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Distribution

Technical Report

- Site Closure

URES

March 2014

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ACTIVE AND ABANDONED PRODUCTION WELLS
Fnvlionmental Consultants
879g Balboa Avenuo, Suite 290
Sen Diego, California 92123

BlackRock
Port LA Distribution Center
300 Westmont Drive
San Pedro, California

Project No.:
01205526.00

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APPENDICES

Technical Report - Site Closure

March 2014

Port

Distribution Conte'.

Appendix

Dissolved- and LNAPL Plume Stability Evaluations and
Discussion of Cleanup Implications
Aqui -Ver, Inc'.
August 30, 2011

To cí7

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port - Site Clatu re

March 2014

DISSOLVED- AND LNAPL PLUME STABILITY EVALUATIONS AND
DISCUSSION OF CLEANUP IMPLICATIONS

FORMER WESTERN FUEL OIL FACILITY
300 WESTMONT DRIVE
SAN PEDRO, CALIFORNIA
August 30, 2011

For:

Mr. Leland Nakaoka
BlackRock Realty Advisors
4400 MacArthur Boulevard, Suite 700
Newport Bench, CA 92660
In Cooperation With:
SCS Engineers
8799 Balboa Avenue, Suite 290
Sau Diego, CA 92123

AQUI -VER, INC.
Hydrogeology Water Resources & Dala Services

DISSOLVED- AND LNAPL PLUME STABILITY EVALUATIONS AND
DISCUSSION OF CLEANUP IMPLICATIONS

FORMER WESTERN FUEL OIL FACILITY
300 WESTMONT DRIVE
SAN PEDRO, CALIFORNIA
For:
Mr. Leland Nakaoka
BlackRock Realty Advisors
4400 MacArthur Boulevard, Suite 700
Newport Beach, CA 92660
In Cooperation With:

SCS Engineers
8799 Balboa Avenue, Suite 290
San Diego, CA 92123

By:

AQUI-VER, INC.
Hydrogrodqgy, Water Resources' cF Data Scrvices
Principal Authors:

C.D. Beckett, R.G.,

CilG,, Principal Hydrogeologist

Nathaniel Beal, P.G. Senior Hydrogeologist

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AQUI-VER, INC
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TABLE OF CONTENTS
ES-1

EXECUTIVE SUMMARY
1.0

DISSOLVED PHASE PLUME EVALUATIONS
1,1 PURPOSE
1.2 METHODS
1,3 DISSOLVED -PHASE MASS ESTIMATES
1,4 ESTIMATION OF CENTER OF MASS THROUGH TIME
n . . . . ... :..:
1.5 PLUME LONGEVITY EVALUATION
4,
1.6 FLUX CALCULATIONS
FATE AND TRANSPORT
i
,
.
1,8 METHOD CONSERVATISM
1.9 SUMMARY OF DISSOLVED PLUME CONDITIONS EVALUATIONS

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APL PLUME EVALUATIONS
2,1 OVERVIEW OF MULTIPHASE MECHANICS
2.1 BASIC PETROPHYSICAL PROPERTIES
. , ,
.
... .
2.2 CAPILLARITY ,
2.3 LNAPL SATURATION
.
.
.
.
. . .
. .
2.3.1 In Situ LNAPL Saturation
LNAPL
Saturation
Results
Mobility/Three-Phase
Residual
2,3.2 LNAPL
2.4 LNAPL PHYSICAL PROPERTIES
2,5 LNAPL CONDUCTIVITY
2,6 LNAPL VELOCITY POTENTIAL-

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Table -3:

Dissolved Mass Estimate for TBA
Longevity Estimate for TBA
Potential Flux Impacts to Groundwat

Table 2 -1:
Table 2 -2a:
Table 2 -2b:
Table 2.3:

LNAPL Hydraulic Conductivity Estimates
Data Used to Determine LNAPL Gradients
LNAPL Gradient Results
Estimate Range of Potential LNAPL Linear Pore Velocity

j7
17
19

..,......,.,. :...::::.. ......... ......... ........ ........ 23
LIST OF TABLES

'Fable -1:
Table -2:

,22

4.0 REPORT CLOSURE
5,0 BIBLIOGRAPHY

l.1

......... ,..,.12

....:......... ..::

3.0 EVALUATION OF LNAPL PLUME AND CLEANUP CONDITIONS
3.1 LNAPL STABILITY CONSIDERATIONS
.
.
, . ..
3,2 LNAPL CLEANUP CONSIDERATIONS

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LIST OF FIGURES
Figure I -l:
Figure l -2:
Figure 1-3:
Figure
Figure
Figure
Figure
Figure
Figure

2 -1:

Figure
Figure
Figure
Figure
Figure
Figure

Site Plan
TBA in Groundwater - August/December 20
Benzene Center of Mass Through Time

Time Series of LNAPL Saturation Distribution under Release Conditions
Literature Ranges for 2 -Phase vs. 3 -Phase LNAPL Saturation

2-2:
2 -3:
2-4:
2 -5:
2 -6:

Initial vs. Residual LNAPL Saturation Results
Example of LNAPL Saturation vs. Applied Pressure
Southwest to Northeast LIF Intensity Cross Section A -A'
Southwest to Northeast LIF Waveform Cross Section A -A'

-I:

Generalized Saturation Profiles Expected Under Cleanup Conditions
Generalized Benzene Change over Time Under Cleanup Conditions
Generalized Chemical Component Stripping By SVE & IAS
Ratio of Benzene to Ethylbenzene at MW -10 Overlapping IAS /SVE Cleanup
Image of IAS In -Situ Air/Stripping Distribution in a Fine Sand
Estimate of 1AS In -Situ Air /Stripping Distribution in the Gage Aquifer

3-2:
3-3:
3-4:
3 -5:
3 -6:

APPENDICES
Appendix
Appendix
Appendix
Appendix
Appendix

-l:

-2:
I -3:
1-4:
l -5:
I

Appendix 2 -I:
Appendix 2 -2:
Appendix 3 -1:

Evaluation Methodology
Dissolved Phase Benzene Plume Maps
Dissolved Phase TBA Statistical Trends
Flux Estimate Calculations
BIOSCREEN Model Inputs & Results

Capillary Parameter Derivations
LNAPL Thickness and Groundwater Piezomenìc Ì-Sydrographs
Key API LNAPL Screening Inputs and Results

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EXECUTIVE SUMMARY
AQUI-VER, INC. (AVI) has completed technical evaluations on behalf of BlackRock Realty
Advisors regarding dissolved and light non-aqueous phase liquid (LNAPL) plume conditions present
beneath the former Western Fuel Oil Site, 300 Westmont Drive, San Pedro, California. The site is
presently operating as the San Pedro Business Center, which handles Port- related commerce and
transportation.

AVI's evaluations consisted of technical

analyses to determine the state of the tert-butyl alcohol
-phase
plumes,
and separate evaluations to determine the state of the
(TBA ) and benzene dissolved
LNAPL plume remaining beneath the site.
Based on several lines of technical evaluation including mass, flux and trends, the TBA plume is
indicated to he stable and Is not being transported into the wider aquifer offsite. This, coupled ,,vith
the marginal quality groundwater beneath the site suggest that this plume meets State standards for
presenting no threat to future groundwater use In addition, potential T'BA mass flux evaluations
indicate that there is generally no threat to future groundwater use at the Site itself.
Based on several lines of technical evaluation, the LNAPL plume remaining beneath the site has also
been determined to be stable. This is due to a number of factors such as time since release, the site
specific subsurface parameters, the observed plume morphology, and other facets. Past cleanup
actions have also likely contributed to this observed LNAPL stability condition.

A framing of the technical exceptions for further LNAPL cleanup was also developed. Given the
site conditions, including past cleanup, there appears to be no net benefit to the waters of the State
to additional cleanup measures. Any cleanup measure having any remote chance of further reducing
contaminant concentrations in the near. term would also severely impede the Port Distribution
Facility operations. As a successful Brownfield redevelopment project, the active use of the site is
important to the area economy.
Given these findings and conclusions, AVI's work suggests that the site move into a monitored
natural attenuation phase, with no further active cleanup, in keeping with the SWI CFS Resolution
92 -49 and the recent SWRCB update to low -risk groundwater policy (2011).

6101 NorW fl200

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Ph. 035 655.13024

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AQth-Y Eli , INC:
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DISSOLVED PHASE PLUME EVALUATIONS

This chapter discusses dissolved phase plume evaluations with respect to stability, status, and threat
to the waters of the Slate. As discussed below, several techniques were used to evaluate the
dissolved phase plumes at the site as related to closure and long -term management considerations.
1.1

PURPOSE

The purpose

of this ttnälyss

two fold:

Evaluate the stability, potential longevity, potential impacts to groundwater utilization, and
the potential fate and transport of the tert-butyl alcohol (TBA) groundwater plume; and

Evaluate the stability of the ben7ene gi oundwatet plument the bite to assist in evaluattng the
LNAPL plume stability in Chapter 2 of this report.

TBA

and tertiary -arnyl alcohol (TAA) are currently the chief dissolved phase fuel oxygenates
of concern (COCs) at the Site; however, T'AA was not evaluated in this analysis due to
the limited data set for this compound, For example, TAA was only sampled in the core of the
plume (wells MW -6R, MW -I4R, and MW -19R) one time, in August 2007, and site monitoring
wells were not analyzed again for TAA until June 2008. In addition, TAA has not been detected
more than once in any of the onsite wells. As 'such, only 'FBA was analyzed during this evaluation,

chemicals

The benzene plume was evaluated because it provides insight into the stability of the LNAPL
plume. For example. if the benzene plume is not moving dowitgradient or is contracting then one
can infer that the LNAPL plume, which is the source of the benzene plume, is not moving as well
This relationship is described in more detail in Chapter 2 of this report.

All analyses presented herein were performed using data provided by

SCS Engineers and from
documents on Geotracker (SWRCB, 2011). Data analyses were performed on the data as provided
and only reflect the most recent data electronically available (generally through June 2011).

will

1.2

METHODS

utilize historic groundwater
concentration data, in context with other site characterization information, as a key indicator of the
historical and future probable plume state. This focus was developed because groundwater is in
contact with residual petroleum hydrocarbons, and understanding the stability, potential plume
longevity, potential impacts to groundwater utilization, and potential fate and transport of the TBA
plume and the stability of the benzene plume in relation to the LNAPL plume directly affect
long -term site care requirements and closure.
be described subsequently, the evaluations conducted herein

valuutìon methodologies and procedures for the plume longevity estimates, potential
impacts to groundwater utilization, and plume stability are provided in Appendix -I, and are
derived from plume genesis and transport theory. The methodologies are consistent with United
1

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hydrogrr9n¿,ry. Nhalfthe laboratory reporting
limits, with exceptions. Elevated laboratory detection limits ranging from 100 to 500 ug /L were

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reported For well MW -10R. Half of the detection limits are greater than or just below historical
detections so non- detect data were not used for the trend analysis for MW-10R to avoid biasing the
trend by using unconstrained non- detect points. The statistical trends exhibited by MW -9R and
MW -1 OR were decreasing over time and these decreasing trend lines were projected through time
until they reached the California drinking water notification level (NL) for TBA, which is 12
micrograms per liter (ug/L),

The exponential trend regression was performed on the time /concentration data using a confidence
interval of 95 %. Confidence intervals assume a normal distribution about a mean of the predicted
scion fit. Then the standard deviation ofthe samples about the predicted concentration Is used
to bound the data Exponential statistical analysis is consistent with the theoretical form of chemical
transport and depletion processes. A linear analysis would tend to estimate shorter plume durations
and be both less conservative and less reflective of the underlying plume depletion processes.
The statistical trend analysis plots for TBA through time for wells MW -9R and MW -IOR are
included in Appendix l -3. Using the statistical regression fit of the concentration data, as shown
in Appendix 1-3, the time to reach the regulatory criteria for TBA was estimated for these wells as
summarized in Table l -2, While the trend predicts when the compound will reach regulatory
criteria, the actual concentration is expected to range between the upper and lower bounds of the
trend line. As summarized in Table I.2, by using both the curve lit and upper 95% confidence
bound, a range of times to regulatory criteria arc estimated with the later date providing a more
conservative estimated

Wells M W -9R and MW- OR are generally located on the downstream portion ofthe plume and are
downgradient of the center of mass. Based on the statistical trends in these wells TBA is predicted
to reach the NL of 12 ug /L, between 2012 and 2015 in well MW-9R and between 2018 and 2 024 in
well M W -I OR. In addition, the decreasing trends in both wells suggest that the leading edge of the
TBA plume is stable and has retracted through time A non -stable or expanding plume would
exhibit an increasing trend Jilong the leading edge of the plume, 'Chus, the 'FBA plume has likely
reached a steady state. This is further supported by the fact that TBA has not been detected in offsite
downgradient well MW -8 located on the ConocoPltillips site (Figure 1.2).
I

1,6

FLUX CALCULATIONS

The statistical mass evaluations for TBA described in Section 1.3 can be used to estimate the
potential groundwater flux of TBA emanating from the site The flux estimate is generated from
the plume -wide statistical groundwater concentrations developed earlier for the geometry of the
plume and the potential groundwater flow rates through the plume. This integrated average
concentration (the some as used in the mass calculations), accounts for spatial plume distribution
that a simple arithmetic average cannot. The flux estimate is used to estimate the potential
worst -case impacts at a hypothetical drinking water production well located onsite. This estimate
is conservative and alleviates the need for more extensive modeling evaluations that would show
significantly smaller potential impacts. The flux estimate pertains to a hypothetical groundwater
production well completed at the site with two different well screen interval scenarios. The first
scenario assumes a well screen of 50 feet which is twice that of the assumed impact thickness in the
shallow water bearing zone. This scenario is the most conservative of the two. The second scenario
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a screen length of 100 feet. Scenario two assumes that the production well screen will
nearly fully penetrate the Gage Aquifer beneath the site.

assumes

Hydraulic conductivity was set at i foot per day (ft /clay) based on a report from CAPE (2007), the
effective porosity was set at 25% based on a report from SCS (2009), and the lateral hydraulic
gradient was set at 0.007 feet per foot (ft/ft) based on SCS (2009). The current lateral hydraulic
gradient in the shallow water bearing zone is 0.003 ft /ft (SCS, 201 lb); therefore, using the higher
gradient of0.007 ft/ft is more conservative. The conceptual groundwater pumping well is assumed
to capture 100% oftheconservative chemical flux emanating in groundwater from the Site The flux
analysis results arc summarized in Table -3 and estimate potential impacts to a production well at
various flow rates, The input and output factors for this flux analysis are provided in Appendix 1.4.
1

For TBA, there is no predicted impact above the regulatory threshold or 12 ug /L for all scenarios
and pumping rates. Furthermore, utilization of groundwater from the Gage Aquifer would require
treatment (e.g., reverse osmosis) to remove naturally occurring dissolved phase constituents as
indicated by water quality samples collected by SCS (2011b), Curing this treatment process
dissolved phase TBA would most certainly be removed from the produced water. As such, this
analysis demonstrates that potential impacts to future groundwater use are unlikely and the TBA
plume poses no risk to the waters Mite State, especially considering the natural poor groundwater
quality in the Gage Aquifer beneath the site.
1.7

FATE AND TRANSPORT

To assess the potential lateral migration of the TBA plume existing data collected from the site and
assumed parameter values from published literature were used in conjunction with an analytical
modeling approach to evaluate plume stability.
The analytical modeling was conducted using the computer program k ItiSCREEN (Newell and
Mcleod, 1996). BIQSCREEN is specifically designed to simulate transport and natural attenuation
of dissolved phase hydrocarbons at petroleum release sites. The software has the ability to simulate
advection, dispersion, adsorption, and aerobic decay as well as anaerobic reactions that have been
shown to be the dominant biodegredation process at many petroleum release sites, BIOSCRPCN
includes three different model types;
Solute transport without decay;
Solute transport with biodegredation modeled as a first =order decay process (simple
lumped -parameter approach); and
Solute transport with bindegredation modeled as an " instantaneous" biodegredation reaction
(approach used by BIOPLUME models),
For this effort, solute transport with biodegredation modeled as a first -order decay process was
selected because of the limited amount ofdata available to support the instantaneous reaction model.

CREEN is based on the Domenico (1987) three- dimensional analytical solute transport model.

The original model assumes a fully- penetrating vertical plane with the source oriented perpendicular
to groundwater flow, to simulate the release of organics moving into groundwater, In addition, the
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Domenico solution accounts for the effects of advective transport, three -dimensional dispersion,
adsorption, and first -order decay.
The source area concentration was set at 18.4 milligrams per liter (mg /L), which is the maximum
observed TBA concentration at the site (MW -14R). The size of the source area was conservatively
defined using the TBA plume dimensions from August /December 2007, as shown by Figure I -2.
The depth of the source area was set at 25 feet, which is the assumed impact thickness for TBA. A
further conservative assumption is that the source area concentration remains constant at its existing
titration Indefinitely. This combination of assumptions is likely to produce the most
votive analysis based on available data The model input parameters arc summarized in
Appendix 1.5, Where appropriate, model input parameters reported by SCS (2009) for the
previously conducted benzene BIOSCREEN modeling were used for the TBA BIOSCREEN
modeling,

The model was calibrated based on field data from August /December 2007 by adjusting solute half
life and the related first order decay coefficient as well as dispersivity until output results fit the field
data set. The best fit was based on the parameters shown in Appendix -5, Based on this calibration
TI3A must be naturally attenuating because the modeled plume would not fit the field data unless
a decay coefficient was assumed, albeit a low decay coeff cientwassimulated, The former Western
Fuel Oil site ceased petroleum operations in 1995. The facilities that served those operations were
demolished between 1997 and 1999 in preparation for redevelopment of the San Pedro Business
Center. Therefore, releases likely ceased by 1995 when the operations stopped, excepting the
possibility of small releases from leli -over product in piping or other ancillary structure, By the end
of demolition, that potential residual source was also eliminated. Assuming no natural attenuation
"WA would have likely been detected in the furthest most downgradient well (MW -8 at the
ConocoPhillips site) by 2007, This well is approximately 500 feet from the source and TBA has
never been detected in this well Thus the TBA plume is likely stable and generally confined to the
site by natural attenuation processes,
1

It should be noted that this approach is not sufficiently rigorous to represent an exact prediction of
site conditions. In addition, calibration using the field data was done using reasonable assumptions,
but there wore some limitations. For example, the defaults for the "distance from source" in the
BIOSCREEN model were not exactly equal to the distances observed with the field data, as such
the model calibration represents the best fit given these limitations. In addition to the field data
imitations, the simulation itself incorporates several limiting assumptions; however, these
ptions do not affect the overall conservative conclusions,

METHOD CONSERVATISM
The plume evaluation methods detailed in Appendix 1.1 and resultant findings summarized in this
report provide conservative, worst -ease evaluations of site -specific dissolved -phase plume
conditions, longevity, and potential impacts to groundwater use The cumulative consideration of
these aspects of plume behavior leads to a conservative, weight of evidence approach using site data,
The underlying premises of the analyses are that observed temporal and spatial groundwater data
trends are the actual observed end products of all partitioning and transport phenomena. These
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methods are derived directly from plume partitioning and transport processes, and are consistent
with USEPA recommended protocols for evaluating plume trends (USEPA, 2002), These methods
have been applied successfully for State Water Resources Control Board Resolution 92 -49 closures
in San Diego; Los Angeles; and, Orange Counties. A brief summary of the conservative factors in
the analyses is provided in the list below,

Geographic -based dissolved -phase mass estimates: When the plume masses are estimated
at different time stamps, an area greater than or equal to the general maximum historic
Footprint size of COC for all subsequent plume mass calculations is used as the outer bound
of the Integration and "Not Detected" (ND) concentrations are expressed as the general
detection limit. Therefore, this conservatively overestimates the dissolved -phase mass in
depleting plumes.

Temporal well by well plume longevity evaluation: The upper 95 % confidence bound has
been used in predicting time to regulatory criteria which adds conservatism to the estimates.
Additionally, the estimates do not account for acceleration of degradation processes as mass
decreases and the assimilative capacity of the aquifer and vadose zone increases, resulting
in conservative estimates, particularly for wells in the plume core.
Mass flux calculations: It is assumed that the hypothetical production well (theoretically
placed on -site) will capture 100% of the already conservatively over- estimated plume mass
The hypothetical groundwater production rates are assumed without
discharge.
consideration whether the aquifer could indeed sustain production at economically viable
rates. When this analysis suggests no risk, it means in effect that a drinking water well could
be placed in the center of the plume and net concentrations at that well would be below
applicable maximum regulatory levels at various flow rates.
In summary, these various layers of conservatism mirror USEPA risk assessment practice s and those
of ASTM to provide a direct analysis based on data rather than models, to assess the safet
closures under Resolution 92.49. It is estimated that the safety factors involved generate morethan
3 orders of conservatism over actual expected conditions.
1.9

SUMMARY OF DISSOLVED PLUME CONDITIONS LNALUATIONS

The following summary points provide key observations of dissolved -phase plume eonditio
site based on the data provided:

at the

The geospatial mass distributions illustrate the plume stability for benzene (Figure lNo wells were observed to exhibit increasing TBA trends and the Wells with sufficient data
for a trend analysis exhibited a decreasing trend and reach the regulatory criteria by at the
latest 2024 in the wells that are located along the leading edge of the plume (Appendix I -3).
Thus the center of mass of the TBA plume is likely stable and r not moving downgradient.
Worst -case scenario predictions using the mass flux from the site to estimate maximum
concentrations of TBA at a hypothetical drinking water well result in no impacts above
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regulatory criteria for TBA (Table 1.3). Furthermore, utilization of groundwater from the
Gage Aquifer would require treatment to remove naturally occurring dissolved phase
constituents. During this treatment process TBA would most certainly be removed from the
produced groundwater.
4.

TBA has not been detected in off-site ConocoPhillips well MW -8 and has not been detected
above the NL (12 ug /L) in offsite well MW -I2, both of which are located directly
downgradient ofthe source area. MW -8 (ConocoPhlllips) and MW -I2 have generally been
monitored for TBA since it was first detected at the site (2007); although MW -12 was
abandoned in 2009.

The plume trends and fate and transport analysis suggests that the TIM plume is stable
laterally and is attenuating, which is further supported by the absence of detections in
downgradient well MW -8 located on the ConocoPhillips site.

As discussed in the main body of the Corrective Action Plan (CAP) report, the IBA plume
is also contained vertically by predominantly upward vertical gradients in the Gage Aquifer
beneath the site.

Based on the summary of findings above, the TBA plume appears to be stable and contained by
natural attenuation processes. This, coupled with the marginal quality groundwater beneath the site
suggest that this plume meets State standards for presenting no risk, and no threat to future
groundwater use.

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2.0 LNAPL PLUME EVALUATiONS

Various light non -aqueous phase liquid (LNAPL) flow and transport properties have been measured
at the site. Coupled with the physics of multiphase flow, the following report sections discuss the
parameter values, as well as the implications and findings from those.
2,1

OVERVIEW OF MULTIPHASE MECHANICS

Light non -aqueous phase liquid (LNAPL) flow and stabilization (mobility /stability) can be
understood through the physicscontrolling the movement of one fluid phase in the presence of other
phases (multiphase flow). Multiphase physics account for the hydraulic interactions and movement
of multiple fluids in the pore space, which for these site conditions typically Include water, vapor,
and LNAPL. 'Those physics control the nature and genesis of' LNAPL plume releases. Ignoring
compositional reactions, multiphase mechanics are governed by the Continuity Equation for mass
conservation (Equation 1), which describes the mass movement of any phase in any direction for
a non-deforming coordinate system (l tuyukorn et al., 1994; Panday et al., 1994),
Where: now is the differential operator, z,
Pt
Ó
the Cartesian direction of the
indicates
I)
(6 p S)
-11f
rk k rp
]
p
p
q
3dimensional
differential equation, ku is
p
of
2'
&x:
the intrinsic soil permeability tensor, k,.,, is
the relative permeability scalar to phase
"p ", strbscr'ipt "p" refers to the fluid phase of interest, (Pis the fluid potential (( ckle c), , is the fluid
potential gradient), "t" is tine, p is soil porosity, p is the density of phase "p", 5 is the phase
saturation, and M is a rrtas's sourcc/sink term.
Despite the complexity of the continuity equation, the principles it represents are easily described.
Movement of any phase (water, LNAPL, or vapor) in any_primary Cartesian direction (represented
by the left side of the equation) is controlled by the fluid and soil properties and the gradient in that
phase at any point in time and space. Net phase movement into or out of an elemental volume must
be equaled by a coincident change in mass within that volume (the right side of the equation). If
either the phase conductivity or the phase gradient is zero, there is no phase movement or mobility.
The fluid potential 9? includes u gravity term, and for LNAPL, is driven by the head conditions of
the LNAPL release, overprinted to varying degrees by the water table gradient.
As a result of these physics, one would expect the development of LNAPL bodies to be highly
controlling physics. An
transient in the early stages of the release due to the nonlinear aspects of
Ideal plume, superimposed on a 0,001 Feel per foot (it /ft) groundwater gradient, would develop
through time as shown in the time series sequence of LNAPL saturation distribution in Figure 2 -1.
One can see from the LNAPL distribution that the LNAPL gradient is initially mounded, with flow
in both tip- and down -stream directions relative to groundwater flow. The LNAPL gradient
dissipates through time, and the mass redistributes laterally, depleting ti fraction olthe concentrated
central mass that was present during the early stages of the release. LNAPL saturations generally
remain greatest in the mass ccntroid area and are lesser in areas distal to the release zones.
As a result of these mechanics, a finite LNAPL release will slow exponentially through time,
eventually coming to static equilibrium with the prevailing field conditions. There are 4 key
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mechanisms that explain this expected stabilization through time, each ofwhich can be amplified
by geologic heterogeneity:
1.

The LNAPL gradient diminishes through time, as the fluid head created by the release
cannot be sustained without an ongoing release;
Many porous materials have a pore entry pressure; non -wetting fluids, like LNAPL in most
conditions, cannot intrude without a sufficient pressure gradient in that phase;
The LNAPL effective conductivity diminishes through time as the finite volume of oil is
spread over larger volumes of aquifer materials. As this occurs, the overall LNAPL
saturation decreases as a function of spreading and the relative permeability toward oil also
decreases exponentially. This is accentuated by water table fluctuations like the overall rise
in site area water levels due to the sea water barrier system, acting to redistribute LNAPL
over larger volumes of aquifer and vadose zone materials, as well as stranding significant
immobile fractions beneath that risen water table;
Soil has a capacity to hold oil against drainage as residual, This means that a finite LNAPL
release will theoretically be retained as residual at some maximum spreading distance. In
practice this final endpoint is not generally observed because of the other tacets of
stabilization,

Given the factors above, there are several interpretive aspects that can assist in assessing the state
oftha LNAPL stabilization process at the site. Given the unknowns on release specifics and timing,
it is often observed that no single line of evidence is sufficient for the stability evaluation. The
evaluation of plume stability /mobility herein uses a weight- oFevidence approach considering all
these factors and interpretations. The associated lines of evidence include,

I.
2.
3.
4.
5,

6.
7.

Confirmation that the LNAPL releases are finite and not ongoing in the site;
Evaluation of the relative ange of the LNAPL plumes; the older a plume, the more probable
It has reached field static equilibrium;
Evaluation of LNAPL gradients;
Comparisons of estimated LNAPL to water conductivity values;
Evaluation of LNAPL flow;
Review of petrophysical properties, including expectations For an entry pressure threshold;
Inspection of LNAPL plume distribution to consider whether the morphology is consistent
with the form of a stable plume.

The sections that follow present the site data pertinent to the controlling physics described above.
2.1

BASIC PETROPHYSICAL PROPERTIES

Basic petrophysica.l properties are those that have some direct and indirect Influences on LNAPL
volume, mobility, and transport, but are not the most sensitive of the influencing factors. These are
commonly measured parameters for application to a wide spectrum of geological and engineering
practices. For this site, they include permeability, porosity, grain and bulk density, moisture content,
and grain -size distribution. Reports generated by the petrophysical laboratory are presented In the
recent comprehensive site investigation (SCS, 201 la); recall that there have been multiple data
collection events, and different sets of parameters were derived during each testing stage, An
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overview of the results of permeability, grain -size, and porosity results is discussed below. The
remaining parameters are less important and are available in the lab reports,
The hydraulic conductivity of the upper aquifer materials has been estimated at about I ft /day
(CAPE, 2007), This corresponds to a soil permeability in the hydraulically responsive zones of
about 0.35 Darcy. Lab testing oft soil cores indicated intrinsic permeability ranging from 0.059 0.087 Darcy (SCS, 201 Ia), smaller than the field -derived value. Typically, field values are favored
as the hydraulic responses represent flow across a larger domain that is less affected by the scale of
the sample than are soil cores.
The grain -size distributions for the soil samples indicates that most of the materials are primarily
fine -grained sand with significant silt and some clay. Except for one sample, SCS -B3 -91 0 that had
about 6.5% tines (silt + clay), the remainder had fines ranging from 20.9 - 62.1 %, with a geometric
mean of 32.3% and a median of 34:9 %. This significant fraction of fines suggests that LNAPL
movement/recovery will be limited because of the high expected capillarity; oil moves less readily
in materials with small pore dimensions, all other things being equal. Measured capillary properties
are discussed below.

Porosity has been measured for several samples, ranging from 24.1 - 47.6 %, with a median of41.9%
and a geometric mean of 40.1 %, The lower values in the 24% range are low for granular
sedimentary materials, but the median and geometric mean values are well within the expected range
for predominantly sandy and silty materials,
2.2

CAPILLARITY

Soil capillarity controls the saturation of any phase (water, oil, air) as a function of fluid pressures
and the pore throat distribution In the sample soil core. Capillary pressure is the difference In
pressure between the non- welting and wetting phase for any couplet (water -air, water -oil, oil -air).
The capillary curves are different for each couplet as a function of the interfacial tensions between
the fluid pairs. However, because the pore geometry is the same for a given sample core, these
curves are scalable to one another by the ratios of interfacial and surface tensions (parr et al., I990),
That means that a single capillary curve for one couplet, say water -air, can describe the remainder
01 the system All three couplets are needed to describe the multiphase conditions of the full system
as described in Equation 2 -I earlier in this section.
swing the norms in the multiphase field, air -water capillary curves were measured for two
ed cores collected in the 201 I characterization events (SCS, 201 I a). Based on the lab data,
AV I determined the capillary parameters presented in Table 4.4 (data and curve fits are in Appendix
2 4). Briefly, smaller values of "cc" indicate overall smaller pore diameters with a larger capillary
indicate a more uniform yore geometry. As expected from the grain-size
rise. Larger values of
results, these two samples exhibit high cap llai ty (high water retention, and a low "a" value). The
residual water saturation is the asymptotic value of the left side of the curve. Last, the breakthrough
pressure is the capillary pressure at which air initially displaces water at 0.5% or more (practical
detection limit). This observed air-entry pressure also implies there is an oil -entry resistance aswell:

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LNAPL SATURATION

Saturation refers to the fraction of the pore space that is filled with any particular fluid phase. For
would mean a volumetric content of 0.04 for
instance, a saturation of 10% within a porosity of
a given fluid. LNAPL saturation is related to volume, mobility and recoverability, as discussed in
the multiphase physics overview above. Because it Is a bulk physical measurement, saturation
results are a relatively simple and direct measurement of oil volume in the pore space and does not
have the same limitations as chemical analyses of mass.
In addition

to the in situ saturation, residual saturation may also be measured in the lab. Residual
saturation refers to the threshold below which physical movement ceases. There are 2 states for
residual saturation; 3 -phase and 2- phase. Three -phase residual saturation is the threshold of
immobility where air is displacing both water and oil. Two -phase residual saturation Is the threshold
of immobility for saturated conditions where only water and oil are present. Typically, 3- phase
saturations are smaller than 2 -phase saturations for the same oil and soil types (e.g., Figure 2 -2).
The summary details of each type of test are discussed in the following subsections.

2.3.1 In Situ LNAPL Saturation
the Dean -Stark method during
events
from
2005
to
present.
This
method
uses
weight
measurements combined
essentially
sampling
with solvent stripping of all liquids from the sample. Knowing the initial sample weight, the volume
of solvent used and recovered, the fraction of water, and the porosity, the LNAPL saturation may
then be determined.
In situ

LNAPL saturation measurements were conducted using

on 12 soil cores (SCS, 2011a) and ranged from 0 to a tnaximtun
20.4%
in
sample
SCS
-132
-98.0.
The median value is 6.1 %, and the geometric mean is 2.5 %.
of
These samples are purposely biased in that they specifically targeted zones of strongest laserinduced fluorescence (LW) signals that suggested the presence of relatively more significant LNAPL
than in zones of lower signals,

LNAPL saturation was measured

2.3.2

LNAPL Mobility /Three -Phase Residual LNAPL Saturation

SCS had testing performed on 5 soils cores for what the lab terms a "Free Product Mobility
Evaluation ", but it is more properly a 3 -phase residual saturation test. For this test, native cores are
placed in a centrifuge apparatus and a force of 1,000 x Gravity (0) is applied to displace both
LNAPL and water. For perspective, 1,000 0
29, 921 in big 84 1,033,227 col water, and is an
exceedingly large displacement pressure that drives the fluids to a residual saturation endpoint The
initial and final volumes of fluids in the pore space are measured, that which is left in the core
represents the 3 -phase residual saturation. The initial saturations represent the native state of a

sample core at the time

of sampling.

Consistent with the multiphase principles, review of Figure 2 -3 indicates that in general, n
is produced from ewes that have a higher initial LNAPL saturation. It is observed that very little
oil is produced from cores that have less than about 7% initial LNAPL saturation. The final residual
LNAPL saturation values range from 5.9 8.2%. Given that the cores are subjected to 1,000 G of
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force, these results represent a force, gradient, and endpoint saturations that cannot be achieved
under ambient or remediation field conditions. A more likely field value would be twice that ranIIe,
as suggested in an example saturation versus pressure data set from a site with similar aquifer
materials (Figure 2.4). The results from these tests will be used subsequently along with data to
assist in estimating the hydraulically recoverable fraction of LNAPL.

Further, as shown in LIP cross -section Figure 2 -5, the majority of the LNAPL is submerged beneath
the water table, and 2 -phase residual saturations would apply to that zone, and would be expected
to be much greater than the 3 -phase results discussed (recall Figuré 2 -2).

2,4 LNAPL PHYSICAL PROPERTIES

The physical properties of the LNAPL include its density, viscosity, and the interfacial t
between the LNAPL, air, and water. These properties together control the physical transport and
recovery of the LNAPL, Other things being equal, a high viscosity product will have a lower
potential mobility and recoverability than a low viscosity LNAPL, much like viscous paint will pool
locally when spilled on the ground, but ethyl alcohol will run out flat, The density, along with
capillary properties, controls the amount of oil that penetrates into the aquifer materials as a function
of the driving head. Interfacial tensions allow the capillary properties for one phase couplet
(air -water in this case) to be scaled to the other capillary couplets (air -oil, oil -water), All 3 couplets
are needed to describe a multiphase system from a mechanistic point of view, as discussed
previously,
Based on carbon chain characterization work done previously (Jones Environmental, 2002), the
LNAPL resembles predominantly kerosene to Jet A ranges of hydrocarbons, which have relatively
similar physical properties. The density is expected to be approximately 0,81 g /cc, and the viscosity
around 1..5 cP, The interfacial tension for air -water is typically around 72 dynes /cm, the water /oil
IFT around 25 (field state) and the oil /air also around 25 dynes /cm. These physical parameters are
based on literature ranges published in the API Interactive LNAPL Cuide (2004) and its assoicated
references.

2.5 LNAPL CONDUCTIVITY

As discussed previously, the ability of LNAPL to flow in the subsurface is proportional to the
intrin.sie and relative permeability, as well as the distribution of LNAPL, Like groundwater, LNAPL
has both a hydraulic conductivity and transmissivity based on these factors.

The aquifer permeability was discussed above, with a field value of about 0.35 Darcy representing
the higher range as compared to lab values. The LNAPL. hydraulic conductivity can be determined
by the formula below:

K =k

PIS 4f

(2)

and

the LNAPL condiaçzivfly,
parameter being previously defined in egf.ratioit (iJ above.
Where "L" denotes. the LNAPL ¡ihn

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IOriItlSVllttfpY

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krc

9r,

K,1r.

(4)

Ifd

«(I- S,,,,)0."(I

Where

Se")xpri M =1 -t

is the van Genuchten

(3)

capillary fitting

parameter discussed previously, and 5'°,,, is the
residual
effective water phase saturation, where
saturation values are settled out äs thora represent
a volume ofdte pore -space not available to active flow.
Given these relationships, and the site parameters discussed previously, the hydraulic conductivity
toward LNAPL is estimated for each of the soil cores collected in recent work by SCS (201 t), and
shown in Table 24 below. As seen, where there is a value greater than zero, the LNAPL
conductivity is quite small, about 100 - 20,000 times less than the groundwater conductivity ofabout
fl/day (discussed above).
1

TABLE 2-1 LNAPL HYDRAULIC CONDUCTIVITY ESTIMATES
!

arameters

ple ID

5,.

h,l

3.704i-02

1.78E-03

6.83%

20.50%

81,32'Y0

2,12E=01

1.02E-02

6.83%

20.50"/°

102.69%

0"00E-F00

O00F"-t00

6.$3°f°

20,50"!°

9770"/e

1581:02

7601',-04

20.50°/"

104 99%

0 001.100

0.001d+00

105.68°f°

0.00E F00

0.00E+00

6,83%

20.50%

5[;8432.98.0'
SCS-ß2-112.0

20.40°l0

4.90%

SCS-133.91:0'

8:50°Í

SCS431-99.0'

10.10%

20%

95.49%

KI"

5C5-133-107.0

SCS-B3-107.0'
....

2.70"/a

6.83%

SCS-1)1-99 0'

7,00°/n

6.83°/u

20.50°l° ..._.__.
20,50"/°

99.76"/"

8.64C-04

4.16E-05

St'5-112.1120'

7,50%

6.83%

20.50%

99.07%

4.92E-03

2.37E-04

730%

6.83%.
._......

20.50"f0

98.80%
6.861;-03
....... .._

3311;-04
...

6.83"/0

20.50%

SC'8-133-910'
.

SCS-B2-98 6'

._-.....

___..
14.20°U/0

6.83°(0 _..

....
-

89.85°/u
......

n
Native LNA1'I., satui
'i dien tiPporo filled with water in a saturated system)
Residual NAPE, Sahn'atiáli, determined by lab testing
= Residual wtüer Satúèatioti, ïlétermined by lab testing
S , -° Effective water phase Saturation in a fully saturated system
L.NAPG eonduotieitv at tha narticular LNA['L s. m
K

--------.--

1.021x01

911'-03

Max

1.02E«02

Min

O.00 E+0

Goomeein

8,06E-04

Median

7.60E"04

2.6 LNAPL VELOCITY POTENTIAL

Using a ©arciali approach, the potential LNAPL flow is determined by combining the effective
conductivity toward LNAPL with the gradient, porosity and saturation. This results in a potential
flow in the LNAPL phase, potential because other plume balancing factors like pore entry pressure,
lateral gradient and conductivity decreases, and mass balance among others arc not considered by
this simple expression (4), where VI, Is the average linear pore velocity, and 0 is the total porosity,
These other tacets will be considered further in the discussion that follows.
In the sub- chapter above, the LNAPL, conductivity range was developed, and the porosity and
saturation values were also measured and discussed previously. The remaining factor as yet
presented is the LNAPL hydraulic gradient. The LNAPL gradient can be derived in the sanie
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manner as the groundwater gradient; Rt is the slope ofthe LNAPL head between wells where LNAPL
is present, or the adjacent groundwater piezo metric surface if LNAPL is not present. The LNAPL
gradient was determined for 4 time periods between 2002 and 2011 for wells MW-19R, MW-6R and
MWl4R, as shown in Table 2 -2a and Table 2 -2b below.

Well ID

I7T)'
(feet ßfOC)

PP Elevation

10/31/2002

89.56

8,11

6/282005

88.7

8.97

12/17/2007

89,76

7.91

6/7/2011

8934

8.33

10/31/2002

95.1

7.17

97.67

102.27

12/17/2007

94.7

.12

-°°

6/7/2011

94.45

7.82

87.75

5.16

87.52

5,3

87.59

5.32

87.06

5.85

92,91

12/17/2607

6/7/2011

E 2-2b

7.57

10/31/2002

6/28/2005

6474945.511

1736943.385

6475143.96

1737134.311

6475586.769

1737298,454

GRADIENT RESULT

1)egrees from North

lieut?

0/31/2 02

0.004

85.67

8/2005

0,008

113.4

,0.009

128.4

12/17/2007

(fimnsl)

94.15

6/28/2005

MW-6R

MW14R

fOC Elev
(ft nmsl)

Unte

W- 19R

RADIENTS

DATA USED TO DETERMINE LNAP

TABLE 2 -2

0.006

6/712011
Notes:
7:

Gradient and Dim lo

alclll

d using EPA ón /1n tools

he LNAPL gradients and other factors discussed, the LNAPL velocity potential relative the
LNAPL saturations measured in each soil core collected by SCS (201 la) are shown in Table 2-3
below for the 2011 gradient. As shown, the maximum potential LNAPL velocity is on the order of
0.35 11/yr, with the geometric mean being 3.36 x 10"x, and the median being 1.95 x 104 R /yr, with
3 of l0 samples having zero mobility (less than residual saturation).

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TABLE 2 -3: ESTIMATE RANGE OF POTENTIAL LNAPL
ID
........ Sample
.
..m._..,

NEAR PORE

Vi,(Cf/yr)

SCS-ß1-99.0'

0,006

0.013

2,89E-01

SCS-62-98.0'

0.006

0.064

3.51E-01

SCS-132-112.0

0.006

n/a

0.00E+00

SCS-133.91.0'

0,006

0.007

2.39E-01

0.006

n/a

0.011E+00

0.1106

n/a

0.00E+00

0.028

3.21E-03

.....

SCS,H3.107.0'

...

,...

SCS-63-107.0'
_._ Ane ..,......

...

SCS13]99.0'

SCS-62 I 12,0'
SCS-S391.0'
SCS-62-98.0'

....

...

.._..

._. .
0,006

0.033
....

0.006

.. ..

0.006
..... .....
0,006

........

Ph49i

....

2.34E-02

0.066

I.64E-01

Max

3.51E-01

Min

0.00E+00

G cornea n

3.36E-02

Median

1.95E-02

LNAPL gradient
0 = LNAPL-tilled porosity
V, -LNAPI.língar velocity pPtentïyl-

bxF

1.5613-02

0.031

il, =

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tlivlropeo loyy. Water Rekaúrçesi4 Pala S'rvos

3.0 EVALUATION OP LNAPL PLUME AND CLEANUP CONDITIONS
There are 2 key questions that must be answered to consider what cleanup or plume management
actions will be most appropriate at the site I) Is the LNAPL plume stable from a management
perspective?; and 2) Will additional active cleanup have any net benefit to the waters of the State?
The following report sections will consider these questions and related factors to result in a
recommended general course for management of the remaining LNAPL beneath the site.
3,1

LNAPL STABILITY CONSIDERATIONS

There were several lines of evidence noted in the initial discussion of LNAPL plume genesis that
would lead to a determination of LNAPL plume stability or not The evaluation takes a weight-ofevidence approach, where each factor alone is not as important as all factors in their totality, For
convenience, these factors arc repeated below;
1.

2.
3,
4.
5.
6.

Confirmation that the LNAPL releases are finite and not ongoing at the site;
Evaluation of the relative age of the LNAPL plumes; the older a plume, the more probable
it has reached field static equilibrium;
Evaluation of LNAPL gradients;
Comparisons of estimated LNAPL to water conductivity values;
Evaluation of LNAPL flow;
Review of petrophysical properties, including expectations for an entry pressure threshold;
Inspection of LNAPL plume distribution to consider whether the morphology is consistent
with the form of a stable plume.

Items I and 2 above are straightforward. The former Western Fuel Oil site ceased petroleum
operations in 1995. The facilities that served those operations were demolished between 1997 and
1999 in preparation for redevelopment of the San Pedro Business Center. Therefore, releases likely
ceased by 1995 when the operations stopped, excepting the possibility of small releases from leftaver product in piping or other ancillary structures. By the end of demolition, that potential residual
source was also eliminated. Thus, it has been 16 years since any releases of importance have likely
occurred. As discussed earlier, LNAPL quickly ceases to move once the gradients induced by the
release have dissipated, and that cessation is generally expected in the 3. 10 year time frame in most
cases.

Item' 3, the LNAPL gradients, were discussed above and are generally of the saine magnitude and
direction as groundwater flow. This Is typical of confined LNAPL, where the pressure regimes in
the LNAPL simply reflect the surrounding hydrostatic pressures, LNAPL is confined in the same
way groundwater is confined, by zones of porous materials having low effective hydraulic
conductivity, in this case with respect to LNAPL (local' processes discussed above). By way of
example, hydrographs for MW- 6 /6Ránd MW -14/ 14 have positive statistical correlations between
groundwater head and product thickness (increasing head, increasing thickness; Appendix 2 -2).
MW-19/19R also has a positive correlation, but only of 0.4. However, this is likely because of the
small LNAPL thicknesses in the well, implying less hydraulic continuity in the formation. But as
can be seen even in M W -I 9R, in.) une 2006 when there is a sharp temporary increase in groundwater
head mirrored by a similar increase In LNAPL thickness, indicating fluids in this well are behaving
2 60U

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confined manner. Increased pressure means higher head or thickness, and vice versa. In
summary, it appears the LNAPL has no independent driving head of significance beyond the forces
in the groundwater regime. That makes perfect sense given the extensive excavation and cleanup
actions taken to date In the shallow portion of the system, effectively cutting off any residual
gradients that might have remained from the original releases.
in

Item 4 has also been discussed above. The analyses determined that, where there is a value greater
than zero, the LNAPL: conductivity is quite small, about 100 - 20,000 times less than the
groundwater conductivity of about I ftlday (discussed above). This of course means the potential
for LNAPL now is also approximately 100 - 20,000 times less than groundwater, And in 30% of
these cores, the LNAPL conductivity was zero. Given that the coring program by SOS targeted
LNAPL -rich zones, if there is a bias in this analysis, it would be expected to be toward the worstse conditions (i.e., conservative).

The potential velocity of LNAPL (Item 5), was also found to be quite low, well less than -f1 /yr at
a maximum, and less than a few hundreths of a 11 /yr in the median and geometric mean case. As
mentioned, the velocity potential does not account for a wide variety of real -world factors that cause
LNAPL plumes to halt movement in the environment. Therefore these de minimis values of
potential mobility are a worst -case screening and indicating the plume is stable.
I

Petrophysicnl properties, Item 6, have also been developed above. The combination of high
capillarity, a distinct non- wetting entry pressure exhibited in the capillary data, and the relatively
high percentage of fines in the majority of soil cores all indicate the LNAPL will not now easily in
this setting absent high pressure gradients. As discussed, gradients are in fact small, and unlikely
to mobilize LNAPL beyond its present position in the subsurface now or in the future.

Finally. Item 7, plume morphology, remains to be inspected, There are 2 facets that will be
reviewed here. First, the distribution of LNAPL inferred from the LIP investigation, augmented
with other data will be reviewed in map and cross -section views. Second, as discussed in the first
part of this report, dissolved benzene concentrations over time will serve as an indirect reflection
of LNAPL conditions; the benzene plume was found to be stable and contracting; The concept here
is simple; if the LNAPL that is the source of benzene is stable, then the benzene plume should also
be stable. Conversely, if the dissolved benzene plume is moving downstream over time, then
potential movement of the LNAPL "source" could be one explanation for that observed behavior,
Cross Section A -A' discussed previously (Figure 2 -5) shows the inferred LNAPL distribution from
the southwest to the northeast. As seen, the submerged LNAPL plume is dominant in the area of
CPT -17 and CPT -21, but other constraining data points indicate that the plume pinches out, as
expected, toward the northeast. The LIF waveform along the sanie section (Figure 2 -6) shows
distinctly different product types in different zones ol'the plume as reflected in LIF spectral color
differences, again consistent with discrete product releases that remained pr cdominantly local to the
areas of the original release. The plume has the expected morphology of a stable plume,
In stimnlary, for this particular site, all the factors above point to LNAPL plume stability. While
there may be small -scale movement in response to localized gradients, the plume is old enough and
displays all the other features of a stable plumé relative to site management objectives,
iINotlN34üWm,

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MUI-Y611, INC.
ftl,tr4.v4lnyy. Water

3.2

gnawun,ODula ótmrices

LNAPL CLEANUP CONSIDERATIONS

Given that the LNAPL plume is stable, as discussed above, the plume management options range
from managing it in -place to more active engineered cleanup approaches. In this section, the net
benefit of various potential actions relative to the waters of the State will be considered. The
discussion will also consider the impact of any potential actions on the site operations of the Port
Distribution Center that represents an economic positive for the property and surrounding area.
As summarized by SCS, this site has had numerous active cleanup actions taken to date, including
pump and treat, extensive soil excavation, air sparge /soil vapor extraction (IAS & SVE), free
product recovery and other ancillary actions. As of 2001, it was estimated that approximately 12
million pounds of hydrocarbons were treated by the IAS /SV1 system, and another 20,000 yd3 of
impacted soil was excavated (Cape, 2001). About 13,000 gallons of water/product mixture have
been hydraulically recovered from wells MW -GR and MW -14R, with water typically being the
major component of that volume (SCS, 2011a). Certainly all of these past cleanup actions have
improved site environmental conditions in that the vapor pathway is now negligible, and the mass
recovered helps to further stabilize and reduce the long -term presence of the LNAPL plume.
However, as observed in the investigations and discussed previously, LNAPL mass remains
submerged below the water table.
As noted in our 2005 Draft Report to the LARWQCB "Bast Practices Study of Groundwater
Remediation al Refineries in the Los Angeles Basin (Beckett, Sale, Huntley. & Johnson, 2005)" the
single -most applied remediation technique in the area to address LNAPL is hydraulic recovery, We
discuss the limitations of that method, but also why it is used so often in practice. In a nutshell,
LNAPL recovery can mitigate the potential for LNAPL transport and it does recover some mass.
Whether it recovers enough mass to make a difference in plume management or the longevity of
chemicals of concern is the key question often left unaddressed at the majority of release sites.
Hydraulics also can typically be installed at site boundaries and not dramatically affect the
operations of various petroleum refining and storage facilities. Whereas more aggressive cleanup
techniques commonly require a much higher density of cleanup and/or control points to be safe and

effective.
The API has developed screening tools to consider the general expect effect o l'LNAPL recovery and
cleanup (API /44715, 2002; API Interactive LNAPL Guide, 2004). These tools arc intended to give
some frauMg to the physical and chemical processes at work, and how cleanup may affect the
longevity of chemicals of concern in the environment. The petrophysical and fluid parameters
discussed above provide the necessary inputs to the screening evaluations. To provide an analogous
initial condition to that observed at the site, the initial LNAPL peak saturations are on the order of
20 %, as measured by SCS in sample SCS -B2 -98.0' (2011). 1'1w surrogate chemistry of key
compounds in the LNAPL were matched to MW -10R, a well with a history of high'IPU-Ig and
benzene impacts. The estimate is run in a "type nle«' context, whew we are interested in relative
change, not in a precise rendering of site -wide plume conditions; the geometry of the type area
includes a depth of 90 -ft, and lateral dimensions of 330 x330 ft ( -100 ni), A Rill report of the inputs
W the estimates that follow is attached (Appendix 3 -1).
'

4871 Nudh 2200 W84 ,111111

Pit

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Avw.Wit,wc.
vhxv. JIt,wr

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Using this screening approach, the baseline condition (natural mass loss scenario) is then compared
to hydraulic recovery by skimming and by pump and treat with active groundwater pumping. As
seen in Figure 3 -1, the expected change in saturation due to hydraulic recovery is quite negligible,
as is the associated change in benzene concentration over time for each scenario (Figure 3.2, IAS
context will be discussed below). In effect, and consistent with an old, stable, and submerged plume
with all the given properties, hydraulics will no longer have any effect on plume management over
the long- term. As observed in MW 10 and other locations, the IAS /SVE cleanup initially reduced
concentrations significantly, followed by rebound to nearly the same levels as prior to that cleanup
action. That observation is completely consistent as well with the fact that submerged LNAPL
exists well below the intervals of cleanup targeted by that IAS /SVE action. Again, this site scenario
is intended only to point toward reasonable technical expectations; like all screening approaches,
the model and method is not designed to be highly site specific (API, 2004).
a step further, IAS can, in principle, remove the volatile components from the LNAPL
long as the subsurface coverage is sufficient in lateral and vertical dimensions. SVG will capture
that vapor stream. Because more volatile compounds partition preferentially into the vapor stream,
the remaining LNAPL will in principle become more enriched in less volatile and heavier
compounds (e.g., Figure 3 -3). As shown then, if coverage and stripping is effectively designed, the
ratio of benzene to heavier compounds should decrease through time as benzene is lost more rapidly
to the IAS. Figure 3.4 is a chart showing the change over time of benzene to ethylbenzene at M W10 overlapping the time of IAS /SVE actions, As observed, this ratio is changing puor to the start
of cleanup, which is also consistent with natural partitioning processes In groundwater and vapor.
It is also seen that the cleanup did not change the overall slope of this ratio, and after IASISVE was
shut down, there was rebound in this ratio (not shown on the particular plot, but observed in the
subsequent well data). These observations are again entirely consistent with not only LNAPL
submerged below the zone of cleanup, but also with the limited lateral coverage of the IAS system
installed on (»t; -ft centers.

Taking this
as

It is well documented through tank and field seal: measurements that the zone of active vapor
stripping around an IAS location is quite limited, I-m instance, Lundegard et al. show an active IAS
stripping zone of about 8 -ft (2,4 ni) in a fiat -grained sand (e.g., Figure 3 -5). Beckett et al. (1995)
demonstrated IAS in the Gage aquifer would have a coverage of about 2 - 3m (- 6 ,5 1040 radially
depending on operating conditions (Figure 3 -6). So, despite recovering significant mass from the
subsurface (12 million pounds), the IAS /SVE system clearly missed existing mass, and thus the
observed rebound and persistence of LNAPL and its associated chemical compounds. Given the
shallow aquifer materials are similar to the Gage, LAS wells would require a spacing of 10- to 15 -ft
on center and to a depth of at least 20 -ft below the present water table, as indicated by LNAPL
saturation impacts at all depth levels investigated to 107 fbg (SCS- B3.107', SCS, 2011).

following further hypothetically on what IAS may achieve in principle. If we take the same
LNAPL scenario discussed above for hydraulics and assume that stripping at an adequate lateral and
vertical distribution of IAS operation could reduce benzene by an order ofmagnitude (as seen onsite
So,

before rebound of the old system); what would be the expected result? Recall in Figure 3 -3 above,
IAS under these ideal conditions would be expected to reduce the overall concentrations of benzene
and other compounds in the near -term, but would not have a significant effect on the long -term
presence of the compound or the management of the site.
(At'

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Latest

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Cardenas drinking water notification revel for either the

Earliest

CA.

Predicted Range to Reach
NLa

(ngIL)

NL'

300 Westmont Dr., San Pedro,

Table 1 -2
Longevity Estimate for TBA

Constituent

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Downgradient

Well Location

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200

100

alt concentrations

(ft/day)

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December/August 2007

Date

Well Production Rates (9p

Potential Flux Impacts to Groundwater Use for TBA

TABLE 1 -3

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Site Plan

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ß AQUI-YER, INC.

J. Parker, 1994

Vadose Zone Oil

Saturated Zone Oil

Figure 2 -2
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Initial LNAPL Saturation

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Figure 2-3
Initial and Residual LNAPL Saturation Measurements

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AQUI -VER, INC.

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40-

350

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1200

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APPENDIX 1 -5
MODEL INPUT AND RESULTS

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MX 4356354026

Observed Ferrous Irons
Delta Sulfate'
Observed Methane

Delta Nitrate`

5E-1

(mg/L)

(mg2)

CH4

(mgt)

22 4

SO4

(mgfi-)

(mg2)

(year)

(per yr)

4.50

07
166

NO3
Fe2+

f -hatf
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orInstantaneous Reaction Mode
Delta Oxygen'
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()

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7E-5

(-1

(ft)

(fr)

(N)

(R)

()

foc

lambda

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50-0

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(kg/1)

4 131ODEGRADATION
1st Order Decay Coeff`

IrtUyr)

Soil Bulk Density
Partition Coefficient
Fraction O rga n icC arbon

101

3 5E-04 (em/sec)
O.007 (fllftj

mo
Koc

ADSORPTION

Retardation Factor
or

Estrnated Plume Length
Lp

alpha y
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Transverse Dispersivey'
Vertical Dispersivity'

alpha

Longitudinal Dfspersrvity

2- DISPERSION

Hydraulic Conductivity
Hydraulic Gradient
Porosdy
n

HYDROGEOLOGY

Seepage Velocity'
or

Air Force Center for Environmental Excellence

2000
1000

Width

Con

View Output

CENTERLINE

RUN

View of Plume Looking Down

Vertical Plane Source Look at Plume Cross-Section
and Input Concennatrons & Widths
for Zones 1, 2, and

View Output

Recalculate This
Sheet

Restore Formulas for Vs,
D.spersivities R, lambda, other

Paste Example Dataset

Help

Observed Centerline Concentrations at Monitoring Wells
if No Data Leave Blank or Enfer "0"

RUN ARRAY

8. CHOOSE TYPE OF OUTPUT TO SEE

(¡t)

I
25

Port LA Drstnbubon Data Input Instructions.
115 I
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cells below (To restore
0 02
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l
(yr)
InstReact T 1st Order
10000000 (Kg)
Soluble Ma
In Source NPPL, Soil
7 FIELD DATA FOR COMPARISON
1a 4
Concentration (mgIL
Dist from Source (ft)

)

Source Thickness in Sat Zone
Source Zoner

SOURCE DATA

SourceHalftrfe see Hel

Simulation Time

5. GENERAL
Modeled Area Length'
Modeled Area Width'

Version 14

BIOSCREEN Natural Attenuation Decision Support System

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2000

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DISSOLVED Ei1DROCARBON CONCENTRATION ALONG PLLME CENTERLINE (mg/L at 7,11)

2500

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APPENDIX 2CAPILLARY PARAMETER

rlh32U0t4ns,,ildR

PI,.

RIVATIONS

Vnte

SCS B2 -112.0

2..70E -03

3.50E -03
1.56

1.75

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=S
S

[(r

(Sr( are capiilary

35.20

7030
0.996

0 988

parameters defined by the following equation (van Gesuchten, 1980),

0.22.

- Sr ) (t + (. °)

alpha (áL p, residual water saturation (SC) and. saturated {total} water content
with m = 1-1,tn, S = water saturation, and h = capillary head (cmy:

Noies:

SCS S2-98

TABLE 7
SUMMARY OF CAPILLARY TEST RESULTS

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NltlengPnlpV.P, Water t7manrtlp8.ö /A

:item

APPENDIX 2 -2
LNAPL THICKNESS AND GROUNDWATER PIEZOMETRIC HYDROGRAPHS

APX'ENDT
6tl7i Noi lAPr2Q9WCai,DYf

PII.d7SAss-RII2,1 VAX tlaä

LNAPL Thickness (ft)

c
c

(Isua

}})

uoReAOl3

nnpunoas
a

FP_írytlmrephsxJs

0.00

Jan94

Jan95

Jan96

Dec96

Jan-

Jan99

Jan-

Dec00

6471 944444 2365 Weye ö SF Faci Ci

-1.00.

1.00

2.00

3.00

Jan02

Jan03

Jan04

Dec04

Jan06

Jan07

Jan-

Dec08

Jan-

84098 Ph. 435E954OZ4 Fas 435653-85:5

0.00

1.00

2.00

rz
3.00
r

4 -00

4.00

elation = 0.78

Outlier thickness of 6.56 ft, 4/29/02 not use

5.00

-o

Groundwater Elevation
LNAPL Observed

5.00

6.00

7.00

8_00

9:00

LNAPL & Corrected Groundwater Elevation Hydrograph: MW-14/14R

AQiì1-VER, INC.
H)viregemhg>; Wflfer *feswirce.v amd lMdc Serzices

LNAPL Thickness (ft)
CD

Ì`'`+

o
Ó

°n
G7

0
Ó

9
Ñ

oo
06

(Is

u©gG'nal

al nnpu noa o

AQULVER,INC,
tpurogaofnpp wow HertománstN Dom

d'npolMS

APPENDIX 3 -1
KEY API LNAPL SCREENING INPUT'S AND RESULTS

i1i220UWaSi.9NP

MASS

F4YA35ag5.NUz

SCS Engineers.

Project Manager:
Date of Analysis:

Layer

3.13E03

User Input Parameters

nditbn

31.82

0.31

1.66

Sro
0.136

0.205

3.13E -01

Srw

(cu mime)

Specific
Volume

3_00E-01:

K (mid)

BASELINE CONDITIONS

9.48E -02

Average

Vertical Equilibrium

van
van
Genutchen Genutchen
n
Alpha (11m)

2.04E -01

Max So

6.25

0.136

(%0)

Selected Sro

Saturation Condition

van Genutchen
Alpha (11m)

LNAPL Zone
Thickness (m)

% Interval
Greater than
Field Sro

Medium Sand

Only apply to multiple layer sail

Repon Greeted. on 8/26120

Simulation.
Number Layer Soil Type

Soil Properties

Flow

Medium Sand

Simulation
Type Area
Number Volume (cu m)

Results

Gasoline

Soil Type

Simulation
Number LNAPL Type

Simulation.
Number

Initial Conditions; Soil

Title of Simulations: Port LA Distribution Center, Former Western Fuel Oil

8/26/2011

Port LA Distribution Center

Site Name:

Executive Summary - Saturation and Volume

0.40

Total
Porosity

Page

of 2

Report Created on 8052011

Equilibrium LNAPL Dístributio

Simulation
Number Method Used To Calculate LNAPL Saturation

25.00

(dyneslcm)
25.00

8.64E -04

Volatilization Included

1.50

(cp)

Viscosity

Criteria For Minimum
Mobility (mlday)

0.81

Oil Density
(gmfcc)

BASELINE CONDITION

Source Volitilization

100.00

OïUAir WT
(dynesTCm)

100.00

O°il(Water IFT

27.40

(m)

Width of
LNAPL Zone

Length of
LNAPLZone

Method Used to Calculate LNAPL Saturation Input Pa

Gasoline

Simulation
Number Product Type

LNAPL Properties

6 25

Vertical
Depth to Top
Formation
of LNAPL
Simulation
Thickness (m)
(an)
Number

Source Area Input Parameters

Page 2 of 2

SCS Engineers

August26., 2011.

Project Manager:

Date of Analysis:

2.04E -01

615

Report Created on 826/2011

Xylene

Compound of Concern
Benzene
Et iyl Benzene
Toluene
3.29E+03
6.93E +02
2.30E+01
1 86E+02

Original
Concentration.
(agil)

3.73E-01

Initial Specific Volume
(eu Wm')

0.31

van Genutchen
Alpha (1fm)

2.30E +01
1.85E +02.

1.85E +02

6.92E +02
2.30E +01

6.92E +02

6.93E+02
2.30E +01

328E +03

ncentration a
20 Years
(agil)

0.136

d Sra

3.29E +03

Sel

324E +03
6.97E +02
2 29E +01
1.85E +02

(ug11)

100 Years

Concentration at

BASELINE CONDITIONS

29E +03

Concentration at Concentration.
1 Year
10 Years
(ugll)
(ugh)

C51

Initial Pe

Medium Sand

Soil Type

Initial VEQ LNAPL
Thickness (m)

Soil Layer

Results (Simulation Number 1)

Simulation
Number

initial Conditions; Soil & Flow

Title of Simulations: Port LA Distribution Center, FonnerWestern Fuel Oii

Port LA Distribution Center

Site Name:

Executive Summary - Source Zone Co position Through Time

Page

of 3

Medium
s

and

25_ùO

Criteria For Minimum
Mobility (mlday)
8:64E-04

Vofa .ization Included

130

3.00E-01

If (mid)

Source VoliUliization

Input Parameters

d Used To Calculate LNAPL Saturation

Equilibrium. LNAPL. Distribution

Repon Created çrn

Simulation
Number

25.00

0.136

0.205

Viscosity
(cp)

Sr*

Srw

Oil Density
(gm /cc)

100.09

OIIfAIr IFT
(dyneslcm)

(m)

(m)
1

Width of
LNAPL Zone

OillWater IFT
(dynes /cm)

27.40

Method Used to Calculate LNAPL Satu

Gasoline

Simulation
Number Product Type

LNAPL Properties

6.25.

Vertical
Depth to Top
Simulation
Formation
of LNAPL
(m)
Number Thickness (m)

fr.60E-03

(min))

Length of
LNAPL Zone

6.23E -03

1.98E -03

1.66

van
Genutchen
n

Groundwater
Gradient

0.31

van
Genutchen
Alpha (11m)

BASELINE CONDITIONS

Velocity
day)

Lin

.eters

(mid ay)

Groundwater
Darcy Flux

Source Area input Pa rame

Simulation
Number

Groundwater Condition Input "Pa

Only apply to multiple layer s

Simulation
Number Layer Soil Type

Soil Properties

User input Parameters

Total
0.40

Porosity

Page 2 of 3

(m)
1.00E-02

(m)
101E-01

3.00E+00

Effective
Porosity

0.318

Report Created on 8/26/2011

Simulation
Number

Longitudinal
Dispersivity
(in)
3.00E-03

Fractional
Carbon
Content

CoNlTIDNS

Vertical
Transverse
Dispersivity

BASELINE

Horizontal
Transverse
Dispersivity

Solute Transport Properties Input Parameters

2.50E -62

Vapor
Diffusion
Efficiency
Coefficient

Page 3 of 3

SCS Engineers

8/26/2011

Project Manager:

Date of Analysis:

Layer

soil conditions

Medium Sand

Report Created on 8726/2011

' Only apply to multiple la

Simulation
Number Layer Soil Type

Soil Properties

User Input Parameters

3.11E+03

Simulation
Type Area
Number Volume {cu mi

Results

Gasoline

LNAPL Zone

2.02E-01

31.06

0.31

fl_136

( °Je)

9.41 E-02

Average

t66

0.205

Srw

111E-01

(cu mime)

Volume

Specific.

After Fixed Period of Remediation

Saturation Condition

0.31

0.136

Sro

3.00E-01

K (mid)

SKIMMING CONDITIONS

Selected Sro

van
van
Genutchen Genutchen
n
Alpha (11m)

Max So

Field'. Sro

625

Oil

van Genutchen
Alpha (11m)

Thickness (m)

% Interval
Greater than

Medium Sand

Soil Type

Simulation
Number LNAPL Type

Simulation
Number

Initial Conditions; Soii & Flow

Title of Simulations: Port LA Distribution Center, Former Western Fuel

Port LA Distribution Center

ion and Volume

Site Name:

Executive Summary - Satu

GAO

Total
Porosity

Page

of 2

boo0

Report Created on 8/26M20

Distribution After Fixed Period of Remedietion

Simulation
Number Method Used To Calculate LNAPL Saturation

Criteria For Minimum
Mobility (rnlday)
8.64E-04

Volatilization Included

1.50

Viscosi

CONDITIONS

Source Volitilization

0.81

25.00

25_00

(dynes /cm)

Oil Density
(gm /cc)

100.00

SK.Í513MIN

©il/Water IFT

27.40

(m)

Width of
LNAPL Zone

Length of
LNAPL Zone
(m)

Method Used to Calculate LNAPL Saturation Input Parameters

Gasoline

Simulation
Number Product Type

LNAPL Properties

6.25

Vertical
Depth to Top
Simulation
Formation
of LNAPL
Number Thickness (m)
(m)

Source Area input Parameters

Page 2 of 2

August 26, 2011

SGS Engineers

Port LA Distribution Center

6.25

Report Created on 8126/2011

'IBenzene
Ethyl Benzene
Toluene
Xylene

Compound of Concern

(eu mim)
3.51E-01

2 02E-01

0.136

( %)

Selected Sm

1.85E +02

(ugh)
3.29£+03
6.93E +02
2.30E +01

(ug/I)
3.29E +03
6.93E +02
2.30E +01
1.86E +02

2;30E+01
1.85E+02

3.28E+03
6.92E+02

(ugR)

3.27E+03
6.92E+02
230E+01
1.85E+02

(ug/1)

3.18E +03
6.9ÓE +02
2 28E +01
1.85E +02

(vg /1)

Concentration at Concentration at Concentration at Concentration at
20Years
1 Year
10 Years
100 Years

Initial pecific Volume

0.31

(1 /m)

Genutchen

Alpha

van.

er Western Fuel Oil

SKIMMING CONDITIONS

Initial Peak So

Original
Concentration.

Results {Simul tion Number 1)

Initial VEQ LNAPL
Thickness (m)

Simulation
Number

and

on Type

Soil Layer

Simulation
Number

Initial Conditions; Soil & Flow

Title of Simulations: Port LA Distribution Center, Fo

Site Name:
Project Manager:
Date of Analysis:

Executive Summary - Source Zone Composition Through Time

Page

of 3

lay

ñl

ndiEío

Medium Sand

6.23E-03

1.98E -03

Oil Density

(gmicc)
0.81

Oil/Air IFT
(dynes/cm)
25:00

25.00

100:00

t 00.00

Source Voliti lization
Volatilization Included

Method Used To Calculate LNAPL Saturation

Distribution After Fixed Period of Re

Report Created on 8/26/2011

rober

Ligation

Sro
3.00E -01

K (mid)

6.64E-04

Mobility(nlday)

Criteria For Minimum

1.50

(cp)

Viscosity

SKIMMING CONDITIONS

0205

Oil/Water IFT
(dynes/cm)

27.40

(m)

Width of
LNAPL Zone

LNAPL Zone
(m)

Method Used to Calculate LNAPL S oration Input Parameters

Gasoline

Simulation
Number Product Type

LNAPL Properties

625

Vertical
Depth to Top
Simulation
Formation
of LNAPL
Number
Thickness (n)
(m)

Length of

(mim)

(mlday)
6.60E -03

Groundwater
Gradient

1.66

Linear Velocity

0.31

van
van
Genutchen Genutchen
Alpha (11m)
n

Darcy Flux
(mlday)

Groundwater

Source Area Input Parameters.

Simulation
Number

Groundwater Condition input Parameters

Simulation
Number Layer Soil Type

Soil. Properties

User Input Paramete

Total
0.40

Porosity

Page 2 of 3

Report Created on

Simulation
Number
3.00E+00

0318

812

(m)
-

Effective
Porosity

Longitudinal
Dispersivity

Dispersivity
(m}
1.00E-02

1.50E-01

Vertical
Transverse

Horizontal
Transverse
Dispersivity
(m)

Solute Transport Properties input Parameters
Vapor
Diffusion
Efficiency
Coefficient
1.00E+00

Fractional
Carbon
Content
100E-03

SKIMMING CONDITIONS

Page

3of3

SOS Engineers

8/26/2011

Project Manager:

Date of Analysis:

Alpha (11m

van Genuchten

(Sirs}

(mfday)

ú23E -03

1.98E-03

Linear Velocity

Groundwater
Darcy Flux
{mfday}

Report Created on 8/26/2011

Simulation
Number

(Eft)

6.60E -03

Groundwater
Gradient

1.66

6.31

van Genutchen

6.19E +00

Alpha (1/m)

(Sirs)

van Genutchen

Groundwater Condition Input Parameters

fuiedium Sand

Simulation
Number Soil Type

Soil Properties

(Yrs)

Residual
Thickness
(m}

Skimming Recovery

overy Method

Time to 15% of Time to 50% of Time to 99% of
Recoverable
Recoverable
Recoverable

User Input. Parameters

Simulation
Number

Results

Medium Sand

Simulation
Number Soil Type

Initial Conditions

Sro
0.136

0205

5.51E-02

(cu mfday)

1 -Year Rate

Srw

5.55E -02

(cu

Rate
mfday)

3 -Month

625

Recovery Initial VEQ LI
Time (yrs)
Thickness (m)

SKIMMING CONDITIONS

Port LA Distribution Center

Site Name:

Executive Summary - LNAPL Recovery

3.00E -01

K (mld)

5.41E-02

0.40

Total Poro

4.14E+03

Page

3.11E -01

of 2

Inital Specific
Volume
(cu mine)

Final Specific
Volume
(eu mire

020

Initial
Peak So

3-Year Rate
(cu mfday)

0.136

Sele

6.25

5.0

(Yrs)

Period of
Recovery

Rep orf Created on 8126/2011

Simulation
Number

Number of
Wells

Skimming Recovery input Parameters.

Distribution After. Fixed. Pero.

Input
Criteria For Minimum
Mobility (mlday)
8.64E-04

Volatilization Included

50.0

1.50

Source Volitilization

ameters

Ratio of Radius of
Influence 1 Radius of
Well (LNAPL) (m)

mediati-on.

NAPL Saturation.

n
P

0_Sf

25.00

(dynes!cm)

Viscosi
(cp)

SKIMMING CONDITIONS

Oil Density
(gmlcc)

100.00

Width of
LNAPL Zone
(m)

Oil/Air IFT
(dynes/cm)

100.00

Length of
LNAPL Zone
(m)

Oi'IANater IFT

2740

Simulation
Number Method. Used.To Calcula

Method Used to Calculate

Gasoline

Simulation
Number Product Type

LNAPL Properties

Simulation
Number

Vertical
Depth to Top
Formation
of. LNAPL
Thickness (m)
(m)

Source Area Input Parameters

Page 2 oft

SCS Engineers

8126(2011

Project Manager:

Date of Analysis:

Layer

Greater than
Field Sro
27.27

3.02Eí-03

interval

di ans.

Medium Sand

Report Created an 8126/2011

' Gnñ} apply to mullipié

Simulation
Number Layer Soil Type

Soil Properties

0.136

031

93E -01

1.66

0205

Srw

3.02E-01

9.16E -02

Specific
Volume
(cu mime

Average

After Fixed Period in Remediation

van
van
Centric hen Genutchen
n
Alpha (11m)

Max

625

Saturation Condition

Selected Sro
(%)

Sra

PUMPING CONDITIONS

van Genutchen
Alpha (11m)

LNAPL Zone
Thickness (m)

Type Area
Volume (cu m)

User Input Parameters

Number

Simulation

Results

Gasoline

Medium Sand

Soil Type

Simulation
Number LNAPL Type

Simulation
Number

Initial Conditions; Soil. & Flow

Title of Simulations: Port LA Distribution Center, Former Western Fuel Oil

Port LA Dist bution Center

Site Name:

Executive Summary - Saturation and Volume

3:00E-01

K.(mld)

Total
Porosity

Page

of 2

/o Z aSed

6(-369'8

uo!lezq!lyvA awnog

papn!oul uo!lezg9e10A.

teol}e!pawa

poPacl

(waisaullp)

l LdZl9Z/8

paleaia.lrodal

minim

uapeinw!s

adAlmposd

JaqwnN
uone!nw!g

pasfl Po4laW

uogesn;es ldtlN1 aleinaJe'J of paskl Poglaihi

id! Jalem!!o

sualawwed indui uo!letn;eg ldtlNl alelnaleO

-Iltl/l!o

JaqwnN
uolleinw!g

satlaadoid 1dVN1
D> LZ

(w)ssaun!a!yl

(w)

(wa¡sauRp)

qi6ual

(to)

60'©0

A!suaa i!o

(33¡w6)

(JteplW) Jrn!iigoiq

wnw!um Jod eualuO

(do)
Apsoasrn

SNOliIaNOO JNldWfid

auoZ ld*JNi
10 gip!M

(w)
auóZ ldtlNl

saapump d;ndul eaJ+ aaun

Report Created on

Toluene
Xylene

812

Compound of Concern
Benzene
Ethyl Benzene

1.85E +02

6.90E +02
2 28E +01

6.92E +02
2.30E +01
1.85E +02

3.27E+03
6.92E +02
2.30E +01
1.85E +02

3.28E+03

3.29E +03
6.93E+02
2.30E +01
1.86E+02

3.29E +03
6.93E +02
2.30E +01
1.85E +02

Concentration at
100 Years
(ugll)
318E+03

3.02E -01

Initial Specific Volume
{eu mlm2)

Concentration at Concentration at Concentration a
1 Year
10 Years
20 Years
fug/I)
Owl)
(ugll)

(%)

o:31

Selected Sri,

Original
Concentration
( tigli)

93E-01

6.25

Results (Simulation Number

t's)

Initial Peak So

Initial VEQ LNAPL
Thickness (in)

Simulation
Number

Soil Type
Medium Sand

Soil Layer

Simulation
Number
Alpaa (llml

Port LA Distribution Center, Former Western Fuel Oil

The of Simulations;

van Genutchen

August 26, 2011

Date of Analysis:

Initiai Conditions; Soil & Flow

SCS Engineers

Project Manager:
PUMPING CONDITIONS

Port LA Distribution Center

Site Name:

Executive Summary - Source Zone Composition Through Time

Page

of 3

Medium. Sand

1.50

0.81

25.00

(dyneslcrn)
25.00

Report Created on 8/26/2

Disàrzbutlon After Fixed Period of R

Simulation
Number Method Used To CalculateL
dìation

PL Saturation

Criteria For Minimum
Mobility (mlday)
&64E -04

Source Vtrlitilization
Volatilization Included

ion Input Parameters

(cp)

(gm /cc)

Viscosity

Oil Density

OiUAir lFT

100.00

00.00

(dynes/cm)

(m)

(in)

3.00E-01

0.136

0:205

PUMPING CONDITIONS

K (mid)

Sra

Srw

Oi.UWater IFT

27.40

od Used to Calculate LNAPL Satu

Gasoline

Simulation
Number Product. Type

LNAPL Prop

6.25

Vertical
Depth to Top
of LNAPL.
Simulation
Formation
Number Thickness (ni)
(m)

6.60E -03

Width of
LNAPL Zone

6.23E -03

1.98E-03

1.66

Groundwater
Gradient
(Wm)

0.31

van
van
Genutchen Genutchen
n
Alpha (11m)

Length of
LNAPL Zone

(m Ida y)

Source Area Input Parameters

Simulation
Number

Linear Velocity

Groundwater
Darcy Flux
(miday)

Groundwater Condition Input Parameters

Only apply to multiple layer Soil conditions

Simulation
Number Layer Soil Type

Soil Properties

User Input Parame

0.40

Total
Porosity

Page 2 of 3

Report Created on

Simulation
Number

0.318

8725/2011.

(m)
3.00E+00

Effective
Porosity

Longitudinal
Dispersivity
1.50E-01

Horizontal
Transverse
Dispersivity
(m)

Solute Transport Properties Input Parameters

1.00E-02

Vertical
Transverse
Dispersivity
(m)
3.00E-03

Fractional
Carbon
Content
1.00E+00

Vapor
Diffusion
Efficiency
Coefficient
PUMPING CONDITIONS

Page 3 of 3

8 /2612 01 1

0.31

(m /day)
6.23E -03

.98E -03

Linear Velocity

Darcy Flux
(m/day)

Groun. dwater

Report Created on 8/2612011

Simulation
Number

6.60E -03

Groundwater
Gradient
(Wm)

1.66

an Genutchen
1205

Srw

1.48E -01

(cu in/day)

(m)
5.94E+00

3 -Month Rate

Rate

0.136

Sro

t.46E-01

(cu m/day)

1 -Year

6.25

300E -01

K (m /d)

1.41E-01

3.75E +03

(cu Wm)

0.40

Page

3.02E-01

(cu m /mf)

of 2

Inital Specific
Volume

Final Specific
Volume

0.19

Initial
Peak So

Total Porosity

Rate
(cu m/day)

3 -Year

Recovery Initial VEQ LNAPL Selected
Time (yrs)
Thickness (m)
Sm

PUMPING CONDITIONS

Residual
Thickness

Dual Pump Extraction

van Genutchen
Alpha (1 /m)

Groundwater Condition Input Parameters

Medium Sand

Seil'. Type

Soil Properties

Simulation
Number

031

van Genuchten
Alpha (1 /m) Recovery Method

estern Fuel Oil

Time to 15% of Time to 50% of Time to 99% of
Recoverable
Recoverable
Recoverable
(yrs}
(yrs)
(yrs)

User Input Parameters

Simulation
Number

Results

Medium Sand

Simulation
Number Soil Type

initiai Conditions

Title of Simulations: Port LA Distribution Center, Forme

of Analysis:

SOS Engineers

Project Manager:

Date

Port LA Distribution Center

Site Name:

Executive Summary - LNAPL Recovery

Oil Density
(gm /cc)
0.81

25.00

25. ©0

100.00

10.0

Period of
Recovery

Repart Created on 8i2612011

Simulation
Number
1.0

Number
Wells

Ratio of Radius of
Influence / Radius
of Well (Water) (m)
500.0

50.0

70.0

8.64E-04

9.6

Water
Production Rate
(cu mldaylwell)

Criteria For Minimum
Mobility (mlday)

Ratio of Radius of
Influence / Radius
of Well (LNAPL (m))

Volatilization Included

Source Volitilization

Fluid {LNAPL and
Water) Saturated
Screen Length (m)

Dual Pump Extraction Recovery Input Parameters

Distribution After Fixed Period of Remediation

Simulation
Number Method Used To Calculate LNAPL Saturation

1.50

(cp)

Viscosity

PUMPING CONDITIONS

OillAir IFT
(dyneslcm)

100.00

(m)

Oil/Water iFT
(dyneslcm)

27.40

Width of
LNAPLZon

Length of
LNAPL Zone

Method. Used to Calculate LNAPL Saturation Input. Parameters

Gasoline

Simulation
Number Product Type

LNAPL Properties

5.25

Vertical
Depth to Top
Simulation
Formation
of LNAPL
Number
(m)
Thickness (m)

Source Area Input Parameters

Program

Water Production
Rate Calculation
Method

Page 2 of 2

SCS Engineers

August 26, 2011

Project Manager:

Date of Analysis:

Report Created on 8(26/2011

Xyiene

Benzene
Ethyl Benzene
Toluene

(ugü)
3.29E+03
6.93E+92
2.30E+01
1.86E+p2

Originai
Concentration

Simulation Number

3.13E -01

Initial Specific Volume
lcu m /m2)

031

Alpha (11m)

van Genutchen

este m Fuel Oil

0.136

(°%a)

Selected Sro

SPARGING CONDITIONS

3.29E+03
6.93E+02
2.30E+01
1.85E+02

6.92E+02
2 30Ey01
1.85E +02

3.29E+03

3.28E +03
6.92E +02
2.30E +01
1.85E +02

6.92E+02
229E+01
1 85E+02

324E+03

Concentration at Concentration at Concentration at Concentration at
20 Years
100 Years
1 Year
10 Years
fug /l)
(ugll)
Ogg)
(ugh])

nitial Peak So

Medium Sand

Soit Type

Initial VEQ LNAPL
Thickness (m)
625

Soil Layer

Compound of Concern

ResuE

Simulation
Number

Initial Conditions; Soil & Flow

Title of Simulations: Port LA Distribution Gen

Port LA Distribution Center

Site Name:

Executive Summary - Source Zone Composition Through Time

Page

of 3

Medium Sand

to multi e toyer soil conditions

(tnlm)
6.60E -03

(rn day)

623E -03

7.98E -03

625

Gasoline

Oil Density
(gm /cc)
0.81

Oíl /Air IFT
(dynes/cm)
25.00

25.00

100.00

Report Created on 82612011

Equilibrium LNAPL Distribution

Simulation.
Number Method Used To Calculate LNAPL Saturation

Q136

Sro

Criteria For Minimum
Mobility (mlday)
8.64E-04
Volatilization Included

3.00E -01

K (mid)

Source Volitilization

1.50

(cp)

Viscosity

SPARGING CONDITIONS

0.205

Srw

Oil/Water IFT
(dyneslcm)

27.40

(m)
100.03

(m)

LNAPL Zone

Length of
LNAPL Zone

Method. Used to Calculate LNAPL Saturation Input Parameters

Simulation
Number Product Type

LNAPL Prapertïe

Simulation
Number

Vertical
Depth to Top
of LNAPL
Formation
(rn)
Thickness (m)

Width..

Groundwater
Gradient

1..66

Linear Velocity

Oil

van
van
Genutchen Genutchen
n
Alpha (11m)

Groundwater
Darcy Flux
(miday)

Source Area Input Parameters

Simulation
Number

Groundwater Condition Input Parameters

OnBy apply

Simulation
Number Layer Sail Type

Soil Properties

User Input Parameters

0.40

Total
Porosity

Page 2 of 3

011

0.318

1A0E-02

(m)

(in)
1.50E -01

(m)
3.00E+00

Vertical
Transverse
Dispersivity

Horizontal
Transverse
Dispersivity

Effective
Porosity

Report Created on 812

Simulation
Number

Longitudinal
Dispersivity

Solute Transport Properties Input Parameters

300E -03

Fractional
Carbon
Content
2.50E

Vapor
Diffusion
Efficiency
Coefficient
SPARGING CONDITIONS

Page 3 of 3

Port LA Distribution Center

Appendix

March 14, 2014 Addendum to Dissolved- and LNAPL Plume
Stability Evaluations and Discussion of Cleanup Implications
Aqul -Ver. Inc.

Report - Site Closure

Marsh 2014

AQObVXß INC.
unwo5eomyX Iv<,rer R¿eowe.oa & Dam Survive

MARCH 14, 2014 ADDENDUM TO:
DISSOLVED AND LNAPL PLUME STABILITY EVALUATIONS AND
DISCUSSION OF CLEANUP IMPLICATIONS

PORT OF LOS ANGELES DISTRIBUTION CENTER
(FORMER WESTERN FUEL OIL FACILITY)
300 WESTMONT DRIVE
SAN PEDRO, CALIFORNIA
Original issue: August 30, 2011

LA.

to the:
Regional Water Quality Control Board
Attention: Paul Cho

For:

Mr. Leland Nakaoka
BlackRoek Realty Advisors
4400

MacArthur Boulevard, Suite 700
Newport Beach, CA 92660

In Cooperation With:
SCS Engineers
8799 Balboa Avenue, Suite 290
San Diego, CA 92123

G.D. Beckett,

CEHO

AQUI -VER, INC.
HydrogeoloD,, Water Resources & Doto Services

5871 North 2200

Woo,

01W

rh. .13202í.01R9 FAX 9J2625-N026

AQt14Ye@,INC.
Htelruganloyv. Water Reitman' & Ana 5'arv,

TABLE OF CONTENTS
ES -I

EXECUTIVE SUMMARY
INTRODUCTION

........ .................. ........ ........ ........ ......... .I
.

RECENT DATA COLLECTION
Conditions Since 2011 AVI Reporting
MW -24 - Decreasing Benzene & Increasing DRO
PetroleumImpacts at MW
REQUEST FOR SITE CLOSURE

1
2
3

.................. ..............................4

REPORT CLOSURE
REFERENCES

,,,.,,,

.................... ..............................7

LIST OF FIGURE,
Figure
Figtire
Figure
Figure
Figure

I: Site Plan
2: MW-24 - Benzene and Diesel Concentration Trends
3: PIANO Analytical Results, MW -10R vs, MW -29
4: Gas Chromatographic Results, MW-10R, MW -26, MW -27,
5: Groundwater Geochemistry Results, MW- IOR vs. MW -29

MW -29

ATTACHMENTS
Attachment #1:
Attachment #2:

-I60300

do Waal rppurtlMö

nsic Report or Dr, Alan Jeffrey

Inclusive in SCS Reporting

Dissolved- and LNAPL Plume Stability Evaluations and Discussion of
Cleanup Implications, Former Western Fuel Oil Facility, 300 Westmont
Drive, San Pedro, California, August 30, 2011
IRdIWA1Vpd

ail,

Non!, 220/ Wart, IMP

Ph. 135á554402q

FAX 435 655.0024

AQU1NI4R, INC
(b*oMvofalry. Wutar Rexuorot,S,

L15-1
1

EXECUTIVE SUMMARY
In 2011, AQUI -VEIL, INC. (AVI) performed extensive analyses into contaminant fate and transport,
free product stability, recoverability, and the degree of remaining practicable cleanup at the subject
site In that work, we found the dissolved -phase plumes to be stable or contracting, posing no threat
to use of groundwater, and expected to reach State maximum contaminant levels (MCLs) in a
reasonMe time frame. We also found that the LNAPL plume is stable and non -recoverable using
commonly available cleanup methods.

In thisupdate, we have reviewed more recent data collected by SCS Engineers over the intervening
and found that conditions remain relatively unchanged and within the n'ange of expectations
seated in our 2011 work. That work therefore stands as published (attached hereto),.

In total, we determined that the site then met and now continues to meet the requirements of State
Resolution 92 -49 closure, and that no further action is warranted at the facility. Since our 2011
report, the State Water Resources Control Board (SWRCB) has also further clarified its position on
closure of low -risk underground petroleum storage tank sites. That Low -Risk Policy states that it
is applicable to petroleum underground storage tank sites and other sites of similar nature, as is the
subject former Western Fuel Oil site (currently the Los Angeles Port Distribution Center).
Based on our past and current work, the site meets all the standards of a 92 -49 and Low -Risk
closure. The plumes are stable and declining, they pose no risk, and they are approaching MCLs in
a reasonable time frame. Additional cleanup is impracticable, as has been shown in our work, and
regardless would have no benefit to the waters of the State if attempted. Given the extensive
cleanup at this site, over many years and many millions of dollars, the non -risk condition, the nonrecoverable remaining LNAPL, and the estimated attainment of MCLs in reasonable time, this site
should he closed with no further action according to State policies, It is, however, recommended
that wells be destroyed and other logistical aspects are dealt with as part of the closure process.

.iasGseaai i r..nesosfea

AQUbGR,

INC.

/QJraReOla/pl IYnur &sOlme>P ip

nun Saito

INTRODUCTION
This is an addendum to our report issued in August 201 I, in coordination with SCS Engineers,
entitled "Dissolved- and INAP, Plume Stability Evaluations and Discussion of Cleanup
lmplwatr'ons, Farmer Western Fuel Oil Facility, 300 Westmont Drive, San Pedro California, August
30, 2011. " That 2011 report is attached here for convenience. Since that tine, additional data have
been collected at the facility by SCS, as discussed below, which do not impact the findings and
conclusions of our referenced 201 I report, which stands as published. Further, State Policy has
changed with the introduction of the Low -Risk Policy for Underground Petroleum Storage Tanks
(acid applicable to related facilities like the subject site).
The subject site is currently the Port of Los Angeles Distribution Center (PDC), and was formerly
the Western Fuel Oil Facility that underwent extensive rcmediation In preparation to facilitate its
present use, as well as post -development rcmediation actions. As summarized by SCS, this site has
had numerous active cleanup actions taken to date, including pump and treat, extensive soil
excavation, air sparge/soi I vapor extraction (IAS & SVE), free product recovery and other ancillary
actions. As of 2001, it was estimated that approximately 12 million pounds of hydrocarbons were
treated by the IAS /SVE system, and another 20,000 yd' of impacted soil was excavated (Cape,
2001). About [3,000 gallons of water /product mixture have been hydraulically recovered from wells
MW-6R and MW -14R, with water typically being the major component of that volume (SCS,
201 la). Certainly all of these past cleanup actions have vastly improved the site environmental
conditions in that the vapor pathway is now negligible, and the mass recovered stabilized and
reduced the long -term presence ofthe LNAPL and dissolved -phase plumes. However, some resIdual
impacts remain, as discussed in SCS's work (2014) and in our prior efforts (201 I).
Stable and declining plume conditions continue to exist today that were demonstrated in ourattached
2011 work to be approaching regulatory cleanup levels In a reasonable time -frame. There are no
risks from these existing stable and declining plume conditions (SCS, 2009, 2014). It. is not
anticipated that the groundwater beneath the site would ever he used for drinking water production
due to its location within the seawater intrusion protection system, and its location adjacent to non beneficial use and saline waters. Any conceivable use of these waters in the future would require
extensive treatment, which in of itself would make the waters beneath the site usable as well if that
were ever to be undertaken. In short, the remaining plumes pose no threat and are approaching
regulatory cleanup limits via natural attenuation processes in a time frame reasonable with the site
and groundwater setting.

Given the extensive cleanup conducted at the facility over time, the low residual levels of impacts,
the contracting plumes, the absence of risk, and the impracticability of further beneficial cleanup,
it is my professional opinion that this site should be closed immediately under the Low -Risk Policy
or Resolution 92 -49, with no further actions excepting well destruction and reporting.

RECENT DATA COLLECTION
As reported by SCS (2014), additional groundwater sampling, gauging, and well installation has
been conducted since AVl's 2011 report. Review of the sampling data indicates that overall
conditions have remained in a state of slow plume decay, consistent with prior reporting and analysis
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(discussed below). Within overall conditions, there were two changes of potential concern in the
newer information, First, ensile well MW-24 has experienced an increasing trend in diesel range
impacts, while at the same time benzene has continued to decrease at that location. As discussed
further below, our interpretation is this represents surface infiltration from the Port Distribution
Center operations down the weilbore into the sampling zone,
lid, newly installed offsite well MW -29 (at the intermediate zone level), exhibited petroleum
range Impacts inconsistent with fate and transport and other site conceptual model aspects. As
explained below, several lines of evidence, including advanced chemical forensic analysis,
demonstrate that the impacts at MW -29 are related to a release source other than the Port
Distribution Center. The adjacent refinery, area pipelines, and historic operations by others are all
possible sources for these relatively low impacts at MW -29. However, since petroleutn impacts at
this well are clearly not connected to the subject Port Distribution Center site, impacts there have
no influence on our prior plume and transport evaluations.

Conditions Since 2011 AVI Reporting

It is important to review updates in overall site plume conditions since our 201 l reporting to ensure
expected trends are continuing, which they areas discussed below.

With regard to fate and transport, groundwater gradient conditions reported by SCS (2014) are
an overall upward gradient and lateral gradients between
0.004 and 0.006 ft /11. The lateral groundwater gradient used in our 2011 transport evaluations was
0.007 fi /fì.

within the ranges of prior conditions, with

Review of benzene data (SCS, 2014) demonstrates that as of the January 2014 sampling, benzene
is either within or below the historical range of concentrations used in our 201 work. Similarly,
forensic and standard analyses fol'TBA and TAA shows these compounds to also be within or below
the historical ranges at that site, again, indicating ongoing downward trends in plume concentration
and mass. TBA and TAA were not detected in the most recent standard lab sampling (January 2014),
and only detected in MW -I OR (85.06 ugh!, February 2014) in the forensic evaluations, which have
a lower detection limit than standard laboratory work.
I

Review of the free product thickness detection data shows that free product co tinuesto be observed
at low historic levels at three locations as of the January 2014 gauging even (SCS, 2014); MW-6R
(0.47,f1), MW-14R (0.30 -f1), and MW-19R (0.05.It). These free product thicknesses are well within
the ranges considered in our 2011 evaluations of free product stability and recoverability.

MW-24 - Decreasing Benzene & Increasing DRO
is an intermediate depth well, located in the truck loading area of the PDC (Figure 1, Site
Plan). As seen by the chemical hydrograph for well MW -24 (Figure 2), benzene has been generally
decreasing in concentration over tine, while there has been a distinct more recent rise in diesel range
organics (DRO) concentrations. Benzene is a compound of concern, DRO itself is not, so the key
takeaway is the ongoing expected decline in benzene concentrations is consistent with the
expectations of our 2011 work.

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It is noteworthy that these recent DRO concentrations are well above the solubility limits of diesel
fuels (typically less than 6 - I5 mgll solubility, API 2004), meaning that the results are emulsified
and invalid as a quantitative dissolved -phase measure, Therefore the apparent dissolved -phase DRO
increases may not in fact be present at concentrations reported by the lab. However, the increasing
concentrations do indicate a change in conditions and this is of potential concern given the location
of MW -24 within the trucking operations area of the PDC. The most obvious source for a new
occurrence of diesel at an intermediate groundwater depth at this location is the surface trucking
operations. Given the historic nature of the subject plume beneath the PDC, and the absence of
significantly changed hydraulics or other conditions, there is no expectation that Oils DRO increase
is a result of natural fate and transport processes, but rather á new and presumably short -term pulse
from surface runoff infiltrating the well box. It is always problematic to have direct conduits to the
aquifer under conditions where there are surface sources that can add contaminants, which are
fundamentally low mass artifacts imprinted on the broader historic plume.

Given the overarching recommendation of our work, which is for site closure, it is recommended
that this well and others within the operations footprint of the PDC be destroyed, as chemical and
gauging trends over the years are well controlled, and the risk of having these wells remain is greater
than the value or maintaining these locations.

Petroleum Impacts at MW -29
Recent work by SCS (20 3/20 4) included installation or new offslte and down gradient wells
relative to the PDC she. An intermediate zone well furthest down gradient, MW -29, exhibited
unexpected petroleum impacts based on the conceptual site model and expected transport conditions
(Figure 1, Site Plan).
I

Advanced Forensic evaluations by Zyrnax Laboratories, and a review by their Senior Geochemist
Dr, Alan Jeffrey (attached hereto), show that the impacts at well MW -29 bear no resemblance to,
and could not have collie from, the PDC area plume. For instance, a diagram of the paraffins,
isoparaffins, aromatics, napthenes, and olefins (PIANO; Figure 3) of MW -29 as compared to ensile
well MW-10R shows the highly distinct differences in these petroleum products. There is also a
poor correlation in the gas chromatographic response between these locations (coefficient of
correlation = 0.29; Figure 4), Given these observations, and those of Dr. Jeffrey, it is chemically
definitive that MW -29 Is unrelated to the PDC site plume.
In addition to that straightforward line of forensic chemistry evidence, there are other supporting
observations for this conclusion. First, as shown in Figure 5, the groundwater geochemistry at MW29 is significantly different from that within the PDC plume. That is, the groundwater at MW -29
is no longer the saine as the PDC groundwater, but rather something much different (saltier). If
transport was from the PDC to MW -29, groundwater geochemistry would tend to be similar. There
is obviously the addition of non -site groundwater to this MW -29 area, and that means that a good
portion (or all) of transport to this area is not from the PDC site.

Well -known plume transport principles, coupled with California's plume distribution studies, dictate
that contaminant concentrations decrease with distance away from the "source" area, It Is not
reasonable to have higher concentrations ofa degradable compound like benzene at a distal location
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like MW -29 than k present in near -source locations like MW -10R. This is physically implausible.
Further, M W -29 does not contain detectable tert-butyl alcohol (TBA) or tert-amyl alcohol (TAA),
the most transportable of contaminants present historically onsite, that will effectively move with
the flow of groundwater and be muted by attenuation processes. It is not expected that a degradable
compound like benzene would travel preferentially to lesser degradable compounds like TBA and
TAA, Further, MW -29 contains diisopropyl ether (DIPE), whereas source area wells at the PDC
do not DIPL was used by some refiners as an anti -knock and oxygen additive from the late 1970s
forward, peaking In the mid -1990s during the Reformulated Gasoline era (RFG). Again, the
presence of DIPE and absence ofTBA/TAA at MW -29 are distinguishing features, along with the
other forensics, of a release attributable to a source other than the PDC site. MW -29 also contains
chlorobenzene, which has never been detected in PDC plume wells.
In summary, petroleum impacts were discovered at MW -29 that are unrelated to the PDC site, and
therefore do not influence past work regarding plume stability, transport, or risk,
In total, given the data reviews above, there have been no changes in overall plume conditions since
2011 that would have an impact on the work and conclusions of our 2011 reporting. That report

stands as issued.

REQUEST FOR SITE CLOSURE
Based on the analysis in our 2011 work, which remains fundamentally unchanged with regard to the
newer data collection since, it is my professional opinion that the site meets the closure
specifications of the SWRCB Resolution 92 -49, as well as the low -risk policy. In specific:
1.

The unauthorized release is located within the service area of a public water system; as
reported by SCS, the site is serviced with public water, and groundwater flows into a non beneficial -use zone, just offsite, Further, the site is within the sea -water intrusion system
whereby changes to these conditions are highly improbable: Plume statistical evaluations
and fate and transport analyses confirm that the plumes are stable and pose no risk to
beneficial surface or groundwater.

The unauthorized release consists only of petroleum; as documented by the data collected
by SCS, the subject plume is the direct result of historic petroleum operations predating the
PDC operations of today.

The unauthorized ( "primary ") release from the tank system has been stopped; tanks and
other operational features of the former Western Fuels svere removed in the late 1990s and
remediated as part of the extensive work preparing the site for its Brownfield conversion
from an impaired property into a viable new business.

Free product has been removed to the maximum extent practicable, The present extent is
limited to three wells that have had generally decreasing observed thickness trends over the
last several years, and low transmissivity values. Despite ongoing vacuum truck recovery,
these small isolated occurrences remain; the greatest remaining observed thickness as of last
measurement in January 2014 was 0.47-ft at MW -6R, with a declining trend. Part of the
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limitation in additional cleanup

is that the majority ofthe plume was already remediated with
the property change to the PDC, The other limitation pointed out in our 2011 report is that
the LNAPL that remains is submerged below and immobilized by the water table levels,

presenting difficult additional remediation targeting.
Site LNAPL transmissivity values (determined with site specific data) are much lower than
the 0.1 to 0,8 ft' /day range that the Interstate Technology & Regulatory. Council (ITRC;
2009) recommended as a practical endpoint to effective hydraulic LNAPL recovery. Our
detailed analysis, using site specific parameters collected by SCS, demonstrates that
additional free product recovery will have no measurable beneficial effect. Other remedial
options are not viable with the footprint of the PDC business operations, and are not
warranted given the negligible expected benefit, as detailed in our 2011 work, At this late
plume stage, natural mass losses likely exceed the faitingly small remaining recovery
possible through hydraulic recovery.
5.

A conceptual site model has been developed; SCS along with AVI have completed
development of a robust site conceptual model based on 3- dimensional data collection and
years of data acquisition (and cleanup) considering petroleum impacts, transport & receptors,

Secondary source removal has been addressed; as part of the redevelopment, a substantial
portion of surface and subsurface soils were removed to create a "clean" buffer around the
new PDC operations. There are no secondary source removal actions remaining.

Soil or groundwater has been tested for MTBE and results reported in accordance with
Health and Safety Code section 25296.15. The small residual impacts ofTBA and TAA
have been demonstrated through our work to pose no adverse risk to the waters of the State.
MTBE is not present at the subject site.

In summary, the site presents no adverse risk to receptors, including the ground and s
's of the State. The residual site plumes are stable and contracting, pose no risks, and
will attain regulatory cleanup thresholds within a reasonable time frame. Given all the
cleanup work done to date, the change from a leaky disheveled old refinery /tank farm to a
viable Brownfield business redevelopment, and the coincident property improvements
thereof, this site is well suited to immediate regulatory closure.

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REPORT CLOSURE
The work herein has been conducted based on current scientific principles and the data provided by
SCS Engineers and other sources, These site evaluation results depend directly on this information,
Changes or corrections to site data could potentially alter interpretations herein, and if such changes
are manifest, it is recommended that these evaluations be updated accordingly. Hydrogeologie and
multiphase (LNAPL) evaluations have some level of inherent uncertainty in that pore and molecular
scale processes are represented by a macroscopic continuum, and results should be viewed
accordingly. Similarly, the discrete distributions and effects olgeologle heterogeneity at most sites
are defined only on a limited basis, The analyses and evaluations herein are intended to set
technical scenarios, not to represent highly detailed spatial or temporal variability. This work has
been conducted in accordance with accepted scientific principles and the professional standards of
the State of California and other states with reciprocal professional standards.

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Air Force Center for Environmental Excellence, 2012 (various authors). Low Risk Site Closure,
API, 2004. Interactive LNAPL Guide
1TRC, 2009. Evaluating LNAPL Remedial Technologies for Achieving Project Goals,

SWRCB, undated. Technical Justification for Groundwater Plume Lengths, Indicator Constituents,
Concentrations, and Buffer Distances (Separation Distances) to Receptors.
SWRCB, October 1996. Resolution 92.49. Policies and Procedures for Investigation and Cleanup
and Abatement of Discharges under Water Code Section 13304
SOS Engineers, 2009, Conceptual Site Model, Port I.A Distribution Center (CAO 85 -17, SLIC No.
352 Site ID 2040069), 300 Westmont Drive, San Pedro California 90733. May.

SCS Engineers, 201la. Report of Cone Penetration Testing Investigation, San Ped
Center, 300 Westmont Drive, San Pedro California 90733. June.
SCS Engineers, 201Ib, Groundwater Monitoring Report, Second Semiannual 2010, San Pedro
y.
Business Center, 300 Westmont Drive, San Pedro California 90733.

SWRCB, 2012. Low -threat Underground Storage Tank Case Closure Policy, www.swreb.ca.gov,
http://www.waterboards.ca.gov/ust/It_els_pley.shtm I.
SCS Engineers, 2014; Groundwater Monitoring Report, Second Semi -annual 2013. San Pedro
Business Center, 300 Westmont Drive, San Pedro, California

Zymax Forensices, February 2014. Forensic Report of Dr. Alan Jeffrey
Zymax Forensices, February 2014. Forensic Testing Results, MW-10R, MW-26, MW -27, MW -29
"* other relevant references are in AVI's 2011 report

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--o Benzene

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Appendix

Report
28,
2014
February

Zymox Port

cul Report

Site Glasure

D. C.

March 2014

forensics

Port D.C.

Report Prepared

SCS

Engineers

3900 Kilroy Airport Way
Long Beach, CA 90806

Report Prepared

By:

Alan Jeffrey, PhD

ZymaX Forensics, 600

Andreasen Drive, Suite
28 February 2014

Escondido, CA 92029

TABLE OF CONTENTS

INTRODUCTION
METHODOLOGY
HYDROCARBON CHARACTERIZATION AND
COMPARISON
6

CONCLUSIONS

Port 17,C',

Page 2

Introduction
Four water samples, labeled M W -10R, M W -26, MW -27, and M W -29 were received at Zymax on

February 13, 2014 for characterization and comparison of petroleum products
following analyses were performed:

the sample, The

gasoline range hydrocarbon concentration by GC /MS

Co -Cio

Fuel oxygenates by GC/MS

C,o -C40 alkane analysis by GC/MS

The complete laboratory data report is presented as an Appendix to this report.

Ft t RC:,
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Page

Methodology
C3 -Cto

gasoline range gaaatitatlott iu water and soil samples by GC /MS

Volatile hydrocarbons are purged from water samples by bubbling helium through the sample.
The purged sample components are trapped and concentrated on an adsorbent trap. When
purging is complete, the sample components are desorbed by heating and back -flushing the
adsorbent trap with helium. The desorbed hydrocarbons are cryofocussed on a capillary pre column. The cryogenic hnp Is then flash -heated and the analytes are injected into the gas
chromatograph (GC) as a tightly focused mass. A 60 meter narrow bore DB5 capillary column is
used to separate the hydrocarbon, which are detected with a mass spectrometer (MS) interfaced to
the GC. A total of 123 volatile hydrocarbons and sulfur containing compounds are quantified by
comparison with authentic standards.

Fuel oxygenates in water and soli samples by CC /MS
Oxygenates are purged from water samples by bubbling helium through the sample, Soil samples
are shaken with methanol, and an aliquot of the methanol extract is injected into distilled water
and purged in the same way as water samples.
The purged sample components are trapped and concentrated on an adsorbent trap. When
purging is complete, the sample components are desorbed by heating and back -flushing the
adsorbent trap with helium. The desorhed hydrocarbons are cryofocussed on a capillary pre column. The cryogenic trap is then flash-heated and the analytes are injected into the gas
chroutatograph (GC) as a tightly focused mass. A 60 meter narrow bore DB5 capillary column is
used to separate MTBE, TAME, ETBE, DIPE, TUA, and ethanol, which are detected with a mass
spectrometer (MS) interfaced to the GC.

Cup -C40

alkane distributl on by CC /MS

Water samples are extracted with methylene chloride solvent and the solvent extract
orated. Extracts are directly infected into a GC equipped with a 60 meter DB I column to
separate the hydrocarbons, which are detected with a mass spectrometer (MS) in Bill scan mode,
interfaced to the GC. N- alkalies and isoalkanes in the range of 0w to C40 are identified by
comparison with standards, and by MS fragmentation patterns.

Pon D.C.

Page 4

Hydrocarbon Characterization and Comparison
The C3-Ci0 gasoline range concentrations in the samples are shown in the Appendix, and are
displayed as bar diagrams in the following pages. MW -10R, shown on p.7, contains a suite of
hydrocarbons that is dominated by cycloalkanes, but contains small concentrations of
trimethylpentanes, which are alkylate hydrocarbons that are blended into gasoline to increase
octane levels. The BTEX components are dominated by benzene and ethylbenzene, which is
characteristic of degradation In ail anaerobic environment (Chapelle, 2001). The bar diagram of
MW -26 on p.7 shows a similar distribution to MW- IOR tip to C8, Benzene and ethylbenzene,
however, are In hutch lower concentrations in MW -26, which would be consistent with the
dissolved hydrocarbon plume migrating Into a more aerobic environment, which would promote
the degradation of the benzene and ethylbenzene. The concentrations of the C3- benzenes and
Cd- benzenes are relatively higher hi MW -26, and may reflect input from another source.
The bar diagram of MW -29 on p,8 shows a very different hydrocarbon distribution, which is
dominated by benzene and a methylpentene. In addition, in comparison with MW -26, the
distribution of ütethylpentaites (identified as horizontal line l) is different, and the concentrations
of the dirnethylcyclopentanes (horizontal line 2) are considerably lower. The relative
concentrations of the BTEX compounds in MW -29 reflect their solubility in water and represent a
relatively undegraded dissolved gasoline plume. MW -29 also contains DIPC, (7 ug/L), a fuel
oxygenate that was not detected in any other samples. These differences in the hydrocarbon and
additive compositions indicate that the gasoline in MW -29 is not sourced from MW-10R.
In the bar diagram of MW -27 on p.9, benzene is dominant, with very small concentrations of
other hydrocarbons. Ethylene dichloride (EDC) was also detected, which is probably associated
with the other chlorinated solvents, dichloropropane and trichloropropane, that were detected in
the sample, as shown in the appendix. Dichloropropane is an intermediate m the production of
tetrachloroethene and other chlorinated chemicals ( Rossberg et al, 2006).
Ilistorically,
trichloropropane has been used as a paint or varnish remover, a cleaning and degreasing agent,
and in the production of pesticides. Currently, it is also being used as a chemical intermediate in
the process of making chemicals such as hexafluoropropyiene and polysulfides and as an
industrial solvent (Cook, 2009). Tetrahydrofuran, an industrial solvent, was also detected in
MW -27: The minor hydrocarbon constituents in MW -27 are in such small concentrations that it
is difficult to make any reliable correlation to the other samples. However, the BTCX distribution
more closely resembles the distribution in MW -29 than MW -26, suggesting that In MW -27 the
BTEX compounds in particular are probably derived from the same source as MW -29.

Chapelle, RL!. (2001) Groundwater Microbiology and Geochemistry ; 2 "" Edition. John Wiley and Sons Inc

New York, pp:398.3l9.
Cooke, Mary (2009). Emerging Contaniiña n =- 1,2,3-Trlchloro

s (TCP (Report). United Slates EPA,

Manfled Rossberg, Wilhelm Lendle, Gerhard I'fleidercr, Adolf 'Mph Eberhard- Ludwig Dreher, Ernst
Longer, i-ieit z Kassaorts, Peter Klelnschmidt, I leint Struck, Richard Cuok; Uwe Beck, Karl- August Lipper,
Theodore R. orkelson, Eckhard Loser, Klaus K. newel, Trevor Mann "Chlorinated Hydreeerbúns" in
Ullmann's Encyclopedia
Industrial Chemistry 2006, Wiley- VCl-I, Weinheim.
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The C,o -Co GC/MS all me chromatograms are shown on pp.7 -9. MW -10R contains a suite of
hydrocarbons from 20 min to 55 min retention time in the carbon range CIO -C24, which is the
range of diesel and 42 fuel oil. Isoalkanes arc dominant, with no evidence of n- alkancs, which
are dominant in fresh diesel and ii2 fuel oil, but are the most readily biodegraded hydrocarbons.
The peaks up to 20 min retention time represent volatile hydrocarbons. There is no evidence of
this diesel(/12 fuel oil in MW -26, MW -27, or MW -29. In MW -26, there is, in addition to the
volatile hydrocarbons up to 30 min retention time, unidentified material from 45 -50 min and a
suite of n- alkanes from nC25 to nC35; this represents a small amount of petroleum wax from an
unknown source, In MW-27, the only alkanes identified were from petroleum wax. MW -29 also
contained a small amount of petroleum wax. A large peak, identified as C IOH 15N ©2S, probably
represents n- butylbenzenesulfonamide, which is widely used as a plasticizer in polyacetals,
polyamides, and polycarbonates, and has been found in ground water and effluent from
wastewater treatment sites.

Conclusions

Water sample MW -IOR contains dissolved hydro carbons that most likely represent
degraded gasoline.

MW -26 contains a similar gasoline, and some heavier aromatic hydrocarbons, probably
from another source.
a different gasoline with the fuel oxygenate DIM,
different source than MW-10R.

MW -29 contains
from

This gasoline

The dissolved gasoline in MW-27 appears to be more similar to MW -29, and is probably
from the same source as MW29.

MW -I OR also contains degraded diesel or #2 fuel oil that was not detected
MW-27, or MW -29.

Port D.C.

Page 6

MW -26,

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