Engineers and

GZA
GeoEnvironmental, Inc.

Scientists

VIA EMAIL
December 13, 2006
File No. 04.0023171.06 C

Mr. Richard Fuller, Chairman and Director
The Blacksmith InstituteTwo Park Avenue, 29th Floor
New York, New York 10016
Re:

380 Harvey Road
Manchester
New Hampshire
03103-3347
603-623-3600
FAX 603-624-9463
http://www.gza.net

Remedial Pilot Study
Chromium Contamination Area
Noraiakheda, Kanpur, Uttar Pradesh, India

Dear Mr. Fuller:
GZA GeoEnvironmental, Inc. (GZA) of the United States of America, as a remedial design
engineering consultant, and EcoCycle India Private Limited (ECI) of Bangalore, India, as anaffiliate remedial product supplier of EcoCycle Corporation of Japan (ECJ), are pleased to submit
to The Blacksmith Institute (Blacksmith) this letter report summarizing the methods, results, andconclusions of a Remedial Pilot Study carried out at the Chromium Contamination Area in the
Noraiakheda neighborhood of Kanpur, Uttar Pradesh, India (Study Area). The Remedial Pilot
Study was performed to collect pre-design level performance data for evaluating whether anenhanced biological remediation (bioremediation) strategy could reduce the hexavalentchromium, Cr (VI) concentration in Study Area overburden groundwater and advance theChromium Contamination Area toward closure. GZA has have prepared this letter report basedon various conference calls with Blacksmith and Mr. R. K. Singh, Ph.D. (Scientist and Quality
Manager) of the Central Pollution Control Board [CPCB]) of Lucknow, India (CPCB-Lucknow),
as well as a September 13, 2005 meeting with Blacksmith at its New York City office.
GZA notes that CPCB-Lucknow provided considerable scheduling, logistical, field staffing,analytical, Computer Aided Design, data summary, and regulatory support for this project.
In fact, given the collaborative nature of this project, hereafter, “Project Team” refers to thispartnering relationship among GZA (remedial design engineering consultant), CPCB-Lucknow(regulatory authority), and ECI (remedial product supplier) in carrying out the Remedial Pilot
Study at the Study Area. Our work and this letter report are subject to the attached Limitations.
This letter report is organized into the following sections:•

Background Information – General background information on the Study Area andsuspected contaminant sources;•

Technical Approach – A summary of the technical approach for the Remedial
Pilot Study;•

Methods – Summary of pilot study methods;•

Results and Discussion – Presentation and discussion of the Remedial Pilot Study results;•

Conceptual Remedial Approach – A conceptual remedial approach, based on pilot study
results, to advance the Study Area towards closure; andCopyright © 2006 GZA GeoEnvironmental, Inc.

An Equal Opportunity Employer M/F/V/H

The Blacksmith InstituteFile No. 04.0023171.06 C•

December 13, 2006
Page 2Conclusions and Recommendations – Conclusions regarding Remedial Pilot Study
results and recommendations for future Study Area work based on those results.

The following items are attached, each prepared by CPCB-Lucknow in collaboration with GZA:•

Data Summary Table of remedial pilot study performance data;•

Figures:−

Locus Map of Kanpur in Uttar Pradesh, India,−

Map of Kanpur City depicting location of Study Area,−

Study Area Map depicting location of Remedial Pilot Study,−

Well Field Exploration Location Plan, relative to the general direction of
overburden groundwater flow,−

Baseline Groundwater Elevation Contour Plans,−Baseline Hexavalent Chromium Isoconcentration Plan,−

Baseline Total Organic Carbon Isoconcentration Plan,−

Post-Injection Groundwater Elevation Contour Plans,−

Post-Injection Total Organic Carbon Isoconcentration Plans, and−Post-Injection Hexavalent Chromium Isoconcentration Plans;•

Boring Logs for four new wells installed in the Study Area and an existing piezometer;•

Summary of Site Hydrogeologic Information; and•Study Area Baseline Chemical Parameter Ranges for Soil.

BACKGROUND INFORMATION
Based upon Blacksmith’s “Polluted Places” Internet site1 and other information sources we havereviewed as well as our January-February 2006 visit to the Study Area, we understand that
Kanpur is the largest and most industrialized city in the state of Uttar Pradesh, the fifth largest
and most populous state of India located in the northern reaches of the subcontinent (Refer to theattached Locus Map of Kanpur, Uttar Pradesh). Kanpur occupies an area of just over
1,000 square kilometers, has a population of about 2.4 million residents (based upon a1991 census), and is considered by some to be the most contaminated city of India.2 Kanpur issituated in the Indo-Gangetic plain on the banks of the Ganga River, the largest river of
Uttar Pradesh, at an elevation of approximately 126 meters above mean sea level. Refer to theattached Base Map of Noraiakheda Area, Kanpur and the attached Location Plan of Pilot Studysite, Noraiakheda Area for plans depicting the approximate location of the Study Area.
During the British colonial period, Kanpur was reportedly known as the “Manchester of the East”
due to the presence of many cotton mills. Following decline of the textile industry, Kanpur
became better known for its leather industry established in about 1857. At the present time, more
1
Uniform resource locator (URL): http://www.pollutedplaces.org/region/south_asia/india/kanpur.shtml(Polluted Places, Site Dossier, Kanpur, Uttar Pradesh, India)
2
URLs: http://en.wikipedia.org/wiki/Kanpur (Kanpur, From Wikipedia—The Free Encyclopedia), andhttp:/experts.about.com/e/k/ka/Kanpur.htm. (All Experts, Kanpur Encyclopedia).

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 3than 350 tanneries are located in the eastern part of the city and many of which release untreatedeffluent into the Ganga River. The tanneries, or the local suppliers of tanning agents such as
basic chromium sulfate, produce a toxic sludge containing Cr (VI), arsenic, cadmium, zinc,mercury, nickel, copper, and cobalt, which have deleteriously impacted the water supply andimpacted human health. A treatment plant, built in the 1990s, has reportedly done little to reduce
contamination in tannery effluent and reportedly mixes effluent with urban sewage and theblended wastewater is treated via an Upflow Anaerobic Sludge Blanket System (UASB) in a
dedicated treatment plant with a capacity of about 36 million liters per day. In accordance withsystem design, a bulk of treated wastewater is utilized for irrigation; however, given limited
irrigation, excess wastewater is discharged to the Ganga River. Wastewater periodically contains
significant concentrations of total chromium, on the order of 2 to 5 milligrams per liter (mg/L) as
a result of inadequate chrome recovery and pre-treatment by individual tanneries.
Pollutants associated with the leather tanning industry have deleteriously impacted Kanpur's
shallow groundwater system. For example, in 2003, CPCB-Lucknow discovered that Cr (VI) has
impacted water supply wells in the Noraiakheda neighborhood, a settlement of some
30,000 residents. The source of that plume was apparently an old chemical manufacturing
facility where toxic sludge had been released over a decade ago. Five piezometers werereportedly installed in that area to evaluate the spatial extent of the Cr (VI) condition. However,until that problem is addressed, local residents have no alternative but to continue using
contaminated groundwater from Cr (VI)-impacted water supply wells. Moreover, while Cr (VI)
has impacted the shallow overburden groundwater system, it has reportedly yet to significantly
impact the deeper groundwater system that Kanpur relies on for much of its potable water needs.
The protection of this deeper groundwater system from Cr (VI) contamination is, therefore, of
critical importance.
In the Jajmau neighborhood, on the eastern outskirts of Kanpur, the lack of treatment facilities fororganized disposal of tannery wastes, which is currently under development outside the city
limits, led to tannery sludge being dumped in temporary locations with unrestricted public access.
Approximately 25 villages located downstream of the tanneries have reportedly been impacted byuntreated tannery effluent. These villages reportedly have no electrical or telephone connections
and poor sanitary conditions. Use of contaminated water for irrigation and other purposes byvillagers, as well as uncontrolled dumping of toxic Cr (VI)-impacted sludge in that community,
have created potential exposure pathways to the local population.
TECHNICAL APPROACH
Cr (VI)3 is a mutagenic, teratogenic, carcinogenic, soluble, and readily mobile cation that exists
under the aerobic, chemically oxidizing conditions of many overburden groundwater systems.
Even so, Cr (VI) can be biogeochemically transformed to its relatively innocuous, insoluble, andimmobile trivalent state, Cr (III)4 under anaerobic, chemically reducing conditions.5

3

With Cr in the +6 valence state.
With Cr in the +3 valence state.
5
URL: http://www.epa.gov/ttnatw01/hlthef/chromium.html (Chromium Compounds Hazard SummaryCreated in April 1992; Revised in January 2000)
4

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December 13, 2006
Page 4

The transformation of Cr (VI) to Cr (III) is ostensibly an irreversible biogeochemical reaction
under most naturally-occurring environmental conditions. According to EPA (2000),6 thebiochemical reduction of Cr (VI) primarily yields amorphous chromium precipitates such as
chromium hydroxide (Cr(OH)30), with chromium as Cr (III). Included below is an Eh – pHstability field diagram for chromium developed by Palmer and Wittbrodt (1991):7

As shown on the diagram, the amorphous chromium hydroxide precipitate Cr (OH)30, withchromium existing in the trivalent (+3 valence) state, is stable at a wide range of pH and Ehvalues spanning the typical ranges of these parameters within overburden groundwater.
Chromates, however, with chromium existing in the hexavalent (+6 valence) state, are only stable
at very high Eh values at pH values approaching neutrality. For example, Cr (OH)30, as shown
above, is stable at pH values ranging from about 6 to 12 standard units and at Eh values ranging
from about -0.7 to + 0.6 volts (-700 to +600 millivolts, mV). Therefore, the conversion of
Cr (VI) to Cr (III) generally yields amorphous chromium precipitates that are fixed onto
formation matrices, with chromium as Cr (III). Such precipitates are generally stable andimmobile and cannot readily be converted back to mobile Cr (VI) by natural processes.
In-situ bioremediation is a remedial approach that leverages the biogeochemical relationshipbetween Cr (VI) and Cr (III) and could potentially address the Cr (VI) condition in
Kanpur groundwater.

6
EPA, 2000, In situ treatment of soil and groundwater contaminated with chromium technical resource
guide, EPA 625/R-00/005, 84 p.
7
Palmer, C.D. and P.R. Wittbrodt, 1991, Processes affecting the remediation of chromium-contaminatedsites, Environmental Health Perspectives. v. 92

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Page 5

Implementation of an in-situ bioremediation approach would involve providing an electron donor
remedial additive to the Cr (VI)-impacted groundwater system to stimulate transformation of
Cr (VI) to Cr (III).8 In addition to reducing chromium toxicity, this transformation mechanism
immobilizes a bulk of chromium contamination in-situ by fixing it onto the formation matrix.
In general, this reaction is irreversible under nearly all naturally-occurring environmental settings.
METHODSThe Remedial Pilot Study involved the following two tasks, each of which is discussed below:•

Task 1 – Background Data Review; and•Task 2 – Remedial Pilot Study Implementation and Reporting.

TASK 1 – BACKGROUND DATA REVIEW
GZA, in collaboration with CPCB-Lucknow, reviewed the work performed to date to characterizehydrogeologic conditions in the Study Area as well as the magnitude and extent of Cr (VI)contamination. The purpose of this review was twofold:•

Development of a preliminary conceptual site model (CSM) of Cr (VI) fate and transport
and an assessment of the risk Cr (VI) contamination poses to potential sensitive receptors
in the Study Area; and•Finalization of pilot study conceptual design consistent with the preliminary CSM.

TASK 2 – REMEDIAL PILOT STUDY IMPLEMENTATION AND REPORTING
The Remedial Pilot Study objective was to evaluate the efficacy of in-situ bioremediation foraddressing the Cr (VI) contamination condition within Study Area overburden groundwater.
The study involved installation of a well field in a portion of the highly Cr (VI)-impacted
groundwater system in the Study Area that was selected based on Task 1 results. The well field
included four new injection/monitoring wells as well as an existing piezometer (hereafter, Skolast
piezometer), with well screens intersecting the same laterally-continuous Cr (VI)-impactedhydrostratigraphic unit. That piezometer is located on a parcel operated by M/s Skolast (I) Pvt.
Ltd., a safety footwear manufacturer located in the Noraiakheda (Panki) neighborhood of
Kanpur.9 The selection rationale for locating the pilot study on the Skolast parcel is as follows:•

While the parcel was secure from unauthorized vehicular and pedestrian traffic, it was
readily accessible to the Project Team for the pilot study and includes a roofed storage
area where equipment/supplies could be temporally stored to facilitate logistics.
In addition, the property operator approved access for the purpose of performing
the study;

8

While contaminants other than Cr (VI) may also be present within the Study Area, Cr (VI) was the primarycontaminant of concern focused on by the Remedial Pilot Study because of its ubiquitous presence at moderate torelatively high concentrations that pose risk to potential sensitive receptors.
9
Street address: M/s Skolast (I) Pvt. Ltd., E-19, Panki Industrial Area, Site-I, Dadanagar, Panki, Kanpur,
Uttar Pradesh, India.

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 6•The highest reported detected concentration of Cr (VI) in overburden groundwater for the
Study Area (10.6 mg/L) was for a groundwater sample collected from the Skolast
piezometer, suggesting the Skolast parcel to be in the general vicinity of a Cr (VI) source
area, such that Remedial Pilot Study results would be conservative;10•

According to the boring log for the Skolast piezometer provided by CPCB-Lucknow, thewell screen intersects sand lenses, interlayered between clay and/or clayey caliche, at a
depth interval consistent with sand lenses reportedly encountered at comparable depth
intervals in other parts of the Study Area, therefore, subsurface conditions for the Skolast
property are likely representative;•

According to CPCB-Lucknow, the sand lenses screened by the Skolast piezometer havemoderately high horizontal hydraulic conductivity, with relatively slow seepage
velocities. Therefore, the formation would likely support batch electron donor delivery
based on our experience with hundreds of in-situ remedial pilot studies; and•Of ten well locations in the Study Area where Cr (VI) has been detected above analyticalreporting limits (RLs),11 groundwater sampling results for nitrate and sulfate reflect thethird highest detected concentration for each anion (i.e., about 6.2 mg/L nitrate versus anarithmetic mean concentration of 5.8 mg/L for those ten wells; and about 123 mg/L
sulfate versus an arithmetic mean concentration of 111 mg/L), such that Remedial Pilot
Study results are conservative. Therefore, if the in-situ bioremediation approach iseffective in an area of high terminal electron acceptor (TEA) concentration, then it would
likely be as or more effective in areas of lower concentration given TEAs can potentiallyinterfere with biotic as well as abiotic transformation mechanisms for Cr (VI).

Based on these collective factors, the Project Team selected the Skolast parcel at which to carryout the pilot study.
The electron donor remedial additive selected for the Remedial Pilot Study was Electron Donor
Compound – Metal (EDC-M), which is manufactured by ECJ and was provided pro bono for thispilot study. EDC-M is a food-grade remedial additive formulated to stimulate the transformationof Cr (VI) to Cr (III). EDC-M was selected for use during the pilot study based on its reportedly
successful track record in Japan for metals remediation as well as the cost effectiveness ofremedial biotechnology in contrast to other treatment technologies.
The Remedial Pilot Study included EDC-M injection into overburden wells to stimulate Cr (VI)transformation to Cr (III), and groundwater monitoring of the injection/monitoring wells toevaluate bioremediation performance. The pilot study was carried out by the Project Team ingeneral accordance with GZA’s December 5, 2006 proposal to Blacksmith entitled “Proposal for
Remedial Pilot Study Services (Remedial Pilot Study), Kanpur Chromium Contamination Area,
Kanpur, India,” with the following notable exceptions:•

Well yield was determined to be too low to practically support the conceptual design,
which assumed batch remedial additive injection into a single well. To compensate forthe low well yield, which could have added a week or more to the injection schedule, the10i.e., if the Remedial Pilot Study is effective in the general vicinity of this “hot spot”, then it would likely beeffective in areas of lower Cr (VI) concentrations.
11
Refer to “Groundwater Quality in Noraiakheda Area, Panki, Kanpur (Period January – March 2005),
available at CPCB-Lucknow.

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December 13, 2006
Page 7

Project Team revised the injection strategy from batch delivery to one well to recirculateddelivery12 to two upgradient wells, such that the injection could be completed within theplanned project schedule; and•

CPCB-Lucknow performed six groundwater sampling rounds (i.e., one baseline andfive post-injection rounds) instead of four rounds (i.e., one baseline andthree post-injection rounds) to provide increased validation of Remedial Pilot
Study results.

Remedial Pilot Study details are briefly summarized below.
Program Preparation
The Project Team coordinated Study Area access, scheduling, and logistical preparation inadvance of the field work, and carried out a drilling program to establish a pilot study well field.
The well field included the following four new wells as well as the existing Skolast piezometer:•

Injection Well (IW);•Sidegradient Monitoring Well (SMW);•

Downgradient Well No. 1 (DW-1); and•Downgradient Well No. 2 (DW-2).

Refer to the attached Well Field Exploration Location Plan, prepared by CPCB-Lucknow,
depicting well locations at the Skolast parcel relative to the general direction of overburden
groundwater flow in the Study Area.
The drilling program was designed by GZA, in collaboration with CPCB-Lucknow, following theTask 1 review of available hydrogeologic data for the Study Area. Blacksmith retained
M/s Drinking Water Organisation of Lucknow, Uttar Pradesh, India to carry out the drilling
program consistent with the Project Team’s conceptual design. The drilling program was carriedout using water rotary drilling techniques to advance each borehole to its termination depth ofabout 47.2 meters below ground surface (bgs) from January 24, 2006 to February 3, 2006, andwas observed by CPCB-Lucknow and GZA. Please refer to the attached Boring Logs, preparedby CPCB-Lucknow, for drilling program details.
Baseline Monitoring
The baseline monitoring program was designed by GZA in consultation with ECI and carried out
by CPCB-Lucknow, which included pre-injection sampling of the well field to establish baseline
conditions for the pilot study from which to evaluate bioremediation performance.
Baseline monitoring parameters included the following metals and indicator parameters:13

12

i.e., extracting groundwater from a downgradient location, amending it with remedial additive, andsimultaneously injecting it at an upgradient location.
13
While methane was a requested analyte, it was not within the capability of the analytical laboratory.

The Blacksmith InstituteFile No. 04.0023171.06 C••

December 13, 2006
Page 8

Metals:−Total chromium (Total Cr)−

Dissolved nickel−

Cr (VI)−

Dissolved copper−

Dissolved arsenic−

Dissolved cobalt−

Dissolved zinc−

Dissolved iron−Dissolved mercury−

Dissolved manganese

Indicator Parameters:−

Dissolved oxygen (DO)−

Nitrate−Redox potential (Eh)−Sulfate−pH−

Sulfide−Total organic carbon (TOC)−

MethaneBaseline groundwater quality sampling was performed using a modified low-flow samplingtechnique. Baseline results are summarized in the attached Data Summary Table, and theanalytical laboratory reports are on file at CPCB-Lucknow.
In addition to the collection of groundwater quality samples, CPCB-Lucknow carried out anelevation level survey of the well field, including baseline static groundwater levels, to tie thewell field into the existing well network in the Study Area.
Remedial Additive Injection
The injection program was designed by GZA, in collaboration with ECI, and carried out by GZA
and CPCB-Lucknow using a recirculation approach. The program included the following:•

Construction of the following recirculation system occurred on February 7 and 8, 2006:−

A 3,000-Liter capacity storage tank with a control valve at the bottom for
temporary storage and injection of EDC-M-amended groundwater into the IW
and SMW,−A mixing tub for blending remedial additive into groundwater,−

Two centrifugal pumps, with associated hosing/fittings, connecting the storagetank and mixing tub14 to agitate remedial additive-amended groundwater andfacilitate mixing,−

A submersible pump for extracting groundwater from DW-2 and pumping it to
the storage tank,−

Plastic pipe recirculation manifold system connecting the groundwater extraction
well (DW-2) with the storage tank to fill the tank, and the storage tank with the
IW (and later the SMW) for injecting EDC-M-amended groundwater, and−Please find below a Remedial Pilot Study Process Diagram conceptually
depicting the layout of the recirculation system components:

14
i.e., one pumping from the storage tank to the mixing tub and the other from the tub to the tank to facilitate
remedial additive dissolution.

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December 13, 2006
Page 9Storage Tank

Centrifugal Pump

Valve

Mixing Tub

IW

SMW

Submersible Pump

Remedial Pilot Study Process Diagram(Not to Scale)
DW-2•

Once assembled, the recirculation system was initially operated without remedial additive
amendment for about three hours on February 9, 2006 to evaluate system components
under steady state recirculation conditions in preparation for the electron donor
injection.15 Initially, the system achieved a recirculation rate of up to about 4 to 8 liters
per minute (LPM) by injecting only into the IW. To increase the recirculation rate,
GZA and CPCB-Lucknow adjusted the pumping configuration and split injection flow
between the IW and the SMW, which ultimately achieved a recirculation rate up to about
22 LPM under steady state conditions, or about 11 LPM per well;•Once steady state conditions were achieved, remedial additive was blended into
groundwater extracted from DW-2 using two counter-circulating centrifugal pumps
connecting the mixing tub and storage tank to agitate the mixture and facilitate EDC-M
dissolution; and•Remedial additive injection into the IW and SMW was carried out for about 43.5 hours at
a flow rate of between about 4 to 21 LPM (mean of about 15 LPM), for a total injection
load of about 540 kilograms of EDC-M dissolved in about 40,000 liters of recirculated
groundwater. Note that EDC-M is formulated with two components, EDC-M1 and
EDC-M2, each of which is packaged separately and injected sequentially (i.e., EDC-M1
before EDC-M2). For the pilot study injection, about 210 kilograms of EDC-M1 were
injected first, diluted in about 12,000 liters of recirculated groundwater, followed byabout 330 kilograms of EDC-M2, diluted in about 28,000 liters of groundwater, inconsideration of ECI’s recommendations.

Performance Monitoring
GZA developed the performance monitoring program in collaboration with CPCB-Lucknow, and
CPCB-Lucknow carried it out. Performance monitoring included five rounds of post-injection
groundwater sampling of the well field on February 9, 2006, February 24, 2006, April 10, 2006,
April 28, 2006, and May 26, 2006. Post-injection sampling was reportedly performed at the same
well locations and for the same parameters as baseline sampling (see the Baseline Monitoring

15
i.e., constant flow rate and no significant changes in hydraulic head for either the extraction well or the
injection well(s) over the period of interest.

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December 13, 2006
Page 10section above), and was reportedly carried out also using a modified low flow samplingtechnique. Post-injection groundwater sampling results are summarized in the attached Data
Summary Table, and the analytical laboratory reports are on file at CPCB-Lucknow.
Data Analysis and Report Preparation
GZA reviewed and analyzed Remedial Pilot Study performance data, in collaboration with
CPCB-Lucknow, and prepared this letter report summarizing pilot study methods, results, andconclusions, and providing remedial recommendations to advance the Study Area toward closure
based on those results. Please refer to GZA’s December 5, 2006 proposal for additional
information on Remedial Pilot Study methods.
RESULTS AND DISCUSSION
Results of Tasks 1 (Background Data Review) and 2 (Remedial Pilot Study Implementation andReporting) are included in this section of the letter report, which includes a Preliminary CSM
developed by the Project Team and a summary and discussion of pilot study results.
PRELIMINARY CONCEPTUAL SITE MODEL
Based on our review of the information obtained during Task 1 as well the attached Boring Logs
for the four new pilot study wells, the geology of the Study Area includes up to about 500 metersof alluvial-fluvial-derived unconsolidated sediments of Quaternary age, which is underlain by
granitic bedrock likely of the Bundelkhand complex. The overburden hydrostratigraphy within
the Study Area includes two notable groundwater flow systems, each of which can be classified
as overburden aquifers given each system is used for water supply:•

A deep regional flow system occurring in stratified sand at a depth greater than about
300 meters bgs; and•Local/intermediate flow systems occurring in sand lenses at shallower depth intervals.

The regional flow system within the deep overburden is hydraulically confined and characterized
by an approximately 100-meter-thick laterally continuous and generally transmissive stratified
sand unit overlying granitic bedrock likely of the Archaean-age Bundelkhand complex.16
The regional flow system occurs at a depth of about 300 to 500 meters bgs. The subordinate local
and intermediate flow systems in the shallow overburden are generally at least partially
hydraulically confined and characterized, at least at the scale of the pilot study, by relatively
continuous transmissive sand lenses, interlayered clay and/or clayey caliche, to a depth of up to
about 300 meters bgs. Based on our understanding of the regional hydrogeologic conditions forthe overburden groundwater system, GZA believes that the vertical hydraulic gradient in thegeneral Study Area vicinity to be downward, consistent with groundwater recharge conditions.
GZA notes that the hydrostratigraphy encountered via the four new pilot study wells as well as
the existing Skolast piezometer is consistent with a local or intermediate groundwater flow
system (refer to the attached Boring Logs prepared by CPCB-Lucknow). Water supply wells are
installed in both the shallow local/intermediate groundwater flow systems serving residential or16

For additional information, please refer to Ganga Action Plan Support Project’s “Kanpur Ganga, Ganga
Action Plan Support Project- Kanpur, Project Planning And Coordination Unit” web page entitled “Other Important
Projects” (Uniform Resource Locator: http://www.kanpurganga.com/other_important_projects.htm).

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Page 11

small community users and the deep regional flow system serving industrial, municipal, or large
community users in the Study Area, and both present potential sensitive receptors owing to thecurrent Cr (VI) condition in shallow overburden groundwater.
With respect to Cr (VI) contamination in Study Area overburden groundwater, the highest
detected concentrations are typically for samples collected from the local and intermediate
groundwater flow systems in the shallow overburden at depths ranging from about 20 to
50 meters bgs. While the deep regional groundwater flow system has reportedly not yet been
impacted by Cr (VI) contamination from the shallow local and intermediate flow systems, there is
the potential for downward advection of Cr (VI), driven by downward vertical hydraulicgradients, to deleteriously impact groundwater quality of the deep flow system. Therefore, it isimperative that Cr (VI) contamination in the shallow groundwater flow systems be addressed
before it impacts the deep flow system, notwithstanding the current unacceptable risk Cr (VI)poses to potential sensitive receptors of shallow overburden groundwater in the Study Area.
PERFORMANCE DATA
Baseline and post-injection performance monitoring results for the Remedial Pilot Study aresummarized in the attached Data Summary Table. Observations regarding these performancedata are summarized below.
Cr (VI) Data
As shown on the Data Summary Table, baseline Cr (VI) concentrations ranged from 8.16 mg/L to
12.55 mg/L (arithmetic mean: 10.74 mg/L)17 for groundwater samples collected from all
five wells, whereas post-injection concentrations for the same well locations ranged from
non-detectable above the analytical RL of 0.03 mg/L to 4.17 mg/L (geometric mean: 0.71 mg/L)
over the pilot study duration, which is consistent with an overall 93 percent reduction (%Reduction)
in Cr (VI) concentration. The magnitude of the overall %Reduction is consistent with thebiochemical transformation of Cr (VI) to Cr (III), driven by electron donor amendment.
Post-injection Cr (VI) results are summarized below on a round-specific basis:•

For the first post-injection sampling round, detected Cr (VI) concentrations ranged from
0.23 to 4.17 mg/L, reflecting an up to two orders of magnitude decrease in Cr (VI)concentrations within about two weeks of the injection program;•

For the second post-injection round, Cr (VI) concentrations ranged from non-detectable
above analytical RLs to 0.32 mg/L Cr (VI), reflecting an up to three orders of magnitudedecrease in Cr (VI) concentrations within about four weeks of the injection program;•

For the third post-injection sampling round, Cr (VI) concentrations were non-detectable
above analytical RLs, reflecting a three orders of magnitude decrease in Cr (VI)concentrations within about ten weeks of the injection program;•

For the fourth post-injection sampling round, Cr (VI) concentrations were non-detectable
above analytical RLs, reflecting a three orders of magnitude decrease in Cr (VI)concentrations within about 13 weeks of the injection program; and17
GZA’s statistical approach for estimating means herein as well as percent reductions assumes a value of
0.01 mg/L Cr (VI) for managing non detects above the analytical RL of 0.03 mg/L. Also note that means, referenced
herein, generally refer to arithmetic mean measurements of central tendency when data vary by less than about an orderof magnitude, or geometric mean measurements when data vary by more than an order of magnitude.

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December 13, 2006
Page 12For the fifth post-injection round, Cr (VI) concentrations ranged from non-detectable
above analytical RLs to 0.67 mg/L Cr (VI), reflecting an up to three orders of magnitudedecrease in Cr (VI) concentrations within about 17 weeks of the injection program.

GZA notes the following Cr (VI) concentration trends for baseline and post-injection
performance monitoring results on a well-specific basis:•

IW: The baseline concentration was 10.01 mg/L, whereas the three rounds ofpost-injection monitoring did not detect Cr (VI) above analytical RLs, reflecting a
99.9 %Reduction in Cr (VI) concentration for this well location over the pilot study duration.
The following is a semi-log plot of the performance monitoring Cr (VI) concentration
versus time data for the IW: (Note: Our plotting approach for handling non detects above
analytical RLs conservatively assumed a Cr (VI) concentration of 0.01 mg/L Cr (VI) for
the non detect.)[Cr (VI)] Versus Tim e, IW
100[Cr (VI)] Versus Time, IWInjectio n P ro gram

Concentration (mg/L)

100

10

Injection Program

10

1
1

0.1
0.1

0.01
Jan-06
Feb-06 Mar-06
Apr-06
May-060.01
Jan-06
Feb-06TimeM(M,Yr)
ar-06
Apr-06

Jun-06

M ay-06

Jun-06

T i me ( M ,Y r )As shown on this semi-log plot, there was a three order of magnitude decrease in Cr (VI)concentration within about ten weeks of the pilot study injection resulting inthree consecutive rounds of non detect Cr (VI) for the remainder of the pilot study
duration, which GZA directly attributes to electron donor amendment;•

SMW: The baseline concentration was 8.16 mg/L, whereas the first round of
post-injection monitoring detected Cr (VI) at 0.56 mg/L and the last three rounds did notdetect Cr (VI) above analytical RLs, reflecting a 93.1 %Reduction to 99.9 %Reduction in Cr (VI)concentration for this well location over the pilot study duration. The following is asemi-log plot of the performance monitoring Cr (VI) concentration versus time data for
the SMW: (Note: Our plotting approach for handling non detects above analytical RLs
conservatively assumed a Cr (VI) concentration of 0.01 mg/L Cr (VI) for the non detect.)The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 13[Cr(VI)] Versus Tim e, SMW

Concentration (mg/L)

10

Injectio n P ro gram

1

0.1

0.01
Jan06

Feb06

Mar06

Apr06

May06

Jun06

Tim e (M,Yr)

As shown on this plot, there was an order of magnitude decrease in Cr (VI) concentration
within about four weeks of the pilot study injection, and then about a two order ofmagnitude decrease resulting in three consecutive rounds of non detect Cr (VI) for theremainder of the pilot study, which GZA directly attributes to electron donor amendment;
DW-1: The baseline concentration was 11.2 mg/L, whereas the first round of
post-injection monitoring detected Cr (VI) at 0.34 mg/L, the second post-injection rounddetected Cr (VI) at 0.06 mg/L, and the last three rounds did not detect Cr (VI) above
analytical RLs, reflecting a 97.0 %Reduction to 99.9 %Reduction in Cr (VI) concentration forthis well location over the pilot study duration. The following is a semi-log plot of theperformance monitoring Cr (VI) concentration versus time data for DW-1: (Note: Our
plotting approach for handling non detects above analytical RLs conservatively assumed
a Cr (VI) concentration of 0.01 mg/L Cr (VI) for the non detect.)[Cr(VI)] Versus Tim e, DW1
100

Concentration (mg/L)•

10

Injectio n P ro gram
1

0.1

0.01
Jan-06

Feb-06

M ar-06

Apr-06

M ay-06

Jun-06

T i me ( M , Y r )As shown on this semi-log plot, there was a two order of magnitude decrease in Cr (VI)concentration within about four weeks of the pilot study injection, and then about anorder of magnitude decrease resulting in three consecutive rounds of non detect Cr (VI)The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 14for the remainder of the pilot study, which GZA directly attributes to electron donor
amendment;•

DW-2: The baseline concentration was 12.55 mg/L, whereas the first round of
post-injection monitoring detected Cr (VI) at 0.23 mg/L, the next three rounds not detect
Cr (VI) above analytical RLs, and the last round detected Cr (VI) at 0.67 mg/L, reflecting
a 94.7 %Reduction to 99.9 %Reduction in Cr (VI) concentration for this well location over thepilot study duration. The following is a semi-log plot of the performance monitoring
Cr (VI) concentration versus time data for DW-2: (Note: Our plotting approach forhandling non detects above analytical RLs conservatively assumed a Cr (VI)concentration of 0.01 mg/L Cr (VI) for the non detect.)[Cr(VI)] Versus Tim e, DW2
100

Concentration (mg/L)

Injectio n P ro gram
10

1

0.1

0.01
Jan-06

Feb- 06

Mar- 06

Apr -06

May-06Jun- 06

T i m e ( M , Yr )As shown on this semi-log plot, there was a nearly two order of magnitude decrease in
Cr (VI) concentration within about two weeks of the pilot study injection, and then about
an order of magnitude decrease resulting in two consecutive rounds of non detect Cr (VI),which GZA attributes to electron donor amendment. For the fifth post-injection samplinground (week 17), GZA observed nearly a two order of magnitude increase in Cr (VI)concentration to 0.67 mg/L that is graphically overstated by the semi-log plotting method.
GZA attributes this apparent rebound to either analytical variability or Cr (VI) advection
to the DW-2 location, and not to chemical oxidation of Cr (III) to Cr (VI) given there wasno significant (order of magnitude or greater) increase in total Cr concentration18 at thiswell location that would be consistent with that transformation pathway; and•Skolast piezometer: The baseline concentration was 11.8 mg/L, whereas the first round of
post-injection monitoring detected Cr (VI) at 4.17 mg/L, the second post-injection rounddetected it at 0.32 mg/L, and the last three rounds did not detect Cr (VI) above analytical
RLs, reflecting a 64.7 %Reduction to 99.9 %Reduction in Cr (VI) concentration for this welllocation over the pilot study duration. The following is a semi-log plot of theperformance monitoring Cr (VI) concentration versus time data for the Skolast
piezometer: (Note: Our plotting approach for handling non detects above analytical RLs
conservatively assumed a Cr (VI) concentration of 0.01 mg/L Cr (VI) for the non detect.)18

letter report.

Refer to the attached semi log plot of Total Cr. Versus time included in the “Total Cr Data” section of thisThe Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 15[Cr(VI)] Versus Tim e, Skolast Piezom eter

Concentration (mg/L)

100
10Injectio n P ro gram

1
0.1
0.01
Jan-06 Feb-06 Mar-06 Apr-06 May-06 Jun-06
Tim e (M,Yr)

As shown on this semi-log plot, there was a two order of magnitude decrease in Cr (VI)concentration within about four weeks of the injection, and then about an order ofmagnitude decrease resulting in three consecutive rounds of non detect for the remainderof the pilot study duration, which GZA directly attributes to electron donor injection.
CPCB-Lucknow also prepared the attached Baseline Hexavalent Chromium Isoconcentration
Plan and five Post-Injection Hexavalent Chromium Isoconcentration Plans corresponding withthe five rounds of post-injection monitoring. As shown on the Baseline Hexavalent Chromium
Isoconcentration Plan, the highest Cr (VI) concentration was near DW-2, and four of the fivedetected baseline Cr (VI) concentrations19 were on the same order of magnitude.
The Post-Injection Hexavalent Chromium Isoconcentration Plans reflect the sequential
reduction20 in Cr (VI) concentration resulting from the pilot study injection. The final
Post-Injection Hexavalent Chromium Isoconcentration Plan, reflecting Cr (VI) concentrations
106 days following the pilot study injection, reflects a rebound in the Cr (VI) concentration for
the groundwater sample collected from DW-2, the well with the highest baseline Cr (VI)concentration. GZA’s explanation for the apparent rebound was discussed previously.
The Remedial Pilot Study performance monitoring data collectively demonstrated broad
reductions in Cr (VI) concentrations over the study duration, which GZA directly attributes toelectron donor amendment. Significantly, Cr (VI) concentrations for the entire well field
decreased below the target remedial goal of 0.05 mg/L21 for all post-injection groundwater
samples collected from the well field within about ten weeks of the injection program. With
respect to the apparent rebound in Cr (VI) concentration at DW-2 observed at week 17 following
the pilot study injection, the rebound seems anomalous based on the fact that results forgroundwater samples collected for all other wells from the second post-injection sampling roundforward did non detect Cr (VI) above analytical RLs. Overall, the Cr (VI) performancemonitoring results are clearly consistent with enhanced bioremediation, driven by electron donor
injection within the Study Area, consistent the Remedial Pilot Study technical approach.

19

i.e., DW-2, IW, DW-1, and Skolast piezometeri.e., from 7 to 78 days following completion of electron donor amendment.
21i.e., the Indian Standard for Drinking Water Quality for Cr (VI).
20

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 16

With respect to the potential re-oxidation of Cr (III) to Cr (VI), once injected electron donor has
become depleted, the biochemical reduction of Cr (VI), as discussed previously, primarily yields
amorphous precipitates with chromium as Cr (III). Such precipitates are generally stable at awide range of pH22 and Eh23 values spanning the typical ranges of these parameters withinoverburden groundwater. For example,••

The pH of baseline groundwater samples collected from the pilot study well field ranged
from about 6.7 to 7.0 standard units (Data Summary Table) and the pH for samples
collected from the general site vicinity range from about six to eight (Site Hydrogeologic
Information, Baseline Chemical Parameters [Groundwater]). GZA notes that themeasured pH values for these samples were within the stability range of 6 to 12 standard
units, which is consistent with Cr (III) stability and not geochemical reversal to Cr (VI).
Hence, the ambient pH condition of overburden groundwater in the Study Area appears
conducive to Cr (III) stability following Cr (VI) transformation; andThe Eh of baseline samples collected from pilot study wells ranged from about +105 mV
to +118 mV (Data Summary Table) and the Eh for samples collected from the generalsite vicinity range from about +100 mV to +120 mV (Site Hydrogeologic Information,
Baseline Chemical Parameters [Groundwater]). GZA notes that the measured Eh values
for these samples were well within the stability range of -700 to +600 mV, which is also
consistent with Cr (III) stability. Hence, the ambient Eh condition of overburden
groundwater in the Study Area appears conducive to Cr (III) stability following Cr (VI)transformation.

Therefore, based on the pH and Eh data for overburden groundwater in the general Study Area,
once Cr (VI) has been biochemically reduced to Cr (III), the reaction is generally irreversible.
Total Cr Data
As shown on the Data Summary Table, baseline Total Cr concentrations ranged from 12.88 to
19.49 mg/L (arithmetic mean: 15.80 mg/L)24 for groundwater samples collected from all
five wells, whereas post-injection concentrations for the same well locations ranged from0.08 mg/L to 10.66 mg/L (geometric mean: 1.21 mg/L), which is consistent with an overall
92%Reduction in the Total Cr concentration. The magnitude of this overall %Reduction is ostensibly thesame as the overall reduction observed for Cr (VI), and is consistent with the biochemicaltransformation of more mobile Cr (VI) to immobile Cr (III), driven by electron donor injection.
Total Cr results on a round-specific basis are summarized as follows for the five rounds ofpost-injection monitoring:•

For the first post-injection sampling round, detected Total Cr concentrations ranged from9.09 to 10.66 mg/L (arithmetic mean: 9.97 mg/L), reflecting a 37 percent (%) decrease inmean Total Cr concentrations within about two weeks of the injection program;•

For the second post-injection sampling round, Total Cr concentrations ranged from
0.46 to 7.79 mg/L Total Cr (geometric mean: 2.02 mg/L), reflecting an 87% decrease in
Total Cr concentrations within about four weeks of the injection program;
22

i.e., 6 to 12 standard units.
i.e., -0.7 to + 0.6 volts (-700 to +600 mV).
24
Our statistical approach for estimating means as well as or percent reductions assumes a value of 0.01
mg/L Cr (VI) for managing non detects above the analytical RL of 0.03 mg/L.
23

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 18[ T o t a l C r] V e rs us T im e , S k o la s t P ie zo m e t e r

100
Concentration (mg/L)

Injectio n P ro gram

10

1

0.1
Jan-06 Feb-06 Mar-06 Apr-06 May-06 Jun-06
Tim e (M,Yr)

As shown on these semi-log Total Cr versus time plots, there was an up to two orders ofmagnitude reduction in the Total Cr concentration with time for all five well locations during thepilot study duration, which is consistent with the biochemical transformation of aqueous soluble
Cr (VI) to the aqueous insoluble Cr (III), driven by electron donor amendment, consistent theRemedial Pilot Study technical approach.
Indicator Parameter Data
Biological transformation Indicator Parameters
The following table summarizes the statistical data including the value range, mean,25 andpercent change (%Change)26 for the biological transformation indicator parameters DO, Eh, sulfate,nitrate, iron, manganese, and TOC, which are generally the primary factors that control thebiologically-mediated transformation of Cr (VI) to Cr (III):SAMPLING
ROUND
DO, mg/L
Baseline
12
3
45
Eh, mV
Baseline
1
2
3
4
5

25

MINIMUM VALUEMAXIMUM VALUE

MEAN%Change

3.2
3.4
0.9
0.8
1.2
0.8

4.9
3.8
3.0
1.7
1.8
1.5

4.3
3.6
2.3
1.0
1.4
1.2

--16
-47
-77
-67
-72

+105
-18
-93
-140
-394
-234

+118
-12
-13
-36
-88
-1

+111
-15
-41
-72
-190
-55

--114
-137
-165
-271
-150

Mean refers to arithmetic or geometric mean, as appropriate, for the respective value relative to baseline.
%Change refers to the percent difference between the mean value and its respective baseline mean value forthe same parameter.
26

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 19

SAMPLINGMINIMUM VALUEMAXIMUM VALUE
MEAN
ROUND
Sulfate, mg/L
Baseline
139
394
260
1
183
352
291
2
140
270
205
3
35.18
95.33
68
4
28.94
148.88
77
5
55
161
89
Nitrate, mg/L
Baseline
2.2
9.79
5.2
1
1.46
6.09
3.2
2
1.05
1.73
1.4
3
0.52
1.4
1.0
4
0.25
1.73
0.9
5
0.23
2.15
1.0
Dissolved Iron, mg/L
Baseline
0.17
5.2
1.3
1
16.82
37.13
27.4
2
4.7
351.65
35.2
3
6.7
100.6
23.3
4
5.99
54.27
19.0
5
4.03
27.12
11.4
Dissolved Manganese, mg/L
Baseline
0.03
0.3
0.1
1
2.42
11.76
7.7
2
1.68
71.0
19.7
3
2.63
15.08
7.2
4
1.71
4.91
3.4
5
0.74
2.51
1.7
TOC, mg/L
Baseline
34.46
52.14
44.4
1
38.21
51.35
45.6
2
34.22
51.64
44.3
3
208.16446.84
302.6
4
30.38
128.37
66.0
5
39.23
98.3
69.7
Note: Sampling Round Nos. 1 through 5 refer to the five post-injection sampling rounds.

%Change
-+12
-21
-74
-70
-66
--39
-73
-81
-83
-81
-+2,008+2,608+1,692+1,362+777-+7,600+19,600+7,100+3,300+1,600
-2.7
-0.2
+582
+49
+57

As tabulated above, the indicator parameters DO (up to 77% reduction), Eh (up to271% reduction), sulfate (up to 74% reduction), and nitrate (up to 83% reduction) each exhibiteda decreasing trend with time, relative to baseline conditions, over the pilot study duration.
This trend of decreasing DO, Eh, sulfate, and nitrate values with time is directly consistent withthe development of anaerobic, chemically reducing conditions stimulated by electron donor
amendment. The reduction in DO, sulfate, and nitrate concentrations are consistent with themicrobial metabolic processes of aerobic mineralization, sulfate reduction, and nitrate reduction,
respectively. The reduction in Eh values with time is consistent with the development ofchemically reducing conditions owing to electron donor amendment perturbing the groundwater
system by scavenging TEAs such as DO, nitrate, oxidized metals, and sulfate.
The indicator parameters dissolved iron, dissolved manganese, and TOC exhibited a generally
increasing trend over the pilot study duration consistent with the typical response of groundwater
systems to electron donor amendment. With respect to these metals, the increased dissolved ironconcentration is consistent with the enhanced biochemical reduction of insoluble ferric iron (III)to soluble ferrous iron (II), mediated by iron-reducing bacteria. The increased dissolved
manganese concentration is consistent with the enhanced biochemical reduction of insolubleThe Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 20

manganese (IV) to soluble manganese (II), mediated by manganese-reducing bacteria. In the caseof both iron and manganese oxide reduction, transformation was stimulated by electron donor
amendment, which provided the organic carbon driving biochemical reduction. GZA notes thatliberated ferrous iron (II) and manganese (II) are expected to be respectively oxidized to ferriciron (III) and manganese (IV), and then re-sorbed onto the formation matrix once they migrate
beyond the anaerobic, chemically reducing treatment zone affected by electron donor amendment
into the initially aerobic, chemically oxidizing reaches of the shallow overburden groundwater
system. These oxidation reactions are expected to be nearly instantaneous at the temporal/spatial
scale of interest.
With respect to TOC, the increased concentration is consistent with EDC-M amendment, as TOC
is a suitable surrogate measurement. GZA notes that TOC concentrations did not generally begin
to increase until about week 10, at which time there was an order of magnitude spiked increase inconcentration for the groundwater samples collected at all locations of the well field.
CPCB-Lucknow also prepared the attached Baseline Total Organic Carbon Isoconcentration Plan
and five Post-Injection Total Organic Carbon Isoconcentration Plans corresponding with thefive rounds of post-injection monitoring. As shown on the Baseline Total Organic Carbon
Isoconcentration Plan, the highest baseline TOC concentration was located in the vicinity of
SMW, and the detected TOC concentrations were on the same order of magnitude.
The Post-Injection Total Organic Carbon Isoconcentration Plans reflect the general increase in
TOC concentrations resulting from the pilot study injection. The latter Post-Injection Hexavalent
Chromium Isoconcentration Plan set suggests that the recirculation delivery approach was
effective in propagating electron donor throughout the desired treatment area.
The indicator parameter, sulfide, was also analyzed as part of performance monitoring.
Sulfide was not detected above analytical RLs during baseline groundwater sampling; however, it
was detected at concentrations ranging from 0.5 mg/L (February 24, 2006; DW-2) to 34.2
(April 28, 2006; IW) during post-injection sampling. The increased sulfide concentration withtime, in response to electron donor amendment, represents a secondary line of evidence that
sulfate reduction was stimulated by electron donor amendment, and is consistent with thegenerally depressed sulfate concentrations, in response to the pilot study injection, as
discussed above.
Collectively, these indicator parameters are generally consistent with conditions conducive for the
microbially-mediated transformation of Cr (VI) to Cr (III), driven by electron donor amendment
during the pilot study.
In addition to the biological transformation indicator parameters, GZA offers the following
observations regarding the general water quality indicator parameters ph and specificconductivity for groundwater samples collected from the pilot study well field:•

pH values, in standard units, for baseline groundwater samples ranged from about
6.7 (IW) to 7.0 (DW-1 and DW-2), whereas values for post-injection samples ranged
from about 4.6 (February 24, 2006; IW) to 7.5 (April 28, 2006; Skolast piezometer).
Post-injection values for groundwater samples collected from the IW, SMW, DW-1, andDW-2 were typically lower than the baseline values approaching neutrality for thesesame locations, likely reflecting organic acid fermentation products of the remedialadditive as well as biogenic production of carbon dioxide from remedial additivemineralization to yield carbonic acid. Despite the general post-injection decrease in pH
for the groundwater samples collected from these wells, the values generally remained

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 21

within the pH range considered conducive for microbial activity and did not appear to
become inhibiting. Importantly, GZA understands that subsurface soils in the
Site Vicinity contain significant bulk fraction of calcium carbonate, which serves as anatural buffering agent to maintain pH near baseline values. The baseline pH value forthe groundwater sample collected from the Skolast piezometer was generally similar tothe post-injection pH values for the same well, likely reflecting its respective location
within the well field (i.e., the most downgradient well); and•Specific conductivity values for baseline groundwater samples ranged from about865 (IW) to 1,450 (Skolast piezometer) microsiemens per centimeter (us/cm), whereas
values for post-injection samples ranged from about 962 (May 26, 2006; SMW) to
10,160 (February 24, 2006; IW) us/cm. Post-injection specific conductivity values forgroundwater samples collected from the IW, SMW, DW-1, and DW-2 were typicallylower than baseline values, likely reflecting the total dissolved solid contribution to
groundwater from remedial additive amendment. The baseline specific conductivity
value for the groundwater sample collected from the Skolast piezometer was generally
similar to the post-injection specific conductivity values for the same well, likely
reflecting the piezometer’s respective location within the well field (i.e., the mostdowngradient location).

Other Metals Data
GZA offers the following observations regarding the analytical laboratory results for nickel,
copper, cobalt, zinc, mercury, and arsenic:•

Nickel was generally detected during baseline sampling and up to the first two rounds ofpost-injection sampling at concentrations exceeding analytical RLs; however, it was
generally not detected above analytical RLs for the last three rounds of post-injection
sampling.
According to CPCB-Lucknow, there is currently no establishedIndian Standard for Drinking Water Quality for that metal;•

Baseline and post-injection groundwater sampling results detected copper at relatively
variable concentrations, with most detected concentrations exceeding the establishedIndian Standard for Drinking Water Quality of 0.05 mg/L for copper;•

Baseline groundwater sampling results did not detected cobalt above analytical RLs;
however, it was detected at concentrations exceeding analytical RLs during up to
two post-injection sampling rounds. According to CPCB-Lucknow, there is currently noestablished Indian Standard for Drinking Water Quality for that metal;•

Baseline and post-injection sampling results detected zinc at variable concentrations that
did not exceed the Indian Standard for Drinking Water Quality of 5.0 mg/L;•

Baseline groundwater sampling results did not detect mercury above analytical RLs;
however, mercury was detected at concentrations exceeding analytical RLs during up to
two post-injection sampling rounds, with all detected concentrations exceeding the IndianStandard for Drinking Water Quality of 0.001 mg/L for that metal. Significantly,
analytical results for the final two post-injections sampling rounds did not detect mercury
above respective analytical RLs; and•The baseline sampling result for arsenic were non detect above analytical RLs for all well
field locations; whereas post-injection results for the last two consecutive rounds ofmonitoring (i.e., April 28, 2006 and May 26, 2006) detected arsenic at concentrations
ranging from 0.04 mg/L (May 26, 2006; SMW) to 0.1 mg/L (April 28, 2006 andThe Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 22

May 26, 2006; Skolast piezometer and DW-1, respectively), suggesting that electron
donor amendment liberated arsenic either at or in excess of the Indian Standard for
Drinking Water Quality of 0.05 mg/L for that metal, but generally not by more an orderof magnitude. According to Brömssen (1999),27 based on a study of arsenic mobility inIndia and Bangledesh, the development of anaerobic conditions stimulates thebiochemical reduction of secondary ferric, aluminum, and/or manganese oxide coatings
on the formation matrix, thereby liberating adsorbed arsenic from those coatings.
However, the baseline overburden groundwater system is generally aerobic28 andchemically oxidizing29 and arsenic is readily adsorbed onto metal oxide coatings offormation matrices existing under such conditions. Therefore, the liberated arsenic is
expected to be re-sorbed onto the formation matrix once it migrates beyond the influenceof the anaerobic, chemically reducing treatment zone, affected by electron donor
amendment, into the aerobic, chemically oxidizing conditions of the overburden
groundwater system. Hence, GZA believes the elevated arsenic concentration associatedwith the pilot study injection program to be short lived and primarily constrained to thearea of influence of the anaerobic treatment program.
Groundwater Elevation Data
Baseline and Post-Injection Groundwater Elevation Contour Plans are attached. As shown in the
Baseline Groundwater Elevation Contour Plans, baseline groundwater flow was generally toward
the south to southwest, trending roughly parallel with the canal to the east. As shown in the
Post-Injection Groundwater Elevation Contour Plans, the groundwater flow net initially30
reflected a groundwater depression in the general vicinity of the extraction well (DW-2), owing togroundwater pumping during recirculation, followed by variable flow directions that ultimately31
resulted in a general flow reversal from the baseline direction of south to southwest, to the final
apparent post-injection direction of north to northeast. Groundwater flow nets, following
remedial injection programs, typically equilibrate to baseline conditions within a few weeks
based on our experience. Therefore, the baseline and post-injection groundwater elevation
contour plan sets are more consistent with conditions unrelated to the Remedial Pilot Study, suchas the pumping of nearby shallow wells to meet potable/process water demand, irrigation
associated with local agriculture, or variation in canal or other surface water stage.
PROPOSED CONCEPTUAL REMEDIAL APPROACH
Based on the positive results of the Remedial Pilot Study, GZA recommends a full-scale remedial
program to advance the Study Area toward closure. The remedial program would focus oncontaminant mass reduction in the identified Cr (VI) source areas directly impacting the local andintermediate groundwater flow systems. The remedial program would be focused on contaminantmass reduction in the identified source areas given that contaminant plumes, once source mass is27
Brömssen, M.V., 1999, Genesis of high arsenic groundwater in the Bengal Delta Plains, West-Bengal and
Bangladesh, in Thesis, Division of Land and Water Resources, Department of Civil and Environmental Engineering,
Royal Institute of Technology, Stockholm, Sweden, 49 p.
28
i.e., DO concentrations ranging from 3.2 to 4.9 mg/L (arithmetic mean of 4.3 mg/L) for baseline
groundwater samples collected from pilot study wells (refer to the “Biological transformation Indicator Parameters”
section of this letter report).
29
i.e., Eh values ranging from +105 to +118 mV (arithmetic mean of +111 mV) for baseline groundwater
samples collected from pilot study wells (refer to the “Biological transformation Indicator Parameters” section of thisletter report).
30
i.e., seven days following completion of the injection program.
31
i.e., 106 days following completion of the injection program

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 23

removed/treated, typically stop expanding and then begin to contract owing to the combined
affects of natural attenuation processes. Therefore, a source-area focused remedial program could
cost-effectively remove Cr (VI) contaminant mass in the Study Area.
The primary objective of the remedial program would be the reduction of risk posed by the
Cr (VI)-impacted shallow groundwater system to the following potential sensitive receptors:•

Residential or small community water supply wells installed in the shallow overburden
groundwater system used to supply potable water to local residents given the presence ofCr (VI) at concentrations exceeding the respective Indian Standard for Drinking Water
Quality of 0.05 mg/L Cr (VI); and•Industrial, municipal, or large community potable water supply wells installed in the
deeper, regional groundwater flow system. While water quality of the regional
groundwater flow system has reportedly not yet been impacted by the shallow Cr (VI)contaminant condition, the possibility exists for vertical migration of Cr (VI) from theshallow Cr (VI)-impacted unit to the deep regional flow system driven by the generally
downward hydraulic gradient, which could have a significant, deleterious impact uponthat natural resource.

Given that CPCB-Lucknow is performing a hydrogeologic investigation to further evaluate themagnitude and extent of overburden soil and groundwater contamination by Cr (VI) and othercontaminants in the Study Area, GZA requested that they develop the attached
Site Hydrogeologic Information and Study Area Baseline Chemical Parameter Ranges for Soil
information packages32 to establish the contaminant hydrogeologic assumptions upon which
GZA could base our Proposed Conceptual Remedial Approach to advance the Study Area
toward closure.
Based on review of the information provided by CPCB-Lucknow, the preliminary CSM for the
Study Area, and the positive results of the Remedial Pilot Study, GZA proposes carrying out afull-scale remedial program to protect potential sensitive receptors within the Study Area.
The remedial program would include the following four main tasks, each of which is expanded
upon below:•

Data Gap Investigation, which would refine the preliminary CSM and form the basis forthe remedial design;•

Preparation of a Remedial Action Plan (RAP), which would propose the final remedial
design based on the results of the Remedial Pilot Study and the Data Gap Investigation,
as well as the revised CSM;•

RAP Implementation, which would involve implementation of the remedial program
proposed in the RAP; and•Performance Monitoring, which would involve implementation of the performancemonitoring program proposed in the RAP.

32

Please note that both information packages were prepared by CPCB-Lucknow in consultation with GZA.

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 24DATA GAP INVESTIGATIONA Data Gap Investigation would be performed to finalize the preliminary CSM for the
Study Area. The investigation would focus on clarifying subsurface hydrogeologic andcontaminant conditions at potential Cr (VI) source areas in the Study Area as well as delineating
the spatial extent of overburden groundwater contamination. The Data Gap Investigation would
include the following:•

File reviews of pertinent historical records and interviews with certain officials having
knowledge of disposal practices of Cr (VI)-impacted waste in the Study Area.
GZA would also include remote sensing to help determine the spatial extent of identified
disposal areas depending on the availability of high and low altitude photographs,
infrared photographs, and other similar resources having coverage of areas of interest.
The focus of this work phase would be the identification of potential Cr (VI) source areasin the Study Area to help select drill target locations for supplemental soil/groundwater
quality sampling;•

Supplemental soil/groundwater quality sampling to better delineate the spatial extent ofcontamination, focusing on identified source areas based on drill target locations as wellas contingency targets identified during the file reviews, interviews, and remote sensing
work;

•

Supplemental hydraulic testing to obtain further design data for the RAP, which would
likely include the performance of hydraulic tests at up to about ten wells in the
Study Area to evaluate horizontal hydraulic conductivity under constant head pumping
conditions;•Level survey of newly installed wells to tie them into the existing well network; and•Update of the CSM of Cr (VI) fate and transport for the Study Area, and characterizationof the unacceptable risk chromium contamination may pose to potential sensitive
receptors.

Prior to start of the Data Gap Investigation, GZA would recommend development of a work plan
for approval by CPCB-Lucknow and stakeholders. The work plan would include the proposed
methods of the investigation, exploration locations, and an implementation schedule. The work
plan would include a Quality Assurance Project Plan (QAPP) describing the specific proceduresby which sampling and analytical procedures would be documented. QAPP activities would
include setting data quality objectives; establishing standard operating procedures; and analysis ofblank, spike, or duplicate samples.
RAP PREPARATION
Following the Data Gap Investigation, GZA would recommend development of a RAP, which
would include a preliminary design for the remedial program based on the revised CSM as wellas the results of the Remedial Pilot Study presented herein. RAP preparation would include thefollowing main elements:•

Review of background information on hazardous material/waste storage/disposal
practices in the Study Area and the investigations completed to date to determine thespatial extent and magnitude of Cr (VI) contamination, including both source anddissolved-phase mass. The review would include a summary of the methods and resultsof the Data Gap Investigation;

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 25•

A remedial options evaluation to optimize the in-situ bioremediation approach.
The review would include a cost benefit analysis of various remedial approaches, within
the framework of the updated CSM, to select the most cost-effective remedial approachto advance the Study Area toward closure. Given the encouraging Remedial Pilot Study
results, the remedial options evaluation would include an evaluation of different remedialadditives (including EDC-M) available at the time of implementation that can stimulate
the biochemical reduction of Cr (VI) to Cr (III) on a cost benefit basis to select the most
cost effective additive for a full-scale in-situ bioremediation program as well as an
appropriate dosage rate;33•

A preliminary remedial design to advance the Study Area toward closure, including
remedial performance standards and target remedial goals. The design will address areaof influence issues for the injection program;•A proposed performance monitoring program specifying sampling locations, analytes,
and sampling frequency to evaluate remedial performance;•

Proposed implementation schedule;•

Review of potentially applicable regulations given the preliminary remedial design;•

A project reporting schedule, which would likely include data submittals following
scheduled performance monitoring rounds and annual reports summarizing project results
and proposing additional work, if warranted, at the conclusion of each calendar year forthe project duration; and•Preparation of a Public Involvement Plan (PIP) to solicit feedback on the proposed
remedial design from the public, non governmental groups, and other stakeholders.
The PIP would include a meeting schedule and periodic status reports at appropriate
project milestones.

RAP IMPLEMENTATION
Once approved by CPCB-Lucknow and identified stakeholders, GZA recommends that theremedial work proposed in the RAP be implemented in accordance with the approved
implementation schedule. Based on the Site Hydrogeologic Information and Study Area Baseline
Chemical Parameter Ranges for Soil information packages provided by CPCB-Lucknow,
GZA preliminarily assumes the remedial program would include electron donor injections
targeted at about ten vadose zone Cr (VI) source areas and about twenty phreatic zone areas ofelevated Cr (VI) concentrations. Based on the information provided by CPCB-Lucknow, we
assume the vadose zone Cr (VI) source areas would include at least 50,000 kilograms of electron
donor and that treatment would take up to about six months to complete, and the phreatic zone
areas of elevated Cr (VI) concentrations would include at least 200,000 kilograms of electron
donor and that treatment would take up to about 18 months to complete. GZA notes that theactual remedial program may vary significantly based on the results of the Data Gap
Investigation and the revised CSM.

33
ECI reports that while the EDC-M used for this Remedial Pilot Study was manufactured in Japan andshipped to the Study Area for the pilot study, ECI reports it would be manufactured in India in the future to reduce unit
cost. ECI indicates they are committed to providing remedial additive on a cost-competitive basis for the Indian
market.

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 26

PERFORMANCE MONITORING
Once the RAP is approved by CPCB-Lucknow and identified stakeholders, performancemonitoring would be implemented in accordance with the RAP. GZA assumes performancemonitoring would include triannual groundwater sampling (three times per year) for Cr (VI) andTotal Cr at up to about 50 monitoring wells in the Study Area for about five years and monitoringof a subset of those locations for the indicator parameters listed in the Baseline Monitoring
section of this letter report. Because electron donor amendment program may temporarily
mobilize arsenic within the area of influence of the anaerobic treatment zone, GZA recommends
that performance monitoring include arsenic to address that issue.
FULL-SCALE REMEDIAL PROGRAM OPINION OF COST
At the request of Blacksmith, GZA has included an order-of-magnitude opinion of cost forcarrying out the conceptual remedial program described herein. The opinion of cost is presented
to facilitate a remedial options evaluation to compare in-situ bioremediation with alternative
remedial technologies and select an appropriate remedy to advance the Study Area toward closureand should not be considered a budget estimate for implementing the described remedial
program. Our order-of-magnitude opinion of cost is summarized below by task:
ASSUMPTIONS34

TASK
•
•
Data Gap
Investigation

RAP
Preparation•••

Work Plan preparation, up to two weeks of engineering.
File Reviews, Interviews, Remote Sensing; up to one month ofengineering.
Supplemental soil/groundwater quality sampling, up to four monthsof engineering.
Supplemental hydraulic testing, up to one week of engineering.
Level Survey, up to one week of engineering.
CSM Update, up to two months of engineering.

•

Up to three months of engineering analysis.

•

RAP Implementation assumes:
About six months of vadose zone injections at up to about
ten locations;
About 18 months of phreatic zone injections at up to
about 20 locations; andRemedial additive unit cost ranging from about $0.1035 to $3.0036
per pound, depending on the results of the remedial options
evaluation.
Performance monitoring assumes triannual monitoring (three times
per year) for Cr (VI) and Total Cr at up to about 50 monitoring
wells for five years and a subset of locations for indicatorparameters.

•

RAP
Implementation••
Performance
Monitoring
Contingency•$20,000$200,000$15,000$5,000$30,000$50,000$1,025,000 to$3,060,000$200,000$160,000 to$360,000

10% of total to address uncertainty
TOTAL

34

SUBTOTAL($)$10,000$1,715,000 to$3,950,000

Assumptions assume direct project collaboration with CPCB-Lucknow consistent with that provided for
the Remedial Pilot Study described herein.
35
This unit cost is based on the use of carbohydrate-based materials and twice the electron donor load of
EDC-M to account for potentially lower relative performance.
36
This unit cost is based on EDC-M, manufactured by ECI in India.

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 27

Because investigative work by CPCB-Lucknow is ongoing, the underlying assumptions for thisopinion of cost will almost certainly be revised as additional hydrogeologic data are gathered andanalyzed. GZA’s opinion of cost is implicitly linked to the assumptions included in the Site
Hydrogeologic Information prepared by CPCB-Lucknow, the preliminary CSM included herein,
our proposed remedial approach given the positive pilot study result, and our remedial
experience at hundreds of similar sites in the USA and internationally, and would need to berevised as additional hydrogeologic data are collected. GZA notes that the RAP would include
an updated opinion of cost based on Data Gap Investigation results and the revised CSM.
CONCLUSIONS AND RECOMMENDATIONS
The pertinent conclusions of the Remedial Pilot Study are as follows:••

Cr (VI) contamination in the local and intermediate groundwater flow systems poses
unacceptable risk to:−

Potential sensitive receptors for shallow overburden groundwater owing to its
presence at concentrations exceeding the Indian Standard for Drinking Water
Quality, and−The deep, regional groundwater flow system owing to potential for verticalmigration from the shallow Cr (VI)-impacted groundwater flow system driven by
the generally downward hydraulic gradient; andElectron donor amendment stimulated the biologically-mediated transformation of up to
about 99.9% of mobile and toxic Cr (VI) mass to immobile and nontoxic Cr (III) during
the 17-week pilot study. In fact, laboratory analysis of groundwater samples collectedfrom four of five well field locations during the last post-injection sampling round did notdetect Cr (VI) at concentrations exceeding Indian Standard for Drinking Water Quality.
Indicator parameter data were consistent with Cr (VI) transformation to Cr (III) owing tomicrobially-mediated processes in accordance with the Remedial Pilot Study
technical approach.

Based on the positive results of the Remedial Pilot Study and the preliminary CSM developed aspart of this work, GZA recommends implementing a full-scale remedial program in the
Study Area as expeditiously as practical to advance it toward closure, which would include thefollowing proposed tasks described herein: 1) Data Gap Investigation; 2) Preparation of a RAP;
3) RAP Implementation; and 4) Performance Monitoring.
ACKNOWLEDGEMENTS
GZA would like to acknowledge the respective contributions of CPCB-Lucknow and ECI/ECJ tothis Remedial Pilot Study. As previously mentioned, Mr. R. K. Singh, Ph.D. of CPCB-Lucknow
and his staff provided considerable scheduling, logistical, field staffing, analytical, Computer
Aided Design, data summary, and regulatory overview support for the Remedial Pilot Study.
Their exemplary support was continuous and of the highest quality throughout the project.
Indeed, the Remedial Pilot Study could not have been executed without the invaluable support ofDr. Singh and his CPCB-Lucknow staff. ECI/ECJ provided the remedial additive, EDC-M, pro
bono for the study as discussed above in Task 2 (Remedial Pilot Study Implementation andReporting). In addition to providing EDC-M, Mr. Shrihari Chandraghatgi, Ph.D. of ECJ provided

The Blacksmith InstituteFile No. 04.0023171.06 C

December 13, 2006
Page 28

pro bono product support throughout the work scoping phase of the project as well as review
comments on this letter report. GZA sincerely appreciates the respective contributions of
CPCB-Lucknow and ECI/ECJ to this Remedial Pilot Study.
GZA very sincerely appreciates the opportunity to be of service to The Blacksmith Institute on
this most important project. Should you have any questions or require additional information,please contact the undersigned at your convenience.
Very truly yours,
GZA GEOENVIRONMENTAL, INC.

I. Richard Schaffner, P.G., C.G.W.P.
Senior Technical Specialist

Steven R. Lamb, P.G., C.G.W.P.
Senior Vice President / Principal

Donald N. Kirkland, P.E.
Consultant/Reviewer

IRS/SRL/DNK:emg
P:\JOBS\23000s\23171\23171.06\Report\Report.doc

Attachments:

Limitations
Data Summary Table
Figures
Boring Logs
Summary of Site Hydrogeologic Information
Study Area Baseline Chemical Parameter Ranges for Soil

cc:

R.K. Singh, Ph.D., CPCB-Lucknow

LIMITATIONSGEOHYDROLOGICAL LIMITATIONS

1.

The conclusions and recommendations submitted in this report are based in part upon thedata obtained from a limited number of soil samples from widely spaced subsurface
explorations. The nature and extent of variations between these explorations may not
become evident until further investigation. If variations or other latent conditions thenappear evident, it will be necessary to reevaluate the recommendations of this report.

2.

The generalized soil profile described in the text is intended to convey trends insubsurface conditions. The boundaries between strata are approximate and idealized andhave been developed by interpretations of widely spaced explorations and samples; actual
soil transitions are probably more gradual. For specific information, refer to the boring
logs.

3.

Water level readings have been made in the test pits, borings, and/or observation wells attimes and under conditions stated on the exploration logs. These data have beenreviewed and interpretations have been made in the text of this report. However, it must
be noted that fluctuations in the level of the groundwater may occur due to variations inrainfall and other factors different from those prevailing at the time measurements were
made.

4.

Except as noted within the text of the report, no quantitative laboratory testing was
performed as part of the site assessment. Where such analyses have been conducted byan outside laboratory, GZA GeoEnvironmental, Inc. (GZA) has relied upon the data
provided, and has not conducted an independent evaluation of the reliability of these data.

5.

The conclusions and recommendations contained in this report are based in part uponvarious types of chemical data and are contingent upon their validity. These data havebeen reviewed and interpretations made in the report. As indicated within the report,
some of these data are preliminary "screening" level data, and should be confirmed withquantitative analyses if more specific information is necessary. Moreover, it should be
noted that variations in the types and concentrations of contaminants and variations intheir flow paths may occur due to seasonal water table fluctuations, past disposal
practices, the passage of time, and other factors. Should additional chemical data become
available in the future, these data should be reviewed by GZA, and the conclusions andrecommendations presented therein modified accordingly.

6.

Chemical analyses have been performed for specific parameters during the course of thisstudy, as detailed in the text. It must be noted that additional constituents not searchedfor during the current study may be present in soil and groundwater at the site.

7.

It is recommended that this firm be retained to provide further engineering services
during design, implementation, and/or construction of any remedial measures, if
necessary. This is to observe compliance with the concepts and recommendations
contained herein and to allow design changes in the event that subsurface conditions
differ from those anticipated.
P:\JOBS\23000s\23171\23171.06\Report\India Package.doc

23171.06

APPENDIX AGZA GeoEnvironmental, Inc.

DATA SUMMARY TABLE
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

DATA SUMMARY TABLE
Location Specifc Format
Location : Injection Well (IW)

SWL

DATE

pH

11.15

DO
6.91

Eh

4.14

Cond
118

S2-

865

SO4 2ND

139

NO3

TOC

3.52

34.46

Cr +6
10.01

T-Cr

Fe

12.88

Mn
0.17

Ni

0.06

Cu

Co

Zn

As

Hg

0

0.01

0

0.08

ND

ND

26.01.06
11.82

Sampling was not possible due to excessive foaming

09.02.06
12

4.6

0.9

-25

10160

**

270

**

34.22

**

6.42

351.65

71

0.34

0.53

0.54

2.13

**

**

12

6.96

1.7

-140

3870

5.96

35.18

0.92

420.21

ND

0.19

40.45

15.08

ND

1.58

ND

1.16

0.04

ND

12.39

6.71

1.6

-163

2290

34.2

28.94

0.25

72.89

ND

0.08

9.94

2.98

ND

0.15

ND

0.96

ND

0.06

13.12

6.45

1

-110

1140

3.3

61

0.23

82.39

ND

0.12

7.16

1.9

ND

0.06

ND

0.03

ND

0.08

24.02.06
10.04.06
28.04.06
26.05.06

Location : Side Gradient Monitoring Well (SMW)

SWL

DATE

pH

11.55

DO
6.94

Eh
4.8

Cond
115

S2-

1014

SO4 2ND

263

NO3

TOC

5.45

52.14

Cr +6
8.16

T-Cr

Fe

16.39

Mn
0.31

Ni

0.06

Cu
0

Co

Zn

0.03

0

As

Hg
0.07

ND

ND

26.01.06
11.93

Sampling was not possible due to excessive foaming

09.02.06
12.6

6.06

1.8

-93

3290

1

140

1.73

46.23

0.56

0.86

67.95

11.11

0.05

0.2

0.02

0.14

**

**

11.95

6.55

1

-70

1535

3.73

60.41

1.03

211.71

ND

0.47

14.68

2.91

ND

0.94

ND

0.17

0.06

ND

24.02.06
10.04.06
12.55

6.74

1.8

-196

1019

1.2

77.38

0.55

30.38

ND

0.87

7.03

3.33

ND

0.08

ND

0.33

ND

0.05

12.98

6.62

1.4

-234

962

6.2

161

1.4

39.23

ND

0.57

5.03

0.74

ND

0.05

ND

0.03

ND

0.04

28.04.06
26.05.06

Location : Downgradient Well No. 1 ( DW-1)

SWL

DATE

pH

DO

Eh

Cond

S2-

SO4 2-

NO3

TOC

Cr +6

T-Cr

Fe

Mn

Ni

Cu

Co

Zn

As

Hg

11.35

7.04

4.6

105

1120

ND

214

2.2

52.02

11.2

15.28

0.27

0.03

0.02

0.4

0

0.23

ND

ND

12.19

5.83

3.7

-18

2250

2.24

337

1.46

51.35

0.34

10.16

37.13

11.76

0.05

0.08

0.03

0.28

ND

ND

12.4

6.39

2.9

-49

1657

0.6

142

1.05

51.64

0.06

1.68

19.78

7.95

0

0.04

0

0.25

0.05

ND

12.2

6.44

0.8

-70

2380

10.2

58.57

0.52

446.84

ND

7.78

100.6

11.04

ND

0.6

ND

0.22

0.08

ND

12.78

6.52

1.3

-394

1309

6.8

31.32

0.52

128.37

ND

0.4

17.94

3.83

ND

0.12

ND

0.32

ND

0.08

13

6.24

1.2

-128

1216

92

76

1.3

98.3

ND

0.2

13.71

2.51

ND

ND

ND

0.19

ND

0.1

26.01.06
09.02.06
24.02.06
10.04.06
28.04.06
26.05.06

Location : Downgradient Well No. 2 ( DW-2)

SWL

DATE

pH

DO

Eh

Cond

S2-

SO4 2-

NO3

TOC

Cr +6

T-Cr

Fe

Mn

Ni

Cu

Co

Zn

As

Hg

11.52

7.02

4.9

112

1256

ND

289

4.89

46.04

12.55

19.49

5.2

0.3

0.01

0.07

0

0.19

ND

ND

12.07

6.15

3.4

-15

1838

12.16

352

2.09

47.33

0.23

9.09

16.82

8.82

0.01

0.03

0.02

0.18

ND

ND

26.01.06
09.02.06
12.35

6.42

2.7

-24

2080

0.5

236

1.33

50.28

ND

7.79

24.45

7

0.03

0.01

0.003

0.09

0.06

ND

11.98

6.58

0.8

-43

1454

4.26

92.98

1.4

225.9

ND

3.3

17.17

4.26

ND

0.09

ND

0.19

0.09

ND

12.54

6.78

1.2

-110

968

8.24

96.09

1.27

41.6

ND

2.71

5.99

1.71

ND

0.08

ND

1.09

ND

0.05

12.98

6.48

0.8

-1

1039

ND

93

2.15

61.6

0.67

2.87

4.03

0.87

ND

0.02

ND

0.02

ND

0.07

24.02.06
10.04.06
28.04.06
26.05.06

Location : Skolast Piezometer ( PM )

SWL

DATE

pH

DO

Eh

Cond

S2-

SO4 2-

NO3

TOC

Cr +6

T-Cr

Fe

Mn

Ni

Cu

Co

Zn

As

Hg

11.77

6.73

3.2

105

1450

ND

394

9.79

37.57

11.8

14.94

0.66

0.15

0.04

0.08

0

0.12

ND

ND

10.78

6.74

3.8

-12

1330

0.85

183

6.09

38.21

4.17

10.66

28.36

2.42

0.11

1.8

0

1.01

ND

ND

26.01.06
09.02.06
11.8

7.16

3

-13

1563

ND

235

1.34

39.2

0.32

0.46

4.7

1.68

0.04

0.1

0

0.11

0.01

ND

11.87

6.75

0.8

-36

1376

3.98

95.33

1.31

208.16

ND

1.44

6.7

2.63

ND

0.87

ND

0.23

0.02

ND

12.15

7.51

1.3

-88

1438

7.7

148.88

1.73

56.92

ND

0.9

54.27

4.91

ND

0.84

ND

0.65

ND

0.1

12.87

7.4

1.5

-156

1372

2.7

55

0.35

66.86

ND

0.28

27.12

2.36

0.05

1.06

ND

0.29

ND

0.05

24.02.06
10.04.06
28.04.06
26.05.06

Note : 1. Results of heavy metals, except Cr(VI), are reported as Total Dissolved metals, analyzed on AAS (Flame mode)a) SWL : Static water level in meters below ground levelb)
Eh in mVc)
Conductivity in μS /cmd) All others except pH in mg/le)
ND: Not detectable ;f) ** : could not be done due to excessive turbidity

FIGURES
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

INDIA

Map of Kanpur Study Area
in following slide..
UP StateBASELINE GROUNDWATER ELEVATION CONTOUR PLANS
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Exclusively for Pilot Study area

Fig: 2: Groundwater Elevation (DWL) – Pre Injection

26.4524

11.55

11.15

11.35
26.45235
11.52

LEGENDGW Flow

11.77
26.452380.27015

80.270280.27025

80.270380.27035

80.2704

Note : Contours plotted using DWL in meters below ground level

Regional Scenario

Fig.:2a : Groundwater Elevation (DWL) – Pre Injection
Regional Scenario*

LEGENDGW Flow

Note : Contours plotted using DWL in meters below ground level* Based on observations for the wells other than those developed in the Pilot Study

BASELINE HEXAVALENT CHROMIUM ISOCONCENTRATION PLAN
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Exclusively for Pilot Study area

Fig.:3: Cr-VI – Pre Injection

26.4524

8.16

10.01

11.2
26.45235
12.55

LEGENDGW Flow

11.18
26.452380.27015

80.270280.27025

80.2703

Note : Contours plotted using conc. of Cr-VI in mg/l

80.27035

80.2704

BASELINE TOTAL ORGANIC CARBON ISOCONCENTRATION PLAN
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Exclusively for Pilot Study area

Fig.:4: TOC – Pre Injection ( on colour scale )TOC Conc. in mg/l
26.4524

52.14

34.46

52
51
50
49

52.02

48
47
46

26.45235

45

46.04

44
43
42
41

37.57

40
39

26.452338
37
36

80.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using conc. of TOC in mg/l

80.2704

35
34

POST-INJECTION GROUNDWATER ELEVATION CONTOUR PLANS
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Exclusively for Pilot Study area

Fig.: 5 : Groundwater Elevation (DWL) – Post Injection ( 1st Round )( 07days after injection of EDC )26.4524

11.93

11.82

12.19
26.45235
LEGEND

12.07

GW Flow

10.78
26.452380.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using DWL in meters below ground level

80.2704

Exclusively for Pilot Study area

Fig.: 6 : Groundwater Elevation (DWL) – Post Injection ( 2nd Round )( 15 days after injection of EDC )26.4524

12.6

12

12.4
26.45235

LEGEND12.35

GW Flow

11.8
26.452380.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using DWL in meters below ground level

80.2704

Exclusively for Pilot Study area

Fig.: 7 :Groundwater Elevation (DWL) – Post Injection ( 3rd Round )( 60 days after injection of EDC )26.4524

11.95

12

12.2
26.45235
11.98

LEGENDGW Flow

11.87
26.452380.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using DWL in meters below ground level

80.2704

Exclusively for Pilot Study area

Fig.: 8 : Groundwater Elevation (DWL) – Post Injection ( 4th Round )( 78 days after injection of EDC )26.4524

12.55

12.39

12.78
26.45235

LEGEND

12.54
GW Flow

12.15
26.452380.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using DWL in meters below ground level

80.2704

Exclusively for Pilot Study area

Fig.: 9 : Groundwater Elevation (DWL) – Post Injection ( 5th Round )( 106 days after injection of EDC )26.4524

12.98

13.12

13
26.45235
12.98

LEGENDGW Flow

12.87
26.452380.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using DWL in meters below ground level

80.2704

Regional Scenario

Fig.: 9 a: Groundwater Elevation (DWL) – Post Injection (after the 5th round)
Regional Scenario*

LEGENDGW Flow

Note : Contours plotted using DWL in meters below ground level* Based on observations for the wells other than those developed in the Pilot Study

POST INJECTION TOTAL ORGANIC CARBON ISOCONCENTRATION PLANS
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Exclusively for Pilot Study area

Fig.: 10 : TOC – Post Injection (1st Round )( 07 days after injection )TOC Conc. in mg/l

26.4524

51
50
49

51.35

48
47

26.45235

46

47.33

45
44
43
42

38.21

41

26.452340
39
38

80.27015

80.270280.27025

80.270380.27035

80.2704

Note : a. Contours plotted using conc. of TOC in mg/l ;b. Well IW and SMW could not be monitored due to excessive turbidity

Exclusively for Pilot Study area

Fig. : 11 : TOC – Post Injection ( 2nd Round )( 15 days after injection )TOC Conc. in mg/l

26.4524

46.23

34.22

51
50
49
48

51.64

47
46
45

26.45235

44
43

50.28

42
41
40
39

39.2

38
37

26.452336
35
34

80.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using conc. of TOC in mg/l ;80.2704

Exclusively for Pilot Study area

Fig. : 12 : TOC – Post Injection ( 3rd Round )( 60 days after injection )TOC Conc. in mg/l

26.4524211.71420.21440420400446.84380360

26.45235

340
320

225.9

300
280
260

208.16240
220

26.4523200
180

80.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using conc. of TOC in mg/l ;80.2704

Exclusively for Pilot Study area

Fig. : 13 : TOC – Post Injection ( 4th Round )( 78 days after injection )TOC Conc. in mg/l

26.4524

30.38

72.89
125
120
115
110
105
100
95
90
85
80
75
70
65
60
55
50
45
40
35
30

128.3726.45235
41.6

56.92
26.452380.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using conc. of TOC in mg/l ;80.2704

Exclusively for Pilot Study area

Fig. : 14 : TOC – Post Injection ( 5th Round )( 106 days after injection )TOC Conc. in mg/l

26.4524

39.23

82.39
95
90
85

98.3

80
75

26.45235

70

61.6

65
60
55

66.86

50

26.45234540
3580.27015

80.270280.27025

80.270380.27035

Note : Contours plotted using conc. of TOC in mg/l ;80.2704

POST INJECTION HEXAVALENT CHROMIUM ISOCONCENTRATION PLANS
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Exclusively for Pilot Study area

Fig. : 15 : Cr-VI – Post Injection ( 1st Round )( 07 days after injection )26.4524

Cr-VI Conc. in mg/l
4
3.5

0.34

3

26.45235

2.5

0.23
2
1.5

4.17

1

26.45230.5
080.27015

80.270280.27025

80.270380.27035

80.2704

Note : a. Contours plotted using conc. of Cr-VI in mg/l ;b. Wells IW and SMW could not be monitored due to excessive foaming

Exclusively for Pilot Study area

Fig. : 16 : Cr-VI – Post Injection ( 2nd Round )( 15 days after injection )Cr-VI Conc. in mg/l

26.4524

0.56

0.55
0.525
0.5
0.475
0.45
0.425
0.4
0.375
0.35
0.325
0.3
0.275
0.25
0.225
0.2
0.175
0.15
0.125
0.1
0.075
0.05
0.025
0

0.06
26.45235
00.32
26.452380.27015

80.270280.27025

80.270380.27035

Note : a. Contours plotted using conc. of Cr-VI in mg/l ;b. Sample from IW could not be analysed due to excessive turbidity

80.2704

Exclusively for Pilot Study area

Fig. 17 : Cr-VI – Post Injection ( 3rd Round )( 60 days after injection )26.452400026.452350026.452380.27015

80.270280.27025

80.270380.27035

Note : Cr-VI ‘ NOT DETECTABLE’ in all the Wells

80.2704

Exclusively for Pilot Study area

Fig. : 18 :Cr-VI – Post Injection ( 4th Round )( 78 days after injection )26.452400026.452350026.452380.27015

80.270280.27025

80.270380.27035

Note : Cr-VI ‘ NOT DETECTABLE’ in all the Wells

80.2704

Exclusively for Pilot Study area

Fig. : 19 : Cr-VI – Post Injection ( 5th Round )( 106 days after injection )Cr-VI Conc. in mg/l

26.4524

0

0
0.65
0.6
0.55

0

0.5
0.45

26.45235

0.4

0.67

0.35
0.3
0.25
0.2

0

0.15
0.1

26.4523

0.05
0
-0.05

80.27015

80.270280.27025

80.270380.27035

80.2704

Note : Cr-VI rebounds in Well DW-2 and ‘ NOT DETECTABLE’ in all the remaining Wells

BORING LOGS
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Well Construction Details(Similar for all 4 wells)

Bore
Dia. / depth
200mm / 47.2.00 m

Casing
Dia. / length
4” PVC / 20.00 m

ScreenDia. / length
4” Ribbed / 27.2 m

Strata details

Assembly details
G. L.

G. L.
Fine to Med Sand
+Traces of silt

PVC. Plain Pipe
OD : 113 mm

16.00 mClayey Silt
19.00 m20.00 mFine to med sand withtraces of silt (inter bedded
clay at 21 m)
PVC Ribbed screen
OD : 113 mm

47.2 m47.2 mDESCRIPTION
G.L. to 16 m bgl.

---------------

16 Mt to 19 m bgl.
19Mt to 47.2 m bgl.
PVC Screen & Plain pipe
PVC screen slot size
PVC screen length
Coarse sand size---------------------------------------------------------------------------

m bgl.: meters below ground level

Annular space filling by
Coarse sand and Native Clay
Bentonite Chips
Coarse Sand
113 mm OD
0.01”
27.2 m3.25 mmSWL(m bgl)11.15-11.77 m

Well Construction Details(Skolast Piezometer)
Bore
Dia. / depth
200 mm / 50 m

Casing
Dia. / length
113 mm PVC / 39 m

ScreenDia. / length4” LCG / 6 m.

Strata details

SWL(m bgl)8 m.

Assembly details

GL

GL
PVC Plain Pipe OD 113 mm
9m
4” LCG Screen
10.5 m9m
Sand
12.8 mClay
19.2

PVC Plain Pipe OD 113 mm

Sand

26 m
4” LCG Screen
27.5 m30.5
Clay
33.5 mPVC Plain Pipe OD 113 mm

Sand

42 m
4” LCG Screen
45 m

46.4
Clay Kankar
50 m

DESCRIPTION
G.L. to 45 m bgl-- -----------PVC Screen & Plain pipe-- -----------PVC Screen slot size-- -----------PVC Screen length-- -----------m bgl.: meters below ground level-

Annular space filling by Pea- Gravel
113 mm OD
0.75 mm
6m

SITE HYDROGEOLOGIC INFORMATION
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Contaminant Hydro-geologic Information / assumptions for
remedial implementation budget estimate
TECHNICAL INFORMATION
A. BackgroundAs identified in the scope of ongoing Kanpur Project, a macro-level study was carried out
to locate monitoring locations for estimating groundwater quality. Simultaneous with thestudy, probable location of Cr-impacted areas were also broadly identified. In order torecord actual site–specific details, especially for precise location of Cr impacted zones, it
is proposed that a detailed inventory is carried out. Such inventory, which shall be
helpful in bridging the ‘data gaps,’ may be followed by (vertical) profiling of soil bydrilling bores and analyzing the soil matrix, to substantiate the estimations. The study
referred above is included in the Budget estimate appended below.
B. Contaminant Information
As per series of investigations carried-out by Central Pollution Control Board, the Cr(VI)has been recorded up to a depth of 45 to 47 meters. Groundwater collected from deeper
tube wells has not shown any appreciable concentration of Cr(VI). Cr(VI) impacted
zones exist in Vadose as well as Phreatic zones; however, the concentration of Cr(VI) has
been relatively higher in areas where Phreatic zones are identified as polluted. As far as
the dimension of the study area for remediation is concerned, the relevant details as per
crude estimate, pending actual detailed estimation, are as under:
B.1 Total Dimension
B.1.1 Vadose Zonea. Horizontal Area: Approximately 5,000 square meter(10 locations each of approximately 500 square meter)b. Vertical Unsaturated thickness: 5 to 10 meters
c. Soil type: Fine to medium sandB.1.2 Phreatic zonea. Horizontal Area: Approximately 10,000 square meter(20 locations each of approximately 500 square meter)b. Vertical saturated thickness: 35 to 20 meters
c. Soil type: Fine to medium sandC. Estimate of the conc. of MnO2 in the Soil
Investigation of soil characteristics was carried out in Dec. 2005, by drilling 03 bores(each of 60 meters depth) in different locations within the study area (Norikheda) at
Kanpur. At all these borings, 30 samples were drawn at 2-meter depth interval. The
results of the study were statistically interpreted and are enclosed. Although thecharacteristics does not include ‘Mn,’ its analysis, as desired by you has been speciallyrequested and the results shall be made available to you shortly. An estimation of MnO2
shall be made with the help of the results. For the sample characteristics referred above,please refer to Tables No. 1, 2, and 3 enclosed.
D. Baseline Chemical Parameters (Groundwater)
SN
1
2
3
4
5

Parameter
Cr(VI)
Total CrDO
Eh
Nitrate6789Sulphate
MethanepH
Specific
conductanceRange of concentration1 – 16 mg/l
2 – 22 mg/l
3 – 4.5 mg/l
+ 100 to + 120 mV
3 – 40 mg/l
(in certain areas goes as high as 60 mg/l)
100 – 400 mg/l*
6–8
700 – 1400

* Regretted for non availability of data about methane

E. Horizontal Hydraulic Conductivity
Hydraulic conductivity of the aquifers in the study area is of the order of
35.78 - 47.22 m/day (0.03 cm/sec).
F. Plan Depicting CR-VI conc. isopleths, groundwater flow direction and areas of
Cr VI exceedances
For Cr(VI) isopleths please refer enclosed Fig.1 below.
Regional scenario of groundwater flow is depicted in Slides No. 7 and 16 in the ppt file
Pilot-1

Fig.1: Cr(VI) Isopleths- Regional Scenario

STUDY AREA BASELINE CHEMICAL PARAMETER RANGES FOR SOIL
Prepared by Central Pollution Control Board of Lucknow, Uttar Pradesh, India.

Table-1
Location : near Sulabh Complex, N-Kheda, (30 Samples)
Reference level: 118.165 m aMSL, Lat. 260 26’ 57” Long. 800 16’ 05”
Parameter
PH
Conductivity (uS/cm)
Chloride (μg/g)
Fluoride (μg/g)
Sulphate (μg/g))
Phosphate (μg/g))
Nitrate-N (μg/g)
Nitrite-N (mg/Kg)
Ammonia-N (μg/g)
TOC (%)
Total Hard (μg/g)
Ca Hard. (μg/g)
Mg Hard. (mg/Kg)
Sodium (μg/g)
Potassium (μg/g)
Total Cr (μg/g)
Hexa. Cr (μg/g)
Lead (Pb) (μg/g)
Bulk Den. (g/cc)
Particle Den. (g/cc)

Min
6.93
86.8
10.1
2.594
145.0
10.79
16.40
0.718
0.0
0.293
90.00
40.00
20.00
9.72
1.77
10.625
0.104
6.742
1.159
2.527

Max
7.77
270.0
120.1
4.669
188.7
57.58
40.00
3.572
84.0
0.741
360.00130.00250.0034.48
13.94
44.125
2.861
26.06
1.524
2.833

Mean
7.39
180.1
82.4
3.486
158.1
38.84
22.50
1.238
54.6
0.501
165.00
93.70
71.33
23.65
5.49
25.681
1.039
13.28
1.320
2.633

S.D
0.27
37.8
25.58
0.57
9.9
12.2
5.1
0.68
25.8
0.1
50.97
20.42
47.76
6.58
2.32
9.000
0.820
4.02
0.080
0.067

Table-2
Location : Open field adj Skolast, N-Kheda (30 Samples)
Reference level: 119 m aMSL, Lat. 260 27’ 05” Long. 800 16’ 18”

Parameter
pH
Conductivity (uS/cm)
Chloride (μg/g)
Fluoride (μg/g)
Sulphate (μg/g)
Phosphate (μg/g))
Nitrate-N (mg/Kg)
Nitrite-N (μg/g)
Ammonia-N (μg/g)
TOC (%)
Total Hard. (μg/g)
Ca Hard. (μg/g)
Mg Hard. (μg/g)
Sodium (μg/g)
Potassium (μg/g)
Total Cr (μg/g)
Hexa. Cr (μg/g)
Lead (Pb) (μg/g)
Bulk Den. (g/cc)
Particle Den. (g/cc)

Min
7.90
81.7
30.0
1.10
56.20
8.86
8.53
0.884
0.0
0.234
200.00140.00
20.00
7.34
1.502
15.130
0.217
9.056
1.128
2.451

Max
8.51
317.0
100.1
6.84
162.00
74.59
57.78
1.989
294.0
0.683
480.00300.00200.00228.0010.08851.913
4.226
59.34
1.442
2.805

Mean
8.10
160.6
46.4
3.02
138.60
35.51
19.60
1.262
91.0
0.462
305.33212.67
92.67
30.43
4.473
31.248
1.039
24.06
1.285
2.640

S.D
0.13
53.8
14.75
1.40
21.32
15.72
11.27
0.30
69.2
0.13
75.01
54.45
46.53
50.41
2.25
8.74
0.82
12.76
0.07
0.10

Table-3
Location: Opp. My Car, adj Substation, N-Kheda ; (30 Samples)
Reference level: 120.460 m aMSL, Lat. 260 27’ 13” Long. 800 16’ 00”
Parameter
pH
Conductivity (uS/cm)
Chloride (μg/g)
Fluoride (μg/g)
Sulphate (μg/g)
Phosphate (μg/g)
Nitrate-N (μg/g)
Nitrite-N (μg/g)
Ammonia-N (μg/g)
TOC (%)
Total Hard. (μg/g)
Ca Hard. (μg/g)
Mg Hard. (μg/g)
Sodium (μg/g)
Potassium (μg/g)
Total Cr (μg/g)
Hexa. Cr (μg/g)
Lead (Pb) (μg/g)
Bulk Den. (g/cc)
Particle Den. (g/cc)

Min
6.52
144.0
60.1
1.53
30.5
17.08
21.73
0.959
0.0
0.117
280.00120.00
20.00
15.81
4.092
17.08
0.042
9.76
1.184
2.449

Max
8.16
514.0
300.3
5.96
125.5
61.46
70.40
7.722
154.0
0.683
600.00460.00280.00
169
95.64
43.21
2.075
21.26
1.457
2.768

Mean
7.71
226.0
84.4
4.32
66.9
28.43
39.30
2.506
41.5
0.356
374.67244.00130.67
45.62
9.624
27.95
0.833
14.02
1.325
2.637

S.D
0.50
70.9
44.74
1.05
28.47
9.46
12.05
1.42
43.6
0.14
79.30
63.50
68.63
28.71
16.348
7.57
0.68
2.68
0.08
0.075