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v ReviewComments on the Revised Hydrogen Report (Phase Z and II) and Phase ITZPhase Iv work Plan.t~ <br />down- radient portions of the site. All three of the borings show,the occurrence of <br />sand ~ayers, previously not shown on cross-sections at these locations, which are <br />present within the till. These sand layers lead to questions regarding the <br />' continuity of the till layer and potential connection between the upper and lower <br />outwash units. <br />cross-section A-A' <br />Additional data from P318~ indicates <br />within the till. The upper sand layer <br />shown for sB~32. The lower sand layer <br />lower till contact elevations for s6-31 <br />the two sand layers to be in connection <br />of the site. <br />the occurrence of two significant sand layers <br />(913 to 919) correlates with a sand layer <br />(889-905) is 16 feet thick, eased on the <br />and Ss-33, there is a potential to interpret <br />with the upper outwash unit for this portion <br />cross-section s-B' <br />The additional data collected for P318~ adds significance to the 1ithblogic <br />interpretation for borings sB15, 5616 and ss-17 which shows a significant sand layer <br />roughly between 890 and 916 for these borings. The sand layer dips down to the east <br />and west of sa16 with a trend that could potentially intersect the lower outwash <br />unit. This sand layer may be connected to the sand layers shown in cross-section <br />A-A' with the potential that the upper and lower outwash units are cannected to farm <br />a groundwater flow pathway. <br />Cross-Section G-G` <br />The litholo~ic data for 317E shows the occurrence of two sand seams (907-912 and <br />$$7-897) within the till. A significant sand layer (893-902) is shown for sa35 <br />further to the south. There is a strong potential for these sand layers to be <br />connected although the cross-section does not show this. There is also a potential <br />that the ~ower sand seam could be connected to the lower outhwash unit. <br />The information from the additional deep borings shows the complexity of the geology <br />and potential lack of continuity in the till confining layer in the south and west <br />portions of the Site. Hydraulic connection between the upper and lower outwash <br />units is not supported by water level monitoring information far nested wells. The <br />water level data show a vertical head difference of approximately 4.5 feet between <br />the outwash units at all locations for this area of the site. <br />Cross-section H-H' has been redrawn to show discontinuity in the outwash and a <br />groundwater flow boundary located between Sa-2 and sB~9. Figures 17, 19 and 20 <br />should be revised to show the extension of the flow boundary further to the east in <br />the northwest area of the s~A. <br />section 5.0 discusses the manitoring wells proposed for the compliance boundary of <br />the s~A. City of Elk River comments of May 11, 2004 identified the concern <br />regarding the proposed distance of •the wells from the fill limit during the early <br />years. of operation. The City suggested that a sequenced approach be taken for the <br />compliance boundary and the placement of compliance boundary wells coinciding with <br />the 10-year fill limit. MPCA correspondence dated July,26, 2005, from aohn Elks to <br />Terry 7ohnson of wMZ indicates that a phased approach will be used for the <br />compliance boundary. The city supports the MPCA in relocating proposed monitoring <br />page 2 <br />