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f 28 February 2005 AGE-NC Project No 99-0624 Page 2 of 12 ground water plume is somewhat defined to the south with CPT-1 and MW-5 "Accordingly, AGE will propose no additional wells south of Kettleman Lane at the present time • Comment 7-At this time,AGE does not agree with EHD's recommendation that soil vapor extraction be used as a method to remediate soil at the subject site Petroleum hydrocarbon- and MTBE-impacted soil does not appear to be significant in the areas assessed, AGE estimated the volume of MTBE in soil to be approximately 10 gallons The site setting is illustrated on Figure 1 Site structures, soil borings and monitoring well locations are depicted on Figure 2 Site history and background information was presented in the AGE prepared Site Assessment Work Plan dated 11 November 2004 2.0. FEASIBILITY OF INTERIM REMEDIAL ALTERNATIVES Based on the site-specific problems associated with ground water and soil vapor extraction techniques discussed above,the remaining viable remedial alternatives that can be used as an interim remediation would be ozone sparging and batch removal of ground water 2 1 IN-SITU OZONE SPARGING The ozone sparge system is an in-situ air stripping and oxidation process utilizing fine bubbles of ozone infected into saturated soil to extract and decompose dissolved petroleum hydrocarbon constituents An ozone generator is utilized to produce gaseous ozone which is injected into the subsurface via microsparge points or fine well screen The "microbubbles" (approximately 50 micrometers) are forced out into the surrounding saturated soil and react with the target analytes, producing carbon dioxide and water The frequency and duration of ozone infection periods can be regulated at the ozone generator control box Initially, operation of the ozone infection system will be based on the manufacturer's recommendations Infection rates, frequency and duration may be adjusted to compensate for site conditions during a pilot test, based on dissolved concentration reaction to the sparging,ground water flow direction changes and to reduce mounding of the ground water where necessary Costs for installation of an ozone system at the subject site range from$30,000 to$40,000,including the installation of sparging wells and underground piping Based on an operational period of 12 to 24 months, costs for the entire project would likely be between $65,000 and $100,000, depending upon regulatory requirements • Advanced GeoEnvironmental,Inc