM provides a method of measuring the electrical conductivity of subsurface soils,
rock, and groundwater. It also is useful for the detection of buried metals.
Electrical conductivity is a function of the soil or rock type, porosity, permeability,
and the presence of liquid that occupies pore spaces within the soil/rock (Dobecki,
1985). As a result, the method is often useful in locating contamination in
groundwater or soils and in differentiating soil types. Conductivity is defined as
the ability of a medium to transmit an electric current. A medium that can pass
an electric current easier than another has a higher conductivity. For instance,
clay typically has a higher conductivity than sand.
An EM instrument has both a transmitter coil and receiver coil. An alternating
current passing through the transmitting coil generates a primary magnetic field.
This oscillating magnetic field induces alternating electrical currents, or eddy
currents, in the earth. These eddy currents create a secondary magnetic field. In
general, the magnitude of the secondary field is linearly related to the subsurface
conductivity. The receiver coil senses the secondary and primary field and
converts it to an instrument readout. This reading is a composite conductivity
reading from the surface to the effective penetration depth of the instrument. The
effective penetration depth is primarily dependent upon the coil spacing, signal
frequency, and soil type (Telford, 1976).
Electromagnetics is also an effective method for detecting buried metal. This is
usually accomplished by measuring the in-phase component of the EM signal.
The secondary field has components that are in-phase and out-of-phase with the
primary field. The in-phase component of the secondary field increase in

5-23
magnitude with good electrical conductors (i.e., buried metals). Measuring the
in-phase signal, therefore, identifies the presence of buried metals. The EM
technique is an excellent reconnaissance tool for tracking certain contaminant
plumes, locating buried metal, detecting pit and trench locations of bulk waste,
as well as locating buried metallic utility lines.
The EM method does not require direct ground contact, therefore, data acquisition
is rapid. The EM instrument is carried over the site as data is recorded. A one-ortwo person field crew is usually sufficient to conduct the field survey. EM survey
results are typically portrayed as profile lines or contour maps.
Table 5.5
Comparison of Five Geophysical Survey Methods
METHOD
USES
1.
Electromagnetic
2.
3.
4.
Magnetic
1.
2.
GPR
1.
2.
3.
4.
5.
DC Resistivity
1.
2.
Seismic
1.
2.
3.
PROS
CONS
Defining hydrogeologic
conditions
Locating buried waste
Tracking conductive
plumes
Locating buried metallic
objects
1.
2.
3.

objects
Mapping of igneous
intrusive
1.
Mapping
near
surface
stratigraphy
Locating trenches
objects
Underground utility
locations
Location of voids
1.
2.
High resolution
Picture Like Graphic
Display
1.
2.
Limited exploration depth

Rough Terrain May Cause
Misinterpretations
Defining
hydrogeologic
conditions
Tracing conductive plumes
1.
2.
Good depth of exploration

Both
sounding
and
profiling capabilities
1.
Cumbersome data processing

and analysis
Susceptible to large conductive
objects (metal fences, Railroad
Tracks, etc.)
Mapping stratigraphy
Mapping
water
table
(refraction technique)
Locat ing
lat e r al
discontinuities (reflection
technique)
1.
2.
4.
2.
3.
4.
Very fast to implement

Relatively inexpensive
Shallow to moderate
exploration depth
Small field crew (1-2
person)
1.
Does not have to pass

directly over target to
identify
Very fast to implement
Deep exploration depths
Small field crew (1-2
person)
1.
Good resolution
Good depth of exploration
2.
3.
2.
2.
1.
2.
3.
Conductive near surface soils

may limit penetration
Susceptible to interference from
metallic objects
Susceptible to interference from
power lines
Highly susceptible to
interference from nearby
metallic objects and power lines
Solar activity and
thunderstorms can interfere
with data acquisition
Cumbersome data processing

and analysis
Relatively expensive
Susceptible to existing ground
vibration
5.7.1.2 Magnetics

5-24
Magnetics utilizes a magnetometer that measures the intensity, in nanoteslas, of

the earths magnetic field. Ferromagnetic objects cause local variations in the
earths magnetic field. A buried ferrous object such as a steel drum or iron tank
distorts the earths magnetic field and results in a magnetic disturbance. The
magnetic method can also be used to map certain geologic features, such as
igneous intrusions, which may play an important role in the hydrogeology of a
site. The magnetic method is effective for detecting buried steel drums, ferrous
containers, iron pipes, and iron tanks (Breiner, 1973).
A variety of magnetometers are commercially available. Most magnetometers
measure the total magnetic field strength, but a few measure a component of the
total field dependent on the sensor orientation. Some magnetometers require the
operator to physically stop and register discrete measurements, while others allow
continuous data acquisition while the instrument is transported across the site
at a fixed height. A dual sensor magnetometer may be used to conduct a
magnetic gradient survey.
Generally, the magnetic method can effectively detect ferro-magnetic materials at
a greater depth than other geophysical methods. However, the magnetic method
is more susceptible to interference from ferromagnetic objects and power lines
than other geophysical methods. In addition, natural sources of noise from sun
spot activity and thunderstorms can also interfere with magnetic surveys.
A one or two person field crew can conduct a magnetic survey in a relatively short
period of time. The shape of magnetic anomalies is dependent upon the geometry,
orientation, and magnetic properties of the object, as well as the direction and
intensity of the earths field. This variability in the shape of the anomaly increases
the difficulty of data interpretation.
5.7.1.3 Ground Penetrating Radar (GPR)
GPR is a type of electromagnetic method. GPR involves use of a transmitter that
introduces an electromagnetic pulse of energy into the ground at a known
frequency. Reflections of the electromagnetic pulse occur when a contrast in the
dielectric constant between two media is present. A receiving antenna at the
surface measures the reflected portion of the transmitted energy pulse. Depth of
the signal penetration is principally controlled by soil conductivities.
GPR is generally an effective method for mapping stratigraphy, locating trenches
or buried objects, and determining the depth to the water table (Beres, 1991).
Typically, buried metallic objects such as underground storage tanks or drums
are readily detected in the GPR record due to strong contrast in electrical

5-25
properties between the metal and surrounding soils. GPR has also been used to
map non-aqueous phase liquids floating on the water table. Data acquisition is
conducted by dragging an antenna across the ground. A two person crew is
typically required.
5.7.1.4
DC Resistivity
DC Resistivity is the direct current (DC) resistivity method which has been
developed to determine lateral and vertical variations in the earths resistivity.
Resistivity surveys are conducted by inserting electrodes into the earth. DC or low
frequency alternating current (AC) is injected into the earth through electrodes.
Other electrodes measure the potential difference (voltage). The potential
measured is a function of the location and geometry of the source electrodes
relative to the potential electrodes.
Conduction of electric current is primarily through water in the pore spaces and
by clay minerals in the soil and rock. Factors controlling earth resistivity are: 1.)
the porosity of the medium; 2.) the amount of pore water; 3.) the concentration of
dissolved solids in the pore water, and; 4.) the clay content of the soil or rock.
Cultural features that are conductors such as metal fencing, railroad tracks,
buried metal pipelines, and heavily salted roadways, will alter the measured
resistivity values and should be avoided.
There are two main types of resistivity surveys: sounding and profiling. A
sounding survey (also known as electrical drilling) has the electrode array expand
over a common center point. A sounding survey delineates depth and thickness
of layers of variable resistivity. The resistivity sounding method is intended for
use in uniformly horizontal-layered geologic conditions, but can yield useful
information in complex geological environments. A profiling survey (also known
as electric trenching) maintains a constant electrode spacing as the array moves
laterally across the site. Profiling surveys are performed when mapping lateral
variations in the subsurface or the boundaries of a conductive plume.


5-26
A 3-4 person field crew is typically utilized when conducting DC resistivity

surveys. Data acquisition is relatively slow due to the direct ground coupling
requirements of the method. Depth of exploration using the DC resistivity method
is virtually unlimited provided that a powerful current source is available, but
resolution will diminish with depth. Data processing is required in order to
interpret survey results.
5.7.1.5
Seismic Method
The seismic method is used to determine the depth and thickness of geologic
layers. Two commonly used seismic techniques are seismic refraction and seismic
reflection. Both techniques measure the travel time of seismic waves propagating
through the subsurface. In the reflection technique, the travel time of a wave that
reflects off an interface is measured. In the refraction technique, the travel time
of a wave that travels along a subsurface interface is measured.
When conducting a seismic survey, an array of seismic energy detectors known
as geophones are implanted in the earths surface. The geophones are connected
to a seismograph which measures the travel times of seismic waves from an
energy source. The energy source for seismic surveys range from striking a
hammer against a steel plate to the use of explosives.
The seismic method has an excellent depth of exploration and yields fair to good
resolution of stratigraphy. The refraction technique can also map the surface of
the water table. The seismic reflection technique can locate lateral discontinuities
in lithologic units and can locate fractures or voids in bedrock. Generally, a three
to four person field crew is utilized when conducting seismic surveys. The seismic
method is expensive relative to other geophysical methods. In addition, data
processing requirements are typically time consuming. Seismic surveys are
susceptible to existing ground vibrations and generally are not suitable for depths
less than ten feet.
5.8 SOIL VAPOR SURVEYS
Soil vapor surveys can assist in site investigations when the investigation team
suspects that volatile organic compounds (VOCs) have been released. There are
two fundamental reasons why the concentration of contaminants detected in soil
vapor surveys cannot be used to estimate the concentration of contaminants in
soil or groundwater (Nielsen, 1991). First, the method relies on indirect
measurement of subsurface conditions, and second, soil vapor concentrations are
the result of complex relationships of highly variable soil or groundwater
contaminant properties. Therefore, the value of using this procedure should be
carefully considered. Ultimately, the applicability of soil vapor surveys is

5-27
dependent upon soil composition, the depth to groundwater, and the properties
of the contaminant of concern. Common uses of soil gas surveys are:
!
!
!
!
!
!
Locating subsurface release sources

Mapping areal and vertical distribution of volatile liquids and gases
Determining the direction of contaminant flow
Optimizing soil and groundwater sampling locations
Evaluating whether biodegradation is occurring
Measuring the potential for vapor migration into buildings
5.8.1
FACTORS INFLUENCING THE APPLICABILITY OF SOIL VAPOR

SURVEYS
Vapor pressure is a measure of the tendency for molecules to transform from a
liquid phase into a vapor phase. The higher the vapor pressure, the greater the
tendency for a specific contaminant to volatilize. Volatilization can occur from
single component liquids (i.e., benzene), multi-component liquids (i.e., gasoline),
or an aqueous solution. Many common organic contaminants are volatile.
The solubility of a contaminant also affects its vapor phase concentration in the
subsurface. Contaminants with low solubility and high vapor pressure are can
be most readily measured by soil vapor surveys. Contaminants with high
solubility will tend to go into solution in soil moisture and groundwater rather
than transforming into the vapor phase.
Diffusion is the primary mechanism for soil vapor migration. Diffusion is the
migration of vapor in response to a concentration gradient. Diffusion in soil is less
than diffusion in air due to the presence of grains, soil moisture, and organic
matter. The migration of soil vapors will vary with changes in site geology.
Diffusion is greatest in dry, coarse grained, high porosity soils with low organic
content. The diffusion rate of vapors in tight soils, such as clays, will be very
slow. Site features such as paved areas, buildings, and utility corridors may
create vapor flow barriers or preferential migration pathways.
Soil vapor samples are collected by applying a vacuum to the probing rod. The
soils must have a high enough air permeability to allow a sufficient flow of soil
vapors into the sample collection system. Soil air permeability depends upon soil
grain size, moisture, and organic content.


5-28
Soil air permeability is greatest in dry, coarse grained, high porosity soils with a
low organic content. Soils with low air permeabilities (clays and silts) will
significantly increase the difficulty of sample acquisition.
5.8.2 SOIL VAPOR SURVEY SAMPLING STRATEGIES
Soil vapor sampling locations can be selected by the judgment, statistical, or
hybrid strategies. The sampling depth interval may depend upon the water table
depth. Soil vapor survey design should take into account the following:
!
!
!
!
!
!
!
!
!
Purpose and objectives of the investigation,

Site hydrogeology,
Nature of contaminants of concern,
Anthropogenic influences on contaminant and vapor migration,
Parameters to be monitored and detection limit,
Method of probe installation,
Site accessibility,
Project budget and time constraints, and
QA & QC.
5.8.3 SOIL VAPOR SAMPLE COLLECTION

Vapor samples are acquired by hand driving, hand augering, power augering, or
hydraulically pushing a hollow probing rod into the earth. The probing rod may
be open ended or screened at its tip. Care must be taken to ensure the tip does
not become clogged during installation. The probing rods need to be installed in
a manner that prevents ambient air from migrating down the boring, outside of
the probing rods, or through joints in the rods.
A vacuum is applied to the probing rod at the surface. The amount of air
evacuated (purged) from the probing rod must be greater than its initial volume.
If a field instrument is to be attached directly to the probing rod, the vacuum
pressure required to draw soil vapors into the probing rod cannot exceed the
capabilities of the instrument. Often the sample is collected in a sample bag
(Tedlar or Teflon), canister, or syringe prior to being subjected to field screening
and/or laboratory analysis.
The information recorded during sample collection should include:
!
!
!
!
Sample location,
Date and time,
Pre-sampling instrument response,
Sample purge volume and flow rate,


5-29
! Difficulty in purging,
! Presence of water in the probe, and
! Peak instrument response during purging.
5.8.4 SOIL VAPOR SAMPLE ANALYSIS
Soil vapor surveys can generate either qualitative or quantitative data depending
on the method of analysis selected. The sample analysis method selected must
be capable of detecting the contaminants of concern or their break down products
at the desired detection levels. Common field analytical instruments include:
!
!
!
!
!
!
!
Photoionization Detector,
Flame Ionization Detector,
Field Gas Chromatograph,
Combustible Gas Indicator,
Detector Tubes,
Oxygen Meter, and
Carbon Dioxide Meter.
Table 5.1 in this guideline contains detailed information about these field
analytical instruments. Soil vapor samples may also be collected in bags,
syringes, or canisters, and sent to an off-site laboratory for analysis. The
concentration of contaminants in soil vapor cannot be correlated with a volume
or concentration of contaminants in soil or ground-water because it is an indirect
measurement. Therefore, the results should be used as a screening tool to assist
in the evaluation of an area requiring further investigation.
Use of an oxygen meter or carbon dioxide meter serves a dual purpose. Typically,
oxygen levels are slightly depressed and carbon dioxide levels are slightly elevated
in soil vapor relative to ambient air (21% O2 and 0.5 % CO
2 in ambient air).
Vapors entering the probing rod may be from leaks or ambient air migrating down
the boring. Including an oxygen and/or carbon dioxide survey with the VOC
screening can help distinguish between ambient air and soil vapors. At locations
where aerobic biodegradation is occurring, oxygen levels will be greatly depressed
and carbon dioxide will be highly elevated.


5-30
5.8.5 DATA REPORTING

Soil vapor survey results are usually depicted as contour maps of contaminant
concentration or instrument response. Variations of less than a factor of 10 in
soil vapor survey may be insignificant. In addition, single point anomalies should
not be over emphasized.
5.9 GROUNDWATER SEEP SAMPLE COLLECTION
Generally, groundwater seep samples are collected to obtain information on
groundwater that may have been impacted by hazardous substances present
within the interior of the abandoned dump and surface water that may be
receiving groundwater seepage originating from the abandoned dump site.
Groundwater seepage generally follows a cyclic pattern that is associated with
local rainfall quantities and surface runoff. Leaching of chemicals in waste
material to groundwater is usually the contaminant release method of greatest
concern at abandoned dump sites. Breakouts of groundwater seepage at the
ground surface is a potential transport mechanism through groundwater
movement or surface runoff to onsite surface water, sediments, and nearby
wetlands.
If encountered at a site, groundwater seep samples should be collected as
judgmental grab samples. A discrete sample should be collected from each
observed seep. At a minimum the sample should be screened in the field for
conductivity and pH. The sample should also be screened for VOCs in the sample
container headspace.
The type of laboratory analysis required will vary with individual site conditions,
but the team will need enough information to evaluate whether hazardous
substances may be present in the leachate. At a minimum, groundwater seep
samples should be analyzed for the following parameters:
! Priority Pollutant Metals (13 elements),
! Volatile Organic Compounds (EPA Method 8260), and
! Surface Water Quality Parameters (see Section 5.15.4 for a list of possible
surface water quality parameters).
5.10 SURFACE SOIL SAMPLE COLLECTION
Generally, surface soil samples are collected to determine whether hazardous
substances are present in surface soil and whether a direct contact exposure risk
is present. Surface soil sampling methods and sample quantities will be based on
several factors, such as the size of the site or area of concern, the amount of site

5-31
cover (i.e., pavement, buildings, vegetation), and the current or future use of the
property. In addition, surface soil sampling is typically focused on locations where
groundwater seeps are observed, stains or discoloration are present, or stressed
vegetation is observed.
A combined judgmental and statistical approach is often taken. However, if a
presumptive remedy such as a cap is being considered, the amount of surface soil
sampling needed may be very limited.
For the purposes of this guidance document, a surface soil sample is any sample
that can be gathered using sampling equipment such as a spoon, shovel, trowel
or spade. Surface soil is typically described as being from the surface to six
inches below ground surface (bgs). Surface soil samples should be tested for the
following parameters, at a minimum.
! Priority Pollutant Metals (13 elements),
! Polynuclear Aromatic Hydrocarbons (EPA Method 8270), and
! Polychlorinated Biphenyls (EPA Method 8080).
Because volatile organic compounds would not be expected to persist in the top
six inches in soil, this parameter is not typically tested for in surface soil, unless
existing data or knowledge infer that they may be present.
5.11 SURFACE WATER AND SEDIMENT SAMPLE COLLECTION
Because surface water and sediment may be affected by migrating contaminants
originating within the site, surface water and sediment samples should be
collected if there are surface water bodies (i.e., ponds, streams, ditches, lakes)
within the perimeter of the site or immediately adjacent to it.
5.11.1
SURFACE WATER SAMPLING
Conditions that may make surface water sampling necessary include:
! A river channel or former river channel cuts through the area of concern.
! A river channel or other surface water body is adjacent to the area of
concern and groundwater is suspected of being contaminated.
! Leachate seeps are observed at the riverbank or the margin of another type
of surface water body.
! Surface drainage passes over the area of concern and leads to a surface
water body.
Methods for surface water sampling vary from simple grab sampling using

5-32
suitable sample containers to more complex methods that enable the investigators
to collect samples from discrete depth intervals. Several types of discrete interval
samplers are available, including Kemmerer bottles and Alpha and Beta bottles.
Surface water samples are typically collected up gradient and down gradient of
any known groundwater/drainage seeps. It is critical to identify other possible up
gradient or historical sources of contamination (i.e., industrial or municipal
sources). If intermittent streams are present on or adjacent to the site, it may be
necessary to conduct stream sampling during or immediately following a heavy
rainfall. In addition, on-site ponds or adjacent lakes may be impacted by surface
water runoff and/or groundwater seeps from the dump site. It is also possible
that contaminated groundwater could recharge to nearby ponds or lakes. Surface
water samples should be tested for the following parameters, at a minimum.
! Priority Pollutant Metals (13 elements), and
! Surface Water Quality Parameters (see section 5.15.4 for a list of surface
water quality parameters).
5.11.2 SEDIMENT SAMPLING
Sediment sampling may be necessary when any of the following conditions are
observed:
!
!
!
Migration of contaminated leachate to the surface water body is ongoing.

Earlier surface water sampling has been inadequate to characterize the
contamination.
Groundwater is discharging into an on-site pond, lake, or wetland.
Sediment sampling methods generally include two categories: grab sampling and
core sampling. Grab samplers, such as Ponar and Ekman dredges, are useful for
collecting samples of surface sediments only. While these are generally easy to
collect, they are only useful for characterizing relatively recent impacts reflected
in the youngest sediments.
Core samplers are required for collecting deeper sediments when historical
deposition data is needed. There are a variety of types available, including vibrocorers, piston corers, and gravity corers.
As with surface water samples, sediment samples are typically collected up
gradient and down gradient of any known groundwater/drainage seeps. The other
factors affecting the selection of surface water sampling locations pertain to
sediment sampling as well. Sediment samples should be tested for the following

5-33
parameters, at a minimum.
!
!
!
Priority Pollutant Metals (13 elements),

Polynuclear Aromatic Hydrocarbons (EPA Method 8270), and
Surface Water Quality Parameters (see section 5.15.4 for a list of surface
water quality parameters).
5.11.3 CAP INVESTIGATION

At most abandoned dump sites, little or no cover may be present on the waste
material. However, a cover or cap investigation should be conducted to determine
if an adequate cover is present at the site. The degree of sophistication of the cap
investigation depends to a great extent on whether the existing cap is going to be
used or incorporated into a new cover system. If the existing cap will not be used,
little investigation is necessary.
If the existing cover may be used for the cover system, it is important to
investigate the following aspects of the existing cap.
!
!
!
!
!
!
Type of cover material(s),

Thickness of cover material(s),
Areal extent of cover,
Whether hazardous substances are present in the cover,
Integrity of cover, and
Potential settlement and stability of waste material, depending on plans
for future use of it.
5.12 EXCAVATION OF TEST PITS

Excavating test pits can be a reliable, fast, and efficient tool for investigating
subsurface conditions at abandoned dumps because fill material is typically
heterogeneous (i.e., not distributed uniformly) near the surface.
The primary purpose of excavating test pits at an abandoned dump site is to
identify and characterize, through physical inspection, the types of materials
within the dump. Information obtained from the preliminary investigation (i.e.,
results of the geophysical survey) should be used to select the test pit or trench
location(s).


5-34
Information that can be obtained from excavating test pits includes:

!
!
!
!
!
!
!
Confirmation of dump boundaries,

Verification of geophysical interpretations,
Verification of the presence of groundwater,
Potential presence of continuing sources of contamination (e.g., drums,
underground tanks),
Soil composition,
Thickness of fill and/or waste material, and
Distribution of fill and/or waste material.
The excavation of each test pit should be conducted slowly and with utmost care
for safety. Site activities should be conducted in accordance with a health and
safety plan prepared for activities at each specific site. A complete description and
field sketch of the test pit should be recorded and should include the following
information:
!
!
!
!
!
!
!
Location,
Approximate surface elevation,
Test pit dimensions,
Soil descriptions (refer to soil descriptions below),
Presence or absence of groundwater,
Results of air monitoring or soil sampling screening results, and
A detailed description of the type(s) and distribution of waste(s).
All test pits should be abandoned in a manner that prevents them from acting as
future conduits or infiltration points for contaminated surface water. As a general
rule, the test pit should be backfilled with material that is at least an order of
magnitude less permeable than the material that was excavated. Typically, a
mixture of soil (i.e., the material that was excavated) and bentonite is used for
backfilling. If significant amounts of waste material or hazardous substances (e.
g., drums containing liquid waste) are encountered during the excavation of the
test pits, disposal and/or treatment of excavated material at a licensed facility will
be required.
The advantages and disadvantages of excavating test pits are outlined in Table
5.6. To minimize health and safety concerns during the excavation of test pits and
to ensure a proper surface seal following completion of the test pit, this activity
should be specifically addressed in the health and safety plan and only
experienced personnel should conduct and direct the excavation.


5-35
Additional information regarding the excavation of test pits and/or trenches is

described in USEPA, 1987 and OEPA, 1995.
Table 5.6
Advantages and Disadvantages of Test Pits
ADVANTAGES
DISADVANTAGES
Cost effective
Health and safety concerns
Possible to inspect large areas of concern
Potential disturbance of surface and cap
Allows visual inspection of waste material
Limited excavation depth (20 feet)

Potential disposal requirements
5.13 SOIL BORINGS

Soil borings are drilled to collect soil samples for chemical testing, geotechnical
testing, and determination of soil composition and characteristics. They are
drilled to varying depths beneath the ground surface. Information obtained from
soil borings is used to characterize the source of contamination and the areal
extent of contamination. They are also routinely used for the installation of
groundwater monitoring wells. There are generally two purposes for drilling soil
borings. The first is to collect representative soil samples to evaluate the
concentration and distribution of hazardous substances. The second is to collect
data concerning the fate and transport of hazardous substances within and
beyond the boundaries of the dump (i.e., the presence of groundwater). To
accomplish these goals soil borings may be drilled within the dump, in areas
immediately surrounding the dump, and possibly at the interface of groundwater
and surface water. Soil borings are also routinely used for the installation of
groundwater monitoring wells. If groundwater is encountered in any of the soil
borings, monitoring wells should be installed.
5.13.1 LOCATION, NUMBER, AND METHODS OF DRILLING SOIL BORINGS
The number of soil borings to be drilled at an abandoned dump will vary from site
to site. However, it is recommended that a minimum of three soil borings be
drilled within the dump and a minimum of four soil borings be drilled outside the
dump in natural soil layers. Depending on the results of the initial investigation,
it is likely that more soil borings and/or monitoring wells will be required to
adequately characterize subsurface conditions at an abandoned dump. Additional

5-36
soil borings may be required due to the size of the dump site or the presence of
several hot spots located in separate areas of the dump site.
The purpose of drilling soil borings within the interior portion of the dump is to
evaluate:
Types and distribution of waste material,
The potential presence of leachate,
Soil composition,
Cap thickness and characteristics (soil classification, grain size distribution,
density and permeability),
! The potential presence of groundwater, and
! The potential for contaminant migration.
!
!
!
!
The purpose of drilling soil borings beyond the boundary of the dump in the
natural soil layers is to evaluate:
!
!
!
!
Soil stratigraphy;
Confirmation of dump boundaries;
The potential presence of groundwater; and
The potential for contaminant migration.
The abandoned dump should be carefully evaluated before drilling the boring to
ensure that the boring is drilled at a preferred location, and potential health and
safety concerns are minimized. Site activities should be conducted in accordance
with a health and safety plan prepared for activities at each specific site.
Soil borings can be drilled using numerous methods. However, southeastern
lower Michigan is dominated by unconsolidated Pleistocene glacial and glaciallacustrine deposits that may be as thick as 400 feet. Therefore, soil borings to be
drilled at abandoned dumps within the River Rouge Watershed should be drilled
using a drill rig equipped with hollow-stem augers or with a Geoprobe.
Either method of drilling has several advantages and disadvantages. At some
sites, both methods of drilling may be used. Table 5.7 lists several advantages
and disadvantages for each drilling method.
For the purpose of minimizing the number of soil borings installed at a site,
several common scenarios can be addressed.
Table 5.8 presents
recommendations for location and minimum number of soil borings for four
common scenarios. In addition, the diagrams presented in Figure 5-8 show

5-37
recommended soil boring locations for several scenarios at a theoretical

abandoned dump site. It is important to note that the minimum number of
borings may increase due to factors such as size of dump site, historical dump
records, and complex geologic settings.
Table 5.7
Drilling Method Advantages and Disadvantages
GEOPROBE SOIL BORINGS
DRILL RIG SOIL BORINGS

Advantages
Disadvantages
Advantages
Disadvantages
Can drill soil borings at Generally more

depths greater than 25 expensive
feet routinely
Generally less expensive
May not be capable of

drilling soil borings at
depths greater than
25 feet routinely
Capable of installing
2-inch monitoring well
with larger diameter
filter pack
Cannot be drilled
quickly
Can be drilled quickly
Difficult to drill in fill

material, cobble, and
gravel
May create more

disturbance to
subsurface soil
layers
May create less

disturbance to
subsurface soil layers
Not capable of
installing monitoring
wells larger than 1inch in diameter; well
would not be adequate
for hydraulic testing
Higher profile
installation
procedures (i.e.,
larger vehicles and
noise levels)
Lower profile installation

procedures (i.e., smaller
vehicles and noise levels)
Typically generates
more waste soil
that may require
special handling
and disposal if soil
is contaminated
Typically generates less

waste soil that may
require special handling
or disposal if soil is
contaminated
Table 5.8
Soil Boring Recommendations for Four Scenarios


5-38
SCENARIO
RECOMMENDATION
Groundwater is not present within the

interior portion of the dump nor in the
natural soil layers surrounding the dump
At least one soil boring drilled in the natural soil

layers surrounding the dump should be located
topographically up gradient and down gradient
and/or between the dump and the nearest
location of surface water
Groundwater is present within the

interior portion of the dump but is not
present in the natural soil layers
surrounding the dump
At least one soil boring should be drilled in the

down gradient direction of the groundwater flow
within the interior portion of the dump, and at a
location between the dump and the nearest
surface water. In addition, a more detailed
inspection of potential leachate seeps is
recommended
Groundwater is not present within the

interior portion of the dump but is
present in the natural soil layers
surrounding the dump
At least one soil boring should be drilled in the

down gradient location of groundwater flow
surrounding the dump, and at a location
between the dump and the nearest surface
water
Groundwater is present within the

interior portion of the dump and in the
natural soil layers surrounding the dump
At least one soil boring should be drilled in: (1) the

down gradient direction of groundwater flow
within the dump; (2) in the down gradient
direction of groundwater flow in the natural soil
layers surrounding the dump, and; (3) at a
location between the dump and the nearest
surface water. In addition, for this scenario it is
recommended that an additional soil boring be
drilled outside the dump in the natural soil layers
down gradient from the direction of groundwater
flow within the dump


5-39
Figure 5-8
Recommended Soil Boring Locations for Nine Scenarios


5-40
Figure 5-8
Recommended Soil Boring Locations for Nine Scenarios (Continued)


5-41
Figure 5-8
Recommended Soil Boring Locations for Nine Scenarios (Continued)


5-42
If a subsurface obstruction is encountered during the drilling of the soil borings

and the soil boring cannot be advanced, the drilling of the soil boring should be
discontinued and another soil boring should be drilled approximately three to five
feet from the location of the original soil boring or the location should be
reevaluated.
During the drilling of the soil borings, the following drill rig observations should be
recorded:
!
!
!
!
!
!
!
Type of drill rig,

Size of auger and bit,
Advance rates,
Presence and/or absence of rig chatter,
Presence of running sands,
Equipment failures, and
Drilling difficulties.
5.13.2 DEPTH OF SOIL BORINGS

The depth of soil borings drilled within the interior portions of a dump will depend
upon the thickness of waste material encountered during drilling. The depth of soil
borings drilled in natural soil layers surrounding the dump will depend upon the
thickness of waste material within the interior portion of the dump and the
regional and site-specific geologic setting. In general, it is recommended that soil
borings drilled within the interior portion of the dump be drilled to a depth below
the waste material.
It should be noted that extreme care should be taken when drilling soil borings
within the interior portions of the dump, not only for health and safety reasons,
but to minimize the potential to penetrate a confining layer. Penetrating the
confining layer may allow the soil boring to act as a conduit for contaminants to
migrate to areas that were not previously contaminated. Therefore, it is important
to evaluate whether to drill soil borings beneath the bottom of the interior portions
of the dump, and/or telescope soil borings drilled within the interior portions of the
dump. It is also important to carefully observe the material being removed from
the soil boring to determine when the bottom of the waste layer is reached.
In southeastern lower Michigan, it is generally not necessary to drill soil borings
more than two to five feet within the lower clay unit (i.e., ground reached. Drilling
should terminate as the underlying clay layer is reached moraine) because the
lower clay unit is an effective barrier (i.e., aquitard) that greatly minimizes the
potential for contaminants to migrate to deeper soils and aquifers. Table 5.9 lists

5-43
the depths at which the lower clay unit is encountered within each recognized
geologic unit in the Rouge River -Drainage Basin.
Table 5.9
Depth to Lower Clay Unit, Rouge River Watershed
GEOLOGIC UNIT
DEPTH TO LOWER CLAY UNIT

(FEET)
7 to 300+
Moraine Unit
Sandy Clay Unit
7 to 20
Sand Unit
5 to 34
Sand and Silty Clay Unit
10 to 30
Upper Clay Unit
10 to 30
Isolated Units
3 to 18
Recent
5 to 60
Depending on site-specific geology and vertical distribution of waste material

within the interior portion of the dump, it may not be necessary to drill the soil
borings to depths listed in Table 5.9.
The depth to the lower clay unit in the river sediment located immediately along
the Rouge River is generally unknown. It is known that the thickness of the river
sediments along the four main branches of the river increase downstream and may
be as thick as 60 feet (from the eastern portions of the city of Dearborn to the
Detroit River). The thickness of the river sediments along the tributaries of the
four main branches will generally be less than 10 to 20 feet.
5.13.3 BOREHOLE ABANDONMENT PROCEDURES
For soil borings that are drilled within the interior portion of the dump and that do
not have a groundwater monitoring well installed, the borehole shall be abandoned
by grouting the entire borehole with bentonite. For boreholes drilled within natural
soil surrounding the dump and where a monitoring well is not installed,
recommended borehole abandonment procedures for several situations are given
in Table 5.10.
Table 5.10
Recommended Borehole Abandonment Procedures

5-44
SCENARIO
RECOMMENDED ABANDONMENT
PROCEDURE
Soil boring was drilled in natural soil, no

evidence of potential contamination and/or
waste material was observed or detected
during drilling or sample inspection, and
groundwater was not encountered
Borehole could be backfilled with: 1.) At least

a one foot thick layer of bentonite grout on the
bottom of the borehole; 2.) native soil brought
to the surface during drilling mixed with
bentonite and brought to within two feet of the
surface, and 3.) bentonite grout from two feet
beneath the surface to grade
Soil boring was drilled in natural soil, no

waste material was observed or detected
during drilling or sample inspection, and
groundwater was encountered
Borehole could be backfilled with: 1.) bentonite

grout to an elevation of at least two feet above
the piezometric surface; 2.) native soil brought
to the surface during drilling mixed with
bentonite and brought to within two feet of the
surface, and 3.) bentonite grout from two feet
beneath the surface to grade
Soil boring was drilled in natural soil,

waste material was observed or detected,
and groundwater was encountered
Entire borehole shall be backfilled with

bentonite grout
It is necessary to observe proper handling, storage, and disposal of soil brought to

the surface during the drilling of soil borings. For soils drilled within the interior
portion of the dump where no suspect contamination is observed or detected
during field screening, the soil should be placed on and covered with plastic sheets
and stored in a secured location until potential contaminant characteristics are
identified. In addition, soil from each soil boring should be individually segregated
and labeled with the soil boring identification code, the date drilled, and any
special handling instructions.
If contaminants are observed or detected during the drilling or inspection of soil
samples, the soil should be placed in Michigan Department of Transportation
(MDOT) approved 55-gallon drums. Potentially contaminated soil cuttings should
not be mixed with soil from other borings. Until proper disposal alternatives can
be arranged, these drums should be placed in a secure location and labeled with
the soil boring identification code, the date drilled, and special handling
instructions.
5.13.4 DECONTAMINATION PROCEDURES
Decontamination procedures for sampling equipment are an essential part of a

5-45
subsurface investigation and should be strictly observed. A decontamination area

should be located on-site in an area removed from the sampling area. This area
should be designed so that all water used to decontaminate equipment is captured
and placed in MDOT-approved 55-gallon drums until disposal alternatives can be
evaluated. The test pit excavation, drilling, and sampling equipment should be
steam-cleaned in the decontamination area following the excavation of each test
pit and/or the drilling of each soil boring according to procedures outlined in the
ASTM 1994 document, Standard Practice for Decontamination of Field Equipment
Used at Nonradioactive Waste Sites. The drums should be placed at a secured
location on-site and be labeled with the soil boring identification code, the date
drilled, and special handling instructions, until proper disposal alternatives can
be arranged.
5.13.5 SOIL SAMPLING PROCEDURES
Subsurface soil samples are collected to characterize physical and chemical
conditions beneath the surface. Therefore, it is recommended that continuous
sampling (i.e., every two feet) be conducted for at least the minimum recommended
number of soil borings and that soil profiles be developed for each boring.
Obtaining a complete soil profile from each boring will assist in constructing an
accurate depiction of subsurface stratigraphy and will minimize the potential for
data gaps.
For soil borings drilled using a drill rig, soil samples should be collected
continuously. Soil samples can be collected every 2 feet using a 2-foot-long, 2inch-diameter split-spoon sampler according to the method described in ASTM
D1586-84. For soil borings drilled using a Geoprobe, soil samples should be
collected every 2 feet using a 2-foot-long, 1- or 2-inch-diameter sampler with an
acetate liner, or every 4 feet using a 4-foot-long, 1- or 2-inch-diameter sampler
with an acetate liner.
Each soil sample collected should be described in detail and include the following
information:
!
!
!
!
!
!
Confirmation and description of soil types (Unified Soil Classification

System);
Thickness of soil horizons and surface cap, if present;
Moisture content (ASTM-2488-90);
Depth to groundwater (feet or meters);
Particle size and distribution (modified Wentworth Scale);
Soil color (Compton 1985 or Geological Society of America Color Chart) and
presence of staining;


5-46
!
!
!
!
Presence of and type(s) of fractures;

Plasticity (ASTM-2488-90);
Presence, type(s), and distribution of waste material; and
Field screening results.
It is recommended that each soil sample collected be retained for future potential
chemical or physical testing. Sample preservation and holding times must be
observed for samples that are submitted for laboratory testing.
5.13.6 SUBSURFACE SOIL SAMPLE COLLECTION
A three-dimensional representation of the distribution of contaminants must be
developed to begin to understand the human health and ecological risk at an
abandoned dump. Therefore, subsurface soil samples should be collected and
submitted for laboratory testing to confirm and/or quantify contaminants at a site.
For soil samples collected from soil borings drilled within the interior portion of the
dump, the following minimum number of soil samples from soil borings should be
submitted for laboratory analysis:
! Where waste/fill material is encountered and ground-water is not
encountered: 1.) the worst-case fill or waste sample based on a visual
inspection and screening results, and 2.) a sample collected from beneath
the waste/fill material.
! Where waste/fill material is encountered and ground-water is also
encountered: 1.) the worst-case fill or waste sample based on a visual
inspection and screening results, and 2.) the sample collected from
immediately above the capillary fringe.
! Where waste/fill material is not encountered but groundwater is
encountered: the soil sample collected from immediately above the capillary
fringe.
! Where waste/fill material and groundwater are not encountered: the soil
sample collected from the bottom of the borehole.


5-47
For soil borings drilled beyond the boundary of the dump, the following minimum
number of soil samples should be submitted for laboratory analysis:
! Where groundwater is encountered and contamination is not observed or
detected during inspection and screening: the soil sample collected from the
capillary fringe.
! Where groundwater is encountered and contamination is not observed or
detected during inspection and screening: the soil sample collected from the
bottom of the borehole assuming the boring is terminated beneath the zone
of saturation.
! If contamination is observed or suspected based on visual inspection or
field screening results: the soil sample that represents the worst-case
sample.
5.13.7 SOIL SAMPLE LABORATORY PARAMETERS
Soil samples should be submitted to a laboratory and tested for the following
parameters, at a minimum.
!
!
!
!
Priority Pollutant Metals (13 elements),

Polynuclear Aromatic-Hydrocarbons (EPA Method 8270),
Volatile Organic Compounds (EPA Method 8260), and
Polychlorinated Biphenyls (EPA Method 8080).
If chemicals are known to be present in soil that are not included in the above
parameter list, the test parameters should include these chemicals.
5.14 GEOTECHNICAL SAMPLING
At some sites, soil samples may be collected for geotechnical testing. Geotechnical
testing is conducted for the purpose of evaluating treatment options and evaluating
contaminant fate and transport. The geotechnical tests that may be conducted
include:
! Mositure content and dry density according to ASTM Method D2216,
! Grain size distribution according to ASTM Method D422, and,
! Coefficient of permeability using ASTM Method D5084 (falling head
method).
Soil samples collected for geotechnical testing should be collected in Shelby tubes.
Because samples cannot be visually inspected in Shelby tubes, it is necessary to
drill specific soil borings for geotechnical testing only. Soil borings for geotechnical
testing should be drilled after initial soil borings are drilled so that optimal

5-48
geotechnical sample locations and depths can be selected.

The following is a list of general locations within the interior portion of the dump
where Shelby tube samples may be collected for geotechnical testing:
! Within the waste/fill material and beneath the waste/fill material at those
sites where groundwater is not encountered;
! Within the waste/fill material at the depth of the worst-case sample and in
the saturated zone in those soil borings where waste/fill material and
groundwater is present;
! Within the saturated zone in those soil borings where waste/fill material is
not encountered but groundwater is encountered; and
! At the bottom of the borehole in those soil borings where waste/fill material
and groundwater are not encountered.
The following is a list of general geotechnical sample locations for soil borings
drilled in natural soils surrounding the boundary of the dump.
! Within the saturated zone in those soil borings where groundwater is
encountered, and
! At the bottom of the borehole in those soil borings where groundwater is not
encountered.
5.15 GROUNDWATER INVESTIGATION
The presence and nature of groundwater at any site of environmental
contamination is important because contaminants can potentially leach from soil
and be transported in and by groundwater to a location where exposure to humans
or sensitive habitats may be possible. Therefore, a complete understanding of the
potential for transport of contaminants in groundwater at a site is crucial to
understanding and managing long-term risk. At an abandoned dump site, the
presence and extent of contamination in the groundwater and its hydraulic
properties are the most important factors that must be evaluated during a site
investigation.


5-49
The first step in conducting a groundwater investigation is to evaluate whether

groundwater is present in a sufficient quantity to collect samples. If groundwater
is present at an abandoned dump site, either within the interior portion of the
dump or in the natural soil layers surrounding the dump, monitoring wells should
be installed to collect a representative sample for screening and laboratory
analysis. If contamination is detected in groundwater at concentrations that may
pose a risk to human health or the environment, then its extent and hydraulic
properties must be studied in sufficient detail to predict the ultimate fate of the
contaminants with a high level of certainty.
5.15.1 MONITORING WELL INSTALLATION
Collecting representative samples of groundwater is inherently more difficult than
collecting air, soil, or surface water samples because of the unavoidable
disturbance associated with drilling a soil boring to install a monitoring well.
Therefore, careful and consistent protocol must be employed to minimize
disturbance when installing groundwater monitoring wells and collecting
groundwater samples.
It is recommended that monitoring wells be installed using a drill rig when the
wells are to be used for sampling ground water and/or evaluating groundwater
geochemistry and aquifer characteristics. Monitoring wells can be installed using
a Geoprobe if they are to be used as piezometers (i.e., to measure groundwater
head) or for evaluating groundwater geochemistry for initial screening purposes.
Table 5.11 outlines the advantages and disadvantages of installing groundwater
monitoring wells using a drill rig and a Geoprobe.


5-50
Table 5.11
Advantages and Disadvantages of Monitoring Well Installation Methods
GEOPROBE MONITORING WELLS
Advantages
Disadvantages
DRILL RIG MONITORING WELLS

Advantages
Disadvantages
Monitoring well
depths can be
greater than 25
feet routinely
Generally more expensive Generally less

expensive
Monitoring well depths

may not be greater than
25 feet routinely
Monitoring well
may be 2-inches
in diameter
Cannot be drilled quickly
Can be drilled quickly Monitoring wells cannot

be larger than 1 inch in
diameter
Can conduct
hydrologic testing
May create more

disturbance to
May create less

disturbance to
Not generally appropriate

for hydrologic testing
Filter packs are

generally thicker
Higher profile installation

procedures (i.e., larger vehicles
and noise levels)
Lower profile
installation
procedures (i.e.,
smaller vehicles and
noise levels)
Filter packs are generally

thinner
Typically generates more

waste soil that may
require special handling
and disposal if soil is
contaminated
Typically generates
less waste soil that
may require special
handling or disposal if
soil is contaminated
Monitoring wells can be installed as temporary or permanent installations. It is

recommended that permanent monitoring wells be installed at the abandoned
dump sites because they enable: 1.) groundwater samples to be collected over long
periods of time; 2.) long-term monitoring of chemical and physical changes in
groundwater to be conducted if necessary; and 3.) more suitable conditions for
hydrologic testing of aquifer parameters. However, under certain circumstances
it may be necessary to install temporary monitoring wells (e.g., on adjacent
property). The advantages and disadvantages of permanent and temporary
monitoring wells are listed in Table 5.12.


5-51
Table 5.12
Advantages and Disadvantages of Permanent
and Temporary Monitoring Wells
PERMANENT MONITORING
TEMPORARY MONITORING WELLS
WELLS
Advantages
Disadvantages Advantages
Disadvantages
Available for sampling
and monitoring for
several years
More expensive
Less expensive
Must be resurveyed to
ensure accuracy
Could potentially be
used for remediation
extraction well
Typically cannot be
used for remediation
extraction well
Less susceptible to
environmental
disturbance (e.g.,
freeze and thaw cycles)
More susceptible to
environmental
disturbance (e.g.,
freeze and thaw cycles)
May be less susceptible

to tampering
Could be more
susceptible to
tampering
Permanent monitoring wells should be installed using threaded 2 inch-diameter,

Schedule 40, polyvinyl chloride (PVC) riser and a 5 foot-long section of No. 10 slot
screen (USEPA, 1991b). Installation of stainless steel risers and screens may be
necessary under special circumstances (e.g., high solvent concentrations).
However, it is not anticipated that stainless steel risers and/or well screens will be
necessary at most abandoned dump sites.
Installation of each monitoring well should be conducted according to the following
procedures:
! Fill the annular void between the well screen and the borehole with a
noncementing, coarse-grained, silica sand filter pack (to a vertical position
one foot above the well screen); this filter pack will minimize the
concentration of soil particulates in the groundwater sample.
! Fill the annular void above the filter pack between the riser and the
borehole with a clean, fine-grained, silica sand (from the top of the filter
pack to a vertical position 0.5 feet above the coarse-grained silica filter
pack); this fine-grained sand will minimize the potential for bentonite to

5-52
!
!
!
!
infiltrate and compromise the integrity of the coarse-grained silica filter

pack.
Place a two foot-long column of bentonite pellets above the fine-grained
sand to seal the annular void space.
Fill the remainder of the borehole with a bentonite grout to a vertical
position approximately 1.5 feet from the surface of the ground.
Install a lockable cap over the well casing and cement a flush-mounted or
aboveground lock box.
Install devices (e.g., wire and lead seals) on the monitoring cap and outer
lock box to detect whether the monitoring well has been tampered with
between sampling or monitoring events.
Figure 5-9 shows a construction diagram for a flush-mounted monitoring well.

Figure 5-10 shows a construction diagram for an aboveground monitoring well.
Monitoring wells should be installed to straddle the piezometric surface so that
chemical compounds that typically float (i.e., light nonaqueous phase liquids
[LNAPLs]) can be detected and monitored, if present (Robbins 1989).


5-53
Figure 5-9 Schematic Diagram Showing a Typical Flush-mounted

Monitoring Well


5-54
Figure 5-10 Schematic Diagram Showing a Typical Lock-box

Monitoring Well


5-55
Chemical compounds that are capable of sinking through the water column (i.e.,
dense nonaqueous phase liquids [DNAPLs]) may be present but are not expected
to be present at high concentrations in deeper portions of aquifers present with the
Rouge River Watershed for the following reasons:
! Saturated zones within the Watershed are generally thin; and
! The sediments within the zone of saturation in the sand unit coarsen
upward, which represents a stratigraphic control on the potential downward
migration of DNAPL compounds that may be present within the unit (Rogers
1996)
An exception may be aquifers within the moraine unit (including subunits) located
in the western and northern portions of the Watershed. Aquifers within the
moraine unit may be thick (greater than 25 feet) and may not exhibit a coarsening
upward sequence. Therefore, at abandoned dump sites located within the moraine
unit, it may be necessary to install nested wells or another acceptable method to
gather data on the vertical distribution of hazardous substances or the hydrology
of thick aquifers.
If installation of fully penetrating monitoring wells is necessary, the location of the
bentonite seal or plug that is placed above the filter pack should not be placed at
a distance greater than 1.5 to 2.0 feet above the well screen because groundwater
located above the screen and below the bentonite seal can enter the monitoring
well during development and sampling. Therefore, the effective length of the well
is equal to the length of the screen plus the distance between the top of the well
screen and the bottom of the bentonite plug. This effective length is termed the
effective well screen length.
When evaluating groundwater chemistry or hydraulic characteristics of a relatively
thick aquifer (saturated thickness generally greater than 20 feet), installation of
nested wells should be considered. Nested monitoring wells are multiple wells
installed at the same location that are screened at different vertical locations within
the zone of saturation.
Therefore, it is anticipated that the only geologic unit within the watershed that
may require the installation of nested wells is the moraine unit, because aquifers
within the moraine unit:
! May be thicker than 20 feet;
! Are not well understood hydrologically, and
! Are sources of potable water.
5.15.2
MONITORING WELL DEVELOPMENT

5-56
Collecting representative samples of groundwater is inherently more difficult than

collecting samples in other media such as air, soil, or surface water. Therefore,
careful protocol must be employed to maximize the collection of representative
samples (Barcelona et al. 1985).
Groundwater samples should be collected from either permanent or temporary
monitoring wells after developing and purging the well. At least 24 hours
(preferably 48 hours) after the well is installed, the monitoring well should be
developed by: 1.) pumping or bailing (using a Teflon bailer) in permeable
formations where water flows freely into the well casing, or 2.) using surging
motions or varying the pumping rates in less permeable formations where water
does not flow freely into the well casing.
Groundwater should be evacuated from the monitoring well until a significant
change in turbidity is observed or at least 10 times the initial casing volume of
groundwater in the well is removed. Casing volume is defined as the volume equal
to the cross-sectional area of the riser and filter pack times the length of the water
column in the riser.
Development water collected from the monitoring wells should be placed in MDOT
approved 55-gallon drums until analytical results are obtained.
If no
contaminants are detected in the groundwater samples, the development water can
be disposed of in any secured manner. If contaminants are detected in one or
more groundwater samples, the development water shall be properly characterized
and disposed of at a licensed facility.
Until laboratory analytical results of groundwater samples are obtained, the drums
shall be placed at a secured location on-site and shall be labeled with: 1.) the
monitoring well identification code; 2.) the date sampled, and; 3.) special handling
instructions, if any, until appropriate disposal alternatives are evaluated.
5.15.3
SAMPLING GROUNDWATER
Before a groundwater sample is collected from a monitoring well, the groundwater
should be purged from the well using either a Teflon bailer or a pump. If a bailer
is used to purge and/or collect a groundwater sample, nonviolent purging and
sampling of groundwater should be conducted. For instance, the bailer should not
enter groundwater within the monitoring well suddenly. This may cause turbidity
to occur and may influence the integrity the groundwater sample (i.e., may cause
some organic compounds that may be present in groundwater to volatilize).
Therefore, the bailer should be lowered into groundwater slowly.
In addition, when purging or sampling groundwater, the bailer should be lowered

5-57
in groundwater within the monitoring well to a depth not to exceed the top of the
bailer. This can be detected by noting the buoyancy force on the bailer once the
bailer is completely submerged. This minimizes the suspension of fine-grained
sediments that may accumulate on the bottom of the monitoring well. Employing
sampling techniques that reduce turbidity within the aquifer will increase sample
quality (Puls and Barcelona, 1996)
A groundwater sample can be collected after: 1.) purging the monitoring well by
evacuating at least three times the initial volume of groundwater in the well; 2.)
once purging at least three casing volumes of groundwater from the well is
completed, monitoring the groundwaters temperature, pH, and conductivity until
at least two of the three parameters have stabilized, or; 3.) purging the well dry.
Once a sufficient quantity of groundwater seeps into the monitoring well after
purging, a sample can be collected using a Teflon bailer. When sampling
groundwater for VOCs, it is recommended that the bailer be equipped with a lowflow Teflon VOC sampler.
Purge water collected from the monitoring wells should be contained in MDOT
approved 55-gallon drums until analytical results are obtained. The drums should
be placed at a secured location on-site and shall be labeled with: 1.) the monitoring
well identification code; 2.) the date sampled, and; 3.) special handling
instructions, until appropriate disposal alternatives are evaluated.
If no
contaminants are detected in the groundwater samples, the purge water can be
disposed of in a secure manner. If contaminants are detected in one or more
groundwater samples, then purge water shall be properly characterized and
disposed of at a licensed facility or can be returned to the well provided there is no
likelihood that contamination will spread.
5.15.4
GROUNDWATER SAMPLE LABORATORY PARAMETERS
Groundwater samples should be submitted to a laboratory and tested for the
following parameters, at a minimum.
! Priority Pollutant Metals (13 elements)
! Volatile Organic Compounds (EPA Method 8260)
! Surface Water Quality Parameters
In areas where groundwater may be used for drinking water analytical methods
must may be required to attain a greater sensitivity (lower MCL). In Michigan,
MDEQs Operational Memorandum #6 provides guidance on analytical methods
and detection limits.
Surface water quality parameters may include nitrate, nitrite, ammonia, total

5-58
nitrogen, total phosphorus, orthophosphorus, dissolved oxygen, biochemical

oxygen demand (BOD), chemical oxygen demand (COD), alkalinity, hardness, and
total suspended solids (TSS).
Typically, polynuclear aromatic hydrocarbons and polychlorinated biphenyls do not
leach into groundwater from soil and they are not miscible with water. Therefore,
these parameters have not been included in the groundwater sample laboratory
parameters. However, if high concentrations of these chemicals are found in soil,
it is recommended that groundwater samples be tested for these parameters.
5.16 SUMMARIZE RESULTS OF INVESTIGATION
Following completion of the investigation, a report should be prepared that
summarizes the activities, findings, and conclusions. The site investigation report
shall follow guidelines set forth in USEPA, 1988 and MDNR, 1990. If the
investigation has not adequately characterized hazardous substances at the site,
the conclusion and recommendation will state that further investigation will be
necessary.
Therefore, a brief summary report may be prepared in lieu of a detailed report at
this point in the investigation process. If a detailed report is prepared, it should
include the following information:
Introduction
! Purpose statement
! Objectives
Site Background
! History
! Size of site
! Location of site
! Physical setting and topography
! Site screening summary
! Site historical survey
Geophysical survey summary
Investigation
! Areas investigated
! Investigation methods and location
! Test pits
! Soil borings
! Monitoring wells
! Other

5-59
!
!
!
!
!
!
!
!
Sampling methods and location

Soil
Groundwater investigation
Geotechnical investigation
QA/QC procedures
Field Screening Results
Decontamination procedures
Waste disposal procedures
Hydrogeology
! Regional geological and hydrogeological setting
! Site geology and hydrogeology
! Groundwater flow direction and estimated rate
! Geological cross-sectional maps
! Soil boring logs and well construction diagrams and logs
Analytical Results
! Soil analytical results
! Groundwater analytical results
! Analytical results from other media (i.e., leachate surface water, sediment
! Tables summarizing analytical results
Nature and Extent of Contamination
! Soil
! Groundwater
! Maps depicting extent of hazardous substances in each affected media
! Sources of contamination
Conclusions and Recommendations
5.17 REFERENCES
Bensen, R., R. Glaccum, and M. Noel, 1988. Geophysical Techniques for Sensing
Buried Wastes and Waste Migration. National Water Well Association. Dublin, Ohio.
p.236
Gibbons, R.D. 1994. Statistical Methods for Groundwater Monitoring. John Wiley
& Sons, Inc. New York, New York.
Gilbert, R.O. 1987. Statistical Methods for Environmental Pollution Monitoring. Van
Nostrand Reinhold, New York, New York.


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Keith, L.H. 1988. Principles of Environmental Sampling.

Society, Washington, D.C. 458p.
American Chemical
Michigan Department of Environmental Quality. 1996. Groundwater and Soil

Closure Verification Guidance. Underground Storage Tank Division. Lansing,
Michigan.
MDEQ Environmental Response Division, 1995. Operational Memorandum #6,
Revision #4: Analytical Detection Level Guidance for Environmental Contamination
Response Activities Under Part 201 of NREPA, 1994 PA 451, as amended
(September 13).
Michigan Department of Natural Resources. 1990. Hydrogeologic Study Guidance
Document, Draft. Michigan Department of Natural Resources, Environmental
Response Division. Lansing, Michigan. 21p.
Michigan Department of Natural Resources. 1994. Guidance Document Verification
of Soil Remediation, Revision 1. Emergency Response Division. Lansing, Michigan.
Nielsen, David M. 1991. , Practical Handbook of Ground-Water Monitoring, Lewis
Publishers, Chelsea, Michigan.
USEPA, 1991a. Removal Program Representative Sampling Guidance: Volume 1.
Soil. OERR. 9360.4-10. PB 92-963408. Washington D.C.
USEPA, 1987. A Compendium of Superfund Field Operations Methods: Volume 1).
USEPA, 1988. Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA, Interim Final. EPA/540/G-89/004. USEPA Office of
Emergency and Remedial Response. Washington, D. C. 179p.
USEPA, 1991. Conducting Remedial Investigations/Feasibility Studies for CERCLA
Municipal Landfill Sites. Office of Emergency and Remedial Response. EPA/540/P91/001. OSWER Directive 9355.3-11. PB91921205.
USEPA. 1994. Assessment and Remediation of Contaminated Sediments (ARCS)
Program: Assessment Guidance Document. Great Lakes National Program Office,
Chicago, IL. EPA905-B94-002.
USEPA. 1996. Soil Screening Guidance: Users Guide. Office of Solid Waste and
Emergency Response. EPA/540/R-96/018. PB96-963505.

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USEPA. 1995a. Test methods for Evaluating Solid Waste, Physical Chemical
Methods. United States Environmental Protection Agency Publication SW-846.
USEPA. 1995b. Guidelines Establishing Test Methods and Procedures for the
Analysis of Pollutants. United States Environmental Protection Agency 600 Series.
40 CFR 136
USEPA. 1986. RCRA Groundwater Monitoring Technical Enforcement Guidance
Document. Office of Solid Waste and Emergency Response. OSWER-9950.1.
Washington, D. C. 317p.
USEPA. 1989. Guidance Document on the Statistical Analysis of Groundwater
Monitoring Data at RCRA Facilities. Interim Final Guidance. Office of Solid Waste,
Waste Management Division. Washington, D. C.
USEPA, 1991. Removal Program Representative Sampling Guidance, Volume 1 - Soil.
OSWER Publication 9360.4-10.
USEPA, 1992. Statistical Analysis of Groundwater Monitoring Data at RCRA
Facilities. Addendum to Interim Final Guidance. Office of Solid Waste, Waste
Management Division. Washington, D. C.
Zohdy, A. A., G.P. Eeaton, and D. R. Mabey. 1974. Application of Surface
Geophysics to Ground-Water Investigations. Techniques of Water-Resources
Investigations of the United State Geological Survey, Chapter D1. p.116
USEPA. 1990. A Guide to Selecting Superfund Remedial Actions. Office of Solid
Waste and Emergency Response. OSWER-9355.0-27FS. Washington, D.C., 6p.
USEPA. 1991a. Conducting Remedial Investigations/Feasibility Studies for CERCLA
Municipal Landfill Sites.
Office of
Emergency and Remedial Response.
EPA/540/P-91/001. Washington, D.C., 294p.
USEPA. 1993. Remediation Technologies Screening Matrix and Reference Guide.
Office of Solid Waste and Emergency Response. EPA 542-B-93-005. Washington,
D. C. 141p.
USEPA. 1994. Physical/Chemical Treatment Technology Resource Guide. Office
of Solid Waste and Emergency Response, Technology Innovation Office. EPA 542B-94-008. 43p.
USEPA. 1994. GroundWater Treatment Technology Resource Guide. Office of Solid

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Waste and Emergency Response, Technology Innovation Office. EPA 542-B-94009. 29p


5-63
CHAPTER 6 - DETERMINING THE NATURE

AND EXTENT OF THE CONTAMINATION
he process of determining the nature and extent of contamination consists

of gathering more detailed information than was generated during the site
investigation, particularly for the primary media of concern. The data can
be used to assess whether the hazardous substance(s) found at the site pose an
unacceptable risk as determined by reference to regulatory standards or by
conducting a risk assessment, and can be used to assess the fate and transport
of the hazardous substance along the crucial exposure pathways.
The basic strategy involves the collection of additional samples of affected media
(i.e. surface soil, subsurface soil, groundwater, leachate), the location and number
of which will be based on the results of the initial investigation. For example, if
groundwater beneath a fill area is found to be contaminated at levels exceeding
established criteria, then either additional wells or fate and transport modeling
will be needed to assess whether the impacted groundwater will present an
unacceptable risk. Or, if the initial investigation shows that surface soils are
impacted at levels that exceed the inhalation criteria for particulate matter, then
it will likely be necessary to investigate the extent of the impacted surface soils.
6.1 EVALUATION OF INITIAL SITE INVESTIGATION RESULTS
The results of the initial site investigation should be reviewed and evaluated to
develop an approach for this phase of the closure process. The evaluation should
include assessment of potential air, water, and soil transport mechanisms for
those hazardous substances detected during the initial site investigation.
6.2 REVISING THE CONCEPTUAL SITE MODEL
Based on the results of the initial site investigation, it is possible that exposure
pathways may have been eliminated or added. Therefore, the conceptual site
model should be reviewed and revised, if necessary.
6.3 ESTABLISHING THE SCOPE OF THE INVESTIGATION
A scope of work for the investigation of the nature and extent of hazardous
substances should be developed for each site that requires further evaluation.
Further evaluation is typically required at sites where hazardous substances are
present at concentrations exceeding acceptable risk levels or clean up criteria and
at which the extent of contamination is unknown. The scope of work should
outline specific investigation objectives. The typical objective of the investigation
is to sufficiently define the nature and extent of contamination in each affected
medium to enable quantification of risk to potential receptors through direct
measurement, predictive modeling, and/or risk assessment.


6-1
I:rouge2:dumps:dumpdoc:chap6.wpd
6.4 WORK PLAN PREPARATION

Once the scope of work has been developed, a work plan should be prepared. The
work plan should include:
!
!
!
!
!
!
!
The scope of the investigation;

Selected investigation methods;
Sampling locations;
Analytical parameters and methods;
A cost estimate;
The project schedule; and
Project deliverables.
The work plan should include the selected methods for investigation (i.e., test pits,
soil borings, monitoring wells), media to be sampled (i.e., soil, groundwater,
sediment), sampling locations and quantities, and analytical parameters for
laboratory testing. The work plan should maintain flexibility and should be
revised during the investigation, if necessary.
Statistical analysis may be useful at several stages of a site investigation. The
application and suitability of using statistical methods should be evaluated.
Detailed information on the application of statistical methods is found in Chapter
5.
If necessary, revisions should be made to the field and management personnel
list, health and safety plan, FSPs, and SOPs.
6.5 PREPARATION FOR FIELD WORK
This step includes obtaining site access and utility clearance, preparation of field
equipment and supplies, mobilization, and scheduling field activities. Details are
provided in Section 4.4.3, above.
6.6 CONDUCTING THE FIELD INVESTIGATION
The investigation will be conducted according to the work plan. However, as
additional site information and data are collected, the project manager and other
technical staff should continually compare the scope of work to the objectives of
the investigation and reduce or expand the scope if site data clearly indicate such
a change is warranted. When the scope of work is revised, the project manager
must submit the revised scope and workplan to the site manager. See Section
4.4, above, for additional details.


6-2
6.7 FATE AND TRANSPORT MODELING

Following completion of the field investigation, the data may require sophisticated
analysis to evaluate risk to potential receptors. This may be achieved by the
process of fate and transport modeling. This type of modeling is typically
conducted at dump sites to evaluate:
! The fate of hazardous substances in groundwater and soils;
! The potential for exposure to contaminants released in groundwater;
! The volatilization of hazardous substances from soil and/or groundwater;
and
! The emission of particulates due to wind erosion.
If a model can be built that represents actual conditions with a high degree of
confidence, the results can be used to establish compliance criteria or even choose
remedial action activities at a waste disposal site. To acquire this level of
confidence, however, the modeler must understand the source characteristics
(i.e.,the nature of the contaminants and the manner in which they are generated
and released into groundwater and air) and the transport characteristics (i.e.,
transmissivity, retardation factors, etc.) of the media through which the
contaminants move. In addition, it is important to understand the characteristics
of the surface water body into which the groundwater discharges. For surface
waters like the Rouge River, factors such as the base flow, seasonal flow
fluctuations, temperature, and antecedent sediment and chemical characteristics
must be assessed to evaluate the mixing characteristics of any contaminants
discharged to the river.
Using the above described information, a model of the contaminant source and
aquifer can be developed to simulate contaminant loading to a surface water body.
Dilution of the contaminants in the surface water can then be estimated. This
process is known as an exposure assessment. The exposure assessment is used
to evaluate the risks associated with human exposure (if any).
6.7.1 THE EXPOSURE ASSESSMENT PROTOCOL
Before launching into a modeling effort, it is important to follow a logical process
for:
! Determining whether groundwater modeling is actually necessary, and
! Selecting the appropriate level of investigation and modeling effort to
conduct the exposure assessment.
The initial step typically involves reviewing the data that is readily available on a
site. This task will enable the modeler to prepare the initial scope of the modeling
effort and, upon review of the data, determine whether modeling is required. For

6-3
example, a landfill with the following characteristics would not require fate and
transport modeling:
! The landfill is old (over 20 years) and site investigation results indicate there
has been little, if any, leachate generation in the landfill at any time of the
year over a period of several years.
! The landfill has a clay cap that is functioning well. As a result, there is no
foreseeable change in leachate generation characteristics nor is there
significant probability of leachate escape through potential surface seeps.
! The concentration of contaminants in the landfill leachate is below riskbased criteria.
! The landfill is situated in lacustrine clays with very low hydraulic
conductivity and limited secondary porosity. There are no interbedded
lenses of sand or other material for transport of contaminants.
At the opposite extreme, a landfill in a sandy aquifer immediately adjacent to or
near (within 2 miles) the Rouge River with a large volume of leachate would
require a detailed study to evaluate whether there is a risk of exposure and, if so,
to what extent. It is likely that many cases will fall somewhere in between these
two scenarios.
6.7.2 MODEL PREPARATION
This is the first stage of model development. It involves evaluation of the existing
site information to determine the type of model necessary to simulate contaminant
fate and migration. Typically, relatively simple analytical models are used to
simulate fate and transport characteristics during this stage to evaluate the effects
of such limiting parameters as groundwater flow, contaminant retardation, and
general source conditions.
Often, the need for additional information to develop a more accurate model is
identified in this stage, in which case, additional investigation may be needed.
When the supplemental data is acquired, more detailed simulations are
conducted. This iterative modeling and investigation process is repeated until a
reliable site model is produced.
6.7.3 CALIBRATION
In this stage, simulations of fate and transport are performed and compared to the
observed field conditions. This can be conducted using the simple model
described in the preparation stage if it is determined that this model is adequate
to perform the exposure assessment. In other cases, additional site information
and/or a more complex model are used to perform the calibration simulations.
Calibration simulations are performed using the available site information and,

6-4
typically, some assumed conditions.

The model results are compared to field monitoring data to evaluate the accuracy
of the model. Additional simulations are performed to determine the sensitivity
of the model to changes in various modeling parameters, with particular attention
given to assumed parameters. If the model results vary significantly when
assumed variables are changed, this is an indication that further site investigation
is necessary to more accurately simulate field conditions and reduce the potential
for error. If the model is insensitive to changes in assumed conditions (i.e., the
model results do not change when assumed factors are changed), this is
indication that additional investigation to confirm these parameters is not
necessary.
If additional data are needed, the data should be collected and put into the model.
Additional simulations should be performed until the model results reflect field
conditions as determined by monitoring data. Sensitivity analyses should then
be performed on assumed conditions to determine whether there is a need for
further field investigation. This process should continue until a model is
developed that simulates field observations with a high level of confidence.
6.7.4 SCENARIO ANALYSIS
Once a model has been built that represents field conditions with a high degree
of confidence, various scenarios can be simulated to estimate contaminant
loadings to a surface water body. This capability is important for landfills because
there are often numerous contaminants associated with landfill leachate. The fate
and transport of these contaminants, sometimes over a period of decades, must
be simulated to evaluate the long term potential for exposure.
While conducting scenario analyses, it is important to consider the fate and
transport characteristics of the various groups of chemicals, referred to as
parameters, identified in the leachate from the landfill. These parameters may
include heavy metals, VOCs, polynuclear aromatic hydrocarbons, PCBs,
semivolatile organic compounds, and other constituents. Before conducting fate
and transport simulations for each of these chemicals, it should be determined
whether simulations of representative parameters in the leachate can be
conducted to evaluate the fate and transport characteristics of an entire group of
chemicals. This approach has been used in conceptual modeling of contaminant


6-5
migration from landfills (Mulkey, et al., 1992) and can save a significant amount
of time and effort without sacrificing confidence in model results. For example,
Mulkey, et al., (1992) used the chemicals listed in the left hand column of the
following table to simulate the fate and migration of contaminants with similar
characteristics as shown in the right hand column of the following table.
Table 6.1
Chemical-Specific Fate and Transport Parameters
CHEMICAL
PARAMETER
CHARACTERISTICS
Toluene
Low sorption, no decay
2,3,4,6-Tetrachlorophenol (TeCP)
High sorption, no decay
Toxaphene
High sorption, low decay
1,2-Dichlorethane (DCA)
Low sorption, high decay
The specific parameters chosen to represent a group of chemicals or elements

should be selected based on site specific data. A clear and justifiable basis for the
selection of these indicator parameters should be documented for each case.
Once fate and transport scenarios have been selected and simulated, an
uncertainty analysis should be performed for the modeled scenarios. This is
essential for calculating a margin of error in the modeled results and in evaluating
the potential for exposure associated with each scenario.
6.7.5 POST AUDIT
The post audit stage is the final stage of the modeling process. In this stage, the
simulated scenarios are compared to monitoring results to confirm the validity of
the modeled results. Monitoring data that consistently confirm the conditions
predicted by the modeling efforts add confidence to the validity of the modeled
scenarios. Under the appropriate circumstances, this can be justification for
reducing or eliminating the monitoring required at a site (Interim Environmental
Response Division Operational Memorandum #17, 1996). The length of the post
audit period must be evaluated on a case by case basis.


6-6
6.7.6 SPECIAL MODELING CONSIDERATIONS

One of the more challenging aspects in developing models for fate and transport
predictions is to adequately define and simulate the source characteristics for the
model. For example, leachate can be generated in several patterns as described
below (Mulkey, et al., 1992):
!
!
!
!
!
Constant leachate concentrations

Exponentially decaying/decreasing concentrations
Extreme pulse - type concentration patterns
Pulse-type patterns followed by a gradual decline
Step-type patterns with alternating high and low concentrations
Except for the first pattern (constant leachate concentrations), each pattern of
leachate generation involves some type of temporal change in the amount and/or
concentration of leachate produced by a landfill. Models have been developed to
simulate these patterns (Mulkey, et al., 1992). However, collecting sufficient
monitoring data to adequately define these types of source patterns can take a
significant amount of time and effort. In cases where it is determined these short
term temporal changes will significantly affect the risk of exposure, it will be
necessary to collect the data or assume a worst case scenario.
In some cases, initial model runs and sensitivity analysis may indicate that the
temporal variations in leachate generation will not affect the exposure scenario.
This, in fact, has been demonstrated in conceptual modeling already. For
example, Mulkey, et al., (1992) discovered that modeling temporal changes in
leachate generation did not produce results that were significantly different from
modeling constant source conditions when there was a significant amount of time
involved in contaminant migration (> 20 years). When the time required for
contaminant migration to a point of exposure is short relative to the temporal
changes in the leachate generation cycle, it may be necessary to model the
temporal changes in leachate generation to adequately estimate the concentration
of leachate at a given point of exposure.
The chances of this latter condition occurring are greatest when a landfill is
situated in a highly transmissive aquifer and is very close to the river. The
potential need for modeling temporal changes in leachate generation is further
increased if the landfill is in an early stage in its leachate generation life cycle (i.e.,
it is in a stage where it is most likely to generate leachate with the highest
concentration of contaminants in its life cycle).


6-7
Conversely, the need for modeling temporal changes in landfill leachate generation
are greatly reduced, or possibly eliminated, if the landfill is old, distant from the
river, is located in an aquifer with low transmissivity, and its leachate contains
only chemicals that are very sorptive and readily undergo decay.
6.8 MODEL SELECTION AND USE
Models are simply tools to perform quantitative assessments with a set of input
parameters. Numerous models have been developed with a wide range of
capabilities. It is very likely that models are available that can perform the types
of simulations necessary to model the fate and transport scenarios associated with
the waste disposal sites near the Rouge River. The particular model chosen for
a given site should be selected based on the specific modeling needs. Generally,
however, the models should be selected based on the following criteria:
! The model should be as simple as possible (especially during the
preparation stage of model development)
! The code of the selected model should be well documented.
! The model should have been validated through calibration with field studies
and/or modeled results from models that have been through a generally
accepted validation process.
! If possible, models should be used that are widely accepted by regulatory
agencies and the professional community.
There are two types of model generally used: analytical models and numerical
models. Numerical models can be further subdivided into finite difference models
and finite element models. Analytical models are simple to use and are capable
of simulating contaminant fate and transport only under simplified conditions.
Numerical models are capable of simulating very complex conditions in two or
three dimensions, although recent software developments have made numerical
models easier to use.
Depending on site conditions, either type of model may be adequate for
conducting an exposure assessment. When numerical models are used, however,
it is often best to keep them as simple as possible despite their complex
capabilities. This reduces the chance of error in model simulations and can help
clarify the limiting factors in contaminant migration, increasing confidence in the
model results, an important consideration in performing exposure assessments.
It is beyond the scope of this guidance document to summarize all the models that
are available that may be appropriate for conducting exposure assessments on
waste sites near the Rouge River. However, numerous models that meet these
criteria are summarized in Mulkey, et al., (1992).


6-8
6.9 MIXING ZONE ANALYSIS

If groundwater contaminated by leachate is discharged to a surface water body
such as the Rouge River, the amount of contaminant dilution caused by flow in
the river must be calculated to complete an exposure assessment. Specific
guidance for this process has been developed in guidelines prepared by the
Michigan Department of Environmental Quality (MDEQ). These guidelines are
subject to revision, therefore their status should be reviewed when conducting a
mixing zone analysis. While a summary of the more basic requirements contained
in the MDEQ guidelines is provided below, a more detailed description can be
found in MDEQ Memorandum 17.
Under the current guidelines, contaminant concentrations in groundwater should
be monitored between the source area and the surface water body. Monitoring
wells for this purpose should be installed as close as possible to the surface water
body as long as they remain in a downgradient from the source. The wells should
not be installed so close to the surface water body that they are hydraulically
downgradient from it and potentially recharged by it. Monitoring wells also should
be installed where maximum contaminant concentrations in the groundwater are
expected. These monitoring wells may be considered compliance points that
represent the groundwater/surface water interface (GSI).
Once the compliance points have been established, they must be monitored for
contaminants of concern. If the concentration of contaminants in any of the
compliance points exceeds generic GSI criteria established by the MDEQ, a mixing
zone study must be performed if one wishes to establish site-specific GSI criteria.
In this latter case, parties seeking a mixing zone determination must place a
request for such with the MDEQ. The request must be accompanied with the
information necessary to calculate mixing zone based GSI criteria. Generally, this
information includes:
! The name of receiving water body and location of the venting groundwater
plume.
! The location, nature and chemical characteristics of past and ongoing
source(s) of the groundwater contaminant plume.
! The name, Chemical Abstract Service (CAS) number and concentration of
the contaminants in the groundwater contaminant plume at the GSI and
upgradient from it to the source area.
! The discharge rate in cubic feet per second (cfs) of the venting groundwater
contaminant plume.
! The location of other contaminant plumes entering the same surface water
body in the vicinity of the facility and their constituents and concentrations,
if available.


6-9
Using this and any other necessary information, the MDEQ will calculate the
extent to which flow in the surface water body dilutes the contaminant plume as
it enters the surface water body. Based on this information, the MDEQ will
calculate a monthly average and daily maximum allowable concentration for the
contaminants of concern at the GSI compliance points (i.e., a mixing zone-based
GSI criteria will be established).
Obviously, the extent to which the surface water body dilutes the venting
groundwater plume will be a key factor (and perhaps the major factor) in
calculating a mixing zone-based GSI criteria. As a general guidance, the MDEQ
states the following:
! Dilution Ratio <10 - For dilution ratios less than 10, the mixing zone-based
GSI criteria may be up to two times the generic GSI criteria. An accurate
calculation of the discharge rate of the venting groundwater plume will be
critical in making mixing zone determinations.
! Dilution Ratio 10-100 - Sites with a dilution ratio between 10 and 100 are
in a transitional range for calculating mixing zone-based GSI criteria. The
mixing zone-based GSI criteria may be in the range of two to 20 times the
generic GSI criteria. An accurate calculation of the discharge rate of the
venting groundwater plume will be critical in making mixing zone
determinations.
! Dilution Ratio 100-400 - Mixing zone-based GSI criteria may be 20 to 45
times the generic GSI criteria when the dilution ratio is 100-400. It is
important to calculate the discharge rate of venting groundwater plume to
the surface water body. In addition, contaminant concentrations which
exceed 100 times the generic GSI criteria will likely require groundwater
treatment or control. This is because the dilution ratio will not affect the
daily maximum concentration criteria which must not be exceeded in the
discharge of the venting groundwater plume.
! Dilution Ratio >400 - Mixing zone-based GSI criteria for situations where
dilution ratios exceed 400 generally will not be greater that 45 times the
generic GSI criteria. Once again, this is because the daily maximum
limitations are likely to become a controlling factor in the acceptable
discharge concentration of the contaminant plume. For this same reason,
contaminant concentrations which exceed 100 times the generic GSI criteria
will likely require treatment.
Although an estimate can be developed for the dilution ratio of a mixing zone,
MDEQ will typically make the determination and/or approval as to the
applicability and details of a mixing zone at a site unless there is a circumstance
where Part 201 requirements are not applicable.


6-10
In addition to the dilution factor, the level of precision and certainty in models
that predict the quantity and concentration of contaminant discharges to a
surface water body will be key factors in calculating the mixing zone-based GSI
criteria, emphasizing the need for fate and transport models that simulate field
conditions with a high degree of confidence.
6.10 SPECIAL INVESTIGATION REQUIREMENTS
Investigation methods for defining most geological and hydrogeological conditions
that can affect contaminant migration have been described in Chapter 5. In some
cases, additional effort may be necessary to define important variables in
developing models for exposure assessments. For example, a pump test may be
needed to accurately define the transmissivity of an aquifer if initial evaluations
and sensitivity analysis so indicate. In some cases, the fraction of organic carbon,
groundwater pH, the presence or absence of ligands, or the quantification of other
parameters may also be important for calculating the migration rate of certain
contaminants. The need for this information will be recognized on a site specific
basis, often as a result of the preparation and calibration stages of the modeling
process.
6.11 FATE AND TRANSPORT MODELING IN GROUNDWATER
The study of the fate and transport of contaminants in the subsurface
environment involves the evaluation and/or prediction of contaminant behavior
in unsaturated and saturated media within a specific geologic environment. The
accurate prediction of the fate and transport of a specific contaminant at a site
requires a thorough understanding of the physical chemistry of the hazardous
substances and the geologic features of the environment into which the hazardous
substances are released.
Of these two fundamental factors, the geologic environment into which the
contaminant is released is typically the least understood. Therefore, to develop
a generic process for investigation and closure of sites of environmental
contamination within a region, it is crucial to understand the fate and transport
of contaminants on a regional basis and at each specific site. A discussion of the
behavior of contaminants in the Rouge River Watershed is found below in Section
6.12.
Predicting the fate and transport of the contaminants may be necessary to
evaluate the potential for human or ecological exposure when groundwater
contamination is present at a site. This is important when the underlying
groundwater discharges to a surface water body or to the ground surface through
springs or seeps. In these circumstances, groundwater models can be useful tools
for simulating the quantity and concentration of contaminants at the points of
potential exposure. Based on the modeling results, the risk of impact to human

6-11
health or the environment can then be estimated. Throughout the investigation,

groundwater models may be used for:
!
!
!
!
!
!
!
Evaluating groundwater movement, flow direction, flow velocity, recharge,

and discharge rates
Identifying data gaps
Designing monitoring well placement
Evaluating potential impacts of contamination to surface water or water
supplies
Assisting in the identification of contaminant sources
Assisting in the design of remedial actions
Modeling future groundwater flow and contaminant transport under
multiple scenarios
To be considered reliable, there must be reasonable assurance that the

groundwater model reflects actual conditions with a high level of confidence.
Building such a model should be accomplished in a logical sequence. Generally,
this involves evaluating site data to determine whether modeling is even necessary
to perform an exposure assessment. If so, the modeling objectives are developed
and a simple conceptual model is built to provide an initial. The conceptual model
should incorporate data on:
!
!
!
!
!
!
!
!
!
!
!
!
Regional hydrogeologic setting

Initial conditions
Boundary conditions (i.e., surface water bodies, rivers, geologic structures)
Areas of recharge and discharge
Hydraulic communication between water-bearing zones
Distribution of hydraulic parameters
Potentiometric surfaces
Composition of geologic material
Effective porosity
Contaminant distribution
Water chemistry
Physical and chemical properties of hazardous substances
If necessary, additional site information is acquired and more complex model

codes might be used to adequately simulate site conditions. Model simulations
are then conducted and compared to conditions observed in the field to confirm
the accuracy of the model.
Further field investigation may be conducted at this stage and additional modeling
simulations performed, until the model simulates actual field conditions with a
high degree of confidence. The model is then used to predict various fate and

6-12
transport scenarios to evaluate risk at the site. Finally, the simulated scenarios
are compared to ongoing monitoring results to confirm the validity of the modeled
results.
Field monitoring results that consistently confirm the conditions predicted by the
modeling efforts add confidence to the validity of the modeled scenarios. Under
the appropriate circumstances, this pattern can justify reducing or eliminating the
ongoing monitoring requirements at a site.
6.12
GEOLOGIC FACTORS THAT INFLUENCE CONTAMINANT FATE &

TRANSPORT IN GROUNDWATER
The study of transport and fate of contaminants in terrestrial subsurface
environments is complex and interdisciplinary. It involves the integration of sitespecific and regional information on geologic, hydrologic, chemical, and biological
processes. This information must also be integrated with site information (i.e.,
historical land use, operational information, source identification) in order to
effectively evaluate contaminant transport and fate processes at a site of
environmental contamination.
Evaluation of the fate and transport of contaminants is fundamental because a
chemical may be transported from its release point, where no potential exposure
risk may be anticipated, to a location that is a significant distance from the release
point, where a potential exposure risk to humans or to the environment may be
present.
6.12.1 SATURATED FLOW
The saturated zone is defined as the portion of the soil column that is saturated
and where the soil water pressure is positive. Flow and transport mechanisms
affecting contaminant behavior in the saturated zone include advection, diffusion,
adsorption, and biodegradation.
Advection is the movement of contaminants with the flow of groundwater at the
seepage velocity. Diffusion is a molecular mass transport process in which solutes
migrate from areas of high relative concentration to areas of low relative
concentration. Dispersion is a mixing process caused by velocity variations in the
porous media, which often causes contaminant fronts to spread out and results
in the dilution of the contaminant at the advancing edge of the contaminant front.
In natural groundwater flow regimes, dispersion occurs in each of the x, y, and z
planes. Adsorption is the partitioning of organic contaminants from the soluble
phase onto the soil matrix and results in retarded contaminant fronts.
Biodegradation is the transformation of contaminants, primarily organic
compounds, to carbon dioxide and water. Flow and transport mechanisms acting
upon a contaminant front have been shown to cause a decrease in concentration

6-13
with increased distance traveled through time (Bedient et al. 1996, and USEPA
1990).
6.12.2 UNSATURATED FLOW
Flow and transport mechanisms affecting contaminant behavior in the
unsaturated zone (i.e., vadose zone or zone of aeration) are much more complex
than those mechanisms in the saturated zone. These flow and transport
mechanisms include porosity, capillary forces, and moisture content. The
unsaturated zone is defined as that portion of the soil column where the amount
of water present is less than the porosity of the soil and where the soil water
pressure is negative. The capillary fringe ( i.e., the tension-saturated zone) is
defined as the area above the water table where the soil pores are saturated but
the pressure head is less than atmospheric (Freeze and Cherry 1979). In an
unsaturated porous medium, a portion of the pore space contains air and a
portion contains water. The total porosity within the unsaturated zone equals the
sum of the two. The moisture content is defined as the ratio of the volume of the
water to the total volume of the porous media.
6.13
CHEMICAL FACTORS THAT INFLUENCE CONTAMINANT FATE AND

TRANSPORT IN GROUNDWATER
Chemical factors that influence contaminant fate and transport include:
!
!
!
!
!
Specific gravity
Vapor pressure
Vapor density
Solubility
Adsorption potential
!
!
!
!
!
Degradability
Biodegradability
Reactivity
Corrosivity
Ignitability
Contaminants released into the environment are generally mixtures of several

chemical compounds. The mixed compounds may be very similar in structure
and composition, but behave differently when released into the environment.
Therefore, understanding the physical chemistry of each of the chemical
constituents at sites of environmental contamination is essential when evaluating
fate and transport.
Most organic compounds biodegrade in the environment due to the affect of
indigenous microorganisms (i.e., intrinsic biodegradation). Research efforts are
being applied to understand the process, applications, and limitations of intrinsic
biodegradation.
Although physical and chemical characteristics of the
contaminant(s) and the metabolic potential of indigenous microorganisms control
the probability of biotransformation reactions, it is the geochemistry of the specific
environment where the contaminants exist that will determine if
biotransformation will actually occur. Therefore, the geochemistry of the specific

6-14
environment represents a potential limiting factor that must be understood

through detailed study of the microbial, chemical, geological, and environmental
features. Ultimately, the most important factor in evaluating VOC migration in
groundwater is the degree to which the geologic environment into which the VOC
was released is understood (USEPA, 1992a).
6.13.1 VOCs
In their pure form, volatile organic compounds (VOCs) have low surface tension;
adsorb strongly to clayey soil particles; adsorb weakly to sandy soil particles; and
have low capillary action, a property which may inhibit VOCs from being retained
between the soil grains (Lindsay 1979 and Schwille 1988). When released into a
subsurface sand substrate, VOCs will typically migrate vertically in unsaturated
soil from the source of release point under the force of gravity (Bedient et al.
1994). Thus, high concentrations of VOCs are not generally detected in very
sandy soils.
When VOCs reach a piezometric surface, the transport mechanism becomes
groundwater flow and dispersion. Therefore, VOCs released at a site with a sand
substrate where groundwater is present have the potential to migrate a significant
distance from the release point. However, because VOCs tend to sorb strongly to
clayey soil particles, they ususally will not migrate in this media as far or as
quickly as VOCs released in a sand substrate.
VOCs may also be found in mixtures of contaminants in geologic structures and
dump sites, such as light nonaqueous phase liquids (LNAPLs) and dense
nonaqueous phase liquids (DNAPLs). These forms are commonly detected at sites
of environmental contamination within the Rouge River Drainage Basin.
DNAPLs typically include degreasing solvents. They have low relative solubility,
low viscosity, and high density (i.e., greater than the density of water). LNAPLs
typically include degreasing solvents and petroleum products such as gasoline.
LNAPLs exhibit a higher solubility, viscosity, and lower density (i.e., less than the
density of water) than DNAPLs. The most important factors that influence the
migration of LNAPLs and DNAPLs are solubility, viscosity, ability to adsorb to soil
grains, biodegradability, and density. (Bouchard 1989, Howard 1988, and
USEPA, 1990b and 1991).
At those sites of environmental contamination where contaminants were released
into the environment years or decades before they were detected, and more than
one chemical compound was released, speciation (i.e., a separation of the mixture
of contaminant) will generally occur. The more mobile compounds will tend to
migrate farther than less mobile compounds.


6-15
Biodegradability of VOCs is also an important factor in evaluating the fate of

contaminants. Biodegradation of VOCs generally occurs under both aerobic and
anaerobic conditions for LNAPLs, but only under anaerobic conditions for DNAPLs
(Wiedemeier et.al. 1995).
Current groundwater remediation technologies appear to be inadequate for
restoration of aquifers contaminated with large quantities of DNAPLs (USEPA,
1992b). For this reason, in-depth risk evaluation and site exposure controls have
been employed to manage many sites of environmental contamination.
6.13.2 PCBs
Polychlorinated biphenyls (PCBs) typically exhibit low solubility, high viscosity,
high density (i.e., greater than the density of water), and strong sorption to organic
matter in soil, important factors in evaluating their subsurface migration (USEPA,
1990). When released into the subsurface environment, PCBs typically are
immobile and will adsorb to organic matter present in the soil; thus they usually
do not migrate a significant distance from the point of release. In addition, PCBs
do not readily biodegrade, making them persistent in the environment(USEPA,
1990).
Factors which may increase the potential for PCB migration in the subsurface
environment include the amount of organic matter in soil, and the presence of oil
in which the PCBs may be dissolved and potentially co-migrate (USEPA, 1990).
When the soil in which PCBs are present possesses little or no organic matter
(e.g., a clean quartz sand), PCBs will not adsorb to soil grains and may migrate
vertically to the capillary fringe. If the PCBs are dissolved in oil of sufficient
volume to facilitate migration, the PCBs may migrate at a rate controlled by the
properties of the oil.
Because PCBs have low solubility in water, when they migrate to groundwater,
they typically become immobilized through capillary retention and remain at the
capillary fringe. Concentrations of PCBs in groundwater are generally governed
by the rate at which they dissolve in groundwater. Therefore, since PCBs are able
to persist in the environment and are not very soluble, PCBs present in the
capillary fringe may represent a long-term source of low concentrations of PCBs
in groundwater.
6.13.3 PAHs
When assessing the migration of Polynuclear Aromatic Hydrocarbons (PAHs) in
the subsurface environment, the investigator must consider the solubility,
viscosity, and density of PAHs, and the permeability and organic carbon content
of soil. PAHs do not readily migrate from the source area because they are only


6-16
slightly soluble in water, tend to adhere to the soil particles; and do not readily
migrate through the soil.
6.13.4 METALS
Rates of migration for metals released in the subsurface environment are strongly
influenced by soil type. In general, chemically-reduced metals exhibit low mobility
in clays, silty clays, and clayey loams due to adsorption and fixation to clay
minerals, and most are only slightly soluble in water. Therefore, uncompounded
(non-ionic) metals released into a subsurface environment with a high clay content
will not migrate far from the point of release.
6.14
REGIONAL GEOLOGICAL OVERVIEW - FATE & TRANSPORT OF

CONTAMINANTS IN THE ROUGE RIVER DRAINAGE BASIN
To develop a generic process for the investigation, remediation, and closure of
sites of environmental contamination located within the Rouge River Watershed
(the Watershed), an understanding of the regions geology and hydrogeology is
required. To develop an effective model, it is crucial to accurately predict the fate
and transport of contaminants: 1.) within the watershed as a whole; 2.) in each
identified geologic unit; and 3.) at specific sites.
The purpose of this section is to describe the geology and hydrogeology of the
Rouge River Watershed and identify specific geologic units that display similar
geologic and hydrogeologic characteristics that will influence the fate and
transport of contaminants. Once these geologic units are identified and described,
sites of environmental contamination can be grouped, prioritized, and investigated
according to similar geologic and hydrogeologic characteristics.
The Rouge River Drainage Basin is located on the southeastern edge of the
Michigan Basin. The Michigan Basin is a 122,000-square-mile area composed of
sedimentary rocks (primarily limestones, shales, and sandstones) (Martin 1957).
The sedimentary rocks within the Michigan Basin are Paleozoic in age. Naturally
occurring outcrops of Paleozoic rocks within the basin are rare because of the
presence of a thick deposit of glacial drift in the region.
Surficial deposits of Pleistocene age overlie the Paleozoic rocks of the Michigan
Basin. This forms an unconformity where deposition has not occurred for
approximately 280 million years (Dorr and Eschman 1988). Surficial geology in
Michigan is dominated by glacial deposits that are typically several hundred feet
thick and, at some locations, more than one thousand feet thick (Rieck 1981).
The glacial deposits in Michigan were deposited during the Pleistocene Epoch, the
Wisconsinan Stage of glaciation (Farrand 1988).


6-17
Approximately 14,500 years ago the glaciers that occupied the region began to
melt. As the glaciers retreated, a series of moraines, lakes, and rivers formed.
However, the ice did not retreat uniformly, as many as 20 distinct stages of retreat
and an occasional readvance of ice have been identified (Farrand 1982 and 1988).
The resulting terminal and lateral moraines became effective natural dams and
were ideal for the development of glacial lakes.
Several significant glacial lake stages have been identified within the Rouge River
Watershed (Bergquist and MacLachlan 1951, Leverett 1911, Leverett and Taylor
1915, Spencer 1888, Sherzer 1913, Taylor 1897 and 1899). Deposits from these
ancient glacial lakes were first observed and mapped in 1838 and 1840 (Hubbard
1840). These deposits extend to the north of the Rouge River Watershed to Imlay
City, Michigan, and to the south through northern Ohio to an area east of
Cleveland, Ohio (Sherzer 1913).
The Pleistocene deposits within the Watershed are composed of: 1.) moraine
sediments of glacial origin, and 2.) lake sediments of glacial-lacustrine origin.
These sediments typically have varied and complex lithologies that include coarse
gravels, fine-grained sands, and clays (Bergquist and MacLachlan 1951, Mozola
1969, and Rieck 1981).
The Defiance Moraine forms the north and western boundaries of the Watershed
and reaches a maximum elevation of approximately 950 feet. To the east are the
lake deposits associated with the retreating ice. The elevations of these deposits
range from 580 to 800 feet.
The occurrence of groundwater in the Pleistocene deposits is influenced by: 1.) the
hydrology of the region, and 2.) the nature, horizontal and vertical extent, and
composition of the sediments. According to Mozola (1954), the depth to
groundwater in the upper unconfined waterbearing zone, horizontal and vertical
extent of groundwater, and the amount of groundwater present can vary from
location to location.


6-18
6.14.1 Surface Geology and Hydrogeology

Several distinct near-surface geologic units are present within the Watershed
(Rogers 1996). Each of these units generally trend in a southwest to northeast
direction. The near-surface geologic units include:
!
!
!
!
!
!
!
!
Moraine Unit
Sandy Clay Unit
Sand Unit
Sandy and Silty Clay Unit
Upper Clay Unit
Isolated Units
Reworked River Sediments
Lower Clay Unit
In addition to the geologic units listed above, several isolated or discontinuous

units are also present within the Watershed and consist of either sand or sandy
and silty clay.
Moraine Unit - Deposits associated with the Defiance Moraine form the western
boundary of the Watershed and are composed of sand, silt, gravel, clay, and
glacial erratics. The moraine unit ranges in elevation from approximately 950 feet
in the extreme northwestern portion of the Watershed to 800 feet along the
contact with the sandy clay unit.
The moraine unit is described as interbedded sands, gravels, and clays with
occasional glacial erratics. The moraine unit is generally less than 150 feet thick.
Subunits within the moraine unit include glacial outwash zones, kames, eskers,
and kettles. Numerous kames are located in the area of the city of Northville and
a glacial outwash zone is located along the Middle Rouge River near Northville
where the Rouge River flows toward the southwest.
Stratigraphically, the moraine unit is the most complex and least understood
geologic unit within the watershed. The moraine unit is the most complex
because the unit was deposited directly by ice, with little or no stratification.
Some early researchers have even characterized the deposition of this unit as
chaotic (Sherzer 1913). The moraine unit is only a few miles wide and extends
beyond the boundary of the watershed to the west and north where several other
moraine units and glacial outwash units have been identified (Farrand 1982).
Groundwater encountered within the moraine unit is under confined and
unconfined conditions. Multiple zones of saturation are present within the unit.
The saturated zones range in thickness from less than three feet to more than 20
feet. Groundwater has been encountered in layers of sediment that range from

6-19
fine-grained sand to large cobbles. At some locations, near-surface groundwater

(i.e., within the upper 20 feet of soil) was encountered in sediments that could be
pumped in large volumes at a sustained rate (i.e., greater than 25 gallons per
minute). Groundwater within the moraine unit is currently used extensively as
a public and domestic potable water source. The hydraulic conductivity at
locations where groundwater was present within the moraine unit ranged from 1.0
x 10-5 to 1.0 x 10+1 centimeters per second (cm/s) [Rogers 1996].
Migration of contaminants within the moraine unit is nearly impossible to predict
without site-specific geologic and hydrogeologic evaluation at each site of
environmental contamination within the unit. Sites located within the subunits
of the moraine unit (i.e., glacial outwash and kames), could potentially contain
large quantities of groundwater. In addition, contaminant migration rates are
most likely very high because the subunits generally are composed of sand and
gravels. Table 6.2 contains a rating of the probabilities of encountering certain
hydrogeological conditions in each geologic unit of the Rouge River Watershed.
Sandy Clay Unit - A sandy clay unit is located east of the moraine unit. The
sandy clay unit ranges in elevation from approximately 700 to 800 feet. The unit
is generally described as a light-brown to gray, mottled, sandy clay with occasional
pebbles. The sandy clay unit ranges from 0.5 to two miles wide and is generally
less than six feet thick. However, the unit is thicker in the southern portion of the
watershed, where the thickness is greater than 20 feet.
Groundwater encountered within the sandy clay unit is unconfined, generally
discontinuous, and not present in large volumes that could be pumped from the
ground at a sustained rate. Generally groundwater is either located within vertical
hairline fractures that may be present locally within the unit, and/or along the
contact between the sandy clay unit and the moraine unit located beneath the
sandy clay unit. Groundwater encountered within the unit may be hydraulically
connected to the sand unit located to the east of the sandy clay unit, especially
along the east-ward margin of the sandy clay unit.


6-20
Table 6.2
Probability of Hydrogeological Conditions in Geologic Units of the Rouge
River Watershed
CONDITION
CLAY
SANDY
CLAY
SANDY
SILTY
CLAY
SAND
MORAINE
RIVER
DEPOSIT
Groundwater
Presence
Low
Medium
High
High
Medium
High
Groundwater
in Aquifer
Low
High
Low
High
High
Transport/
Connection to
Aquifer
Low
Medium
Low
High
High
Transport to
Surface
Water
Low
Low
Medium
High
Medium
High
Low
Low
Low
Low
Low
Low
High
Low
Drinking
Water Use:
- On-site
- In vicinity
of site
Notes:
?=Unknown-insufficient information available
The direction of groundwater flow, at those sites where a flow direction could be
established, was generally toward surface water. Groundwater within the unit has
not been used as a source of potable water, most likely because of insufficient
water yield. Groundwater encountered within the sandy clay unit may be
hydraulically connected to the sand unit and to surface water.
Therefore, contaminants detected within the unit may have the potential to
migrate to surface water or to groundwater present within the sand unit,
especially at those locations along the sandy clay unit and sand unit margin.
The sandy clay unit is not an effective aquitard in most cases because the unit
is generally thin (i.e., less than six feet) and most likely contains a significant
amount of vertical hairline fractures. These hairline fractures tend to act as
pathways for contaminants to migrate both horizontally and vertically. Therefore,
because the sandy clay unit is generally thin and is not an effective aquitard,
contaminants released at sites located within the unit may migrate relatively
quickly into the upper portion of the moraine unit (which has been characterized

6-21
as a sensitive unit), or may migrate to the sand unit. Table 6.2 contains a rating
of the probabilities of encountering certain hydrogeological conditions in each
geologic unit of the Rouge River Watershed.
Sand Unit - A sand unit is located east of the sandy clay unit. The sand unit
ranges in elevation from approximately 690 to 720 feet at its western margin to
approximately 640 feet at its eastern margin. This unit is characterized as a
moderate yellowish-brown to light olive-gray, fine- to coarse-grained quartz sand.
The sand becomes less coarse with increasing depth. The composition and
mineralogy of the sand has been historically described as containing 90 percent
or more quartz (Sherzer 1917).
At many locations, the sand unit is stratified and has well-developed
crossbedding, ripple marks, and scour and fill features. In addition, localized
evidence of reworking and eolian deposition are present within the upper portion
of the unit. Clay rip-up clasts are present in the lower 0.5 feet of the unit, which
indicates that the contact between the sand unit and the unit beneath it (the
Lower Clay Unit) is an erosional contact.
The width of the sand unit ranges from approximately three to five miles. The
thickness of the unit is 10 to 20 feet in the southern portion of the Watershed and
increases northward into the western portions of Livonia, where the thickness may
exceed 30 feet. North of the city of Livonia, the unit thins significantly and may
only be five feet thick in the city of Farmington. North of Farmington, the unit
thickens and may be 10 to 15 feet thick in the northern portion of the Watershed.
From west to east, the thickness of the sand unit increases significantly from one
to 20 feet over a horizontal distance of only 400 feet along its western margin near
the city of Plymouth. In areas east of Plymouth and through the city of Livonia,
the unit gradually thins and becomes intercalated with the sandy and silty clay
unit in the township of Redford.
Groundwater encountered within the sand unit is unconfined. The direction of
groundwater flow within the unit is generally toward surface water. Groundwater
encountered within the unit is regional in extent. The unit occupies approximately
25 percent of the Watershed. The saturated thickness within the unit ranges from
just a few feet (near Farmington) to more than 20 feet (in portions of Livonia).
Groundwater within the unit has been observed to discharge into the Rouge River
at numerous locations.
The degree and nature of urbanization within the Watershed has also affected the
rate and direction of groundwater flow within the sand unit. The construction of
roads (i.e., Hines Drive and I-96), storm sewers, retention basins, and ditches

6-22
within the unit act as points for groundwater to discharge to surface water.
Therefore, the residence time for groundwater in the aquifer has most likely
decreased as a result of urbanization.
In addition, urbanization has resulted in a decrease of recharge to the aquifer
because impervious cover (i.e., roads, paved parking areas, buildings, and
landscaping) and stormwater runoff controls divert runoff from storm events
directly to the Rouge River and its tributaries.
Recharge of groundwater within the sand unit is most likely from surface
precipitation because of the surficial nature of the unit.
In portions of Livonia, Hines Drive has cut into the sand unit at many locations.
This has resulted in numerous seepage points along the north side of Hines Drive.
From the seepage points, groundwater has been observed to seep from the ground,
flow along ditches, and discharge into the Middle Rouge River.
In addition to Hines Drive affecting the direction and rate of groundwater flow on
a local scale, I-96 through portions of Livonia has also created the same effect.
Several groundwater seepage points are located along I-96 in Livonia where the
highway has cut into portions of the saturated zone within the sand unit,
especially near underpasses where the highway was excavated deeper for the
overpass and surface water drainage.
The sand unit is a heterogeneous aquifer. It is a multi-layered lacustrine deposit
with highly variable grain size distribution between the individual layers. In
addition, because of the fluctuating glacial shorelines and the general regressive
history of the glacial lakes, the grain size distribution horizontally within the unit
is also highly variable and complex. Therefore, the heterogeneous configurations
of the unit include both layered heterogeneity and trending heterogeneity (Freeze
and Cherry 1979).
The hydraulic conductivity of the sand unit decreases significantly with depth.
The upper portion of the saturated zone within the unit is characterized as a
medium- to coarse-grained sand, which has a hydraulic conductivity ranging from
1 x 10-1 to 10+1 cm/s. The lower portion of the saturated zone within the unit is
characterized as a very fine-grained sand, which has a hydraulic conductivity
ranging from 1 x 10-4 to 1 x 10 -2 cm/s (Rogers 1996).
Recovery wells installed in the sand unit at sites of environmental contamination
have pumped groundwater at rates that range from 0.5 to 50 gallons per minute.
The wide range in yield depends upon: 1.) the saturated thickness of the sand,
which ranges from less than three feet to more than 20 feet, 2.) the range in grain

6-23
size, and 3.) the diameter of the recovery well. The average yield from the
saturated zone within the sand unit ranges from five to 10 gallons per minute.
The decrease in hydraulic conductivity represents a stratigraphic control that
minimizes the vertical migration of contaminants within the unit, especially
contaminants that have a specific gravity greater than water, such as DNAPLs.
Therefore, contaminants are more likely to be concentrated within the upper
portion of the unit.
The composition and mineralogy of the sand unit has historically been described
as 90 percent or more quartz and little or no silt or clay. The absence of
significant amounts of silt or clay within the unit is significant when evaluating
contaminant migration within the unit. Contaminants present within the unit
that typically adsorb strongly to clayey soil particles (e.g., PNAs, PCBs, most
VOCs, and metals) may migrate a greater distance than otherwise predicted.
However, there are localized exceptions where the unit is stratified and has welldeveloped crossbedding, ripple marks, and scour and fill features.
The scour and fill features typically have been filled with a significant amount or
clay-size organic matter that may provide isolated pockets where higher
contaminant concentrations may be present.
In summary, contaminants detected in groundwater within the sand unit will
migrate to surface water if they are not controlled, captured, or degraded. In
addition, the sand unit has historically been a source of potable water. Therefore,
the sand unit is a geologic unit that is especially sensitive to urbanization and
industrial development. Table 6.2 contains a rating of the probabilities of
encountering certain hydrogeological conditions in each geologic unit of the Rouge
River Watershed.
Sandy and Silty Clay and Upper Clay Units - A sandy and silty clay unit and
upper clay unit are located east of the sand unit. The sandy and silty clay and
upper clay units range in elevation from approximately 640 feet on their western
margin to approximately 580 feet on their eastern margin. Due to the degree of
interbedding between the sandy and silty clay and upper clay units, the precise
boundary between the two units is interpolated.
The sandy and silty clay unit is characterized as a medium- to light-olive gray,
mottled, well rounded-pebble bearing, sandy to silty clay. Discontinuous finegrained sand lenses may also be present within the unit especially along its
western margin. The width of the unit ranges from approximately three to five
miles. The thickness of the unit ranges from 10 to 20 feet. In general, the unit
has more sand content along the western portion of the unit.

6-24
Well-developed varves have been observed within the sandy and silty clay unit and
upper clay unit. The varves appear to be more numerous along the western
margin of the sandy and silty clay unit, where they are interbedded and beneath
the sand unit. The individual varves range in thickness from approximately 0.1
to 0.25 inches and have been observed to extend for more than two feet vertically
within the unit. The upper clay unit is located east of the sandy and silty clay
unit. The upper clay unit forms the eastern boundary of the watershed and
ranges in elevation from 620 feet along its western margin to 580 feet at its
eastern margin. The upper clay unit is characterized as a bluish to light-olive
gray, mottled, clay with trace amounts of well-rounded pebbles.
Vertical hairline fractures may be present within the upper portion of both clay
units. These hairline fractures are caused by stress changes from wetting and
drying cycles and/or freezing and thawing (Freeze and Cherry, 1979). The
occurrence of the fractures decreases with increasing depth within each unit. In
addition, root fragments may also be present within the upper portion of any of
the near-surface geologic units. A mottled appearance and/or zones of oxidation
indicate the presence of fractures within the clay units.
The presence of vertical hairline fractures and discontinuous sand lenses within
the two clay units located east of the sand unit has resulted in a hydraulic
conductivity that is slightly higher that what would have been otherwise predicted.
The hydraulic conductivity for these two clay units ranges from 1 x 10-6 to 1 x 10 -2
cm/s.
The upper clay unit appears to be uniformly deposited in the north-south
direction within the Watershed and thickens from west to east. Along its western
margin, the upper clay unit is approximately 10 feet thick and may be more than
30 feet thick along its eastern margin near the Detroit River.
Groundwater encountered in the sandy and silty clay and upper clay units is
unconfined to semi-confined. When groundwater was encountered within the
units, it was present 1) within discontinuous sand lenses, and/or 2) at the contact
with the lower clay unit. Groundwater that is present within each of these clay
units is generally discontinuous and is not present in large volumes that could be
pumped from the ground at a sustained rate. However, groundwater encountered
within the sandy and silty clay unit may be hydraulically connected to the sand
unit, but groundwater within the sandy and silty clay unit is hydraulically down
gradient.
A groundwater flow direction was determined at some sites of environment
contamination located within the two clay units. The direction of groundwater


6-25
flow at those sites was toward the east-southeast. This flow is in the general
direction of the dip of the units and toward surface water.
Groundwater within the sandy and silty clay and upper clay units has not been
used as a source of potable water. Table 6.2 contains a rating of the probabilities
of encountering certain hydrogeological conditions in each geologic unit of the
Rouge River Watershed.
Isolated Units - The discontinuous and isolated units consist of two subunits:
! Discontinuous sand subunits, and
! Discontinuous sandy and silty clay subunits.
The discontinuous and isolated units are located in two primary regions of the
Watershed which are along the boundary between:
! The moraine unit and the sandy clay unit, and
! The sandy and silty clay unit and the clay unit.
The discontinuous sand units are generally described as fine-grained sand, less
than five feet thick, and less than 0.5 miles wide. However, the discontinuous
sand unit extending north of Ferndale through Royal Oak is more than 18 feet
thick. Historically, these units have been described as sand ridges (Sherzer 1913,
and 1916 and Leverett 1917). However, urbanization has obscured most evidence
that this unit is currently in the form of a sand ridge.
The discontinuous sandy and silty clay units are described as a bluish- to
medium- to light-olive gray, mottled, well-rounded pebble-bearing, sandy to silty
clay. The units are generally less than five feet thick and less than 0.5 miles wide.
These discontinuous sandy and silty clay units are located along the boundary
between the sandy and silty clay and clay units.


6-26
Groundwater encountered within the discontinuous and isolated units is

unconfined. When groundwater is encountered, it is generally within the
discontinuous sand subunits. The direction of groundwater flow is generally
toward the south-southeast.
According to Mozola (1954), the discontinuous sand subunit located north of the
city of Ferndale and extending through the city of Royal Oak, was once used as
a source of potable water by the city of Royal Oak. The saturated zone within the
subunit was within two feet of the surface of the ground and extended to the
bottom of the subunit at a depth of 18 feet.
The discontinuous sand subunit located east of the city of Dearborn Heights and
west of the city of Dearborn is generally less than five feet thick, consists of veryfine-grained sand, and is not capable of producing large volumes of water. Based
on available historical data, this subunit has not been a source of potable water.
The two discontinuous sand subunits located in the western portion of the city of
Detroit are less than five feet thick, consist of very-fine-grained sand, and are not
capable of producing large volumes of water.
These two subunits are
approximately 1,000 feet wide and three miles long. Based on available historical
data, these two subunits have not been a source of potable water.
Two additional discontinuous sand subunits are located in the western portion of
the watershed west of the city of Farmington and north of the city of Southfield
and a third discontinuous sand subunit is located west of Plymouth. These
subunits are less than five feet thick, approximately 1,000 feet wide and three
miles long. These subunits consist of very-fine-grained sand and are not capable
of producing large volumes of water. Table 6.2 contains a rating of the
probabilities of encountering certain hydrogeological conditions in each geologic
unit of the Rouge River Watershed.
Reworked River Deposits - Reworked river deposits are located along the Rouge
River. Groundwater may be encountered within the reworked river deposits and
may be present in large volumes, especially along the Lower Rouge River from the
city of Dearborn east to the city of Ecorse where the river discharges into the
Detroit River. The reworked river deposits have formed since the Rouge River
originated approximately 11,850 years ago, when the glacial lakes that once
occupied the region retreated.
The reworked river deposits are generally not as significant in the western portions
of the Watershed but are significant in the eastern portion and along the main
branches of the Rouge River. These deposits consist of alternating thin layers of
sand, silt, and clay that dip toward the Rouge River. A sand deposit is located
near the location where the Rouge River discharges into the Detroit River. This

6-27
sand deposit may be reworked river sediments from the Detroit River and not from
the Rouge River. The deposit has been described as being as thick as 40 feet
(Sherzer 1917). Groundwater present within the reworked rivers deposits most
likely is hydraulically connected to the Rouge River. Table 6.2 contains a rating
of the probabilities of encountering certain hydrogeological conditions in each
geologic unit of the Rouge River Watershed.
6.15 HYDRAULIC CONDUCTIVITY AND AVERAGE LINEAR VELOCITY
The hydraulic conductivities at evaluated sites where groundwater was present
ranged from 1.0 x 10-6 to 1.0 x 10+1 cm/s [Rogers 1996]. Table 6.3 presents the
range in hydraulic conductivities for each geologic unit.
The range in hydraulic conductivities was greatest for those sites located in the
moraine unit. Sites with groundwater in the sand unit generally had a high
hydraulic conductivity. Sites located in the clay unit generally had a low hydraulic
conductivity.
Table 6.3
Probability of Encountering Groundwater and Hydraulic Conductivities in
the Rouge River Watershed
GEOLOGIC UNIT
PROBABILITY
OF
ENCOUNTERING
GROUNDWATER
ESTIMATED
HYDRAULIC
CONDUCTIVITY
(CM/S)
Moraine Unit
35%
1.0 x 10-5 to 1.0 x 10+1
Sandy Clay Unit
14%
1.0 x 10-4
Sand Unit
97%
1.0 x 10-4 to 1.0 x 10-1
Sandy and Silty Clay

Unit
30%
1.0 x 10-5 to 1.0 x 10-2
Upper Clay Unit
22%
1.0 x 10-6 to 1.0 x 10-3
Discontinuous and
Isolated Units
81%
1.0 x 10-5 to 1.0 x 10-1
50.9%
1.0 x 10-6 to 1.0 x 10+1
Total


6-28
The average linear velocities of groundwater have been estimated at numerous

sites where the hydraulic conductivity and hydraulic gradient have been
evaluated. The average linear velocity of groundwater at these sites has ranged
from negligible flow to nearly 0.1 cm/s. Overall, the rate of groundwater flow
appears to be greater at sites located within the sand unit and the moraine unit
[which includes glacial outwash (Rogers 1996)]. In addition, the rate of
groundwater flow appears to be most consistent for those sites located within the
sand unit. The rate of groundwater flow was much lower for those sites located
within the sandy clay, sandy and silty clay and clay units.
6.16 SUBSURFACE GEOLOGY AND HYDROGEOLOGY
Beneath the near-surface units, a thick clay unit (lower clay unit) is present.
This unit underlies the entire Watershed. The lower clay unit ranges in thickness
from more than 180 feet beneath the moraine unit to approximately 50 feet
beneath the upper clay unit. The lower clay unit is characterized as a medium
bluish-gray clay with pebbles and cobbles, and rarely a boulder. The lower clay
unit was deposited directly by the glaciers and is termed a ground moraine
(Sherzer 1916 and Farrand 1988).The upper 0.5 feet of the lower clay unit may
have a light-olive gray to reddish brown color that grades into the medium bluishgray color, which is the dominant color of the unit. The color change is the result
of iron staining by water from the previous glacial lakes. The lower clay unit can
be differentiated from the upper clay unit by differences in lithology and the color
change between the two units. Lithologically, the lower clay unit has more
pebbles, the pebbles are generally larger (occasionally a boulder), and the pebbles
are not as well-rounded as the pebbles in the upper clay unit.
A discontinuous sand, gravel, and cobble layer is present beneath the lower clay
unit and directly overlies bedrock. The layer ranges in thickness from five to 10
feet in the eastern portion of the Watershed and is greater than 50 feet thick
beneath portions of western Livonia. The sand, gravel, and cobble layer thins
considerably west of Livonia and may not be present at locations beneath
Plymouth.
Groundwater has not been encountered in the lower clay unit. The hydraulic
conductivity of the lower clay unit ranges from 1.4 x 10-8 to 8.3 x 10 -8 cm/s. The
hydraulic conductivity of the lower clay unit is nearly uniform horizontally and
vertically. Therefore, the lower clay unit represents a regional aquiclude because
of its: 1.) thickness (greater than 50 feet), 2.) continuous horizontal distribution,
and 3.) low and uniform hydraulic conductivity. Other thick clay tills of the
nature, horizontal distribution, thickness, and hydraulic conductivity have been
observed at other locations in North America (Freeze & Cherry 1979 and Keller
et.al. 1989).


6-29
The presence of fractures or mottling, with the exception of the contact with the
near-surface units, within the lower clay unit have not been observed. The lack
of hairline fractures and mottling within the lower clay unit is most likely the
result of the unit being at a sufficient depth beneath the surface, which has
insulated the unit and prevented or minimized the potential development of
fractures.
The thickness, horizontal distribution, and low and uniform hydraulic
conductivity of the lower clay unit has influenced near-surface groundwater flow
on a regional basis. The presence of the lower clay unit has prevented
groundwater from migrating to lower aquifers. Instead, groundwater in nearsurface aquifers discharges to surface water.
6.17 AIR MODELING
Toxicity data indicate that risks from exposure to some chemicals via inhalation
far outweigh the risks via ingestion (USEPA, 1996). Therefore, if concentrations
of hazardous substances are elevated in surface or subsurface soil, it may be
necessary to conduct air modeling to estimate the concentration of soil
contaminants in ambient air. Air modeling can be conducted for both volatiles
and fugitive dusts.
Inhalation from fugitive dusts results from particle entrainment from the soil
surface; thus contaminant concentrations in the surface soil horizon (i.e., the top
two centimeters) are of primary concern for this pathway. On the other hand, the
entire column of contaminated soil can contribute to volatile emissions at a site.
However, the top two centimeters are likely to be depleted of volatile contaminants
at most sites. Therefore, contaminant concentrations in subsurface soils, which
are measured using core samples, are of primary concern for quantifying the risk
from volatile emissions.
For volatiles, the soil-to-air volatilization factor (VF) is used to define the
relationship between the concentration of the contaminant in soil and the flux of
the volatilized contaminant to air. VF is calculated using chemical-specific
properties and either site-measured or default values for soil moisture, dry bulk
density, and fraction of organic carbon in soil (USEPA, 1996). VF can be
calculated based on the assumption of an infinite source of contamination or a
known mass of contaminant using a finite source model.
The particulate emission factor relates the concentration of contaminant in soil
to the concentration of dust particles in the air. Dust from open sources is
typically termed fugitive because it is not discharged into the atmosphere in a
confined flow stream (i.e., discharge from a point source or stack emission). Wind
moving across an open site with erodible areas of exposed surface soil can create

6-30
an emission flux. Other sources of fugitive dusts that may lead to higher
emissions due to mechanical disturbances include unpaved roads, tilled
agricultural soils, and construction operations (USEPA, 1996).
Several models can be used to estimate the air concentration of volatiles and
fugitive dusts. For fugitive dusts, USEPA currently uses the unlimited reservoir
model from Cowherd et al. (1985) to estimate particulate emissions due to wind
erosion. The unlimited reservoir model is most sensitive to the threshold friction
velocity, which is a function of the mode of the size distribution of surface soil
aggregates. The mode soil aggregate size determines how much wind is needed
before dust is generated at a site. This parameter has the greatest effect on the
emissions and resulting concentration.
For volatiles, USEPA currently uses the infinite source Jury model because this
model was shown to most accurately predict the available measured soil
contaminant volatilization rates and considers the influence of the liquid phase
on the local equilibrium partitioning. Other than the initial soil concentration, airfilled soil porosity is the most significant soil parameter affecting the final steadystate flux of volatile contaminants from soil (USEPA, 1996). The higher the airfilled soil porosity, the greater the emission flux of volatile contaminants.
To calculate the concentration of potential surface soil emissions in air, a
dispersion model is used. An air dispersion model for fugitive dust or volatile
emissions from a site should have the following characteristics (USEPA, 1996):
! Dispersion modeling from a ground-level area source on-site receptor
! A long-term/annual average exposure point concentration
! Algorithms for calculating the exposure point concentration for area sources
of different sizes and shapes
USEPA is currently using the Industrial Source Complex Model (ISCST3) to
estimate dispersion of airborne contaminants.
6.18 FINAL RISK EVALUATION
Once the sampling and data collection has been completed, the data must be
reevaluated with respect to potential risks posed by the site. The final risk
evaluation should include a description of the receptors, exposure pathways, and
whether concentrations of hazardous substances exceed the applicable risk-based
clean-up criteria. A detailed description of the risk assessment process is
presented in Chapter 7.
6.19 PREPARATION OF FINAL REPORT


6-31
Following completion of the investigation, a final report should be prepared that

summarizes the activities, findings, and conclusions, and includes a detailed
description of the risk evaluation.
6.20 REFERENCES
Bedient, Philip B., Rafai S. Hanadi and Charles J. Newell. 1994. Groundwater
Contamination, Transport, and Remediation. Prentice Hall PTR. Englewood Cliffs,
New Jersey, 541p.
Berquist, A.P. & D.C. MacLachlan. 1951. Guidebook to the Study of Pleistocene
Features of the Huron-Saginaw Ice Lobes in Michigan. The Glacial Field Trip of the
Geological Society of America, Detroit Meeting.
Bouchard, D. C., 1989. Transport Processes Involving Organic Chemicals. Robert
S. Kerr Environmental Research Laboratory. Ada, Oklahoma. 195p.
Cowherd, D., G. Muleski, P. Engelhart, and D. Gillette. 1985. Rapid Assessment
of Exposure to Particulate Emissions from Surface Contamination. EPA/600/885/002. NTIS PB85-192219. Office of Health and Environmental Assessment,
U.S. Environmental Protection Agency, Washington, D.C.
Dorr, John A. & D. Eschman. 1988. Geology of Michigan. The University of
Michigan Press. Ann Arbor, Michigan.
Farrand, W. R. 1982. Quaternary Geology of Southern (& Northern) Michigan.
Michigan Department of Natural Resources, Geological Survey Division. Lansing,
Michigan. 1:500,000, 2 Sheets.
Farrand, W. R. 1988. The Glacial Lakes Around Michigan. Michigan Department
of Natural Resources Bulletin No. 4. Lansing, Michigan. 15p.
Fetter, C. W., 1993. Contaminant Hydrogeology. Macmillan. New York, New York.
576p.
Freeze, R. A. & J. A. Cherry. 1979. Groundwater. Prentice-Hall, Inc. Englewood
Cliffs, New Jersey.
Howard. P. H., 1988. Handbook of Environmental Fate and Exposure Data. Lewis
Publishing, Chelsea, Michigan. 245p.
Hubbard, B. 1840, in: Houghton, D., Second Annual Report of the State Geologist,
Mi. Geo. and Bio. Survey, Lansing, Michigan, 30p.


6-32
Keller, K. C., Van Der Kamp, G., and J. A. Cherry. 1989. A Multiscale Study of
the Permeability of a Thick Clayey Till. Water Resources Research. Vol. 25. No. 11.
p. 2299-2317.
Leverett, F. B. 1911. Map of the Surface Formations of the Southern Peninsula of
Michigan. Geological Survey of Michigan, Publication 25, Lansing, Michigan.
1:1,000,000. 1sheet.
Leverett, F. B. 1917. Surface Geology and Agricultural Conditions of Michigan.
Annual Report of the Board of Geology Survey of Michigan. Lansing, Michigan.
223p.
Leverett, F. B. & Taylor, F B. 1915. The Pleistocene of Indiana and Michigan and
the History of the Great Lakes, U. S. Geo. Survey, Monograph 53, 529p.
Martin, H. 1957. Geologic Map of Michigan. Michigan Department of Conservation.
Lansing, Michigan. 1 sheet.
MDEQ. 1996. Interim Environmental Response Division Operational
Memorandum #17: Instructions for Obtaining Definitions on Mixing Zone-Based
Groundwater Surface Water Interface Criteria for Inclusion in Remedial Action Plans
and Monitoring Compliance with Criteria for Discharges of Groundwater
Contaminants to Surface Water. Michigan Department of Environmental Quality.
Interoffice Communication. April 12, 1996.
Mozola, A. J. 1954. A Survey of the Groundwater Resources in Oakland County,
Michigan. Michigan Geological Survey. Publication 48, Part II. Lansing, Michigan.
Mozola, A. J. 1969. Geology for Land and Groundwater Development in Wayne
County, Michigan. Michigan Geological Survey. Lansing, Michigan.
Mulkey, L. A., Donigian, Jr., A.S., Allison, T.L., and Raju, C.S. 1992. Evaluation
of Source Term Initial Conditions for Modeling Leachate Migration from Landfills.
EPA/600/R-92/233. Office of Research and Development. U.S. Environmental
Protection Agency. Athens, GA.
Rieck, R. L. 1981. Map. Glacial drift thickness, Southern Peninsula. Plate 15.
Hydrogeologic Atlas of Michigan. Western Michigan University. Kalamazoo,
Michigan.
Rogers, D.T. 1996. Environmental Geology of Metropolitan Detroit.
Environmental Consultants, Inc. Novi, Michigan.

Clayton

6-33
Sherzer, W. H. 1913. Geology of Wayne County, Geo. Survey of Mi., Pub. 12:
Lansing, Michigan.
Sherzer, W. H., 1916. Geologic Atlas of the United States, Detroit Folio No.E205,
U. S. Geo. Survey, Reston, Virginia, 1:62,500, 4 Sheets.
Spencer, W. 1888. The Iroquois Beach, Science, Vol. XI, 49p.
Taylor, F.B. 1897. Correlation of Erie-Huron Beaches with Outlets and Moraines in
Southeastern Michigan. Bulletin of the Geological Society of America. Vol. VIII, 52p.
Taylor, F.B. 1899. The Great Ice-Dams of Lakes Maumee, Whittlesey, and Warren.
American Geologist. Vol. XXIV. 23p.
United States Environmental Protection Agency (USEPA). 1990. A Guide to
Selecting Superfund Remedial Actions. Office of Solid Waste and Emergency
Response. OSWER-9355.0-27FS. Washington, D.C., 6p.
USEPA. 1996. Soil Screening Guidance: Technical Background Document. Office
of Solid Waste and Emergency Response. EPA/540/R-95/128. PB96-963502.
(May 1996).
USEPA. 1991. Conducting Remedial Investigations/Feasibility Studies for CERCLA
Municipal Landfill Sites.
Office of
Emergency and Remedial Response.
EPA/540/P-91/001. Washington, D.C., 294p.
USEPA, 1993. Remediation Technologies Screening Matrix and Reference Guide.
Office of Solid Waste and Emergency Response. EPA 542-B-93-005. Washington,
D. C. 141p.
USEPA, 1994a. Physical/Chemical Treatment Technology Resource Guide. Office
of Solid Waste and Emergency Response, Technology Innovation Office. EPA 542B-94-008. 43p.
USEPA, 1994b. Groundwater Treatment Technology Resource Guide. Office of
Solid Waste and Emergency Response, Technology Innovation Office. EPA 542-B94-009. 29p
USEPA. 1990b. Groundwater. Volume I. Groundwater and Contamination, United
States Environmental Protection Agency. Washington, D. C. 144p.
USEPA. 1991.
Groundwater.
Volume II.
Methodology,
Environmental Protection Agency. Washington, D. C. 144p.
United States

6-34
USEPA. 1992a. Estimating the Potential for the Occurrence of DNAPL at Superfund
Sites. Environmental Protection Agency Quick Reference Sheet. United States
Environmental Protection Agency Publication 9355.4-7FS. Washington, D. C.
USEPA. 1992b. Dense Nonaqueous Phase Liquids (DNAPLs): A Workshop
Summary. EPA Groundwater Issue Paper. United States Environmental
Protection Agency Publication EPA/600-R+92/030. Washington, D. C.
Van der Heijde, Paul K. M.; Aly I. El-Kadi, and Stan A. Williams, Groundwater
Modeling: An Overview and Status Report, United States Environmental
Protection Agency, December 1988. Document No. EPA/600/2-89/028.
Wiedemeier T. H., D. C. Downey, J. T. Wilson, D. H. Kampbell, R. N. Miller, and
J. E. Hansen., Technical Protocol for Implementing the Intrinsic Remediation with
Long-term Monitoring Option for Natural Attenuation of Dissolved-Phase Fuel
Contamination in Groundwater. United States Air Force Center for Environmental
Excellence, Brooks AFB, San Antonio, TX, March 1994.


6-35
CHAPTER 7 - PERFORMING A RISK EVALUATION

A risk evaluation or risk assessment is conducted to satisfy one or more of the
following objectives:
! Characterize health and environmental risks associated with the site;
! Determine if additional investigation is necessary to adequately characterize
risks associated with the site; and
! Determine the need, if any, for response activities.
The risk evaluation will typically include data evaluation, fate and transport
analysis, exposure pathway assessment, and risk characterization. Each of these
activities is described in the following text.
7.1 DATA EVALUATION
The first step in data evaluation is to review the existing site and chemical-specific
data.
These data may include demographic, hydrologic, hydrogeologic,
climatologic, geologic, and chemical-specific soil, surface water, and groundwater
data. Some of the general considerations with respect to data sufficiency and
adequate characterization of the site include:
! Identification of the hazardous substance source areas;
! Definition of the nature and extent of hazardous substances;
-identify all hazardous substances present in applicable media
-identify maximum concentrations of hazardous substances
-define areal extent of hazardous substances
! Identification and understanding of the contaminant transport and
exposure pathways;
! Validation of the sampling and analytical methods;
! Evaluation of data quality and completeness;
! Interpretation of the data; and
! Assessment of property history and current property conditions and land
use.
The data evaluation may also include a review of chemical property data, generic
studies on the environmental behavior of contaminants, and toxic effects
databases. To ensure the use of the most up-to-date sources of toxic effects data,
one or more of the following data sources can be referenced:
! Integrated Risk Information System (IRIS);
! Health Effects Summary Tables (HEAST);
! Registry of Toxic Effects of Chemical Substances (RTEC);

7-1
! EPA Health Effects Assessment Documents; and

! International Agency for Research on Chemicals (IARC) Monographs.
7.2 CONTAMINANT FATE AND TRANSPORT ANALYSIS
The assessment of contaminant fate processes and characterization of
contaminant transport pathways are the key to the identification of significant
exposure pathways. The overall objective of this analysis is identification of
critical pathways that most influence hazardous substance distribution,
environmental concentrations in various media, and ultimately, the degree of
exposure. The output of this analysis is an assessment of the likelihood and
extent of offsite contaminant migration. A detailed description of fate and
transport analysis can be found in Chapter 6 of this document.
7.3 EXPOSURE PATHWAY ASSESSMENT
The exposure assessment step takes into account hazardous substance
distribution, migration pathways, and potential receptors to define the types and
levels of exposure attributable to site contamination. Results of an exposure
assessment are weighed against the human health and environmental effects of
each compound to assess the risk of exposure and the potential for adverse effects
in the event of exposure. All possible exposures should be characterized. Critical
elements in the exposure analysis are:
!
!
!
!
!
Source(s) of the chemical constituent,

Routes of exposure,
Duration and frequency of exposure,
Amount or extent of exposure, and
Size of the population exposed.
It is also important to assess whether there is likely to be any exposure at

adjacent or nearby properties that is attributable to environmental contamination
at the abandoned dump site and to identify the potential off-site receptors.
Examples of potential offsite receptors are nearby residents or persons using water
supplies downgradient of the site, and plant and animal communities in the
vicinity of the site.


7-2
A list of the potential exposure pathways and conditions should be developed and
may include one or more of the following:
Hazardous Substance Sources
! Abandoned substances not yet dispersed and free phase liquids (i.e. drums,
tanks, lagoons, buried materials, free product, etc.)
Groundwater Contamination
! Drinking water usage;
! Dermal exposure (i.e. direct contact with hazardous substances in soil,
water, etc.);
! Indoor air hazards; and
! Hazards to surface waters.
Soil Contamination
! Direct contact hazards (i.e. ingestion, dermal adsorption);
! Ambient air inhalation hazards;
! Indoor air inhalation hazards;
! Injury to drinking water use of aquifer (i.e. leaching of hazardous
substances from soil to groundwater);
! Dermal exposure to groundwater affected by hazardous substances in soil
(i.e. by leaching from soil); and
! Exposure to surface water impacted by leachate-contaminated groundwater
! Contaminated soil runoff to surface water.
Other Pathways/Conditions
! Acute toxic impacts and physical hazards, and
! Ecological and aesthetics impacts
Once the exposure pathways have been identified, the applicable cleanup criteria
can be chosen. It is important to note that it is critical to verify that the cleanup
criteria are appropriate to the site, considering such things as land use and
activity patterns anticipated at the site. Since many abandoned dumps are
located on sites with current or proposed recreational land use and generic
cleanup criteria for recreational land use have not yet been established by the
MDEQ, generic recreational soil cleanup criteria have been developed for this
abandoned dump closure process. These cleanup criteria and a description of the
data and methods used to develop the criteria can be found in Appendix A.
Generic cleanup criteria are calculated using generic exposure assumptions (i.e.
hours of exposure, number of days exposed, etc.); these exposure assumptions
may or may not reflect actual conditions at a specific site. If it is determined that
the generic cleanup criteria do not accurately reflect site-specific exposure

7-3
conditions, it may be necessary to revise the generic cleanup criteria or develop

site-specific target cleanup criteria. A site-specific risk assessment is designed to
utilize site data and a proposed land use or exposure scenario to assess whether
known hazardous substances pose an unacceptable risk at that specific site.
Refer to Chapter 3 for a detailed description of the process for evaluating and
identifying the exposure pathways and establishing the applicable cleanup criteria
(i.e. target cleanup criteria).
7.4 RISK CHARACTERIZATION
The risk characterization step integrates the exposure, health, and environmental
assessment information into a determination of risk conclusions for the site in its
present condition. Based on information developed in the previous steps, the risk
characterization determines the likelihood and extent of exposure to hazardous
substances. One of the major objectives of this assessment is to identify site
conditions that pose an unacceptable risk, and therefore, need cleanup and/or
control (i.e. remedial action)
As part of the risk characterization step, the concentration of hazardous
substances in applicable media are compared to the target cleanup criteria. If the
exposure concentration is less than the applicable cleanup criteria, there is
minimal or no concern to human health. If the exposure concentration is greater
than the target cleanup criteria, there may be a concern to human health. See
Chapter 3 for a detailed description of the process for applying cleanup criteria.
It is important to note that if concentrations of hazardous substances exceeding
generic residential criteria are to remain on site, institutional controls will likely
be implemented to restrict site activities or to ensure the integrity of a presumptive
remedy. Refer to Chapter 1 and 2 for a description of the use of institutional
controls.


7-4
CHAPTER 8 - SELECTING REMEDIAL ALTERNATIVES
he selection of remedial alternatives is necessary in situations where the

levels of contaminants exceed the established criteria and are found to pose
an unacceptable site-specific risk. This is typically the end point of an
investigation and involves the analysis of selected remedial strategies. The
primary objective of this step in the investigation strategy is to reduce the human
health and environmental risks to an acceptable level and to permit reuse of the
site. This evaluation process is often termed a feasibility assessment or study.
For example, if an unacceptable groundwater exposure risk is found, then
remedial alternatives such as groundwater pumping, installation of a barrier, or
capping to prevent water infiltration could be considered. The specific remedies
evaluated and selected will depend on site-specific conditions.
8.1 EVALUATION AND SELECTION OF REMEDIAL ACTION ALTERNATIVES
It may be necessary to conduct a remedial action at a site to either maintain long
term exposure controls or reduce potential risk posed by hazardous substances
present at the site. This section provides a brief description of potential remedial
actions that may be used at an abandoned dump site.
Where remedial action is deemed necessary, the approach can take the form of
containment, management, or full scale remediation.
Placing a specific
remediation technology in one of these categories is not always straightforward
and some overlapping can be expected. For example, application of pump and
treat methods may be viewed as a management approach or a remediation
technology, depending on site-specific conditions, objectives and site-specific
technological effectiveness.
The selection of a remedial action is influenced by several factors including the
types of wastes, site characteristics, potential uses of surface water and
groundwater, and federal and state regulatory requirements. These factors are
evaluated in terms of the potential risk to human health and the environment
posed by the site.
Table 8.1 summarizes the remedial actions considered applicable to abandoned
dump sites. In addition, Table 8.1 identifies the different technologies of
containment, management, and remediation and lists the advantages and
disadvantage of each technology. Because of the relatively large size of landfill
sites and the waste composition, the most likely preferred response actions for
most abandoned dumps will be in the containment category. More aggressive
treatment of hot spots, if they exist, may be necessary.
Some of the remediation methods useful for soil and groundwater contamination

8-1
have not been included in Table 8.1 because they have not been used in landfill
situations enough to be considered candidates. Those remediation methods not
shown include bioventing, biosparging, air sparging, and soil flushing, as well as
numerous ex-situ processes.
8.2 IMPLEMENTATION OF REMEDIAL ACTIONS
Once a feasibility study has identified suitable remedial actions for a site,
implementation of the selected remedial action is the next step. Whether the
approach involves a presumptive remedy or other remediation strategy, the
requirements are comparable.
8.2.1 REMEDIAL ACTION PLANS AND MICHIGANS PART 201
As described in Chapter 2.0, the state of Michigan has adopted specific statutes
and rules regarding the completion, review, and approval of RAPs, and has
formulated comprehensive sets of cleanup criteria for a variety of closure options.
The relevant resources are as follows:
! Address:
!
!
!
!
Environmental Response Division

Michigan Department of Environmental Quality
P.O. Box 30426
Lansing, Michigan 48909
Phone: (517)373-9837
Web Page: www.deq.state.mi.us/erd/
Statute: Part 201(Environmental Remediation) of the Natural Resources and
Environmental Protection Act, 1994 PA 451, as amended
Draft Rules: R299.5101 et seq., of the Michigan administrative code
Operational Memoranda, Training Materials available by mail from the
Environmental Response Division or by download from the ERD Web Page.
The category of closure is of primary importance in determining not only the

cleanup criteria that will apply but also other aspects of the RAP submittal. If the
Residential category is selected, no land use restrictions or monitoring will be
required once the remedial action is completed. Selection of any other category
(industrial, commercial, recreational) will necessitate the filing of a Notice of
Approved Environmental Remediation (NAER) with the county register of deeds.
This notice will specify the land use category that is consistent with the approved
remediation and state that any change in land use will require an evaluation of
risks associated with such a change.


8-2
Table 8.1
Summary of Remediation Technologies Potentially Appropriate for
REMEDIAL ACTION
CATEGORY
ADVANTAGES
DISADVANTAGES
Slurry Walls
Low cost; readily available
Unknown long-term effectiveness;

difficult to maintain; possibly less
acceptable to community and
regulatory agencies
Soil Cover
Low cost, depending on the

availability of soil and size
of site; easy to implement
Requires maintenance; disturbance

may result in inhalation and direct
contact risk
Clay Cap
Easy
to
implement,
depending on the source of
clay;
greater
exposure
protection than soil cover
Requires maintenance; disturbance

may result in inhalation and direct
contact risk
Composite Barrier
Cap
Maximum
protection
e xposure
Requires a specialty contractor for

installation; medium to high cost
Solidification/
Stabilization
Readily available; moderate

cost
Not applicable to groundwater

contamination; long-term risk not
well defined
Not applicable to groundwater
contamination; not recommended
for VOCs; high cost for large areas
Excavation
M, R
Good for hot spots
Natural Attenuation
M, R
Readily available;
moderate cost
to
Requires
extensive
site
characterization,
simulation
modeling, and ongoing monitoring;
regulatory
and
community
acceptance may be low
Passive Treatment
Walls
M, R
Destructive technology that

reduces overall toxicity
Applicable at limited depths; time

period of usefulness may be short,
requiring replacement; technology
not widely used
Groundwater
Recovery and
Treatment (Pump
& Treat)
M, R
Cost effective way to control

spread
of
groundwater
plume
Not
effective
at
eliminating
contamination over a short time;
effectiveness
limited
in
heterogeneous geologic settings
Bioremediation
Destructive technology; cost

effective
Can be slow or ineffective with

some types of contaminants or
geologic settings
Soil Vapor
Extraction
Proven,
effective
Effective with volatiles only;

requires treatment of recovered
vapors
reliable,
low
cost
Category: C = Containment; M = Management; R = Remediation


8-3
Part 201 also specifies that any land use or resource use restrictions are to be
described in a restrictive covenant, filed with the county register of deeds. The
requirement for a restrictive covenant applies to all remedial actions that require
any type of containment or exposure barrier. The statute allows for application
of institutional controls to be applied in cases where a restrictive covenant will be
impractical or ineffective at limiting exposure to hazardous chemicals.
According to Part 201 the remedial action plan will include the following:
! A description of the remedial action, including a description of compliance
with the applicable statute and rules;
! All applicable technical submittals, including remedial investigation report,
feasibility study, risk assessment, closure report, etc.;
! An operation and maintenance plan;
! A monitoring plan;
! An explanation of any land use or resource use restrictions, as well as a
plan for the monitoring and enforcement of these restrictions; and,
! a schedule for implementation of the RAP.
If a RAP is submitted to achieve closure under commercial, industrial, or
recreational criteria, the operation and maintenance plan, monitoring plan, and
financial assurance plan must be submitted if they will be required to ensure
compliance with applicable criteria outside the boundary of the property that is
the source of the release.
8.3 PRESUMPTIVE REMEDIES
As described in Chapter 1, USEPA has developed presumptive remedies to
accelerate cleanup of some sites. The USEPA has identified containment as the
presumptive remedy for CERCLA municipal landfill sites. Containment methods
applicable to abandoned dump sites include capping, source area ground water
control, leachate collection and treatment, gas treatment, and institutional
controls.
8.3.1 CAPPING
Capping is typically required when contaminated materials are to be left in place
at a site. It is commonly used when the underground contamination is so
extensive that it prohibits excavation and removal. It may also be used if the
removal of wastes from the site would pose a greater threat to human health and
the environment than simply leaving them in place. The purposes of a cap may
include any of the following:
! Preventing direct contact with landfill contents (i.e. exposure barrier);

8-4
! Minimizing water infiltration and resulting contaminant leaching to ground

water (i.e. impermeable cap);
! Controlling surface water runoff and erosion (i.e. site grading and surface
cover); and
! Control landfill gas emissions.
If the chosen presumptive remedy is a landfill cap, it is not necessary to conduct
extensive surface soil sampling for the purpose of defining risks associated with
direct contact to soil. Installation of the landfill cap will prevent direct contact
with contaminants present in surface soil.
The composition of the cover will include some combination of geotextile,
compacted clay, and topsoil, depending on the requirements of the specific site.
For example, if a physical barrier to prevent direct contact is needed, a layer of
topsoil may meet this requirement. If a barrier is needed to prevent infiltration of
rainfall, an impermeable cap of compacted clay or an impermeable synthetic liner
will be appropriate.
Regardless of the composition of the capping material, long-term operations and
maintenance considerations are critical to the effectiveness of a cap. Most caps
require periodic inspection for settlement, standing water, erosion, or disturbance
by deep-rooted plants. In addition, the ground water monitoring wells usually
associated with caps need to be sampled periodically and maintained.
The design of a landfill cap will require a variety of types of data. This will include
information on depth to water, availability of appropriate materials, stability of the
waste material, site topography, characteristics of the cover material, frost depth,
land use in the vicinity of the site, and future land use of the site. Consideration
of these factors will dictate the type of capping material that will be most
appropriate for a specific site. For instance, if all or most of the waste is above the
water table, then infiltration protection is more important, and therefore so is
freeze thaw protection, than if a majority of the waste is saturated. As saturated
thickness of waste increases, hydraulic containment increases in importance as
an element, and infiltration protection decreases.


8-5
In addition, installation factors must also be considered. These include such

factors as compacting the various layers of the cap, running structural stability
tests to assure uniformity of the capping materials, ensuring that a synthetic liner
is not punctured, and ensuring that waste material is not inadvertently spread
over the site or mixed into the cap material during installation.
8.3.2 LEACHATE COLLECTION AND TREATMENT
The presence of a plume of contamination originating from the abandoned landfill
necessitates the implementation of a ground water treatment program. Collecting
and treating contaminated ground water and leachate may be the most suitable
strategy to contain the contaminant plume and prevent further migration from
source areas. This remedy may be accomplished by applying several different
technologies, some of which are described in Table 8.1.
The most common approaches for preventing ground water migration are recovery
and treatment (pump & treat) using vertical wells or subsurface drains, slurry
walls, and passive treatment barriers. The most appropriate technology will
depend on site specific factors, especially the properties and concentrations of the
contaminants of concern.
Leachate treatment methods may be chemical, physical, or biological in basis, and
may be implemented on- or off-site. The design and implementation of a leachate
treatment system requires detailed chemical analysis of the leachate, including all
contaminants, variability in leachate composition, and conventional water quality
parameters. Treatability studies will also be necessary during the design phase.
8.3.3 GAS TREATMENT
When the unsaturated soil zone is found to contain elevated levels of landfillrelated gases such as methane, produced through the natural decomposition of
organic materials, some recovery strategy may be required. The conditions that
are likely to necessitate implementation of gas collection include proximity to
structures, public use or access, unpleasant odors, or specific state requirements.
Landfill gas collection is typically accomplished through passive systems involving
pipe or trench vents, or active systems employing gas extraction wells and vacuum
blowers. Gas treatment, when necessary, is commonly by thermal destruction,
through enclosed ground flares. To design such a system, the quantity,
composition, and heat value of the landfill gas must be determined, and pilot tests
are often necessary to ascertain operating efficiency.
8.3.4 SOURCE AREA GROUND WATER CONTROL

8-6
Ground water is often collected to manage offsite migration of leachate as well as

to recover a plume of contaminated ground water. Both objectives are typically
accomplished using ground water extraction wells or subsurface drains.
In addition to ground water collection, migration of contaminants in ground water
or leachate may also be controlled through the use of vertical barriers composed
of a soil-bentonite slurry. The applicability of such barriers, also known as slurry
walls, is dependent on topography, soil and geological conditions, depth to
bedrock or an aquitard, and the chemical characteristics of the leachate.
8.3.5 INSTITUTIONAL CONTROLS
It is important to note that because the continued effectiveness of the containment
remedy depends on the integrity of the containment system, it is likely that
institutional controls will be necessary to restrict site activities and ensure the
integrity of the presumptive remedy.
Institutional controls are those controls that can be used by responsible parties
and regulatory agencies in remedial programs where, as a part of that program,
certain concentrations of the chemical(s) of concern will remain on site(ASTM,
1995).
Types of institutional controls include (ASTM, 1995):
! Deed restrictions
! Use restrictions such as 1.) a prohibition on using on-site ground water for
drinking water, 2.) a prohibition on activities that may disturb a
containment cap, 3.) restricting access to the site, and 4.) restricting
property use.
! Access controls limit the access to any particular site for the purpose of
limiting exposure to contaminants present on the site.
! Notice involves providing notice of specific locations of chemicals on the site
and disclosure of any land use restrictions. Notice may be 1.) recorded on
the land record, 2.) a requirement for direct notice to parties of a land
transaction, or 3.) a notice to government authorities.
More detail on the use of institutional controls can be found in Chapter 1.


8-7
8.4 PERMITTING REQUIREMENTS

Implementation of a remedial action plan can be a complex undertaking consisting
of many components, some of which will require regulatory approval. The permits
required for a remediation project will vary with the location of the site and the
activities to be performed. The jurisdiction of the dump site will dictate, for
example, if the soil erosion\stabilization permit will come from the county or the
municipality. The following checklist (Table 8.2) is intended to provide some
general guidance regarding the types of permits that should be anticipated.
Table 8.2
Remediation Permit Checklist
PERMIT
SOURCE
COMMENTS
Groundwater Discharge
Exemption
State of Michigan
Needed for discharge of

ground water generated
during aquifer testing and
ground water remediation
Soil Erosion
County or Municipality
May be combined with storm

water permit
Dust Control
Municipality
Stormwater
County or Municipality
May be combined with soil

erosion permit
Floodplain
State or County
Needed for construction work

in floodplain
Tree Removal
Municipality
Lakes and Streams
State or County
Needed if cut/fill activities

will impact river channel
Wetlands
Federal, State or County
Needed if wetlands will be

impacted
Well Drilling
Local Municipality
8.5 MANIFESTING AND WASTE DISPOSAL

During implementation of the remedial action, it is likely that waste will be
generated. It will be necessary to characterize the waste prior to disposal to
determine whether it is a hazardous waste. If the waste is characterized as a
hazardous waste, it must be stored, handled, and disposed of according to state
and federal hazardous waste regulations. If the waste is nonhazardous, but

8-8
consists of various types of landfill waste and/or liquid waste, there will likely be
special handling and disposal considerations and requirements.
8.6 LONG TERM OPERATIONS AND MAINTENANCE
The following are aspects of operations and maintenance that must be considered
in the years following remedial action implementation.
! Permanent markers to describe restricted areas of the site and the nature
of any restrictions.
! Monitoring of the effectiveness and integrity of the remedial action
! Operation and maintenance of the remedial action
! Continued financial responsibility is the establishment of financial
mechanisms by which a party ensures continued funding of remediation
measures.
8.7 REFERENCES
USEPA. 1998. Memorandum. Subject: Findings and Recommendations of the
Working Group Reviewing Landfill Cover Requirements and Decision-Making by
Region 5 Superfund Program. From: James N. Mayka, Chief, Remedial Response
Branch #2 and Wendy Carney, Chief, Remedial Response Branch #1; To:
Superfund RPMs. April 14, 1998.
USEPA. 1992. EPA Facts About Capping. Compiled from: Superfund Innovative
Technology Evaluation (November 1990). June 1992.


8-9
CHAPTER 9 - PUBLIC INVOLVEMENT
ublic involvement (PI) is an interactive process for establishing

communication links between business or government agencies and the
stakeholder groups affected by their laws, policies or decisions.
Stakeholders are those individuals or groups who are affected, will be affected, or
feel that they will be affected by the policy or decision. The PI process provides a
means by which interested individuals and groups can be identified, opinions and
issues of concern can be raised and explored, and potential solutions can be
arrived at by consensus. It is an essential component in the investigation and
remediation of abandoned dump sites.
This section of the guide defines public involvement and its key principles, and
outlines a four-step process to assist the closure team in developing a public
involvement plan. There are two key principles to observe when developing a
public involvement program:
1. maintain public awareness and participation, and
2. distribute information that may affect the communities involved in a timely
manner.
Because a properly executed public involvement process can provide a project
manager with valuable feedback from the local stakeholders, it is important that
public understanding, input, and acceptance be considered in the early stages of
a site investigation.
The four-steps in developing a public involvement plan are:
1. preliminary assessment,
2. preliminary public contact,
3. preparation of a detailed public involvement plan for the abandoned dump
site, and
4. implementation.
The first step, preliminary assessment, serves to enable a community to determine
the type of program that is appropriate for the site. Because public involvement
will vary, no single public involvement program can be applied to all sites. A
variety of factors must be specifically addressed, including the particular
demographic circumstances of the site and location of the community.


9-1
The second step, preliminary public contact, opens the public involvement
dialogue and helps the team to determine the list of potential stakeholders.
During this phase, preliminary information about the proposed closure process
is provided to stakeholders in anticipation that the stakeholders will provide the
project manager with meaningful feedback and express their concerns. This step
is complete when the project planners understand the issues that the
stakeholders have raised and have determined both the level of public interest and
the significance of those issues.
After all significant issues have been identified, a detailed public involvement plan
can be prepared which integrates the issues raised into the decision-making
process. The following key factors should be considered when choosing public
involvement tools for an abandoned dump situation:
!
!
!
!
!
time and funding commitment,

cost,
required expertise,
the project schedule, and
the ultimate objective(s) of the project.
The following elements should be included in a detailed public involvement plan:

the specific objectives of the project, site characteristics specific to the abandoned
dump in question, a detailed list of individuals, groups, and others likely to be
affected or interested in the dump site investigation, a clear description of the
dump site investigation activities, and a sequential plan of public involvement
activities which will be integrated into the decision-making process.
The final step in the four-step process is to implement the public involvement
plan. Depending upon the information gathered in the previous steps, this phase
may not need to be lengthy or costly. If little interest is shown in the proposed site
investigation during the first informational meeting, the team may only need to
send a notice of the proposed activity to the stakeholders and the media and/or
conduct a series of periodic media interviews and written stakeholder updates to
ensure public scrutiny. Although this phase will probably take the longest to
complete, its success will depend largely on how much time and effort were spent
formulating the plan.
Public involvement is an important component in the investigation and
remediation of abandoned dump sites located within a community. This section
of the guidance document describes a generic public involvement plan which a
local unit of government can use to develop a more specific public involvement
plan that is appropriate for its specific situation.
Effective risk communication is recognized as one of the critical components of a

9-2
successful public involvement program when certain lands are viewed by the
public as locally unwanted land uses. Because residents feel strongly about their
property and the health and safety of their families, policy decisions involving
locally unwanted land uses can trigger serious disagreements between
communities and their local governments. The issues pertaining to locally
unwanted land uses that are typically of greatest concern to public stakeholders
are:
! health and environmental risks,
! risks to the most sensitive population groups such as children and the
aged,
! the value of property located near a potentially contaminated site, and
! trust in the governing regulatory agencies and the parties responsible for
site cleanup.
The solutions to community opposition engendered by citizen participation
programs include establishing public comment and review periods, holding public
hearings, and setting up active, influential citizen advisory boards. The success
of these participation mechanisms depends on local politics, the composition of
the affected public, and the receptivity of decision makers to citizen input.
Consensus is not guaranteed simply because an open process in used. For these
complex risk-based policy making decisions, a more democratic format may
facilitate a more effective two-way exchange of ideas, power, and influence
between officials and citizens.
9.1 PRINCIPLES OF PUBLIC INVOLVEMENT
This section of the guidance document describes a generic public involvement
plan which a local unit of government can use to develop a specific plan that is
appropriate for its situation. There are a number of key principles that serve as
the foundation for a successful public involvement program. In developing such
a program, all interested parties should keep these concepts in mind:
! It is essential to let people know about and contribute in a meaningful way
to decisions that may affect their health, the environment, their lives, and
the communities in which they reside. The public not only needs to be
informed, but often has the right, by law or regulation, to be informed of
plans that may affect it made by an organization, public or private.
! To participate effectively, the public must have access to accurate and
timely information about the site and any plans for action at the site. It is
essential to continuously maintain access to information. To the extent
possible, the closure team should use commonly used terms when
discussing technical matters. A complete file of project activities, including
technical information, should be readily accessible to the public through

9-3
local repositories such as public libraries. If the public is allowed access to

technically sound and independent information, and given adequate time
to understand the technical and social dimensions of a risk issue, it will be
more likely to reach decisions that are fair, efficient, wise and stable.
The public involvement program must be coordinated with all other
components of the closure process so that the public will be assured that
its input will influence project planning and implementation.
Public involvement is based on the assumption that the project team cannot
over-communicate with the public and that a public dialogue and the
involvement process should be started early. Face to face discussions,
regular meetings, and maintaining relationships are critical to the
democratic decision-making process.
Public involvement implies that consensus is achieved through information
access, negotiation, and compromise from all parties involved in the
process.
Public participation that is democratic includes direct participation of
citizens representing diverse interests and perspectives (e.g., residents,
business persons, opinion leaders, academics, local elected officials, citizen
advisory councils, health professionals, local activists, etc.).
An equal distribution of power in collective decision-making is a sign of a
democratic mechanism for citizen participation. Broader community
perspectives should be sought throughout the process.
9.2 WHY DEVELOP A PUBLIC INVOLVEMENT PLAN?

In order to achieve public understanding, input and acceptance of the work
required for closure of an abandoned dump, it is necessary to involve the public
in a meaningful way at the outset of the closure process. Early contact with the
local stakeholders will give the project manager access to valuable feedback as
they react to and offer advice about closure plans. In return, the stakeholders are
assured of receiving continuous information related to the potential risks and
proposed remedies.
9.2.1 A PUBLIC INVOLVEMENT PLAN FOSTERS A SUCCESSFUL OUTCOME
BY ESTABLISHING TRUST
Credibility of the public involvement process is of paramount importance. Since
the goal is to achieve consensus, it may not be possible for every group to win
every issue. Therefore, if the stakeholders in a community have faith that the
decision-making process has been fair, the likelihood of acceptance of eventual
decisions will be much greater. If a level of trust is established early and fostered
throughout the process, this relationship is more likely to facilitate an agreeable
compromise than might have been anticipated at the beginning of the project
planning process. Proactive steps taken to eliminate misunderstanding or
mistrust are the key to successful project outcomes.

9-4
9.2.2 A PUBLIC INVOLVEMENT PLAN AVOIDS ALIENATING THE PUBLIC BY

ESTABLISHING A CONTINUAL DIALOGUE
A properly planned project should steer clear of the D.A.D. Syndrome, i.e.,
Decide, Announce, and Defend. Using this approach, the project manager decides
in advance what the outcome should be and then announces his/her decisions
to the public. A more reasonable, sensible, and cost-effective approach is to
involve project stakeholders at the beginning of a project rather than later. Early
and consistent involvement of the public in project plans can preclude public
relations setbacks and often results in cost savings by reducing false starts,
avoiding delays, and minimizing the risk of lengthy and costly court proceedings.
9.2.3 A PUBLIC INVOLVEMENT PLAN HELPS THE PUBLIC UNDERSTAND
RISK
The goal is public involvement, not public relations. If people are offered a
meaningful way to discuss and analyze risk and are allowed to make certain
choices in accepting or rejecting risk, local support for and confidence in the
decisions and subsequent actions will be much greater.
9.3 DEVELOPMENT OF A PUBLIC INVOLVEMENT PROCESS
The public involvement activities described below are designed for a community
that has decided to investigate and, if necessary, remediate an abandoned dump
site in its midst. While this four-step process appears orderly, it should be noted
that, because various aspects of human nature - time and budget constraints,
degree of contentiousness of issues, and other community and stakeholder
dynamics - are certain to vary, the public involvement process rarely proceeds in
a straightforward manner. It is more likely that activities related to each of the
steps will be taking place concurrently. Depending on the length of the process
and the level of controversy, various stakeholders may be more or less active as
their interest in the issues changes.
9.3.1 PRELIMINARY ASSESSMENT
Because the level of public involvement associated with an abandoned dump site
investigation will vary depending on the specific circumstances of the site and the
community in which it is located, no single prescription for a public involvement
program can or should be applied to every abandoned dump. Therefore, the
preliminary assessment step is necessary to enable the team to gather pertinent
information and data regarding the site and the issues of greatest concern.
Abandoned dump sites are a problem to the communities in which they are
located because of their potential to pollute important natural resources, such as
adjoining surface water bodies, groundwater, parks, other recreational land, or
private property. The contaminants may be known or unknown, and will vary in

9-5
concentration and toxicity. To help establish the essential elements of a specific

public involvement program, it is necessary at the outset to address several
pertinent issues: what social, environmental, economic, historical, political,
cultural, and public health concerns are currently known about the abandoned
dump site? These often complex issues must be clearly understood so that key
information may be obtained in a timely manner.
Issues that are likely to be of concern to the public are remediation criteria, risk
levels, waste disposition plans, the remedial design, suggested presumptive
remedies, and future land use. The important and relevant aspects of the
abandoned dump problem should be assembled into an information packet and
distributed to the public. A helpful guide to identifying relevant information is
presented in Figure 9-1.
9.3.2 PRELIMINARY PUBLIC CONTACT
This step is undertaken to begin the public involvement dialogue and prepare the
list of potential stakeholders. There are different types of networks in each
community, some are more formal than others. By asking stakeholders to identify
other interested parties, it is more likely that a complete stakeholder list will be
developed. During this phase, preliminary information about proposed activities
is provided to individual stakeholders and stakeholder groups. Usually, as the
information is disseminated, the project manager begins to hear public concerns
about the project.
Each step in this process should be undertaken with an open mind about public
concerns. It is essential to move beyond any for or against positions and identify
the specific issues the public believes should be addressed. Also in this way, more
complex questions may be broken down into discrete issues that are easier to
resolve.
An initial public meeting is recommended, at which stakeholders and the closure
team can discuss what is known about the dump site and consider future
activities. It should be emphasized that although some technical planning may
have already taken place, specific outcomes should have not been decided before
this stage in the process. Section 9.5 contains recommendations for conducting
public meetings prepared by a community group that is actively involved in the
outcome of abandoned dump sites.
Figure 9-1
The Abandoned Dumps Public Involvement Worksheet


9-6
This suggested public involvement worksheet can be used to summarize the

information about abandoned dumps that is of great importance to the public. It
should include:
1.
2.
3.
4.
5.
6.
7.
8.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Name and all aliases of dump site,

Dump location (topo maps, address),
Location of dump relative to surface waterbodies or tributaries,
Historic dumping practices and identification of waste origin,
Legal history of site (i.e., licensing, bonds, ownership),
Current and future use of site,
Site accessibility,
Frequency of use,
Groundwater use,
Site characteristics and conditions,
a. Presence of leachate,
b. Location and extent of waste/fill material, and
c. Summary of previous investigation(s).
Site Map,
Population characteristics,
Decision-making authority,
List of stakeholders,
Location of repository of site information and contact person,
Triggering event or legal justification,
a. Potential risks,
b. Listed site (i.e., NPL site, state hazardous waste site),
c. Public pressure,
d. Change of ownership (legal),
e. Change of site use, and
f. Potential presence of hazardous waste.
Potential exposure pathways (i.e., soil contact, drinking water ingestion), and
Contaminated media (i.e., soil, drinking water, surface water, sediment).
In many situations it may be desirable to establish a local citizen advisory

committee that includes representatives of significant stakeholder groups, as well
as recognized local public opinion leaders. When stakeholder representatives
actively participate on a citizen advisory panel, the project manager can be
assured that relevant questions are raised, addressed, and credibly communicated
to stakeholder constituencies in the community.


9-7
As this step is completed, the project team should have a better understanding of
the major issues and areas of concern that stakeholder groups and other
individuals have raised, the level of public interest, the significance of the issues
and concerns, and the key stakeholder groups and community public opinion
leaders interested in the project.
9.3.3 PREPARATION OF A DETAILED PUBLIC INVOLVEMENT PLAN FOR AN
ABANDONED DUMP SITE
The detailed public involvement plan integrates public input into the decisionmaking process. Because this step is vital to maintaining a well-managed and
cost-effective investigation and closure project, the following elements should be
included in each PI plan:
!
!
The specific objectives of the public involvement plan - These

objectives will emerge from stakeholder discussions.
Site specific characteristics - This information is gathered during the
preliminary assessment and should include all pertinent data on the
history and current condition of the site.
A detailed list of individuals, groups, and others likely to be affected
or interested in the dump site investigation - The stakeholders list was
gathered during the preliminary public contact step and should be
continually updated. Ideally the list should be computerized for the
printing of mailing labels. The list should include each persons name,
stakeholder group affiliation, street address, telephone and fax numbers,
and E-mail address (if available).
Identification and validation of stakeholder values - Clarification and
agreement on a set of consensus values by interested stakeholders will
guide the project team in decision-making. Examples of consensus values
include environmental values, social and human values, long term
management values, and general use values. An example of an economic
value is emphasis on future site uses which provide some level of
employment for area residents. An example of an environmental value is
prevention of contamination of nearby surface water. An example of a
social or human value is minimize negative aesthetic impact of an
abandoned dump site.
A clear description and schedule of the dump site investigation
activities - The public is interested in the specific project activities and
the planned scheduling of these activities. This comes largely from the
project manager, but public input should be encouraged.
A sequential plan of public involvement activities which can be
integrated with the decision-making process - This plan can be
developed by the citizen advisory panel and project managers as the
dump-site investigation plan is being developed. The plan should also


9-9
identify key points in the site investigation process when the public
involvement plan will be reviewed, evaluated, and updated based on
additional project information or issues that may have arisen.
Clarification and evaluation of options - There may be several options
available for providing safe closure of an abandoned dump site. Options
may include presumptive remedies (i.e., exposure barrier), limited closure
based upon land use, or waste and contaminated soil removal. Each of
these options has different social, environmental and economic impacts
that must be evaluated. Involving the public during this stage promotes
a high level of public buy-in for the final solution.
9.4
IMPLEMENTING THE PUBLIC INVOLVEMENT PLAN
The length and cost of the implementation phase will depend on the complexity
of the issues and the level of interest of the stakeholders. If the stakeholders have
little or moderate interest in the proposed site investigation, then a notice of the
proposed activity sent to stakeholders and the media, and a series of periodic
media interviews and written stakeholder updates may be sufficient to keep the
public informed. However, in this case, the project manager must be certain that
all interested stakeholders have been identified or informed of the project. At the
other extreme, an angry community with a potentially highly toxic abandoned
dump site in its midst may require:
!
!
!
!
!
!
!
!
Numerous meetings with large numbers of individuals and groups;

Establishment of a local advisory committee;
Large-and small-scale public hearings;
Meetings, open houses, or workshops;
Preparation of extensive informational materials;
Meetings with government agencies;
Media interviews; and
Other public involvement techniques.
Success in implementing the public involvement plan is usually a reflection of the

time and effort spent on formulating the plan. In addition, it is essential that the
plan is followed during implementation, however contentious and time-consuming
the process may become. If the plan is practicable and the implementation phase
adheres to its principles, complex issues and problems should be understood and
resolved. In a consensus-based process, sound risk policy decisions can be both
technically based and politically legitimized.


9-10
9.5
PUBLIC MEETING RECOMMENDATIONS
This section contains recommendations for conducting a public meeting.
9.5.1 PUBLIC NOTICE
Because it is essential to properly notify those citizens who are locally affected by
the site and actions proposed by the team, the public should be appropriately
notified of the meeting date, time, and location. The notice should appear in local
newspapers as well as in the larger metropolitan papers, and should be broadcast
a number of times on a major market radio station.
9.5.2 MEETING FORMAT
The following recommendations are made for organizing the format of the public
meeting:
Introductions - The following should be a part of the introduction phase at the
initial public meeting:
!
!
!
!
The regulatory agencies involved in the investigation should agree, in

advance of the meeting, which agency will take the lead.
It should be the responsibility of the lead agency to make sure that other
participating agencies are notified and they are at the meeting to answer
questions.
A representative of the lead agency should chair the meeting.
In opening the meeting, the representative of the lead agency who is acting
as chairperson of the meeting should state why it has assumed the lead
role at this site.
The chairperson should introduce the important participants in the
audience, including potentially-responsible parties (PRPs), other agency
staff, and consultants. When the participants are introduced, each should
state his/her involvement in the clean-up and identify his/her
responsibilities.
The important participants should sit at the head table or in a special
section so they are easily identified. Name tags should be worn,
identifying the individual and his or her affiliation.
As an indication to the local citizens that their representatives are aware
of and interested in the investigation, government representatives should
be encouraged to attend and to introduce their consultants, if present, and
make it clear that they support the activities of the consultants they have
hired.
Representatives of other agencies should be careful to avoid contradicting
the lead agency during the meeting on matters of policy or jurisdiction.
These issues should be resolved privately.
Audio/Visual equipment should be set up before starting the meeting so


9-11
that the publics time is not wasted.

Conducting the Meeting - The following suggestions for conducting the meeting
are offered to ensure more productive discussions and invite a useful dialog.
!
!
!
The lead agency should start the information phase of the meeting by
presenting the following information:
- The agenda for the meeting
- A brief definition of the problem
- A summary of the strategies and remedies that may be used to resolve
the situation
- Processes (sampling needs, etc.)
- A proposed schedule
- Cost estimates
The team manager should identify any anticipated project delays (i.e.,
analytical results, weather delays). This will eliminate surprises and
disappointments.
The information that is presented should be appropriate to the members
of the audience. Each presenter should give a brief overview of the
information he or she is going to discuss and indicate how it addresses the
publics concerns.
Since the primary concerns of the residents will generally relate to
potential health effects, property values, and the well-being of their
children, these issues must be addressed during the meeting and are more
important than volumes of technical information that they may not
understand. The investigation team should attempt to adopt the publics
perspective and provide information that would reassure residents living
near the dump site that the major issues are being adequately addressed
and appropriately handled.
At the end of the meeting, the lead agency should outline its future plans.
A date for the next public meeting should be set, if appropriate, to assure
the public that the investigation will be moving forward and that its
progress can be monitored.
When asking questions or making statements, citizens should be
videotaped only if they have given written permission. Being on camera
intimidates many people; using such practices may inhibit the trust of the
public.
Adequate time should be provided during the meeting for questions and
answers.
Visual Aids - Visual aids are a valuable component of the presentation.

Suggestions for their use are given below.

9-12
!
!
!
Visual aids should be used to help the audience understand the

information being presented.
Aerial photos of the area and expanded maps are very helpful in
characterizing the site.
Slides should be used to briefly reinforce what the speaker is saying and
should be limited to a few phrases or bullets. Wordy, crowded slides will
distract the audience as it tries to understand the technical information
or to read the entire content. Handouts are more appropriate for providing
technical or administrative information which the public can digest at its
leisure.
Messages should be kept simple. Information that is highly technical may
make the public feel inadequate or frustrated and less likely to return for
future meetings.
Handouts - Handouts are very useful and appreciated by the public. The
following recommendations are offered on the types and content of handouts that
are most valuable to the public.
!
A fact sheet should be distributed to the public at each meeting. The fact
sheet should include the following items:
- A summary of the problem and the proposed remedial activities.
- Any facts known at the time such as sampling results for contaminants
at the site, risk exposure analysis data, potential hazards (physical, etc.),
routes of exposure, location of site, owner of site, responsible parties.
- How the site may affect the public.
- What resources may be impacted (water, land, air, etc.).
- Which agency is in charge of the remediation.
- A contact list, including agency contacts for all those involved (name,
addresses, and phone numbers). A local contact person should be
identified so citizens do not have to call long distance.
- The location of a complete repository of information pertaining to the site
at the local library or other public building. Placing only selected
information in this file should be avoided. It also would be helpful if a
complete copy of the project file was also available at the government
office where the site is located. Each file should include a table of
contents to ensure that it is complete and that documents have not been
removed.
- A description of what is not known about the site and which activities
will be conducted to make those determinations.
- A project organization chart, showing who is in charge and how other
agencies fit into the picture.
- The law or policy under which the investigation and remedial activities


9-13
!
!
are authorized.
- A glossary of the most commonly-used terms and acronyms.
An example of a fact sheet is presented in Figure 9-2.
A written agenda should be prepared for each meeting and furnished to
the public.
If a risk assessment will be used to assist the team in making decisions,
the public should be made aware of which models will be used and how
they are qualified.
Meeting minutes should be made readily available to the public as soon as
possible after the meeting.
Follow-up Meetings - The following items should be discussed at all subsequent

meetings:
!
!
!
!
Any new findings since the last meeting

Costs associated with remediation
Alternative or modified procedures used since the original proposal
New data, especially that which the public was anticipating, should be
available at the meeting, if possible. Participants should not be forced to
file a Freedom of Information Act (FOIA) request to get information
understood to be forthcoming from the project team.


10-14
Figure 9-2
Example EPA Fact Sheet
United States
Environmental Protection
Agency
EPA Fact Sheet
Region 5
77 West Jackson Blvd.
Chicago, Illinois 60604
Illinois, Indiana,
Michigan, Minnesota,
Ohio, Wisconsin
Nankin Township Dump Site

Westland, Michigan
January 1994
SITE HISTORY
The Nankin Township Dump Site is located near the intersection of Conan and Warren Roads in
Westland, Wayne County, Michigan. The site consists of approximately 12 acres of land along
Tonquish Creek: a wooded portion that is part of a county-owned nature preserve known a William
P. Holiday Park, and an overgrown open field that is owned by Crestwood Development, a local real
estate development firm. From the 1950s to the 1970s, this land was used as a dump for
industrial and municipal wastes. A former facility of the Minnesota Mining and Manufacturing
Company (3M), located in Wayne, Michigan, was one of the sources of the industrial waste that was
dumped at the site. The United States Environmental Protection Agency (U.S. EPA) received
information about the site in late winter 1993 during an investigation of three other hazardous
waste sites in southeast Michigan.
U.S. EPA ACTIONS AT THE SITE
U.S. EPA conducted a preliminary site assessment of the Nankin Township Dump site on April 14,
1993. During the assessment, investigators observed partially buried drums, exposed solid waste,
and partially buried scraps of metal in the wooded area along the south bank of Tonquish Creek
and in the open field. On May 17 and 18, 1993, U.S. EPA conducted a survey over an area of the
site measuring 200 feet square, including an area where partially buried drums were visible at the
ground surface. This survey was conducted using a magnetometer--an instrument capable of
detecting the presence of metallic objects by measuring the intensity of the objects magnetic fields.
Magnetometer results indicated the presence of metal objects, possibly drums, buried at depth over
a large portion of the surveyed area.
On June 7, 1993, U.S. EPA representatives collected five samples of waste from partially buried,
deteriorated drums. Chemical analysis of the samples detected a number of hazardous substances
in various samples, including chromium, lead, zinc, toluene, and ethylbenzene. Analysis of one
sample indicated that the material is readily ignitable at the relatively low temperature of 140
degrees Fahrenheit.
In July 1993, U.S. EPA received information from a former waste hauler who had transported
industrial waste to the site from operator of the dump at this site, who reported that waste from
the 3M facility had been dumped at the site. On July 27, 1993, U.S. EPA notified 3M, Wayne
County, and Crestwood Development of their potential liability as Potentially Responsible Parties
(PRPs)--the parties considered liable for the contamination.


9-15
RECENT ACTIONS
Representatives of U.S. EPA and the three PRPs entered into negotiations for a consensual
agreement concerning further investigation and cleanup of the site. The negotiations were
concluded on December 17, 1993, without reaching an agreement.
On January 5, 1994, the Director of U.S. EPAs Region 5 Waste Management Division approved
an Action Memorandum which documented the determination that the Nankin Township Dump
site poses a threat to human health and the environment. The determination was based on the
accessibility of the site, the hazardous nature of the materials found at the site, the deteriorated
condition of the partially buried metal drums containing some of the wastes, and evidence from
the site investigations which indicted the possible presence of additional buried waste. Further
concerns cited were the dump=s location near residential developments, and the proximity of some
wastes to Tonquish Creek, which is a tributary to the Middle Branch of the Rouge River. In
addition, seasonal flooding of the creek may be contributing to the erosion of contaminated soil and
containers of waste from the bank of the creek.
The Action Memorandum further stated that conditions at the Nankin Township Dump site
warranted the initiation of an immediate removal action. On January 7, 1994, U.S. EPA issued
a Unilateral Administrative Order (UAO) to 3M, Wayne County, and Crestwood Development,
requiring these PRPs to conduct cleanup activities. Specific activities to be conducted include
securing the site to prevent public access; excavating and properly disposing of hazardous
substances and contaminated soil; and conducting an extent-of-contamination (EOC) study to
determine the full extent to which the soil, sediment, ground water, and surface water may have
become contaminated as a result of the burial of hazardous materials at the site.
NEXT STEPS
The UAO provides an opportunity for the PRPs to meet with U.S. EPA or submit comments on the
UAO to U.S. EPA prior to the effective date of the UAO. If the PRPs comply with the UAO, the PRPs
will conduct the cleanup activities required at the site, to be overseen by U.S. EPA representatives.
If the PRPs do not comply with the UAO, U.S. EPA can request that a U.S. District Court enforce
the UAO, or U.S. EPA can conduct the cleanup and recover the costs of the cleanup from the PRPs.
Representatives of U.S. EPA Region 5 plan to conduct an informal public meeting in February to
provide an opportunity for members of the community to obtain further information about the site
and the proposed cleanup. Additional fact sheets will be issued in the coming months to keep the
community informed of events concerning the site.
FOR MORE INFORMATION
For more information about the Nankin Township Dump site, you may contact the following U.S.
EPA representatives:
Heidi Valetkevitch (P-19J)
Community Relations Coordinator
U.S. EPA Region 5 Office of Public Affairs
77 West Jackson Boulevard
Chicago, IL 60604-3590
312-886-1303
Ralph Dollhopf (HSE-GI)

On-Scene Coordinator
U.S. EPA Region 5 Response Section I
9311 Groh Road
Grosse Ile, MI 48138-1697
313-692-7660
U.S. EPA Region 5 Toll-free Number: 1-800-621-8431


9-15
9.5.3
GENERAL SUGGESTIONS
The following suggestions are offered to improve the effectiveness of public
meetings.
! The agencies and consultants making presentations should endeavor to
furnish all available factual information to the public and avoid the
perception that the government is attempting to hide adverse information
or data. If a question cannot be answered or information cannot be
released during a meeting, the public should be made aware of the
legitimate reason (i.e., litigation). If the public determines that an agency
was dishonest or evasive, that agencys credibility may be permanently
impaired.
! The Chairperson and presenters should be thoroughly familiar and
conversant with the information being provided and be capable of answering
most questions regarding the material. If a speaker does not know the
answer to a question posed by a member of the public, he or she should
admit that he does not know, rather than guess, and indicate that he/she
will try to determine an accurate answer for discussion at the next meeting.
Leaving questions unanswered creates a poor impression of the project
team.
! The public is often able to discern hidden agendas among the participants
and does not trust individuals who bring them to the meeting.
! The public should not be perceived as uninformed. Residents will lose
respect for the project team if they think they are being patronized.
! Roundtable discussions held early in the process and involving members of
the public, responsible parties, and participating agencies, often help
prevent adverse public reactions later in the project.
9.6 PUBLIC INVOLVEMENT METHODS
There are many ways to provide information to and foster communication with the
public regarding abandoned dump sites. The public involvement methods chosen
will depend on:
! the characteristics of the individual site,
! gaps in the information base which need to be filled,
! the degree of formality desired,
! contentiousness of the issue,
! available resources (i.e., funds),
! the project schedule, and
! the degree of entrenchment of stakeholder positions.
Several public involvement methods are listed below. In addition, Table 9.1

9-16
contains a matrix that rates each method in terms of several factors.

Open house - An open house is a drop-in event designed to allow the public to
obtain information and respond at its convenience. Typically, an open house will
consist of a visual display, complemented by handout materials and cordial,
knowledgeable staff who answer questions raised by the visitors and possibly
solicit their views and suggestions. The open house can last over several evenings
or part of a day or weekend.
Public Meeting - A public meeting provides an opportunity to inform people and
to make formal and informal presentations and to exchange comments with a
large group of people. To be productive, a public meeting needs to be kept on
course. It is generally chaired by a representative of the proponent, or a neutral
party, and it follows a set agenda.
Panel - This mechanism brings together experts or representatives from a
particular community or region and concerned citizens to present information and
listen to the publics views in a forum such as a public gathering or conference.
An effective panel presentation can:
!
!
!
!
!
!
expand understanding of more obscure aspects of the issues

expand the range of ideas on the issues
clarify the views of the stakeholders
stimulate discussion
educate the audience
clarify contentious issues
Much of the success of a panel is determined by the appropriate mix and balance
of its members.
Conference - A conference is a meeting, lasting one or more days, at which
experts and spokespersons outline their views and discuss predetermined topics.
Conferences may have free or paid admissions. The emphasis is on educating,
clarifying views, or fostering an agreement on an issue or project. Conferences
may lead to a climate of opinion; they frequently bring forward leading-edge
knowledge and views. They are a valuable source of stories and perspective for
reporters. Opinions have also been known to change on a conference floor due to
persuasive new knowledge or points of view.


9-17
Public Meeting
Open House
Focus Groups
Community
Visits
Electronic
Bulletin Board
Panels
Town Meeting
Conferences
Public
Seminar
Task Force
Workshops
Public
Hearings
Advisory
committees
Legend:
- = Low
0 = Medium
+ = High
+
+
0
0
+
+
0/+
-/0
-/+
-
0
+
+
+
0
0
+
0
0
+
0/+
0/+
+
0
0
0
+
+
0
+
+
+
0
0
9-19
+
0
+
0
0
+
0/+
0
0
0
0
0/+
0/+
0
0/+
0
0/+
0
0/+
0/+
-/0
0/+
0
+
+
+
+
+
+
0
+
+
+
0
0
0
+
-
Public
Range of Issues Degree of
Number of
Time
Cost of
Potential for
Expertise
Involvement
that can be
Interaction People Who Commitment
Running
Public/Media Required to
Mechanism Accommodated
among
can
to Plan and Mechanism
Visibility
Run
Participants Participate
Implement
Mechanism
Table 9.1
Choosing the Right Public-Involvement Mechanisms
-/0
0/+
-/+
-
-/+
-/+
/0
-/0
Ability to
Accommodate
Different
Levels of
Participation
-/0
-/0
Workshop - A workshop is a carefully planned forum designed to clarify certain

issues and to share different points of view. Individuals work together in groups
on a common problem or task. The workshop is usually limited to small numbers
of invited participants. It is usually run by a facilitator, whose function is to
encourage constructive dialogue amongst the participants, structure their input
and ideas toward the common workshop goal, and summarize the results of the
discussion at the end of the session.
Town Hall Meeting - A town hall meeting has a relatively open agenda; it is an
opportunity for people from the community to get together with public figures to
discuss whatever is on their minds. No votes are taken, and the discussion is
between the audience and the officials. Such meetings can sensitize officials to
the concerns of the local community and can lead to early identification of
problems. This sort of meeting can also lead to the development of open
communication between the proponent and the community.
Task Forces - A task force is a type of advisory group that is mandated to
accomplish a specific task. Unlike other types of advisory groups that are ongoing
in nature, a task force has a limited life span. The type of task force depends on
the nature of the project, ranging from strictly technical to multi-sectoral or multistakeholder. In a highly charged situation, a task force usually reports to a third
party, such as a government agency or neutral chairperson rather than the
proponent of the project.
Community Advisory Committee - A community advisory committee is a group
of representatives from a particular community or group, appointed to provide
comments and advice on an issue. An advisory committee does not need to be a
permanent or long-lasting group. Members of the committee meet regularly with
proponents to provide input and advice on predetermined issues or to monitor
stages of the project.
Focus Group - A focus group is a meeting of select and formally-invited
individuals that represent specific public sectors. Its purpose is to identify the
probable response of those public sectors to a proposed action or initiative.
Generally, the facilitator has a set sequence of discussion topics, sometimes
broken up with sub-conversations in breakout groups, which are then reported
back to the whole gathering. Participants are chosen to represent particular
communities or regions, socioeconomic or demographic groups, or particular
stakeholder interests. Up to 20 individuals can participate in sessions that can
last anywhere from two hours to a full day.


9-20
Public Hearings - Public hearings are special, highly formal public meetings at
which a problem is presented, a wide range of possible solutions outlined, and
reaction received from the public. Experts can be called to verify assumptions.
The moderator, like a judge, firmly controls the proceeding. The hearing takes
place in three parts: first, a summary of the main points of the project is
presented. Second, the range of solutions, including the recommended solution,
if one exists, is presented. The final part of the hearing consists of the competing
interests reactions to the proposed course of action. In most cases, a permanent
record is kept at the hearing and becomes part of the public record.
Dissemination of Information - There are many methods that can be employed
by project proponents and stakeholders groups to disseminate information about
the issues and to request feedback:
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
Speakers Bureau/other organizations meeting

Briefings/Briefing books
Facsimile messages
Informational kiosks/booths
Media advisories/news releases
Legal notice advertising of events
Paid advertising (newspapers, radio, cable, television, yard signs, billboards,
etc.)
Brochures/flyers/posters
Targeted mail-letters, postcards
Telephone calls/phone tree
Announcements in other organizations publications/ newsletters/employee
publications
Public service announcements
Door-to-door canvassing and/or distribution of information materials
News conferences
Maps/exhibits/displays/other visuals
Technology demonstrations
Information repository/reading room
9.7 REFERENCES
Duffield, J.J., and Depoe, Dr. S.P., 1997. Lessons From Fernald: Revising
NMBYism, Through Democratic Decision-Making. Risk Policy Report. Pp. 31-34.
February 21, 1997.
Applegate, J.S., and Sarao, D.J., 1996. Coping With Complex Facts and Multiple
Parties in Public Disputes. Consensus: [Harvard-MIT Public Disputes Program].
31pp. 1, 12. July 1996.


9-20

Stages of Site Investigation

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Stages of Site Investigation

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CHAPTER 5 - CONDUCTING THE INITIAL SITE INVESTIGATION

hen the information gathered during the background investigation

Guidelines for Closure of

Rouge River National Wet Weather

EVALUATION OF INFORMATION GATHERED DURING THE BACKGROUND INVESTIGATION

Rouge River National Wet Weather

3. Prepare a Preliminary Diagram of the CSM - Prepare an illustration of the

Guidelines for Closure of

Rouge River National Wet Weather

Widely used and

Used for organic vapors only;

Detects organic and

Widely used and

New portable GCs are

Requires specific modules for

Requires experience; 10 samples

Guidelines for Closure of

Rouge River National Wet Weather

Rapid results; easy to

Limited number of kit types

Not much experience

Cannot detect specific

Must have specific tubes

Certain monitors may be cross

Most probes cannot distinguish

Fully automatic; 3-way

Used mainly for health and safety

Guidelines for Closure of

Rouge River National Wet Weather

Direct reading with

For vapors only; instrument

Not definitive; not compound

High volume air

Sample media available

Requires experience; off- site

VOC and particulate

Requires training for use; off-site

5.3.2 SELECT THE SCREENING LOCATIONS

Rouge River National Wet Weather

determining physical and/or chemical properties of samples;

The Quality Assurance requirements for QA1 are:

CONDUCTING THE INITIAL INVESTIGATION

5.4.1 DETERMINING THE SCOPE OF THE INVESTIGATION

Rouge River National Wet Weather

Rouge River National Wet Weather

Similar services are available in other states.

Summaries of the site background and scope of work.

Guidelines for Closure of

Rouge River National Wet Weather

Emergency response contingency plan.

An outline of a typical HASP is located in Appendix D. Federal Occupational Safety

Preparation of a Field Sampling & Analysis Plan with Standard

Surface water sampling

Rouge River National Wet Weather

Development of a site-specific work plan

An example of a cost estimate is included in Appendix F.

determining appropriate sampling locations;

Rouge River National Wet Weather

Guidelines for Closure of

Rouge River National Wet Weather

CONDITIONS WHEN THE SAMPLING

A very homogeneous population over time and space is

The target population should be clearly defined,