NXARZYN fcOOOOOCM

May 3. 1991

Ms. Terese Van DonselU.S. Environmental Protection AgencyRegion V-5HS-11230 South Dearborn StreetChicago, Illinois 60004

Re: Final Feasibility StudyFadrowski Drum Disposal SiteFranklin. Wisconsin

Dear Ms. Van Donsel:

On behalf of the Acme Printing Ink Company and in accordance withSection IX of the Administrative Order by Consent dated April 17, 1987(and your request to limit the submhtal to those pages containingrevisions), \Varzyn has enclosed six copies of these revisions and newreport covers for the Fadrowski Drum Disposal Site (FDDS) FinalFeasibility Study (FS).

The FS report contains a summary of the results of the investigativeactivities, provides a thorough evaluation of potential remedialtechnologies, assembles those technologies into a comprehensive set ofalternatives, and provides a detailed evaluation of the alternatives forthe FDDS. With the attached revisions, the FS report also addressesthe U.S. EPA comments on the Draft Final Feasibility Study (March1991) contained in a letter dated April 3,1991.

If you have any questions regarding this report, please contact us.

Sincerely,

WARZYN INC.

T1IF. PHKFFX.T BA1ANCFUKTOF.KN TKOINOIXX;Y CC!

AND CKF.VnvnY

MADISONONF. SCIF.NCF. COl'KT

CO BOX S.WSMADISON. Vi'l S3~()i

( ( > < « ! 2M -T-rFAX'«),S> 3~.1-2513

Steven CTer?n6nt-Schenk, P.E.Project Manager

208128MT/kml/STS/TFL[ccf-104-76]25389.92

Enclosures: Revisions to be incorporated into the Draft Final FS for the FinalFeasibility Study Report (6)Response to Agency Comments on the FDDS Draft FinalFeasibility Study

William S. Roush, Jr. - Friebert. Finerty & St. John, S.C. (2)Celia VanDerLoop - Wisconsin DNR (2)Frank Schultz - Wisconsin DNR (2)Randy Walbrun - Acme Printing Ink Co. (1)Michael J. Tennis - Acme Printing Ink Co. (!)

Response to Agency Comments on the FDDS Draft Final Feasibility Study

Section 3

Page 4-5, para 1

Page 5-5, para 4 andPage 5-6, para 2

Page 6-7, para 5

Page 6-32, para 2

Page 6-35

Text has been included on pages 3-14 and 3-15 toinclude the risk to potential residential constructionworkers at the FDDS.

These metals were included in the discussion.

The reference to Table 1 has been revised to Table 3.

We've discussed the "waters of the state" issuefurther with Celia VanDerLoop. Celia contacted aSoutheastern District Water Regulation and Zoningrepresentative and confirmed that the manmadepond is not considered "waters of the state."

The text has been revised to state that risks frompotential contaminant migration would be evaluatedthrough groundwater monitoring.

Pages ix, 6-36, 6-39, 7-2, 7-4, 7-9, Table B3, Table C6,and Table 9 have been revised to includegroundwater monitoring with In Situ Vitrification,Alternative 6.

MT/kml/STS/TFL[ccf-104-76a]25389.92-MD

Report Final Feasibility Study25389.92 Fadrowski Drum Disposal Site

Franklin, Wisconsin

Prepared for:

Acme Printing Ink CompanyMilwaukee, Wisconsin

Prepared by:

Warzyn Engineering Inc.Madison, Wisconsin

May 1991

Final Feasibility StudyFadrowski Drum Disposal Site

Franklin, Wisconsin

May 1991

Alternative PNW Cost

Alternative 1 - No Action No Cost

Alternative 3A- Containment $ 2,030,000

Alternative 3B- Containment $ 3,900,000

Alternative 4 - Debris, Soil and Container $ 11,400,000

Removal

Alternative 5A- Containment/Container Removal S 2,230,000

Alternative 5B- Containment/Container Removal $ 4,110,000

Alternative 6 - In Situ Vitrification $63,600,000

State and Community Acceptance

The state acceptance and community acceptance criteria will be addressed in the ROD after

public comments on the Proposed Plan and FS are received.

-ix-MT/kml/STS/RJM/RP[vlr-600-23h]25389.84-MD

Feasibility StudyFadrowski Drum Disposal Site

May 3, 1991Page 3-14

The cumulative cancer risk for the same pathway was calculated to be 4 x 10-6 based on the

reasonable maximum exposures to carcinogenic chemicals of potential concern in fill and

sediment. Carcinogenic chemicals were not detected above natural background in surface

water. These risk calculations are conservatively high, because they were based on the

maximum concentration of carcinogenic chemicals of potential concern in fill and sediment

with the exception of PAHs, heptachlor, and PCBs. The exposure point concentration of

these contaminants (PAHs, heptachlor, and PCBs) were based on an estimate of the 95

percent upper-bound confidence limit of the arithmetic mean. The majority of the cancer

risk (i.e., 93 percent of the total cancer risk) is due to exposure to PAHs. The remainder

of the cancer risk (i.e., not considering PAHs) was calculated to be 3 x 10~7.

Concentrations of chemicals in surface water are below the National Ambient Water

Quality Standards (NAWQS) for the protection of aquatic life, with the exception of

cyanide. Although cyanide was detected above the NAWQS in the pond and unnamed

stream, it was detected at slightly lower concentrations in the upstream surface water

sample in the unnamed stream (the upstream concentration exceeds the cyanide NAWQS).

It appears the FDDS contributes to the cyanide present in the pond. The levels of other

chemicals detected in sediment are comparable to levels of chemicals detected in the

upstream (i.e., background) sediment. Based on the limited migration of chemicals from

the FDDS to surface water bodies under current conditions, ecological impacts on the

surface water bodies would be expected to be minimal. Based on the exceedance of the

NAWQS for cyanide there is the potential for adverse health effects to occur to aquatic

species in the pond and unnamed stream.

Future Site Conditions. In accordance with RAGS, future use of the FDDS must be

evaluated assuming no institutional controls at the site. To assess the risks of possible

future use of the FDDS in accordance with guidance, risks were calculated based on the

possible development of the FDDS as a residential community. Children born and raised

in homes on-site and residential construction workers were assumed to be the most likely

receptors in this scenario.

Feasibility StudyFadrowski Drum Disposal Site

May 3,1991Page 3-15

It was assumed that children and young adults would be exposed to fill while playing in

gardens. It was also assumed that children would live at the on-site residence until theywere 21 years old. Younger children from ages 1 to 6 were assumed to be exposed to fill

via dermal contact and incidental ingestion more frequently (4 days/week) than olderchildren and young adults (2 days/week). It was also assumed that an on-site private wells

would be developed in the clay aquitard and that children would drink two liters of waterper day. Based on these assumptions, noncancer and cancer risk estimates were calculated.The total noncancer risk estimate (i.e., HI) was estimated to be 0.9 assuming children andyoung adults would drink the water and would be exposed to the fill under future

conditions. Approximately equal levels of risk were attributable to each pathway. Based on

the assumptions used and risk calculations performed, noncancer health risks would not beexpected.

Assuming the same exposure conditions, the cancer risk for children and young adults wasestimated to be 1 x 10-5 based on reasonable maximum exposures to carcinogenic chemicals

of potential concern detected in groundwater and fill. The primary portion of the risk wasassociated with fill exposure via incidental ingestion of PAHs (i.e., 86%). The cancer risks

calculated for fill exposure via incidental ingestion are above the U.S. EPA point ofdeparture of 10~6. The cancer risk due to groundwater exposure alone was 1 x 10-6 (i.e.,

7% of the total risk).

Construction workers were assumed to be on-site for one year during the construction offoundations and other associated earthwork. While on-site, workers would be exposed tofill material through incidental injestion, dermal adsorption, and inhalation. The totalnoncancer risk estimate (i.e., HI) was estimated to be 0.8. The cumulative cancer risk was1 x 10-6 based on reasonable maximum estimates of carcinogenic concentrations in the fill.The majority (86%) of this cancer risk was due to the PAH concentrations present in the

fill.

Feasibility StudyFadrowski Drum Disposal Site

May 3,1991Page 3-16

Although the preceding risk estimates address exposure to presently contaminated or

possibly contaminated media under future land use conditions, they do not address the

potential hazard at the FDDS associated with the containers buried in the fill, the contents

of which are unknown. If construction workers encountered containers during residential

construction activities, there is a possibility that containers could be ruptured and release

their contents. The magnitude and nature of the chemical exposure or soil or groundwater

contamination resulting from such an occurrence cannot be predicted or quantified.

MT/kml/STS/RJM/RP[sss-6()l-12c]25389.82

Feasibility StudyFadrowski Drum Disposal Site

May 3, 1991Page 4-5

Groundwater response actions were considered to address the NR 140 preventive actionlimit (PAL) exceedances for barium, benzene, chromium, cyanide, the NR 140 enforcementstandard exceedance for mercury, and the potential of the FDDS to cause future

groundwater contamination. The low permeability of the clay till aquitard greatly limits theeffectiveness of any groundwater remedy (i.e., extraction, injection or in situ treatment).

Based on the results of the long-term quarterly groundwater monitoring, the following

conditions would necessitate further considerations of groundwater treatment options:

concentrations of contaminants in groundwater have increased;

groundwater contamination presents a threat to human health or the environment;

groundwater contamination is not attenuating at a sufficient rate to meetgroundwater Cleanup Standards within 5 years after commencement of remedialaction; or

groundwater Cleanup Standards are not being maintained.

The exceedance of NR 140 PALs or ESs does not require the use of groundwater actions.Table 5 and 6 of NR 140 describes the types of responses required to address PAL and ESexceedances. Groundwater actions as well as source control measures may be used toaddress the exceedances. At the FDDS, source control measures will be much moreeffective than groundwater actions.

The general response actions and associated processes that are carried through thisidentification step are:

General Response Action Process Option

No Action None

Institutional Controls Deed RestrictionsControlling Land and Groundwater Use

Groundwater MonitoringAccess Restrictions

Containment Soil CoverClay and Topsoil Cap

Clay, Rooting Zone, and Topsoil Cap (NR 504 Cap)Multilayer Cap with a Synthetic Membrane Cap (RCRA Subtitle C)

Leachate Collection Trench

Excavation and Treatment RCRA Incinerator (Containers)Off-site

Removal and Disposal Off-site Solid Waste LandfillOn-site Solid Waste Landfill

In Situ Treatment In Situ Vitrification

MT/kml/SBH/STS/RJM/RP[sss-601-12dj25?«°.R2

Feasibility StudyFadrowski Drum Disposal Site

May 3,1991Page 5-5

SCREENING OF ALTERNATIVES

The alternatives that are developed are given an initial screening to eliminate any

alternatives that would not be applicable. In accordance with the Work Plan (Warzyn,

1988), this screening uses the following criteria:

• Compatibility with project objectives;Effectiveness in controlling on-site releases;

• Effectiveness in mitigating off-site impacts;Adverse environmental impacts;Technological feasibility, applicability, and reliability;

• Preliminary cost estimates (high, medium or low); and• Consistency with state and federal policy.

The criteria above are consistent with the three screening criteria identified in the

NCP: effectiveness, implementability, and cost. The first four criteria above evaluate

the effectiveness of the alternatives. Technological feasibility, applicability, and

reliability address the alternatives' implementability, while preliminary cost estimates

evaluate cost. The last criterion (policy consistency), provides an additional screening

step for known applicable regulations.

The alternatives and the criteria are presented in a matrix (Table 3) to show the

results of this evaluation. One of the disposal methods in Alternative 4 was dropped

from further consideration because disposal of the waste in an on-site solid waste

landfill was considered unfeasible due to the landfill siting requirements (the landfill

would be within 120 ft of a private well, and within 1,000 ft of a state or federal

highway (Highway 45)).

Compatibility with project objectives was split into two categories: reduce the

exposure risk to an acceptable range of 10-4 to 10*6, and reduce the potential for a

release to groundwater.

The criteria of adverse environmental impacts for each alternative of Table 3 was

weighed against the "No Action" alternative. The only known adverse impact was the

short-term impact associated with disturbing the waste.

Feasibility StudyFadrowski Drum Disposal Site

May 3, 1991Page 5-6

The alternatives were considered to be technically infeasible if there were known

technical requirements that might hinder implementing the alternative. In the case of

on-site landfills, this alternative was considered to not be feasible due to regulatorysiting requirements.

Table 3 alternatives were technically applicable if they made progress towards any ofthe project objectives and were a proper waste management tool. Hazardous waste

management of the fill was not considered to be applicable because solid waste

management is possible.

Costs were evaluated in a subjective manner. High, medium or low was used to

describe the relative cost of each alternative.

Although ISV may have some limitations due to rubble and potentially high organicconcentrations, this alternative is retained because of the NCP emphasis on treatment.

The following alternatives will be carried into the detailed analysis portion of the FS1

Alternative 1 - No ActionAlternative 2 •• Access RestrictionsAlternative 3 - Containment

a) NR 504 cap with a topsoil cover, rooting zone, and a clay capb) RCRA Subtitle C compliant multilayer cap with a synthetic

membrane componentAlternative 4 - Debris, Soil, and Container Removal

Alternative 5 - Containment/Container RemovalAlternative 6 - In Situ Vitrification

MT/kml/SBH/STS/RJM/RP[sss-601-12e]25389.82

Feasibility StudyFadrowski Drum Disposal Site

May 3,1991Page 6-32

This alternative would be expected to reduce the potential for future migration ofleachable constituents to groundwater, and thereby reduce the potential risksassociated with groundwater contamination. The removal program would eliminate

contaminants that could migrate to the groundwater, while capping would reduce

infiltration of precipitation through waste, and thus reduce the migration of water-

soluble compounds (e.g., VOCs).

Should mobile constituents be released to groundwater in -he fu ture , risks resultingfrom the potential migration of constituents to potable water sources would be

evaluated by the groundwater monitoring program. Grouiidwatei sampling and

analysis will provide a means to assess potential contaminant migration. If significant

groundwater contamination is identified in the future, further actions could beimplemented before the contaminants reached potable water supplies.

Adequacy and Reliability of Controls. Container removal and containment are

generally considered a reliable means of removing and reducing the impacf ofleachable constituents on groundwater by reducing the infiltration of precipitation.

Implementation of institutional controls (deed rjstiicticris), and a groundwatermonitoring program are considered effective and reliable in minimizing the potentialfor contaminant exposure associated with futuie land use conditions.

The long-term management of this alternative will include continued monitoring of

groundwater quality, and maintenance of the integrity of the perimeter fence and cap.

Reduction of Toxicity, Mobility or Volume Through Treatment - Alternative .5This criterion considers factors such as the treatment process used and the material

treated, the amount of hazardous material destroyed or treated, the reduction in

toxicity. mobility or volume, the irreversibiliiy of the treatment, the type and quantityof treatment residual, and the reduction of inherent hazards. These factors areconsidered where appropriate.

Feasibility StudyFadrowski Drum Disposal Site

May 3, 1991Page 6-39

Technical Feasibility. ISV is generally technically feasible; however, the existence ofrubble and organic content at the FDDS may limit its feasibility. A treatability study

should be performed if this alternative is selected.

Administrative Feasibility. This alternative is administratively feasible. Permissionfrom the current FDDS would be necessary. WDNR and City of Franklin approvals

will also be needed for these activities.

Availability of Materials and Services. Required materials, services, and equipment areavailable through specialized contractors to provide the ISV treatment. Electricity can

be taken directly from the utility transmission lines (12,500 or 13,800 volts) or suppliedby an on-site generator. Grading materials and services are available locally.

Cost - Alternative 6This criterion considers factors such as capital costs, operation and maintenance

(O & M) costs, and present net worth (PNW) costs.

Capital. The major capital costs of this alternative are the costs for ISV treatment.

apital costs are estimated to be $63,300,000.

O & M. The annual O & M costs of this alternative are limited to groundwater

monitoring, cover monitoring and repair. O & M costs are estimated to be $32,100 peryear.

PNW. The 30-year PNW (10% discount rate) associated with the above costs are

estimated to be $63,600,000.

The estimated capital, O & M, and PNW costs for this alternative are presented inAppendices A, B, and C (Tables A7, B3, and C7) and are summarized in Table 9.

State Acceptance - Alternative 6

This criterion will be addressed in the ROD after agency review of the FS.

Feasibility StudyFadrowski Drum Disposal Site

May 3, 1991Page 7-2

All alternatives (except Alternative 1) rely on institutional controls as a portion of the

remedy. Alternatives 3 and 5 include deed restrictions to control site development.

Alternatives 3 through 6 include groundwater monitoring to ensure the effectiveness of

the remedy.

Alternative 3 (Containment) and Alternative 5 (Containment/Container Removal)

provide protection of limiting exposure by placing a soil barrier between the waste and

potential receptors. The soil barrier also has a range of construction types that would

determine the degree of precipitation infiltration migrating through the cap. Limiting

the infiltration rates would reduce the potential of waste constituents to migrate into

the groundwater.

Alternative 4 (Debris, Soil, and Container Removal) provides adequate protection

through a removal program which results in a long-term residual risk of 1 x 10-6 or

less. Due to the magnitude of this alternative (excavating and transporting about

11,000 truckloads of contaminated fill to a solid waste landfill), this alternative does

pose a risk to the community and on-site workers from accidents.

Alternative 5 (Containment/Container Removal; also protects human health and the

environment through both a focused container removal program arid access

restrictions. The container removal program could resolve or significantly reduce the

potential for future exposure or release of contaminants to the groundwater andenvironment by removing containers located in the vicinity of test pits TP-3 and TP-9

and the other test pits identified on Figure 8.

If feasible for the fill present at the FDDS, Alternative 6 provides protection by

removing or immobilizing the contaminants.

Alternatives 3 through 6 provide adequate protection of human health and the

environment, thereby meeting this threshold criterion.

COMPLIANCE WITH ARARS

This criterion considers factors such as compliance with chemical-specific, location-

specific, and action-specific ARARs.

Feasibility StudyFadrowskj Drum Disposal Site

May 3, 1991Page 7-4

Alternative 4 would constitute closure by removing fill to risk based or background

levels and would comply with either the solid or hazardous waste closure requirements.

Alternative 1 would not be able to comply with these closure requirements.

Alternatives 3 and 5 would accomplish the solid and hazardous waste closure

requirements through capping, groundwater monitoring, and long-term care.

LONG-TERM EFFECTIVENESS AND PERMANENCE

This criterion considers factors such as residual risks remaining following

implementation of the remedy and the adequacy and reliability of controls. This latter

factor considers the long-term management of treatment residuals, long-term reliability

of engineering and institutional controls, and the potential need for replacement of the

alternative.

Magnitude of Residua) Risk

Potential heallh risks for Alternative 1: No Action are presented in the BRA

(summarized in Section 3). Under this scenario^ the estimated cancer risk for current

land use conditions (trespasser exposed to contaminants in surface soil) of 4 x 10-6,

was above the U.S EPA 1 x 10~6 point of departure for cancer risk.

Alternatives 3 and 5 are expected to decrease residual risk by preventing direct contact

with waste materials through containment. Alternative 5 further reduces the risk by

removing containerized waste found during the focused container removal program.Alternative 4 reduces uncertainties and residual risk to less than 1 x 10-6 by removing

containerized wastes and contaminated soil from the FDDS. Alternative 6 reduces the

residual risk by removing the organic contamination and encapsulating the inorganic

contamination.

Each of Alternatives 3, 4, 5, and 6, are expected to reduce residual risks associated with

exposure through institutional controls and the groundwater monitoring program.

Institutional controls restricting groundwater use would minimize the potential for the

installation of a well at the FDDS in the future. Should a release of constituents from

the wastes to groundwater occur in the future, the groundwater monitoring program

would identify the migration of constituents prior to impacting potable water wells,

thereby reducing potential risks. Containment (Alternatives 3 and 5) is expected to

decrease precipitation infiltration by reducing the permeability of the cover and

Feasibility StudyFadrowski Drum Disposal Site

May 3, 1991Paee 7-9

ALTERNATIVES COST SUMMARY

Capital O & M FNV

Alternative 1 • - - No CostsNo Action

Alternative 3Containment

a) NR 504 Cap $ 1,730.000 $32.100 $ 2,C30,OCOb! RCRA Subtitle C Cap $3,600,000 532, LOO $ 3 vOO,000

Altevnathe 4Debris, Soil, andContainer Removal $11,200,000 522,700 111,400.000

Alternative 5Containment/Container Removal

a) NR 504 Cap $1,930,000 532,100 52,230,000b) RCRA Subtitle C Cap $3,810,000 $52,100 S 4,110,000

Alternative 6In SituVitrification $63,300,000 332.100 S51S600.000

STATE ACCEPTANCEThis criterion will be addressed in the ROD after agency review of the FS.

COMMUNITY ACCEPTANCEThis criterion will be addressed in the ROD after pubjic comments on the ProposedPlan and the FS are received.

MT/kml/SBH/STS/RJM/RP[vlr-600-23f]25389.84-MD

TABLE 9COST SUMMARYIN SITU VITRIFICATION (ALTERNATIVE 6)FADROWSKI DRUM DISPOSAL SITE

CAPITAL COSTS

Institutional Controls $10,000

In Situ Vitrification $60,400,000

Containment $874,000

Capital Cost Subtotal $61,300,000

Construction Management Allowance $500,000Design Engir.ee; ing Allowance $500,000Construction Documentation Allowance $1,000,000

Total Capital Costs $63,300,000

OPERATION AND MAINTENANCE COSTS (ANNUAL)

Groundwater Sampling $22,700Containment Mcnitoiing $1.800Containment Maintenance $7,600

Total Operation and Maintenance Costs $32,100

30 YEAR PRESENT NET WORTH(5% Discount Rale) $63,600,000

Note:1. Rr-fer to Appendices A, B, and C for the detailed summary of capital,

operation ?.n.-i maintenance, and present net v/orth costs, respectively,for each alternative.

2. Cost estimates were prepared using the sources and methods noledin the Appendices-.

MT/TAPB/STS4/10/90

Table B3In Situ Vitrification (Alternative 6)Operation and Maintenance CostsFadrowski Drum Disposal Site

OPERATION AND MAINTENANCE COSTS QUANTITY UNIT UNIT COST COST

Groundwater Sampling (6 wells quarterly)

a. sampling costs-field technician

-transportation

-per diem

b. analytical costs

-6 wells,1 duplicate, 2 blanks

c. report preparation

-senior professional

-support

Containment Monitoring

-field technician (6 hours/quarter)

-transportation

Maintenance Costs

a. repair and regrade ditches

i). revegetate

c. mow grass

60 hrs

600 mi4 @

36 samples

12

4

24

600

hrs

hrs

hrs

mi

$60.00

$0.67

$25.00

$477.00

SI 00. On

$50.00

$60.00SC.c7

53,600

$400

SI CO

Si 7.200

SI, 200

S200

WOO

111100

4

LS

sy

&

$4,000.00

50.25

$200.00

34.000

S2.BCO

SiW

Tots I 06 M Cost So?., "CO

Note: Unit costs based on similar project costs.

MT/JCK/STS

4/10/91

Table C6In Situ Vitrification (Alternative 6)Present Net Worth CostsFadrowski Drum Disposal Site

Year1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

MT/STS

4/10/91

fadappd

CapitalCosts

$63,300,000

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

O&MCosts

$0

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

532,100

$32.100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

Note.

PNW cost is

TOTAL$63,300,000

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$3?, 100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

$32,100

S32.10C

$32,100

$32, 100

$32,100

$32,100

$32,100

$32, ICO

$32,100

$32,100

$32,100

$32,100

Total Present

P/WFACTOR

i

0.90909

o.szew0.75'i 3 1

0.68301

0.62092

0.56447

0.51316

0.46651

0.4?410

0.38554

0.35049

0.3 -.363

O.c~89e6

3.26333

0 23939

C.2I763

0.19734

0.17S36

C.iS:J.51

0. 14664

0.12513

0 -i?28S

0.11158

0.10153

009230

0.08391

0.07628

0.06934

0.06304

0.05731

Net Worth

PRESENT NETWORTH

$63,300,000

$29,182

$26,529

524,117

S2:,925

$19,93.?

&18,i20

$16/72

$14,975

$13,614

$12,376

$11,251

$10,123

.19,293

58,453

$7,684

S6 38«

$6,351S5.773

$5,249

$.4.7/1

$4.338

$3,943

$3,585

$3,259

$2.963

$2,633

S2,4<19

.<:2.226

$2,024

$1,840

$63,600,000

based on a 10% discount rate.