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, 1 <br /> In September 2001, six Hydropunch groundwater samples were collected and analyzed for <br /> VOCs from three locations (Haley & Aldrich, 2001b). The full results of the Hydropunch <br /> project were presented in the November 2001 Interim Remedial Action Plan (Haley & Aldrich, <br /> 2001 c). <br /> Pre-remediation tests were performed in the fall of 2001 (Haley & Aldrich, 2001b). This work <br /> included an analysis of general chemistry and indicators of natural attenuation in groundwater <br /> samples, aquifer tests at monitoring well MW-3B, and well testing on the two inactive water <br /> supply wells at the facility. <br /> Data from the first half of 2002 showed reduced groundwater concentrations in wells MW-3B <br /> and MW-413 that historically had the highest levels of carbon tetrachloride and chloroform. To <br /> address this change in site conditions, Haley & Aldrich re-evaluated remediation plans and, with <br /> concurrence from RWQCB, implemented a groundwater extraction pilot test program (Haley & <br /> Aldrich, 2002). The pilot test was designed to evaluate the efficacy of utilizing groundwater <br /> extraction to remediate portions of the aquifer known to be most impacted with carbon <br /> tetrachloride and chloroform. The pilot test was concluded in April 2003. Interpretations of the <br /> test results were presented in the Pilot Test Report (Haley & Aldrich, 2003a), and in the 2003 <br /> Annual Groundwater Monitoring Report (Haley&Aldrich, 2003b). <br /> In July 2003, an application for a WDR was submitted to the RWQCB for a proposed Hydrogen <br /> Release Compound (HRC) injection pilot test. The RWQCB adopted the WDR in October 2003 <br /> (California RWQCB, 2003). Subsequently, the HRC injection pilot test was placed on hold and <br /> the feasibility of other remedial technologies were evaluated during 2004. <br /> A Waste Discharge Requirements (WDR) for a Granular Zero Valent Iron (GZVI) pilot test was <br /> applied for and approved by the RWQCB in October 2004 (Order no. R5-2004-0160). In August <br /> 2004, monthly baseline sampling was started in support of the GZVI pilot study (Haley & <br /> Aldrich, 2005). In April and May of 2005, two new monitoring wells, MW-9B and MW-10B, <br /> were installed in accordance with the WDR to monitor the results of the GZVI pilot test. <br /> Hydraulic fracturing and GZVI injections were conducted on 12 April through 16 April, and 16 <br /> May 2005. A Pilot Study Evaluation Report was submitted to the RWQCB in May 2006. A <br /> Remedial Action Plan was submitted to the RWQCB in February 2007. In October 2007, the <br /> RWQCB granted conditional approval for a recirculation pilot study. This groundwater <br /> recirculation system, consisting of a pair of injection/extraction wells and one new monitoring <br /> well,was installed in May 2008. <br /> 1.2 Hydro eog logy <br /> The geology underlying the French Camp Elevator site consists of thick intervals(individual <br /> units are up to 50 feet thick) of fine-grained sediment(predominantly silt and clay), separated by <br /> occasional lenses of silty sand, sand, and/or gravel (up to 20 feet thick). This formation extends <br /> to a depth of at least 180 feet bgs. The sand lenses are generally semi continuous across the site <br /> 4 <br />