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3.ANNUAL REPORT FOR 2013 <br /> Overall,the concentrations of BTEX and TPH constituents began to increase after extraction <br /> stopped from well N-17 in February 2004. This likely occurred because clean, downgradient <br /> groundwater was no longer being pulled into the capture zone (and into wells N-16 and <br /> N-17) to dilute the BTEX and TPH constituents that were being pulled downgradient from <br /> the source area. Since the initial concentration increases after the extraction was shut down, <br /> ' a new equilibrium appears to have been established where the naturally occurring processes <br /> are resulting in decreasing concentrations for the BTEX and TPH constituents. <br /> 3.2 Effectiveness of the Current Remediation System <br /> The current remediation system consists of MNA and the phytoremediation system, as <br /> summarized in Section 1. The combination of these two strategies is effective,resulting in a <br /> sitewide decline in TPH and BTEX concentrations in groundwater and a stable-to-shrinking <br /> extent of these constituents in groundwater. As discussed with the RWQCB during <br /> meetings on July 12,2007, and September 21, 2007,and reflected in the current MRP issued <br /> by the RWQCB, the steady reduction in hydrocarbon mass,as well as reductions in BTEX <br /> ' and TPH concentrations,at the Site are the result of fate-and-transport processes occurring <br /> naturally in the subsurface. These naturally occurring processes are documented in the Final <br /> Site Characterization Report(CH2M HILL,2002) and in the 3-Year Evaluation of the <br /> Bioremediation Pilot Study(CH2M HILL,2007a). The steady reduction in hydrocarbon mass <br /> is shown in the time-series concentration charts in Appendix D and Appendix E. <br /> i 3.3 Identification of Data Gaps and Potential Deficiencies/ <br /> Redundancies <br /> No data gaps or deficiencies have been identified. Routine groundwater monitoring at the <br /> Site was implemented in March 1992. To date, the groundwater monitoring program has <br /> been performed for approximately 21 years and has provided important time-series <br /> information with respect to groundwater elevations and gradients, NAPH thicknesses, and <br /> chemical concentrations in groundwater and surface water. Seasonal patterns in <br /> groundwater elevation fluctuations,as well as seasonal and long-term trends in BTEX and <br /> TPH concentrations,have been identified, as documented in the Final Site Characterization <br /> Report (CH2M HILL, 2002) and in subsequent routine groundwater monitoring reports. <br /> Robust data have been collected to demonstrate that the naturally occurring processes are <br /> sufficient to result in a continued declining trend of these hydrocarbon constituents without <br /> the active remediation systems, as documented in the 3-Year Evaluation of the Bioremediation <br /> Pilot Study(CH2M HILL,2007a). <br /> No redundancies have been identified regarding the wells that are sampled and analytes <br /> that are analyzed in the laboratory. Current MRP No. R5-2007-0831 was developed to be <br /> streamlined to monitor current Site conditions with MNA and phytoremediation as <br /> remedies. This MRP eliminated most of the parameters added in the previous MRP to <br /> monitor the bioremediation pilot test,eliminated unnecessary monitoring wells and <br /> parameters,allowed for the destruction of unnecessary monitoring wells, and allowed for <br /> the destruction of the soil vapor extraction well system. <br /> ' WBG101513183707SCO/HOLT_2SA13_REPORT_FINAL 3-3 <br />