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1 ' • Treatment and disposal of significant volumes of extracted groundwater is problematic and was one of the reasons pump and treat was not implemented in 1990 This is still an issue ' today, and even more so given an expected extraction rate of 30 gpm ' • Fenton's Reagent. Fenton's Reagent is infected into the subsurface under pressure via a series of infection points or wells Highly reactive hydroxyl radicals are generated which oxidize hydrocarbons primarily into carbon dioxide and water Because conventional ' Fenton's Reagent operates at a low pH range of 3 — 4, and large amounts of heat and vapor are generated due to the use of high reagent concentrations under pressure, modified Fenton's Reagent patented by ISOTEC was evaluated for the site to replace the conventional Fenton's ' Reagent It uses stabilized hydrogen peroxide and chelated-iron catalysts to avoid the conventional requirements of strong acids and high reagent concentrations, and consequently reduces the generation of heat and mobilized organic vapor and contaminants as well as the ' risk of explosion Modified Fenton's Reagent reacts at a pH range of 5 - 7 The addition of heat and/or liquids below the water level in areas that contain LPH and ' residual phase hydrocarbons may cause downgradient mobilization due to changes in pore pressure Case studies have shown transport of residual hydrocarbons away from infection points (Appendix I) ' Because the saturated zone is heterogeneous and largely silty, infected material is not expected to be uniformly distributed and instead flows in preferential channels in the ' saturated zone, making hydrocarbon removal from fine-grained materials difficult Based on current site conditions, use of this alternative is expected to have limited effectiveness and raises potential risks I I ' CrSProq«ts173942VMA5TERNWP1WP03035WPlx dm 20