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Harold and Dena Knowles - NW <br /> 102 S. Wilson Way <br /> Page 2 of 3 <br /> GZA has interpreted the dissolved contaminant data to show that three distinct <br /> plumes are impacting your site, two of which appear to be coming onto your site <br /> from adjacent sites. GZA has requested that other parties be given the <br /> responsibility and ownership of those wells monitoring the dissolved MTBE <br /> plume. EHD cannot assign ownership and responsibility for wells to other parties, <br /> but can direct responsible parties to properly investigate, characterize and <br /> monitor their plumes. Exchange of well ownership, etc, must be worked out <br /> between the parties involved. <br /> At this time, EHD believes that the circumstances and data from your site make it <br /> unlikely that the MTBE plume is related to your release, however EHD has not <br /> been able to confidently identify the likely responsible party or parties, or the <br /> proportions contributed by each party to directly seek their assistance on this <br /> matter. To help EHD assist you in this matter, please have your consultant <br /> review the data from the three known sites in the area and, in the context of an <br /> overall site conceptual model (SCM), offer a professional opinion as to the <br /> source or sources of the MTBE and the proportions contributed by each. The <br /> model should show contaminant migration pathways consistent with the <br /> hydrogeological framework in the SCM and account for the observed <br /> contaminant mass distribution and migration history. The model should <br /> adequately demonstrate all your consultant's interpretations and opinions. Please <br /> submit this opinion and SCM to EHD by 03 January 2006. <br /> At this time it appears that monitoring well MW-15C demonstrates the vertical <br /> extent of COCs to be less than 110 to 120 feet below surface grade (bsg) in the <br /> down-gradient direction except for 1,2-DCA. EHD believes the data indicates that <br /> the primary source of the 1,2-DCA plume was on your site. Laboratory analysis <br /> of the grab groundwater samples from CB5 has shown that intensely impacted <br /> groundwater occurs at 74 feet bsg and at 88 feet bsg, moderately impacted <br /> groundwater at 114 feet bsg and less intensely impacted at 140 feet bsg. <br /> Groundwater in MW-13B and MW-16B, both screened 70 to 80 feet bsg is <br /> intensely impacted and no deeper wells are located in the source area. The data <br /> justifies installation of a deeper well in the source area, and the CPT1 data and <br /> MW-15C data indicated a depth of 110 to 120 feet bsg would be appropriate. <br /> Submit a work plan to install such a well in the source area to EHD by 01 <br /> November 2005. <br /> While the vertical extent of impacted groundwater in the source area is not <br /> clearly delineated, the high concentrations of contaminants indicates that interim <br /> remediation of the groundwater would be appropriate. Groundwater is intensely <br /> impacted to depths as great as 88 feet bsg (C135), indicating a column of <br /> intensely impacted groundwater at least 45 feet thick (recent depth to water <br /> approximately 43 feet). Dissolved contaminant concentrations are as high as <br /> 140,000 micrograms per liter (µg/1) TPH-g, 23,000 µg/I benzene and 1,200 pg/I <br />