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1 <br />' FEASIBILITY TESTING OF ON-SITE GROUND WATER EXTRACTION <br /> • In a document titled Corrective Action Plan - November 1995, dated 15 November 1995, AGE <br /> recommended implementation of soil vapor extraction in conjunction with >n-situ air sparging for <br /> remediation of the petroleum hydrocarbon-impacted soil and ground water at the site At the time <br />' the CAP was prepared, ground water extraction was generally not viewed as an effective and cost <br /> efficient method of ground water remediation, but this method has gained more favor recently as a <br /> method to address impacted ground water when other technologies (e g , air-sparging) may not be <br />' controllable or effective, due in part to reduced extracted water treatment and disposal costs <br /> Since the approval of the CAP in December 1995,the local and regional ground water elevation has <br />' risen significantly(20 feet)and has maintained a depth-to-water of approximately 25 feet bsg AGE <br /> believes that the sustained increase of ground water elevation has significantly decreased the <br /> potential effectiveness of the proposed SVE/IAS method as a stand alone treatment for impacted soil <br />' and ground water, due to a reduction in thickness of the impacted vadose zone and an increase in <br /> thickness,and volume,of impacted soil(and ground water) in the saturated zone The impacted soil <br /> is primarily fine grained, which may make the upward and lateral path of sparged air through the <br />' saturated zone unpredictable and stripped hydrocarbons unrecoverable <br /> The vertical extent of hydrocarbon-impacted soil had not been fully assessed when the CAP was <br />' developed The mass of adsorbed hydrocarbons now known to be within the saturated zone is <br /> significant Recent evaluation of soil and ground water below 50 feet bsg has documented significant <br /> concentrations of dissolved and adsorbed hydrocarbons that must be satisfactory mitigated to achieve <br /> lie site closure <br />' At the present time,dissolved hydrocarbon concentrations are known to extend to 80 feet bsg,where <br /> low concentrations suggest that 80 feet bsg is close to the dissolved plume's vertical extent The <br /> anticipated limited overall effectiveness and reliability of IAS technology to remediate the impacted <br />' soil and ground water require a re-evaluation of this proposed method <br /> AGE conducted a ground water extraction pumping test on 18 October 2001 Analysis of the ground <br />' water extraction data indicted that ex-situ ground water treatment was feasible The radius of <br /> influence generated by a pumping rate of five gallons per minute was interpreted to be adequate to <br /> control further off-site migration of contaminants toward the east, in the predominantly down- <br /> gradient direction The results of the pumping tests were reported in the AGE-prepared Ground <br /> Water Extraction Pilot Test Report dated 31 January 2002 <br />' The January 2002 report stated that the soil at the site has a high percentage of fine-grained matrix <br /> and overall is homogenous and mostly fine-grained In general this soil type has a high adsorption <br /> capacity and low permeability, and thereby could potentially limit migration of dissolved <br />' hydrocarbons However,despite the fine-grained nature of the soil,the feasibility test results showed <br /> that ground water extraction should be effective on the site The ground water extraction rates during <br /> full-scale remediation are not likely to exceed the pilot test extraction rate(five gallons per minute), <br />' and may be less for effective ground water extraction and stabilized drawdown <br /> Advanced GeoEnvironmental Inc <br />