NWI-2229.180.001 Revision 1 Evaluation of the Radon-222 Deficit Technique for Delineating DNAPL Distribution and Assessing DNAPL Removal at the OK Tool Source Area, Operable Unit 1, Savage Municipal Well Superfund Site, Milford, New Hampshire: Final Report January 2007 NWI-2229.180.001 Revision 1 Evaluation of the Radon-222 Deficit Technique for Delineating DNAPL Distribution and Assessing DNAPL Removal at the OK Tool Source Area, Operable Unit 1, Savage Municipal Well Superfund Site, Milford, New Hampshire: Final Report Robert C. Starr Prepared for: U.S. Environmental Protection Agency National Exposure Research Laboratory Technology Support Center Characterization and Monitoring Branch U.S. Environmental Protection Agency Region 1 Office of Site Remediation & Restoration U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response Measurement and Monitoring Technologies for the 21st Century (21M2) Initiative and U.S. Department of Energy Under DOE Idaho Operations Office Contract DE-AC07-05ID14517 North Wind, Inc. 1425 Higham Street Idaho Falls, ID 83402 January 2007 ii EXECUTIVE SUMMARY Radon-222 (Rn-222) is a natural constituent of groundwater and its concentration is affected by the presence of non-aqueous phase liquids (NAPL) and other factors. Radon readily partitions from water into NAPL, and therefore radon concentrations in groundwater are lower near a NAPL body than far from NAPL. The reduction of dissolved radon concentrations led to the name “radon deficit technique” for the approach of using radon concentrations to make inferences about the presence of NAPL. Previous research suggests that spatial variations in dissolved Rn-222 concentrations may be useful for delineating the spatial extent of NAPL in the subsurface, while temporal variations may be useful for evaluating effectiveness of NAPL remediation. The OK Tool site in Milford, New Hampshire has NAPL contamination in a sand and gravel aquifer, and in situ chemical oxidation (ISCO) is being used to remediate NAPL. Measurements of Rn-222 concentrations in groundwater before ISCO began suggested that Rn-222 concentrations were lower in NAPL-bearing areas than in NAPL-free areas, in agreement with lab and field studies performed previously by others, although the preliminary results were not definitive. The study described here evaluated two applications of the radon deficit technique. First, the utility of the radon deficit technique for delineating the spatial extent of NAPL at a multi-acre field site was evaluated. Second, the ability of the technique to evaluate the effectiveness of NAPL removal was examined. This study was performed in conjunction with an ISCO project performed by others. ISCO was performed by injecting a potassium permanganate (a strong oxidizer) solution into the subsurface in an area where NAPL was known to be present. Two injections were made, separated by approximately 1 year. Groundwater samples for Rn-222 analysis were collected prior to the first oxidant injection and approximately 1 year after the first and second oxidant injections. Wells in areas where NAPL was present and wells in background areas remote from NAPL were sampled. Rn-222 concentrations at the OK Tool site are highly spatially variable, and concentrations measured in background areas cannot be discriminated from those measured in NAPL-contaminated areas. The large spatial variability in Rn-222 concentrations in NAPL-free areas is thought to result from heterogeneity in sediment properties. The inability to discriminate NAPL-free from NAPL-bearing areas based on measured Rn-222 concentrations at this site indicates that the radon deficit technique cannot be used to delineate the spatial extent of NAPL in the subsurface at the OK Tool site. However, the technique may be useful at sites where background Rn-222 concentrations are more uniform. The persistence of permanganate in groundwater for approximately 1 year after injection, the decline in volatile organic compound concentrations, and increase in chloride concentrations collectively suggest that ISCO reduced NAPL saturation in the subsurface. Based on this, it was anticipated that concentrations of radon in groundwater would increase over time as a result of reduced partitioning from water into NAPL. Contrary to this expectation, temporal trends in Rn-222 concentrations were highly variable. It is not known how much of the difference in measured Rn-222 concentrations is due to changes in NAPL saturation and how much is due to other factors. Nevertheless, the lack of a trend of increasing Rn-222 concentrations over time is inconsistent with the expected response of the system and is interpreted as indicating that the radon deficit technique cannot be reliably used to evaluate NAPL remediation at the OK Tool site. Factors that may affect dissolved Rn-222 concentrations include that the relationship between NAPL saturation and radon partitioning may be more complicated than assumed and that oxidation reaction products (i.e., MnO2) may affect radon partitioning or emanation from minerals. Variation in sampling and analysis and the hydrogeologic system may also contribute to variability in measured radon concentrations. Investigation of these topics may account for unexpected trends observed in this study and support application of the technique at other sites. iii CONTENTS 1 INTRODUCTION............................................................................................................................... 1 2 BACKGROUND ................................................................................................................................. 3 2.1 O K Tool Source Area................................................................................................................ 3 2.1.1 2.1.2 3 4 Site Description .......................................................................................................... 3 Previous Remediation................................................................................................. 5 2.2 Evaluation of the Radon Deficit Technique in Conjunction with In Situ Chemical Oxidation ................................................................................................................................... 5 2.3 Theory of the Radon Deficit Technique.................................................................................... 6 EXPERIMENTAL METHODS......................................................................................................... 9 3.1 Groundwater Purging and Sampling ......................................................................................... 9 3.2 R adon-222 Analysis .................................................................................................................. 9 RESULTS AND INTERPRETATION ........................................................................................... 11 4.1 Baseline Data Set..................................................................................................................... 11 4.2 Spatial Variability in Background Radon Concentrations at OK Tool and Use of Radon Deficit Technique for Delineating Non-aqueous Phase Liquid............................................... 14 4.3 Temporal Trends in Radon and Use of Radon Deficit Technique for Assessing Non-aqueous Phase Liquid Remediation ................................................................................ 17 5 SUMMARY AND CONCLUSIONS ............................................................................................... 20 6 ACKNOWLEDGEMENTS.............................................................................................................. 21 7 REFERENCES.................................................................................................................................. 22 iv FIGURES 2-1. DNAPL-bearing areas at the OK Tool site (from NHDES, 2003). ................................................. 4 4-1. Wells sampled for radon-222 analysis in one or more sampling events (Starr, 2005). ................. 12 4-2. Rn-222 in baseline (before ISCO) groundwater samples (adapted from Starr, 2004)................... 13 4-3. Correlation between Rn-222 and dissolved PCE concentrations, baseline conditions at the OK Tool site (adapted from Starr, 2004). ...................................................................................... 14 4-4. PCE concentration in selected wells at OK Tool (Starr, 2005)...................................................... 15 4-5. Radon concentrations in groundwater, September 2004 (Starr, 2005). ......................................... 15 4-6. Mean radon concentrations in background and non-background areas in three sampling events. One-standard deviation error bars are shown (Starr, 2006). .......................................................... 17 4-7. Mean radon concentrations and 1-standard deviation uncertainty measured in 2003, 2004, and 2005 (Starr, 2006). .................................................................................................................. 18 TABLES 2-1. Schedule of radon sampling and oxidant injections......................................................................... 6 4-1. Descriptive statistics for the 2004 radon dataset (Starr, 2005). ..................................................... 16 4-2. Temporal trends in radon concentration in non-background wells in the INEL Well Array......... 19 v ACRONYMS 21M2 Measurement and Monitoring Technologies for the 21st Century DNAPL dense, non-aqueous phase liquid EPA Environmental Protection Agency ISCO in situ chemical oxidation NAPL non-aqueous phase liquid NHDES New Hampshire Department of Environmental Services NWI North Wind, Incorporated PCE tetrachloroethene RDT radon deficit technique Rn-222 radon-222 SVE soil vapor extraction TCE trichloroethene VOC volatile organic compound vi Evaluation of the Radon-222 Deficit Technique for Delineating DNAPL Distribution and Assessing DNAPL Removal at the OK Tool Source Area, Operable Unit 1, Savage Municipal Well Superfund Site, Milford, New Hampshire: Final Report 1 INTRODUCTION Laboratory and small scale field studies performed by other researchers have suggested that the radon deficit technique (RDT) may be used to identify areas where non-aqueous phase liquid (NAPL) is present in the subsurface, and to assess the effectiveness of remedial techniques that remove NAPL from the subsurface. Hunkler et al., (1997) observed that dissolved radon concentrations declined by approximately 50% as diesel saturation increased from 0 to 2.3% in laboratory batch experiments. Semprini et al., (1998, 2000) describe laboratory column and physical aquifer model experiments, mathematical modeling studies, and measurements of dissolved radon concentrations at a field site where NAPL is present in the subsurface. Davis et al. (2002, 2003) describe studies of static and push-pull tests using dissolved radon-222 to assess NAPL saturation in a model aquifer. These studies show that concentrations of radon in groundwater are lower in the vicinity of NAPL than they would be if NAPL was absent, and suggest that spatial and temporal trends in dissolved radon concentrations may provide information on the spatial distribution of NAPL and changes in NAPL saturation over time, respectively. Historical manufacturing and disposal activities at the OK Tool site in Milford, New Hampshire, resulted in tetrachloroethene (also known as perchloroethylene [PCE]) being present in a sand and gravel aquifer as a dense, non-aqueous phase liquid (DNAPL) (i.e., a NAPL that is denser than water and therefore can readily sink below the water table). Dissolution of DNAPL created a plume of dissolved PCE that migrated to a nearby municipal water supply well in the town of Savage, New Hampshire. Investigation of the source of contamination at this well led to characterization and remediation of subsurface contamination at the OK Tool site. Previous characterization activities have delineated the spatial extent of several DNAPL-bearing zones and created an experimental infrastructure that includes numerous monitoring wells and a closely-spaced array of wells in an area where a substantial volume of DNAPL is present. In addition, aggressive remediation of dissolved and DNAPL PCE using in situ chemical oxidation (ISCO) is being conducted at the site. The combination of extensive subsurface characterization data, ongoing groundwater monitoring, and aggressive subsurface remediation provided an opportunity to evaluate the RDT under conditions of an active remediation site and at a larger scale than in previous studies. A baseline data set collected before ISCO was initiated suggested that the RDT could be used to discriminate between zones where DNAPL was present from zones where it was absent at the OK Tool site, although the data were not conclusive. Based on this baseline data, the U.S. Environmental Protection Agency (EPA) provided funding for a more extensive evaluation of the RDT at the OK Tool site, in conjunction with a pilot test of ISCO. The evaluation addressed two applications of the RDT. First, the use of the RDT to delineate the spatial extent of NAPL-bearing zones by using measured concentrations of radon in groundwater to discriminate areas where NAPL is present from areas where it is absent. Second, the use of the technique to assess the effectiveness of NAPL remediation and to provide an indicator that NAPL has been removed from an area. 1 The overall approach included measuring concentrations of radon in groundwater in both background areas (areas where DNAPL was absent) and non-background areas (areas where DNAPL was present) following each of two phases of oxidant injection. Radon concentrations measured in background areas were compared to those measured in non-background areas to evaluate the ability to discriminate between these types of areas based on radon concentrations. The baseline data set and two additional data sets collected in this study were used in this evaluation. To evaluate the utility of the RDT for assessing NAPL remediation effectiveness, temporal trends in radon concentrations in groundwater were evaluated in areas affected by the ISCO pilot test and subsequent larger-scale implementation of ISCO. The baseline data set and concentrations measured after two phases of oxidant injection were used in this evaluation. The baseline data set was collected just before the first injection of oxidant, and two post-ISCO data sets were collected approximately 1 year after the first and second oxidant injections, which allowed a long period for injected oxidant to react with NAPL in the subsurface. This document summarizes the results of this evaluation of the RDT at the OK Tool site. More detailed information is presented in the following data reports that describe the baseline, first, and second post-ISCO data sets: • Baseline sampling: Data Report: Radon in Groundwater at the OK Tool Site, Milford, New Hampshire, September 2003 (Starr, 2004). • Post ISCO Pilot test sampling: Data Report: Radon in Groundwater at the OK Tool Site, Milford, New Hampshire, September 2004 (Starr, 2005). • Post Large-Scale ISCO sampling: Data Report: Radon in Groundwater at the OK Tool Site, Milford, New Hampshire, October 2005 (Starr, 2006). This summary report includes a description of background information on the OK Tool site and the RDT (Section 2), the methods utilized (Section 3), presents and interprets the data generated (Section 4), and summarizes the results and draws conclusions (Section 5). 2 2 BACKGROUND This section provides information about site conditions at the OK Tool site (Section 2.1), the approach for evaluating the RDT at that site (Section 2.2), and background information about the RDT (Section 2.3). 2.1 OK Tool Source Area 2.1.1 Site Description The OK Tool Source Area is Operable Unit 1 of the Savage Municipal Well Superfund Site. Site characterization is described in the Remedial Investigation, Savage Municipal Water Supply Site, Milford, NH (HMM, 1991) and subsequent documents. The site is located within the Milford-Souhegan glacial drift aquifer of south-central New Hampshire. The subsurface materials include alluvial, glacial, and bedrock units. The surficial deposit is alluvium. Underlying the surficial alluvium is a boulder/cobble zone (5 to 20 ft below ground surface), which is underlain by stratified sand and gravel glacial outwash deposits approximately 40 ft thick. Beneath the sand and gravel deposits is a discontinuous till unit (typically 20 to 40 ft thick where it is present) that consists of gravel, sand, silt, and clay. Fractured bedrock lies beneath the till unit. A highly permeable unconfined aquifer is located in the sand and gravel deposit. The water table typically is less than 10 ft below ground surface. Volatile organic compound (VOC) contaminants were discovered in the Savage Municipal Well near the site in 1983. An inspection of the OK Tool Company by the New Hampshire Department of Environmental Services (NHDES) revealed potential releases of contaminants to a floor drain and the ground. A remedial investigation identified a dissolved chlorinated ethene (mainly PCE) plume in groundwater that extended approximately 6,000 ft downgradient from the site. The site was listed as Operable Unit 1 (the OK Tool Source Area) of the Savage Municipal Well Superfund Site; the dissolved plume downgradient of the site is Operable Unit 2. The OK Tool Company was a machine tool and machine tool parts manufacturing facility that operated from the 1940s to 1987 and used PCE in the manufacturing process. Site characterization activities indicate that PCE is present as a DNAPL in the subsurface, primarily in the vicinity of the former manufacturing facility. A vertical profiling investigation performed in 1995 (CDM, 1995) delineated the spatial extent of DNAPL in the subsurface (Figure 2-1). 3 Figure 2-1. DNAPL-bearing areas at the OK Tool site (from NHDES, 2003). 4 2.1.2 Previous Remediation The major remedial activities at the OK Tool site were construction (in 1998) of a low permeability cutoff wall that extends from ground surface to the top of bedrock and encircles the site, and operation of a pump-and-treat system that extracts groundwater from within the cutoff wall enclosure to cause groundwater to flow into the enclosed area, thereby cutting off the source of contaminants to the dissolved plume downgradient of the site. Although pump and treat is an effective technique for maintaining hydraulic control of a groundwater plume, it is typically not effective for remediating contaminant sources, particularly DNAPL sources. In recognition of this, a variety of techniques for remediating the DNAPL source material have been considered for application at the site. On technique considered was a co-solvent flushing method. A network of wells (known as the INEL Well Array or the Test Array) was installed in the area of the former manufacturing building where a DNAPL-bearing zone had been delineated during previous site characterization activities. Although this project did not proceed to a field test of the technique, it did leave the legacy of a network of wells in a contaminant source area. Two iterations of ISCO have been used to remediate PCE in the Test Array area. ISCO is performed by injecting an oxidant solution (potassium permanganate in this case) into the subsurface to oxidize dissolved contaminants, such as PCE, to non-hazardous reaction products. Destruction of dissolved phase PCE accelerates dissolution of PCE from DNAPL, and the newly-dissolved PCE can then be destroyed by oxidation. Hence, although oxidation occurs only in the dissolved phase, the net result of ISCO is enhanced removal of DNAPL. 2.2 Evaluation of the Radon Deficit Technique in Conjunction with In Situ Chemical Oxidation Two iterations of ISCO have been performed using the Test Array wells. The first iteration (a pilot test), and the associated data interpretation, are described in the Annual Report of the Groundwater Remediation Progress at the Savage Municipal Water Supply Well Superfund Site, OU-1, The OK Tool Site, July 2003 – June 2004 (NHDES, 2005). The pilot test began September 23-27, 2003, with injection of approximately 8,400 lb of potassium permanganate as a 2.7% by weight solution into wells CI and WI, with concurrent extraction from wells NCP and NWP in the first few hours of the injection. The area near these four wells was selected for the ISCO pilot test because previous vertical profiling data indicated that it contained a substantial portion of the DNAPL present in the entire test array area. Water quality monitoring data generated approximately 1 year after oxidant injection was interpreted as indicating that chemical oxidation destroyed approximately 145 lb of VOCs, which is approximately 12% of the DNAPL mass estimated to have been present in the Test Array area at the beginning of the ISCO pilot test. The majority of the VOC mass destroyed during the ISCO pilot test was in either the DNAPL or sorbed phase, not the dissolved phase, at the start of the test. The mass in the DNAPL phase is probably much larger than the sorbed mass. The estimated amount of VOCs destroyed is likely less than the amount actually destroyed because the estimate does not account for oxidant or degradation products that were transported beyond the test well array. The second iteration of ISCO and the interpretation of the data generated are described in the In-Situ Chemical Oxidation – Phase II Program at the OK Tool Source Area Savage Municipal Well Superfund Site – Draft Copy (NHDES, 2006). The second iteration involved more wells and a larger mass of oxidant than the pilot test. Approximately 24,000 lb of potassium permanganate was injected as a 2.7% by weight solution into four Test Array wells (CI, WI, NWP, and SWP) and in four wells installed as soil vapor extraction (SVE) wells (SVE-1, SVE-2, SVE-3, and SVE-5). Injection was accomplished 5 October 4-15, 2004. Water quality monitoring data generated during the year following the second oxidant injection was interpreted as indicating that an additional 98 lb of VOC was destroyed in the Test Array area; the mass destroyed outside the test array, including the areas near the SVE wells that were used as injection points in the second ISCO iteration, was not estimated. As in the ISCO pilot test, it is thought that most of the VOC destroyed was in the non-aqueous phase (DNAPL and sorbed phases) at the beginning of ISCO. The mass of VOC destroyed was estimated to be approximately 8% of mass initially present in the Test Array area prior to the ISCO pilot test. Thus, a conservative (low) estimate of the amount of VOC destroyed during two iterations of ISCO is approximately 20% of the amount initially present, which suggests that a significant fraction of the VOC mass in the Test Array area remained after both iterations of ISCO. Rebound in VOC concentrations supports the interpretation that some DNAPL remains in the Test Array area. Although mass balance calculations suggest that substantial amounts of DNAPL remain in the Test Array area, the persistence of permanganate in that area for 1 year suggests that DNAPL has been largely removed from the horizons flushed by oxidant solution, but remains in horizons that were either not permeated by oxidant solution or where too little oxidant solution was provided to oxidize all of the PCE present. In summary, two iterations of ISCO appear to have destroyed at least 20% of the amount of VOC present in the Test Array area. The majority of the VOC was initially present in a non-aqueous phase (probably almost entirely as DNAPL), and some DNAPL appears to remain in the Test Array area. An evaluation of the RDT (see Section 2.3) was performed in conjunction with two applications of ISCO. Groundwater samples for radon analysis were collected before the ISCO pilot test, approximately 1 year after oxidant was injected in the pilot test, and approximately 1 year after a second injection of oxidant in a larger-scale application of ISCO. The dates of radon sampling and oxidant injections are shown in Table 2-1. Table 2-1. Schedule of radon sampling and oxidant injections. Activity Date Baseline radon sampling September 8-12, 2003 ISCO Injection #1 September 23-16, 2003 Post ISCO radon sampling #1 September 13-16, 2004 ISCO Injection #2 October 4-15, 2004 Post ISCO radon sampling #2 October 17-19, 2005 2.3 Theory of the Radon Deficit Technique Radon-222 (Rn-222) is a naturally occurring constituent of groundwater that is continually produced in the subsurface by radioactive decay of radium-226 (Ra-226). Ra-226 and Rn-222 are members of the uranium-238 (U-238) decay series (Friedlander et al., 1981), and hence the abundance of Ra-226 and Rn-222 in groundwater depends on the concentration of U-238 in rocks or sediment that host the aquifer and the rate at which radon is released from minerals (known as the “emanation rate”) (Hall et al., 1987; Wathen, 1987; Cecil and Green, 2000). For a given rate of Rn-222 production in a mineral, Rn-222 concentrations in groundwater tend to be higher in finer-textured porous media than in coarser textured media because a greater proportion of the radon travels far enough to exit the mineral grain, and hence 6 heterogeneity in texture may cause heterogeneity in dissolved Rn-222 concentrations (LeGrand, 1987; Cecil and Green, 2000). Radon concentrations reach secular equilibrium because the radioactive decay half-life of Rn-222 (3.8 days) is short relative to that of U-238 (4.5 × 109 years) and Ra-226 (1,600 years). Hence, under steady-state flow conditions in the absence of sinks or sources for radon, other than production by Ra-226 decay, Rn-222 concentrations in groundwater would vary from place to place due to spatial variations in the rate of radon emanation from rocks and sediments along a groundwater flowpath; temporal variations would be negligible. However, the presence of isolated sinks for Rn-222 would cause spatial variations in concentrations in addition to those due to heterogeneity in radon emanation; temporal variation in sink strength would cause temporal variation in radon concentrations. If the spatial variations in the background Rn-222 concentration could be accounted for, then the additional spatial variation could be used to identify the location of radon sinks. Even without knowing the natural heterogeneity in background concentrations, temporal variations in radon concentrations could be used to assess variations in source strength over time. Sinks for radon in groundwater include partitioning from water into other phases (Hunkler et al., 1997), but not chemical reactions. Radon (a noble element) is chemically inert, and thus concentrations of radon in groundwater are not affected by reactions in the dissolved phase or by reactions between the dissolved and solid phases. However, radon readily partitions from groundwater to other phases (i.e., gas bubbles and NAPLs). Gas bubbles are typically present in groundwater only near the water table, and thus partitioning into gas bubbles is generally not an important process in groundwater except near the water table. DNAPLs can occur at any depth in an aquifer, and thus partitioning into NAPL as a radon sink can also occur at any depth in an aquifer. Laboratory studies (Semprini et al., 2000) demonstrated that radon readily partitions into some NAPLs, including PCE. Partitioning from water to NAPL locally reduces the aqueous concentration, and hence partitioning is a sink for radon in groundwater. The radioactive decay half-life for radon is sufficiently short that decay of Rn-222 in NAPL prevents equilibrium between radon in the dissolved and NAPL phases. This results in a continuous mass flux of radon from the aqueous phase to the NAPL phase, and thus partitioning into NAPL is a long-term sink for aqueous radon. Hence, the occurrence – spatially and temporally – of depressed radon concentrations can be used as an indicator of the presence of a NAPL. The use of radon concentrations in groundwater that are depressed relative to background concentrations leads to “the radon deficit technique” as the name for this approach, which was suggested by Semprini et al., (1998). Laboratory and modeling studies (Semprini et al., 2000; Davis et al., 2002; 2003) show that the amount of partitioning, and hence the reduction of Rn-222 concentrations in groundwater from background, increases with increasing NAPL saturation. Trichloroethene (TCE) saturations in excess of approximately 1% within 1 to 2 m of the sampling point cause easily detectable reductions in Rn-222 concentrations (Semprini et al., 2000). Two applications of the RDT have been tested in the lab and in small-scale field studies: 1) delineating the spatial extent of NAPL and 2) assessing NAPL removal. The spatial extent of NAPL-contaminated zones can be delineated by generating “snapshots” of Rn-222 concentrations. Rn-222 concentrations measured in a suspected NAPL-contaminated zone are compared to background concentrations measured in a NAPL-free area (the background area). A sample whose Rn-222 concentration is significantly less than the background concentration indicates that NAPL is present in the immediate vicinity (typically within approximately 1 to 2 m) of the sample location. Background concentrations are measured in samples collected from the same geologic setting as the suspected NAPL-contaminated zone, but outside the area where NAPL is present. 7 The second application, evaluating NAPL removal, relies on time series data instead of snapshot data. To generate a time series data set, samples are collected repeatedly from the same locations. Changes in Rn-222 concentrations over time indicate that the rate of partitioning into the NAPL has varied, presumably as a result of NAPL removal during remedial activities. If radon concentrations increased, it could be interpreted that NAPL had been at least partially removed from the vicinity of the sample point. If the background radon concentration is known and the radon concentration stabilized at the background value, then it could be concluded that all NAPL had been removed from the close to the sample point. The radon method was previously tested in two controlled field studies at the Canadian Forces Base Borden test site in Ontario, Canada (Semprini et al., 2000). In the first study, a fairly uniform NAPL source composed of a mixture of chloroform, TCE, and PCE was emplaced in the shallow sand aquifer and slowly dissolved under natural groundwater flow conditions. Groundwater samples for radon analysis were obtained upgradient, within, and downgradient of the source. Within the NAPL zone, dissolved radon concentrations decreased to 0.3 to 0.5 of the upgradient (background) concentration, and rebounded within a few meters to the background value. This data set indicates that the radon deficit occurs locally near the NAPL contamination. Simulated radon concentrations along the flowpath are in good agreement with the field results. A NAPL residual saturation of 4.5%, estimated based on the model simulations, is similar to the value of 3.8% provided by the researchers responsible for creating the emplaced source. The second experiment at Borden, referred to as the “Free-Release” experiment, involved releasing 5 L of NAPL into a sand aquifer within a steel sheet pile test cell. The NAPL was permitted to distribute itself in the aquifer and form an irregular NAPL zone. Groundwater flow (10.1 cm/day) was induced by injecting and pumping groundwater at opposite ends of the cell. Radon-stripped recharge water (20 pCi/L aqueous radon) was injected upstream of the NAPL spill. Radon concentrations were measured downgradient at selected locations. Modeling of a residual NAPL zone (0.5 m in length with a residual saturation of 7.8%) produced a predicted radon concentration profile that matched the field observations. The modeling and field results indicate NAPL contamination exists at this location. This zone of NAPL contamination was confirmed when the contaminated zone was excavated. Increases in radon concentration during NAPL remediation has also been recently reported in large physical aquifer model experiments conducted by Davis et al., (2003). Detailed contour analysis of radon concentrations showed concentration increases were associated with the remediation of the NAPL by alcohol cosolvent flushing. These investigations indicate that the RDT has the potential for being a very useful tool for delineating the spatial extent and amount of NAPL present and for assessing NAPL removal activities, at least in the relatively small physical systems examined. The evaluation at the OK Tool site described here examined the performance of the method at a much larger and more heterogeneous site where active groundwater remediation is in progress. 8 3 EXPERIMENTAL METHODS The techniques used for purging and sampling groundwater (Section 3.1) and analyzing samples for Rn-222 (Section 3.2) are described in this section. 3.1 Groundwater Purging and Sampling This section provides an overview of the techniques utilized. Detailed descriptions are provided in the following sampling plans and information about purging and sample collection is documented in the corresponding data reports: • Baseline Sampling in 2003: Protocol for Collection of Samples in Support of Bioremediation Polishing Step and for Assessing the Effectiveness of In Situ chemical Oxidation (ISCO) for Source Removal, OK Tool Site, Milford, NH – Pre-ISCO Baseline Sampling (Starr et al., 2003). • Sampling in 2004 after the ISCO pilot test: Protocol for Collection of Samples in Support of Bioremediation Polishing Step and for Assessing the Effectiveness of In Situ chemical Oxidation (ISCO) for Source Removal, OK Tool Site, Milford, NH – Post-ISCO Sampling and Radon Background Sampling – Revision 0 (Starr and Macbeth, 2004). • Sampling in 2005 after larger-scale application of ISCO: Protocol for Collection of Samples in Support of Bioremediation Polishing Step and for Assessing the Effectiveness of In Situ chemical Oxidation (ISCO)for Source Removal, OK Tool Site, Milford, NH – Pre-ISCO Sampling and Radon Background Sampling – Revision 1 (Starr and Macbeth, 2005). The major differences between these documents are addition of information needed to meet EPA quality assurance requirements in the 2004 document, modification of the locations sampled in the 2004 and 2005 documents, and minor editorial changes in the 2005 document. Groundwater samples were collected using the low-flow purging and sampling approach. Purging was carried out until water quality indicator parameters stabilized, and then samples for dissolved radon analysis were collected. Samples were collected without exposure to the atmosphere and placed into sample bottles that did not contain a headspace. Samples were stored on ice in an insulated cooler and shipped to the analytical laboratory via overnight courier. Details related to purging, sampling, and shipment are documented in a data report prepared for each sampling event (Starr, 2004; 2005; 2006). 3.2 Radon-222 Analysis Samples were analyzed via liquid scintillation counting at the Environmental Assessment Laboratory in the Idaho State University Physics Department. The lab prepared subsamples for analysis by transferring an aliquot of groundwater to a scintillation vial that was pre-loaded with scintillation cocktail using techniques that minimized exposure to the atmosphere to prevent loss of radon via volatilization. The activity of Rn-222 in each sample was determined by counting in a scintillation counter, correcting for background, counting efficiency, and quench. The activity per unit volume of groundwater at the time of analysis was calculated using the measured mass of groundwater present in the samples analyzed. The activity per unit volume of groundwater at the time of sample collection was determined by correcting the activity at time of analysis for radioactive decay between the time of sample collection and analysis. A quench correction method, developed as part of this study to account for possible interference with scintillation photon transmission that might occur as a result of the color imparted by permanganate in samples, was applied to all samples. 9 Additional details on the sample collection and analysis procedures are provided in the sampling plans and data reports for each sampling event. The analytical data and associated calculations are provided in appendices to data reports prepared for each sampling event. A laboratory calculation error was discovered in the baseline (pre-ISCO) radon data (2003) after the post-ISCO pilot test samples (2004) were analyzed. Corrected baseline radon data are provided in the Data Report: Radon in Groundwater at the OK Tool Site, Milford, New Hampshire, September 2004 (Starr, 2005). 10 4 RESULTS AND INTERPRETATION The results of limited sampling in the pre-ISCO baseline sampling event in 2003 (Section 4.1) suggested that the RDT might be useful at the OK Tool site, although whether the background radon concentrations could be differentiated from radon concentrations in DNAPL-contaminated areas was ambiguous. More extensive sampling of background wells, which was performed in the post-ISCO pilot test sampling in 2004, was used to resolve this ambiguity (Section 4.2). Temporal trends in radon concentrations during three sampling events (baseline, approximately 1 year after the first oxidant injection, and approximately 1 year after the second oxidant injection) were interpreted relative to inferring information about DNAPL removal at the OK Tool site (Section 4.3). 4.1 Baseline Data Set Baseline Rn-222 and VOC sampling was conducted during August and September 2003 immediately before the initial oxidant injection of the ISCO pilot test. Samples were collected from the ISCO pilot test area where DNAPL is present (wells CI, EI, NCP, NEMLS, NEP, MWMLS, and NWP), from an area where DNAPL is present but outside the influence of the pilot test (PW6-S and PW6-M), and from three wells in background areas (B95-8, PW5-M, and PW7-S). The locations of wells sampled in this sampling round and in subsequent sampling rounds are shown in Figure 4-1. Measured radon concentrations in triplicate samples from each well are shown with ±1 standard deviation error bars (Figure 4-2). Note that the radon concentrations plotted in Figures 4-2 and 4-3 differ from those reported in the baseline sampling event data report (Starr, 2004) because laboratory calculation errors caused the concentrations previously reported to be too high, although the general trends in the data were not affected. The calculation error is discussed and the revised data set is provided in the 2004 sampling event data report (Starr, 2005). The following features are apparent in this data set: • In general, analysis of triplicate groundwater samples for Rn-222 showed excellent reproducibility. However, the results for three wells (PW7-S, NEMLS and NEP) each have two similar values and one dissimilar value. The cause for the dissimilar (low) values is not known. • Radon concentrations (~5,400 pCi/L) in two of the background wells (B95-8 and PW7-S) are distinctly different from the remainder of the values (~1,500 to ~4,200 pCi/L), which is consistent with partitioning into DNAPL, reducing the aqueous concentration of Rn-222. • The measured concentrations in one well that is thought to be a background well (PW5-M) fall in the range of values for wells in DNAPL areas. 11 PCE DNAPL Source Area (INEL Well Array) HCN NCP HCNW NWP NW-MLS SVE-4 HCW NC-MLS NEP Cl WI HCNE NE-MLS El HCE P2 SG1 P2 SG3 SW-MLS HCSW SC-MLS SWP SCP SEP HCSE P2 10 PW3D PW12S PW12M PW3S B95-3 PW9M HCS PW11D PW11M Current P/T Reinjection (Gallery) MI-22A B95-4 TP-3 MW-27 PW8M SVE-6 SVE-3 PW10M B95-15 MI-22 PW10D MI-23 SP-2 PW14M B95-2 IW-2 PW13M PW13S HM-1 10 0 RW-2 P2 SG2 P2 SG4 SE-MLS PW13D PW12D PW12R MI-68 MOW-63 MI-63 TP-2 PW14D PW14S MI-47 EW-1 RW-1 B95-16 SVE-5 B95-10 PW7S MI-24 PW6S SVE-4 B95-1 MI-24A SVE-1 B95-8 RW-2 MI-21A PW5M PW5R PW6D PW6R PW6M PW7M B95-6 PW5D B95-11 SP-1 Former location of OK Tool Building PW2R PW2M B95-17 SVE-2 PW4D PW4M B95-13 MI-32 PW2S PW1D EW-2 PW2D MW16C MW16B IW-1 10 0 MW16R MW16A MI-26 B95-9 MI-25 B95-7 PW1S 10 B95-5 RW-3 OK Tool Site Well Infrastructure TP-1 MI27 Savage Well OK Tool Source Area Treatment Plant B95-12 Milford Police Station Explanation GW Extraction Well INEL Well Air Sparge Well Well (active) Well (abandoned) MI28 Soil Vapor Extraction Well Figure 4-1. Wells sampled for radon-222 analysis in one or more sampling events (Starr, 2005). 12 Sampling Wells Slurry Wall LocationMI-31 OK Tool Area September 2003 7,000 Background Non-Background 6,000 Rn (pCi/L) 5,000 4,000 3,000 2,000 1,000 N EP P C N P W N N EM LS EI 6M 6S PW M W N PW LS I C 7S PW 5M PW B9 58 0 Well Identifier Figure 4-2. Rn-222 in baseline (before ISCO) groundwater samples (adapted from Starr, 2004). If only the two high (~5,400 pCi/L) values represent background conditions, this data set would indicate that Rn-222 concentrations may be used to identify the spatial extent of DNAPL. On the other hand, if the low Rn-222 concentrations at PW5-M are also background values, then the data set would indicate that radon concentrations in background areas are similar to those in DNAPL-bearing areas. Determining the variability in background concentrations was critical to the evaluation of the utility of the RDT at the OK Tool site. Comparison of dissolved PCE (the major dissolved VOC in groundwater at the site) and Rn-222 concentrations (Figure 4-3) shows that Rn-222 concentrations were depressed relative to background where PCE concentrations were greater than approximately 60 µg/L, at least in this limited data set (assuming that PW5-M does not represent background). This behavior is consistent with DNAPL, causing both elevated dissolved VOC concentrations and depressed Rn-222 concentrations. The baseline data set suggested that radon concentrations might be useful for delineating DNAPL-bearing zones and assessing DNAPL remediation at the OK Tool site; however, the low concentration of Rn-222 in well PW-5M relative to other background wells was problematic. In order to further evaluate the utility of the RDT for discriminating between NAPL-bearing and background areas, a more extensive network of background wells was sampled approximately 1 year after the ISCO pilot test began (Section 4.2). 13 September 2003 7,000 B95-8 6,000 PW-7S Average Rn-222 (pCi/L) 5,000 Postulated Relationship 4,000 3,000 2,000 PW5-M 1,000 0 1 10 100 1,000 10,000 PCE (ug/L) Figure 4-3. Correlation between Rn-222 and dissolved PCE concentrations, baseline conditions at the OK Tool site (adapted from Starr, 2004). 4.2 Spatial Variability in Background Radon Concentrations at OK Tool and Use of Radon Deficit Technique for Delineating Non-aqueous Phase Liquid The fundamental requirement for applying the RDT to delineate DNAPL-bearing zones is that it must be possible to discriminate radon concentrations in DNAPL-bearing zones from those in background areas. The baseline data set (Section 4.1) suggested that the RDT could possibly be used at the OK Tool site to identify areas where DNAPL was present, although the preliminary results were somewhat ambiguous. The ambiguity arose because two background radon concentrations appeared to be distinctly different from those in DNAPL-bearing areas, but a third background value was comparable to those in DNAPL-affected areas. The RDT can be used to identify NAPL-bearing zones only if radon concentrations in these areas can be unambiguously differentiated from those in background areas. The ambiguity in background radon concentrations in the baseline data set led to a more extensive sampling of background wells to better characterize background radon concentrations at the OK Tool site. Radon concentrations were measured in 13 background wells in the 2004 sampling event. Each of the 24 wells sampled in 2004 was assigned to either the background or non-background category based primarily on its location relative to areas where DNAPL has been previously inferred to be present and secondarily based on contemporaneous measurements of PCE concentrations (Figure 4-4). In the background wells, PCE concentrations (determined in August and September 2003 and August and September 2004 by NHDES and Veolia Water Systems [now NA WaterSystems]) were less than 100 µg/L. In contrast to the low concentrations in background wells, PCE concentrations in the non-background wells were above 100 µg/L in one or both of the 2003 and 2004 sampling events. Lower concentrations in 2004 at wells in the Test Array are thought to be a result of the ISCO Pilot Test conducted in that area. 14 100000 2003 2004 Background Non-Background 10000 PCE (ug/L) 1000 100 10 1 WI PW-6S PW-6M NWP NWMLS NEP NCP NEMLS NCMLS EI CI PW-9M PW-7S PW-8M PW-7M PW-5M PW-4M PW-4D PW-3D MW-16B MW-16C B95-8 B95-5 B95-3 0.1 Well ID Figure 4-4. PCE concentration in selected wells at OK Tool (Starr, 2005). The background radon data set consists of concentrations measured in samples collected from 13 wells, and the non-background data set consists of data from 11 wells (Figure 4-5). The measured value and ±1 standard deviation error bars are plotted. Visual examination of these data sets suggests that the non-background data cannot be differentiated from the background data. 6,000 Background Non-Background 5,000 Rn-222 (pCi/L) 4,000 3,000 2,000 1,000 0 -1,000 I EI S 5 3 8 B P LS E P P M S S C L LS 5- 95- 95- 16 16C -3D -4D -4M -5M -7M -7 -8M -9M W 6 -6 9 M N C EM N M N W- W W W W B W W P B B W W W W W C W P P P P P P P P P N N N M M Well Identifier Figure 4-5. Radon concentrations in groundwater, September 2004 (Starr, 2005). 15 W I Descriptive statistics for the 2004 data sets are summarized in Table 4-1. These statistics were computed using the means of measured values for each well so that all wells would be weighted equally while calculating population statistics, even though there are three measured values for some wells and four for others. The overlap of the P=0.95 confidence interval for the means of the background and non-background datasets indicates that the means are not significantly different. The same conclusion can be drawn by comparing the 2003, 2004, and 2005 data sets (Figure 4-6). Table 4-1. Descriptive statistics for the 2004 radon dataset (Starr, 2005). Statistic Background Dataset (pCi/L) Non-Background Dataset (pCi/L) Mean 2,260 2,497 Standard Deviation 1,354 1,242 0.95 Confidence Interval for the Mean 1,442 – 3,078 1,663 – 3,332 To further compare the 2004 data sets, two additional statistical techniques were used. First, the means of the two data sets were compared. Second, data for each non-background well were individually compared to the background data set. The comparison of the means of the background and non-background data sets began by calculating the mean radon concentration for each well and computing a global mean of background and non-background values by averaging the means for background wells and non-background wells. This gives equal weight to each well, in spite of there being three measurements for some wells and four for others. The global means of the background and non-background data sets were compared using Student’s t-test via the statistical analysis software package SigmaStat 3.1 (Systat Software, Inc.). The t-test indicates that the means of the two data sets are not significantly different, which is consistent with the overlap between the confidence intervals of the means. Next, data for each non-background well were compared to the background data set. This comparison used all three (or four) data values for an individual non-background well and the mean concentration for each background well. In cases where the assumptions of normality and equal variance were met, the t-test was used to compare the means. If these assumptions were not met, then the non-parametric Mann-Whitney Rank Sum test was used to compare median concentrations, again using SigmaStat. The radon concentration at only one of the 11 non-background wells (NCMLS) could be discriminated from background radon concentrations. Based on these comparisons, the background and non-background data sets are not statistically different. Hence, it can be concluded that the RDT cannot be used at the OK Tool site to differentiate between background and non-background areas, and therefore cannot be used to delineate the spatial extent of DNAPL-bearing zones. This finding is specific for the OK Tool site and cannot be generalized to other sites. 16 Figure 4-6. Mean radon concentrations in background and non-background areas in three sampling events. One-standard deviation error bars are shown (Starr, 2006). 4.3 Temporal Trends in Radon and Use of Radon Deficit Technique for Assessing Non-aqueous Phase Liquid Remediation Lab tests and small-scale field trials at other locations suggest that dissolved radon concentrations increase as NAPL saturation declines, and thus variations in radon concentrations in groundwater over time may provide information about changes in NAPL saturation. In this study, concentrations of radon in groundwater were monitored before and after two iterations of ISCO in a DNAPL-contaminated area. It was anticipated that ISCO would reduce DNAPL saturation and that there would be a corresponding increase in dissolved radon concentrations. Monitoring data (permanganate, VOCs, and chloride) collected during two iterations of ISCO in the Test Array area were interpreted as indicating that at least 20% of the VOC mass present in the Test Array area prior to ISCO was removed during two iterations of ISCO (NHDES, 2005; 2006). The majority of the mass removed was probably in the DNAPL phase at the beginning of ISCO. Although the majority of the estimated DNAPL mass was thought to remain in the Test Array area after two iterations of ISCO, the persistence of permanganate for approximately 1 year after injection suggests that DNAPL was largely removed from the zones flushed with oxidant solution. If DNAPL remained in these horizons, then permanganate would be expected to be completely consumed via oxidation reactions with VOCs. 17 Groundwater samples for radon analysis were collected from Test Array wells within the depth interval where oxidant solution was injected. Many of the post-ISCO samples for radon analysis were pink or purple, indicating that permanganate was present in groundwater at those locations. It is assumed that DNAPL saturation declined in the vicinity of monitoring wells where radon samples were collected, and hence it was expected that radon concentrations would increase between the baseline and post-ISCO sampling events. If this expected behavior was observed, it would support the use of the RDT for assessing DNAPL remediation at this site. On the other hand, if the expected trend was not observed, then it would be concluded that the RDT does not provide definitive information about DNAPL remediation at this site. Radon concentrations measured in background and non-background (nine Test Array wells and one well, PW-6D, in a DNAPL-bearing area outside the Test Array) areas are shown as the mean and standard deviation of analysis of replicate samples (Figure 4-7). Here we focus on the Test Array wells because it was expected that there would be a trend of increasing radon concentration over time in conjunction with ISCO and the associated reduction in DNAPL saturation. Radon concentrations varied from place to place and varied in time at most wells in the Test Array. The 2003 radon data represent pre-ISCO conditions, and the 2004 and 2005 data represent conditions after approximately 1 and 2 years of oxidation. Figure 4-7. Mean radon concentrations and 1-standard deviation uncertainty measured in 2003, 2004, and 2005 (Starr, 2006). 18 In contrast to the expected trend of increasing radon concentrations with time at all wells in the Test Array, only one (NEMLS) of the seven Test Array wells sampled all 3 years shows this trend (Figure 4-6 and Table 4-2). The expected trend of increasing radon concentrations over time, in conjunction with DNAPL remediation, was not observed at the remaining six Test Array wells. One well showed stable radon concentrations, one showed a decline in radon concentration, and the remaining four had inconsistent trends over time. The failure for the anticipated trend to be observed indicates that either ISCO was not effective for removing DNAPL from the immediate vicinity of the locations where radon samples were collected, that radon concentrations are not related to DNAPL saturation in a simple manner, or that other sources of variation in radon concentrations mask the changes caused by reduction in DNAPL saturation. As a result of observing trends counter to the expected trends, our interpretation is that changes in radon concentrations over time cannot be used to evaluate the effectiveness of DNAPL remediation at the OK Tool site. Table 4-2. Temporal trends in radon concentration in non-background wells in the INEL Well Array. Observed Trend Increasing Decreasing Stable Wells NEMLS CI NWP 1 1 1 Number of Occurrences Variable EI NCP NEP NWMLS 4 The finding that radon concentrations did not show an increasing trend over time in the INEL Well Array is contrary to the results of laboratory studies and field studies performed by others (Semprini et al., 2000; Davis et al., 2002; 2003). We speculate that the following factors may account for the expected trend not occurring: • The variability in measured radon concentrations due to factors other than changes in DNAPL saturation may mask the expected trend. The temporal variation in radon concentrations measured in background wells (left portion of Figure 4-7) may reflect differences in the groundwater flow system, sampling technique, or analytical technique. Similar variability in the Test Array wells may be larger than the changes caused by removal of DNAPL. • Although ISCO was performed for approximately 2 years between the 2003 and 2005 sampling events, it is possible that DNAPL saturations in the immediate vicinity of the radon sampling points were not substantially affected. This could occur if DNAPL was initially absent from the immediate vicinity of the sampled depth in each well or if DNAPL saturation near a sampled depth was not affected by ISCO. • The relationship between DNAPL saturation and radon partitioning may be more complex than assumed. For example, partitioning between the aqueous and DNAPL phases is probably related to the DNAPL-water interfacial area as well as DNAPL saturation, and the relationship between interfacial area and saturation may be complicated, especially at high DNAPL saturation (i.e., as DNAPL transitions from a high saturation “pool” configuration to a low saturation “residual” configuration). • Precipitation of MnO2 on mineral grain surfaces could reduce the radon emanation rate, which could account for the reduced Rn-222 concentrations in groundwater sampled from well CI. 19 5 SUMMARY AND CONCLUSIONS The study described in this report, which was funded by the EPA, evaluated the RDT for delineating the spatial extent of DNAPL in the subsurface at a multi-acre field site, and also evaluated the ability of the technique to evaluate the progress of DNAPL remediation. This study was performed in conjunction with ISCO, which was used to remediate DNAPL in a sand and gravel aquifer at the OK Tool site. Rn-222 concentrations measured in groundwater samples collected before the first oxidant injection suggested that Rn-222 concentrations in background samples (i.e., samples from areas where DNAPL was not present) were higher than concentrations in samples collected from areas where DNAPL was present. This finding was consistent with the results of lab and field studies performed by others, and suggested albeit with some ambiguity - that the RDT could be used to delineate the spatial extent of DNAPLbearing zones at the OK Tool site. Approximately 1 year after the first injection of oxidant, groundwater samples were collected from numerous wells in background areas and in areas where DNAPL was present. Although measured radon concentrations in replicate samples showed good agreement, radon concentrations showed considerable variation between wells in background areas. Furthermore, Rn-222 concentrations in background samples were similar to concentrations measured in samples collected from DNAPL-bearing areas. These features prevent Rn-222 concentrations in background areas from being discriminated from concentrations in NAPL-contaminated areas. The inability to discriminate background areas from DNAPL-contaminated areas (based on Rn-222 concentrations) indicates that the RDT cannot be used to delineate the spatial extent of NAPL in the subsurface at the OK Tool site. This conclusion does not necessarily apply to other sites. Indeed, the technique may be feasible at sites that have more homogeneous background Rn-222 concentrations. Examples of such sites include ones smaller than the approximately 4-acre OK Tool site and sites with more homogeneous subsurface media. Temporal trends in Rn-222 concentrations in groundwater were determined for selected wells in background areas, in areas where NAPL was present and affected by ISCO. The expected trends included no change in background areas and a monatomic increase in areas affected by ISCO. The observed trends were not consistent with the expected trends and in particular, radon concentrations in the areas affected by ISCO did not uniformly increase. The inconsistency between the observed and expected trends suggests that the RDT does not provide reliable information about the extent of DNAPL remediation at the OK Tool site. It is recognized that some of the variability in measured Rn-222 concentrations may result from variability in the purging, sampling, and analytical processes. However, the procedures employed were typical of those used for routine groundwater sampling at remediation sites, and therefore we anticipate that a similar level of variability would be encountered at many sites. Additional variability may be attributed to differences in hydrologic conditions caused by precipitation events, fluctuations in river stage, and changes in groundwater flowrates and direction, which were affected by variations in operation of groundwater extraction wells. These complicating factors may interfere with application of this technique but are typical of active remediation sites. In summary, the RDT at this site does not appear to be useful for delineating the spatial extent of NAPL or for evaluating the effectiveness of remedial activities. Although the extent to which these findings can be transferred to other sites is unknown, these findings do not encourage further application of the RDT at active remediation sites outside the research arena. 20 6 ACKNOWLEDGEMENTS The study described in this report was funded by the EPA Office of Solid Waste and Emergency Response’s Measurement and Monitoring Technologies for the 21st Century (21M2) initiative, EPARegion 1, and the National Exposure Research Laboratory Technology Support Center. EPA Region 1 provided overall project management for the OK Tool site, coordinated activities among various organizations, and provided review comments on project work control documents and data reports. The United States Geological Survey provided natural gamma logs for selected boreholes at the site. The New Hampshire Department of Environmental Services provided analytical data from their groundwater monitoring program. NA WaterSystems performed the ISCO project and provided logistical support to sampling activities. North Wind, Inc. (NWI) field teams led by Tamzen Macbeth collected groundwater samples. Rn-222 analyses were preformed by the Environmental Assessment Laboratory at Idaho State University, under the direction of Richard Brey. Discussions with Lewis Semprini of Oregon State University provided useful information during formulation of research plans. Funding for this project was provided by the EPA as a result of a proposal submitted by Richard Goehlert of EPA Region 1. These funds were managed by EPA’s Technical Support Center in Las Vegas under the direction of J. Gareth Pearson, Chris Sieborg, and, currently, Brian Schumacher. Funds were transferred to the U.S. Department of Energy via an interagency agreement managed by Robert Jones of the Idaho Field Office, to Battelle Energy Alliance via a project managed by Kenneth Moor, and thence to NWI. 21 7 REFERENCES CDM, 1995. 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