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� I <br /> J 4} <br /> 'Ms. Lori Duncan <br /> January 11, 2005 <br /> Page 3 of 7 <br /> Ground Zero installed and sampled four groundwater monitoring wells in January 2001 and <br /> conducted four additional rounds of groundwater monitoring andI sampling between June 2001 <br /> j and March 2002 to investigate the lateral extent of groundwater contamination at the site. Based <br /> upon the analytical results of soil and groundwater samples collected at the site through March <br /> 2002 (Table 2), Ground Zero submitted a formal request for site closure as a low risk <br /> groundwater case in correspondence dated June 18, 2002. EHD disagreed with Ground Zero's <br /> recommendation and requested additional investigation in a letter dated August 1, 2002. <br /> In correspondence dated October 3, 2002, Ground Zero responded to EHD's request for <br /> additional investigation. The October 2002 document addressed specific concerns raised in <br /> EHD's August 2002 letter and included a contaminant partitioning'evaluation demonstrating that <br /> the vertical extent of groundwater contamination had been defined and an analysis of the fate and <br /> transportation of dissolved MTBE in support of Ground Zero's recommendation for site closure. <br /> r The simple fate and transportation analysis predicted MTBE concentrations in the former onsite <br /> domestic well and the closest offsite domestic well of 0.037r micrograms per liter (µg/L) and LO <br /> µg/L, respectively, assuming. first-order biodegradation rates, and 1.3 µg/L and 4.9 µg/L, <br /> respectively, assuming no biodegradation. However, as stated in the October 2002 document, the <br /> model was overly conservative, as it did. not account for': the fact that the supply wells are <br /> undoubtedly completed much deeper than the shallow aquifer, which persists to less than 25 feet j <br /> bgs. The model also-had no provision for the fact that the nearest offsite domestic well is actually J <br /> upgradient from the source area. <br /> In a letter dated March 21, 2003, EHD rejected Ground Zero's contaminant partitioning analysis <br /> and requested additional sampling and monitoring wellsl�to confirm the vertical extent of <br /> groundwater contamination and to further define the lateral extent of contamination in the f <br /> shallow aquifer. EHD also requested that the nearest supply wells be sampled for gasoline <br /> constituents. <br /> Pursuant to EHD's directive, the three nearest supply wells;(the offsite well 125 feet upgradient <br /> from the UST, the onsite fire suppression well 220 feet downgradient from the UST, and the onsite <br /> facility well approximately 500 feet cross gradient from the UST) were sampled for gasoline <br /> constituents on September 26, 2003. No gasoline constituents, including benzene or MTBE, were <br /> detected in any of the wells, further evidence that the fate and' transport analysis was overly <br /> conservative. I <br /> Ground Zero also installed and sampled three additional shallow monitoring wells and <br /> supervised the drilling of additional borings in January 2004 to:further investigate the lateral <br /> extent of groundwater contamination in the shallow aquifer.!'and to investigate the vertical extent <br /> of soil and groundwater contamination in the source area.",Confirmation groundwater samples j <br /> were collected from site wells in March 2004. An investigation summary report was submitted <br /> on April 27, 2004. The report concluded that the vertical extent of groundwater contamination <br /> had been defined and the downgradient extent of contamination in the shallow aquifer had been <br /> essentially defined, based upon the results of two groundwater samples collected from the down <br /> gradient well, MW5. The samples from MW5 in January and March 2004 contained MTBE at <br /> s <br /> 6:IGROU NDZENTuff$oy\ReporLs\W orkplansl W P I204.doc <br /> t <br /> f <br /> i <br />