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tMr. James L. Barton <br /> ' January 17, 2008 <br /> Page 2 <br /> ' vertical and lateral extent of impacted groundwater, the redesign of the remediation system included <br /> replacing the existing AS piping, air compressor, and system controls. Additionally, the RSRT <br /> recommended the testing of the existing AS piping for integrity (pressurized air flow without leaks)and the <br /> ' AS points for operability (pressure, air flow), and to evaluate need to install new AS points to improve the <br /> ability to address the extent of vertical groundwater impacts. ENSR conducted the field testing in February <br /> and March 2007. Findings from ENSR's field testing included: <br /> ' • At 40 to 60 pounds per square inch (psi)of pressure, approximately 30 to 50 standard cubic feet <br /> per minute(SCFM) of air flow was being lost in the AS conveyance piping. <br /> ' • On the former Wards property, ENSR observed field measurements that confirmed sparging was <br /> occurring, but not at the deeper depths of the most impacted monitoring wells. <br /> • On the former Unocal property, ENSR observed pressure at the wellheads of the sparge wells, <br /> ' however, the sparge pressure was too low to establish air flow at these wells. <br /> • Air flow can be established in wells on both sides of Robinhood Drive by using a higher-pressure <br /> capacity air compressor than is currently being operated at the Site. <br /> The results from the field testing, the basis for the system re-design, are presented in ENSR's memo <br /> dated March 28, 2007, which is included as Attachment B. Based on the results from the field testing, <br /> ' ENSR designed the upgraded AS/SVE system and presented the design to the RSRT in May 2007 for a <br /> review of the design's technical soundness, compliance with EMC's safety devices/specifications, and <br /> ability to achieve the desired goals. Once a vault has been installed with a valve to isolate the conveyance <br /> ' line under Robinhood Drive and the dedicated piping for the new AS wells, the integrity of the conveyance <br /> line under Robinhood Drive can be further evaluated. If the additional testing indicates that the line has <br /> been compromised, a remedy will be proposed for implementation at that time. <br /> ' Comment No. 2 <br /> ' The Workplan does not include labeled geologic cross sectional views of the remediation well construction <br /> and the lithological sequence to be remediated. Submit two geologic cross sections oriented as an "X"(at <br /> right angles), and include the proposed remediation wells, along with the existing remediation and <br /> tmonitoring wells, within the lithology of the remediated zones. <br /> Response No. 2 <br /> The requested cross-sections are presented as Figures 5 and 6. <br /> ' Comment No. 3 <br /> Revise the map or plan view to include the lines of above cross sections indicated as an "X"on <br /> ' Attachment B Figure 2(attached). <br /> Response No. 3 <br /> ' Figure 4 shows the locations of the requested cross-sections presented in Figures 5 and 6. <br /> ' 01231-154 <br />