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• 23 Apnl 2002 AGE-NC Project No 95-0142 Page 4 of 16 Since the approval of the CAP in December 1995,the local and regional ground water elevation has risen significantly(20 feet)and has maintained a depth-to-water of approximately 25 feet bsg AGE believes that the sustained increase of ground water elevation has significantly decreased the potential effectiveness of the proposed SVE/1AS method as a stand alone treatment for impacted soil and ground water, due to a reduction in thickness of the impacted vadose zone and an increase in thickness, and volume,of impacted soil(and ground water)in the saturated zone The impacted soil is primarily fine grained, which may make the upward and lateral path of sparged air through the saturated zone unpredictable and stripped hydrocarbons unrecoverable The vertical extent of hydrocarbon-impacted soil had not been fully assessed when the CAP was developed The mass of adsorbed hydrocarbons now known to be within the saturated zone is significant,recent evaluation of soil and ground water below 50 feet bsg has documented significant concentrations of dissolved and adsorbed hydrocarbons that must be satisfactory mitigated to achieve site closure At the present time,dissolved hydrocarbon concentrations are known to extend to 80 feet bsg,where low concentrations suggest that 80 feet bsg is close to the dissolved plume's vertical extent The . anticipated limited overall effectiveness and reliability of IAS technology to remediate the impacted soil and ground water require a re-evaluation of this proposed method AGE conducted aground water extraction pumping test on 18 October 2001 Analysis of the ground water extraction data indicted that ex-situ ground water treatment was feasible, the radius of influence generated by a pumping rate of five gallons per minute was interpreted to be adequate to control further off-site migration of contaminants toward the east, in the predominantly down- gradient direction The results of the pumping tests were reported in the AGE-prepared Ground Water Extraction Pilot Test Report dated 31 January 2002 The January 2002 report stated that the soil at the site has a high percentage of fine-grained matrix and overall is homogenous and mostly fine-grained In general this soil type has a high adsorption capacity and low permeability, and thereby could potentially limit migration of dissolved hydrocarbons However,despite the fine-grained nature of the soil,the feasibility test results showed that ground water extraction should be effective on the site The ground water extraction rates during full-scale remediation are not likely to exceed the pilot test extraction rate(five gallons per minute), and may be less for effective ground water extraction and stabilized drawdown In the report, AGE recommended the use of ground water extraction as an alternative ground water remediation technique at the site Ground water extraction should provide adequate capture of the dissolved hydrocarbons, based on site-specific hydrogeologic conditions and hydrocarbon distribution The limited areal distribution ofhigh concentrations of dissolved hydrocarbons near the Advanced GeoEnvironmental,Inc