FL200 A2313petitionpart2

User Manual: FL200

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San Pedro, California

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APPENDICES

Technical Report - Site Closure March 2014

Port LA Distribution Conte'.

Appendix A

Dissolved- and LNAPL Plume Stability Evaluations and

Discussion of Cleanup Implications

Aqui -Ver, Inc'.

August 30, 2011

To cí7 nlcol fte 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

EXECUTIVE SUMMARY ES-1

1.0 DISSOLVED PHASE PLUME EVALUATIONS 1

1,1 PURPOSE . , 1

1.2 METHODS 1

1,3 DISSOLVED -PHASE MASS ESTIMATES , 2

1,4 ESTIMATION OF CENTER OF MASS THROUGH TIME 2

1.5 PLUME LONGEVITY EVALUATION ......... n . . . . ... :..: ..... . . ..:. . .1

1.6 FLUX CALCULATIONS .... .............:. 4, ............ ..;....4

i J FATE AND TRANSPORT ................... ............,,,.,,,.,5

1,8 METHOD CONSERVATISM , , , . .... , ,. Ç

1.9 SUMMARY OF DISSOLVED PLUME CONDITIONS EVALUATIONS ... , , , . 2

APL PLUME EVALUATIONS 9_

2,1 OVERVIEW OF MULTIPHASE MECHANICS ,.:.,,,,,,,,,,;,;,,,,,,,,,;,9

2.1 BASIC PETROPHYSICAL PROPERTIES ,,,,,,,,,,,,,,,,,,,,,,,,,,,,;,, IQ

2.2 CAPILLARITY , ......... . ... . .... . , , . , , , l.1

2.3 LNAPL SATURATION 12

2.3.1 In Situ LNAPL Saturation . . . . . . . ... . . . . . . ......... .

2,3.2 LNAPL Mobility/Three-Phase Residual LNAPL Saturation Results

2.4 LNAPL PHYSICAL PROPERTIES

2,5 LNAPL CONDUCTIVITY ....:......... ..:: 13

2,6 LNAPL VELOCITY POTENTIAL- 14

3.0 EVALUATION OF LNAPL PLUME AND CLEANUP CONDITIONS ,....... ,,,.., j7

3.1 LNAPL STABILITY CONSIDERATIONS 17

3,2 LNAPL CLEANUP CONSIDERATIONS . , . .. .... . ... . .......... . 19

,..,.12

...12

4.0 REPORT CLOSURE ,22

5,0 BIBLIOGRAPHY ..,......,.,. :...::::.. ......... ......... ........ ........ 23

'Fable 1 -1:

Table 1 -2:

Table 1 -3:

LIST OF TABLES

Dissolved Mass Estimate for TBA

Longevity Estimate for TBA

Potential Flux Impacts to Groundwat l'BA

Table 2 -1: LNAPL Hydraulic Conductivity Estimates

Table 2 -2a: Data Used to Determine LNAPL Gradients

Table 2 -2b: LNAPL Gradient Results

Table 2.3: Estimate Range of Potential LNAPL Linear Pore Velocity

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LIST OF FIGURES

Figure I -l: Site Plan

Figure l -2: TBA in Groundwater - August/December 20

Figure 1-3: Benzene Center of Mass Through Time

Figure 2 -1: Time Series of LNAPL Saturation Distribution under Release Conditions

Figure 2-2: Literature Ranges for 2 -Phase vs. 3 -Phase LNAPL Saturation

Figure 2 -3: Initial vs. Residual LNAPL Saturation Results

Figure 2-4: Example of LNAPL Saturation vs. Applied Pressure

Figure 2 -5: Southwest to Northeast LIF Intensity Cross Section A -A'

Figure 2 -6: Southwest to Northeast LIF Waveform Cross Section A -A'

Figure 3 -I: Generalized Saturation Profiles Expected Under Cleanup Conditions

Figure 3-2: Generalized Benzene Change over Time Under Cleanup Conditions

Figure 3-3: Generalized Chemical Component Stripping By SVE & IAS

Figure 3-4: Ratio of Benzene to Ethylbenzene at MW -10 Overlapping IAS /SVE Cleanup

Figure 3 -5: Image of IAS In -Situ Air/Stripping Distribution in a Fine Sand

Figure 3 -6: Estimate of 1AS In -Situ Air /Stripping Distribution in the Gage Aquifer

Appendix I -l:

Appendix I -2:

Appendix I -3:

Appendix 1-4:

Appendix l -5:

Appendix 2 -I:

Appendix 2 -2:

Appendix 3 -1:

APPENDICES

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

(TBA ) and benzene dissolved -phase plumes, and separate evaluations to determine the state of the

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).

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LO 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 is two fold:

I. 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

2. 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

chemicals 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,

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).

As will be described subsequently, the evaluations conducted herein 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.

1.2 METHODS

valuutìon methodologies and procedures for the plume longevity estimates, potential

impacts to groundwater utilization, and plume stability are provided in Appendix 1 -I, and are

derived from plume genesis and transport theory. The methodologies are consistent with United

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States Environmental Próteçtiôn Agency (USEPA) récommended protocols for evaluating plume

trends (USEPA, 2002).

The fate and transport analysis for TBA was performed using BIOSCREEN (Newell and McLeod,

1996): BIOSCREEN is an analytical groundwater model designed to simulate transport and natural

attenuation of dissolved phase hydrocarbons at petroleum release sites. The tate and transport

analysis was performed to assess the potential lateral migration of the TBA plume and plume

stability based on site data and assumed parameter values from published literature.

1.3 DISSOLVED -PHASE MASS ESTIMATES

The mass of TBA dissolved in groundwater was statistically evaluated to estimate the maximum

dissolved phase TBA mass observed at the She based on available site data This mass estimate was

used to estimate plume longevity and to evaluate potential mass flux impacts to future groundwater

use at the Site as described in Sections 1.5 and 1.6, respectively. The maximum historical dissolved

phase mass was estimated for August /December 2007, This time period represents the most

comprehensive data set available for the site and includes onsite wells MW -6R, MW -14R, and

M W- 19R,which were only sampled one time in August 2007 by collecting discrete samples below

the LNAPL layer in the well casing, as well as onsite wells MW -5R, MW-8, MW -9R, and MW -10R

and offsite wells MW -12, and MW -I3, 'Phis data set also includes off -site wells MW -4, MW -7, and

M W -8, which are part of the ConocoPhillips site investigation to the north. These wells are shown

by figure I -1. All of the wells included in this analysis are completed within the shallow water

bearing zone characterized at the site, which is part of the Gage Aquifer (SCS, 201 la). Wells

completed in the intermediate and deep water bearing zones were not considered for this analysis

because the majority of the plume mass is in the shallow water bearing zone.

The first step in calculating the dissolved mass is to coustram the area of integration for TBA, which

reflects the maximum plume dimensions historically observed. The TBA groundwater concentration

data were compiled, log -transformed, and analyzed using kriging statistical methods, The

statistically generated results were reverse transformed to arithmetic values and integrated across

the spatial domain to provide a mass estimate based on the estimated impacted aquifer volume.

The impacted aquifer thickness was assumed to be 25 feet thick and the aquifer total porosity is

assumed to be 40% based on core data collected by SCS Engineers (SCS, 201 la).

Table I -I summarizes the results of the estimated dissolved -phase mass for TBA: The statistically

interpolated plume distribution map is illustrated on Figure l -2. The dissolved phase mass was

405.3 kilograms (kg) in August /December 2007 and this mass is thought to represent the maximum

historical dissolved phase mass based on available site data.

1.4 ESTIMATION OF CENTER OF MASS THROUGH TIME

An evaluation of the TBA center-of-mass through time could not be conducted due to the lack of

available TBA data Therefore, TBA plume stability was evaluated using a fate and transport

screening, as described subsequently. The benzene center- of-mass was evaluated through time;

however, there were some limitations to this analysis as described below,

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The statistical center -of -mass for benzene was estimated for three time stamps (April 2002, June

2005, and June 2011) using available data from onsite wells MW -5R, MW -8, MW -911, and

MW -1 OR and offsite wells MW -12, and MW -13, This data set also includes off -site wells MW-4,

MW -7, and MW -8, which are part of the ConocoPhillips site investigation to the north. Wells

MW -6R, MW -19R, and MW -14R are located within the core of the benzene plume; however, these

wells were only sampled twice (April 2002 and August 2007) by collecting discrete samples below

the LNAPL layer in the well casing. During the first sampling event in April 2002 it appears that

the groundwater samples were emulsified (i,e,, mixture of LNAPL and groundwater) based on

elevated total petroleum hydrocarbon gasoline range (TPH -GRO) sample results that exceed

solubility limits. As such, this data could not be used leaving only one time stamp that is meaningful

for these wells. Given that one time stamp is not suitable for estimating the center -of -mass through

time, these wells were eliminated from the data set. This results in a plume center-of-mass that is

slightly mislocated for all time stamps; however, evaluating the relative change or lack thereof in

the center -of -mass is the objective of this analysis not finding the exact location ofthe center -of-

mass.

The wells used in this analysis sure shown by Figure I -t and all of the wells included in this analysis

are completed within the shallow water bearing zone characterized at the site, which is part of the

Gage Aquifer (SCS, 2011a). Wells completed in the intermediate and deep water bearing zones were

not considered for this analysis because the majority of the plume mass is in the shallow water

bearing zone. In addition, thé submerged LNAPL plume is not present in the underlying water

bearing zones,

Plume statistics for benzone were generated using the same mass estimate analysis procedures

described in Section 1,3 for TBA. Based on these statistics the location of the statistical

center -of-mass was calculated, The center -of -mass calculation is performed by summing the

concentrations at the statistical grid intersects across the spatial domain established by the

interpreted plume boundary (Anton, 1984). At each grid intersect, a specific northing and casting

are associated with a specific concentration. In each coordinate direction, the north or east

coordinate is multiplied by its specific concentration and summed across the grid in that coordinate

direction: This value is then divided by the sum of concentrations at each grid intersect, leaving the

estimated coordinates of the center of mass (east and north, respectively).

of -mass location for each time stamp are illustrated in Figures 1 -3. The plume maps used

tat e the center -of mass location for each time stamp are included in Appendix I -2, The

center -of -mass analyses for benzene demonstrates a stable plume, The relative center -of -mass has

actually retracted through time.

1,5 PLUME LONGEVITY EVALUATION

Statistical trend analyses of dissolved -phase concentrations of Tl3A were performed on historical

analytical data from site wells with sufficient temporal data This includes wells MW -9R and

MW -10R, as these wells were the only wells at the site with more than one detection of TEA.

The graphs analyses were performed with non- detections settc>halfthe 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- I 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).

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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assumes a screen length of 100 feet. Scenario two assumes that the production well screen will

nearly fully penetrate the Gage Aquifer beneath the site.

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 1 -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.

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 of data 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 1 -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,

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

discharge. The hypothetical groundwater production rates are assumed without

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 l-

No 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.

5. 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.

6. 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,

Ó rk k Pt ] (6 p S) -11f I) indicates the Cartesian direction of the

2' q rp &x: of p p p 3- dimensional differential equation, ku is

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

transient in the early stages of the release due to the nonlinear aspects of controlling physics. An

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;

2. 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;

3. 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;

4. 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. Confirmation that the LNAPL releases are finite and not ongoing in the site;

2. Evaluation of the relative ange of the LNAPL plumes; the older a plume, the more probable

It has reached field static equilibrium;

3. Evaluation of LNAPL gradients;

4. Comparisons of estimated LNAPL to water conductivity values;

5, Evaluation of LNAPL flow;

6. Review of petrophysical properties, including expectations For an entry pressure threshold;

7. 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

rise. Larger values of indicate a more uniform yore geometry. As expected from the grain-size

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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2.3 LNAPL SATURATION

Saturation refers to the fraction of the pore space that is filled with any particular fluid phase. For

instance, a saturation of 10% within a porosity of would mean a volumetric content of 0.04 for

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

In situ LNAPL saturation measurements were conducted using the Dean -Stark method during

sampling events from 2005 to present. This method essentially uses weight measurements combined

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.

LNAPL saturation was measured on 12 soil cores (SCS, 2011a) and ranged from 0 to a tnaximtun

of 20.4% in sample SCS -132 -98.0. The median value is 6.1 %, and the geometric mean is 2.5 %.

These samples are purposely biased in that they specifically targeted zones of strongest laser-

induced fluorescence (LW) signals that suggested the presence of relatively more significant LNAPL

than in zones of lower signals,

2.3.2 LNAPL Mobility /Three -Phase Residual LNAPL Saturation 1

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 k PIS / (2)

/ 4f

Where "L" denotes. the LNAPL ¡ihn , and Kf, is the LNAPL condiaçzivfly, zlre re»XCZinrler of the

parameter being previously defined in egf.ratioit (iJ above.

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9r, _ K,1r. OS (4) Where N is the van Genuchten capillary fitting

parameter discussed previously, and 5' °,,, is the

effective water phase saturation, where residual 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

1 fl/day (discussed above).

TABLE 2-1 ! LNAPL HYDRAULIC CONDUCTIVITY ESTIMATES

ple ID arameters Nd ,

S 5,. h,l KI"

SCS431-99.0' 10.10% 6,83% 20.50% 95.49% 3.704i-02 1.78E-03

5[;8432.98.0' 20.40°l0 6.83% 20.50% 81,32'Y0 2,12E=01 1.02E-02

SCS-ß2-112.0 4.90% 6.83% 20.50"/° 102.69% 0"00E-F00 O00F"-t00

SCS-133.91:0' 8:50°Í 6.$3°f°

_.. ....

20,50"!° 9770"/e 1581:02 7601',-04

5C5-133-107.0 3 20% 6.83°(0 20.50°/" 104 99% 0 001.100 0.001d+00

SCS-B3-107.0'

.... 2.70"/a 6.83% 20.50°l° ..._.__. 105.68°f° 0.00E F00 0.00E+00

SCS-1)1-99 0' 7,00°/n 6.83°/u

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

SC'8-133-910' 730% ___.. 6.83%.

._...... 20.50"f0 98.80% ....... 6.861;-03

.._ 3311;-04

...

SCS-B2-98 6' ._-.....

14.20°U/0 6.83"/0 20.50% ..

89.85°/u 1.021x01 4 911'-03

...... --------.--

Native LNA1'I., satui n

'i dien tiPporo filled

Residual NAPE, Sahn'atiáli,

= Residual wtüer Satúèatioti,

S , -° Effective water phase Saturation

K L.NAPG eonduotieitv at tha

with water in a saturated system)

determined by lab testing

ïlétermined by lab testing

in a fully saturated system

narticular LNA['L s. m

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; R t 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.

TABLE 2 -2 DATA USED TO DETERMINE LNAP RADIENTS

Well ID Unte fOC Elev

(ft nmsl)

I7T)'

(feet ßfOC) PP Elevation

(fimnsl)

X Y

W- 19R

10/31/2002

97.67

89.56 8,11

6474945.511 1736943.385

6/282005 88.7 8.97

7.91

12/17/2007 89,76

6/7/2011 8934 8.33

MW-6R

10/31/2002

102.27

95.1 7.17

6475143.96 1737134.311

6/28/2005 94.15 .12

° ° ° ''

12/17/2007 - 94.7 -°° - 7.57

6/7/2011 94.45 7.82

MW14R

10/31/2002

92,91

87.75 5.16

6475586.769 1737298,454

6/28/2005 87.52 5,3

12/17/2607 87.59 5.32

6/7/2011 87.06 5.85

0/31/2 02

E 2-2b NA GRADIENT RESULT

lieut?

0.004

1)egrees from North

85.67

8/2005 0,008 113.4

12/17/2007

6/712011

,0.009

0.006

Notes:

7: Gradient and Dim lo alclll

128.4

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 NEAR PORE V

OCITY

.. ....... Sample ID i @ Vi,(Cf/yr) __..

. . ..m._..,

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

SCS,H3.107.0' ..... .... ..

0.006 n/a 0.011E+00 ......_

... .. .. ,...

SCS-63-107.0'

_._ ... 0.1106 n/a 0.00E+00

Ane ..,......

SCS13]99.0' ._. .

0,006

.._.. 0.028 3.21E-03

SCS-62 I 12,0' 0.006 0.033

.... ......_._.. 1.5613-02

. .... __.

SCS-S391.0' 0.006

..... ..... . ........ 0.031 2.34E-02

SCS-62-98.0' .. .. 0,006

__ _. 0.066 ..

I.64E-01

Max 3.51E-01

Min 0.00E+00

G cornea n 3.36E-02

Median 1.95E-02

il, = LNAPL gradient

0 = LNAPL-tilled porosity

V, -LNAPI.língar velocity pPtentïyl-

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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 -of-

evidence approach, where each factor alone is not as important as all factors in their totality, For

convenience, these factors arc repeated below;

1. Confirmation that the LNAPL releases are finite and not ongoing at the site;

2. Evaluation of the relative age of the LNAPL plumes; the older a plume, the more probable

it has reached field static equilibrium;

3, Evaluation of LNAPL gradients;

4. Comparisons of estimated LNAPL to water conductivity values;

5. Evaluation of LNAPL flow;

6. Review of petrophysical properties, including expectations for an entry pressure threshold;

7, 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 left-

aver 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 ill .4j]0354n34 rn%á9lbls.nilw

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in a 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.

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 worst-

se conditions (i.e., conservative).

The potential velocity of LNAPL (Item 5), was also found to be quite low, well less than I -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.

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,

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3.2 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).

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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).

Taking this a step further, IAS can, in principle, remove the volatile components from the LNAPL

as 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 W-

10 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.

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).

So, 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

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.

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IAS is in any ways a surrogate for any form of intensive or aggressive cleanup. Cleanup well

densities vertically and laterally are intense, particularly at this site, both for control and for the

effectiveness of the action. But more to the point, executing such an action at this site has obvious

limitations from a feasibility point of view, and again, even it implemented, would have negligible

benefit to the environment or the waters of the State. SCS has extensively discussed the poor water

quality and the limited value of the resource at this particular location.

Any use of the groundwater in the future at or near the site would require treatment prior to use to

remove salt and other man -made impacts besides the petroleum beneath the site. Water treatment

would also remove any petroleum hydrocarbons that might reach that hypothetical point of use. As

shown in the groundwater analyses earlier in the report, the dissolved -phase plumes are stable, and

in the case of benzene, where there are sufficient data to so demonstrate, that plume is contracting.

Therefore there are no reasonable or plausible impacts to water use by the remaining LNAPL, at this

facility.

Given that the site has all risk pathways contained and managed (low- rIsk), and given that additional

cleanup would have no net benefit to the waters of the State, and a high impact to site operations that

would need to cease to complete that effort, it is our opinion that no further action is warranted,

beyond monitoring plume stability and ongoing natural attenuation. There simply is no additional

action that might be taken in the thee of these beneficial site commercial operations that would have

any benefit, and in a variety of scenarios would have negative net benefits.

In summary, this site meets the concepts of the SWRCB 92 -49 Resolution allowing impacts greater

than MCL.s to remain in -place if they pose no threat to the waters of the State, and if additional

cleanup is infeasible or expected to have no net benefit, and if those impacts are stable and naturally

diminishing. The site meets all these criteria..

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4.0 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 may alter interpretations herein, and ifsuch changes are manifest,

it is recommended that these evaluations be updated accordingly. Flydrogeologic 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 ofgeologic heterogeneity at most sites are unknown.

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 scienti fie

principles and the professional standards of the State of California and other states with reciprocal

professional standards. No other warranty, express or implied, is provided.

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017INUn0EannWC 41xfiYbAO¢4 PAX "Q3655H0

IQOIXFIIt, INC.

H)vhogePl,a , lY,hr Rarouroer.@ 1krmSVrvurs

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in Monitoring Wells. Ground Water, v. 28, no. I, p. 57 -67.

Lundegard, P.D., Mudford, B., 1995. A Modified Approach to Free Product Volume Estimati ©n,

Conference Proceedings of the 1997 Petroleum Hydrocarbons & Organic Chemicals in Ground

Water; Houston, Texas, sponsored by the National Ground Water Association & American

Petroleum Institute,

MAGNAS3, [992, 1994. Multiphase Analysis of Groundwater, Non -aqueous Phase Liquid and

Soluble Component in 3 Dimensions, Documentation and User's Guide, Hydrogeologic, Inc,,

Herndon, Virginia.

Mercer, J. W Faust, C,R Cohen, R.M., Andersen, P.F. and Huyakorn, P.$ 1985, Remedial Action

Assessment for Hazardous Waste Sites via Numerical Simulation. Water Man, Res 3, pp. 377 -387.

Mercer, J, W and Cohen, R.M., 1990. A Review oflmmiscible Fluids in the Subsurface: Properties,

Models, Characterization and Remediation. Journal of Contaminant Hydrology, Vol. 6, Pp.

107 -163.

Morrow, N;R., Chatzis, I. and Taber, J.J., 1988. Entrapment and Mobilization of Residual Oil in

Bead Packs. Soc, Pet. Eng. Reserv. Eng., Aug. 1988, Pp. 927 -934.

Mualem, Y., 1976b. A New Model for Predicting the Hydraulic Conduetivity of Unsaturated Porous

Media. Water Resources Research. Volume 12, pp: 513 -522,

M.ualem, Y., I976a, A Catalogue of the Hydraulic Properties of Unsaturated Soils, Development

of Methods, Tools and Solutions for Unsaturated Flow with Application to Watershed Hydrology

and Other Fields. Israel Institute of Technology.

Newell, C,J and McLeod, R.K., 1996. B1OSCREEN Natural Attenuation Decision Support

System, User's Manual Version 1 -3, Groundwater Services, Inc, Houston, TX, EPA /600/12- 96/087,

August 1996

Nilkuha, K, and Hüyakorn, P., 1989. Numerical Solution of Two -phase Flow Through Porous

Media, Dept. OfGeoscience, New Mexico Inst. Of Mining and Technology.

Ostendorf, D.W., 1990. Long Term late and Transport of Immiscible Aviation Gasoline in the

Subsurface Environment. Water Science and Technology, Vol. 22, pp, 37 -44.

Panday, S., Forsyth, P,A,, Falta, R.W., Wu, Y.S. and Huyakorn, P.S., 1995. Considerations or

Robust Compositional Simulations of Subsurface Nonaqueous Phase Liquid Contamination and

Remediution. WRR, Vol. 3I, No. 5, pp. 1273 -1289.

51371 Nmlh 33D0 Wc,l, If NP i'b, d14 (dSS AX J9.9 63d

A4UI.V@II,INC.

±pdNgm/ugk. IYtilJr 2w017662s ä {blm5'bwvlHm 27

Panday, S., Wu, Y.S., Huyakorn, P.S., and Springer, E.P., 1994. A Three -dimensional Multiphase

Flow Model for Assessing LNAPL Contamination in Porous and Fractured Media: li. Porous

Medium Simulation Examples. Journal of Contaminant Hydrology, Vol 15, pp 131 -156.

Pankow, J.F., Cherry, J.A., 1996, Dense Chlorinated Solvents and Other DNAPLs in Groundwater.

Waterloo Press, Portland, Oregon..

Penman, D.W., 1977. Fundamentalso

176.

tealreservoir simulation. Elsevier, Amsterdam, pp.

t inder,G.F.andAbriola,L.M., 1986. On the Simulation ofNonaqueous Ph

in the Subsurface. Water Rescrv. Res., Vol. 22, No 9, pp. 109S -I 195.

Rathmell, J.i., Braun, P.H. and Perkins, T.K., 1973. Reservoir Waterilood

from Laboratory Tests, J. Pet. Technol pp. 175 -185.

Schiegg, I1,O., 1985. Considerations on Water, Oil, and Air in Porous

Technol., Vol, 23, No. 4 & 5, pp. 467 -476,

SCS Engineers, 2009. Conceptual Site Model, Port LA Distribution Center (CAO 85 -17, SI IC No.

352 Site ID 2040069), 300 Westmont Drive, San Pedro California 90733. May.

se Organic Compounds

Residual Oil Saturation

Media. Water Science

SCS Engineers, 2011a, Report of' Cone Penetration Testing Investigation, San Pedro Business

Center, 300 Westmont Drive, San Pedro California 90733. June.

SUS Engineers, 2011b. Groundwater Monitoring Report, Second Semiannual 2010, San Pedro

Business Center, 300 Westmont Drive, San Pedro California 90733. May,

Water Resources Control Board, 1996. Resolution No 92 -49, "Policies and Procedures for

Investigation and Cleanup and Abatement of Discharges Under Water Code Section I3304 ",

Stone, Ht., 1973. Estimation of Three-phase Relative Per

Pet. Technol., Vol. 12, No. 4, pp. 53 -61.

Theis, C,V 1935, The Relation Between the Lowering of

Duration of Discharge of a Well Using Ground Water

Transactions, vol. 16, pp. 519 -524,

USEPA, 2002 (Newell, C.J.; et al.).

Monitored Natural Attenuation Studies ".

ulatión zuid IJ

eability and Residual Oil Data. Can.

Piezometrie Surface and the Rate and

rage, American Geophysical union

of First -Order Rate Constants fi

van Genachten, M.Th., 1980. A Closed Forni Equation for Predicting the Hydraulic Conductivity

of Unsaturated Soils. Soil Sel. Soc. Ant J. 44, pp,892 -898.

682 l Nnrih 2200 Nis1, eer Ph. 435 655.8024 CA%J35155.ygáb

AQ(it-Vitte, INC.

pldrogeuloyy. Water Remnrw ,31 28

Wise, WA., Chang, C.C., Klopp, R.A. and Bedient, P.B., 1991. Impact of Recharge Through

Residual Oil upon Sampling of Underlying Ground Water, GWMR, pp, 93 -99.

Wu, Y.S., Huyakorn, P.S. and Park, N,S., 1994, A Vertical Equilibrium Model for Assessing

Nonaqueous Phase Liquid Contamination and Remediation of Groundwater Systems. WRR, Vol,

30, No. 4, pp, 903 -912,

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Table 1 -1

Dissolved Mass Estimate for TBA

300 Westmont Dr.,. Pedro, CA

Constants and Conversions.

Porosity 0,40

Impact Thickness 25.0 ft

Vol 28.32 Licubic ft

Mass Estimate Calculation

Integrated

Volume Area of

Integration Ave Conc

Volume of

Groundwater - Mass

(u& L) x sqn sgft ugfL L kg

1217/2007* - 1.43E+09 1603.95 _ 2.53E +08 405.3 8.92E +05

Note: "Samples also aoliected on 819107

Mass Es males. as æs

Asedara.cc

'h>tioxeaìere. Wart vrrerwnxsw,t Dan St. ,un

Table 1 -2

Longevity Estimate for TBA

300 Westmont Dr., San Pedro, CA.

Welt ID Well Location Constituent NL'

(ngIL)

Predicted Range to Reach

NLa

Earliest To Latest

MW-9R Downgradient TBA 12 2115/2012 - 5752015

MW-30R Downgradient TBA 12 _1.1l11/2018 - 12/252024 ,

1:_ £aitomie drinking water notification rawer (NL)

22 Range represents earliest and latest predicted dale to reach

Cardenas drinking water notification revel for either the

best erediclon endder the 35t CI estimation.

u9t£. = micrograms per tier.

Tßn - tertiary-boy alcohol.

MBA trend na'.ask Yxh:3ln Wet sllF,hùCCt.LZVON pkiï&i>Ni2t rat:43565>aIR6

Comment

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TABLE 1 -3

Potential Flux Impacts to Groundwater Use for TBA

Purring Well Production Rates (9p

(-Lit rc

Thickness Compund

CO Date K (ft/day) 100 200 400 500 1000

50 TBA ', December/August2007 1 10.72 5:36 3.57 2.68 . 2.14 1.07

100 TBA December/August 2007 5.36 2.68 139 1.34 1.07 0.54 '

alt concentrations are in units of ugli

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MW-200 cvr 10`-¿P'r-13

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ó Scale n Feet

0 150 300 450

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Site Plan

ElathRmd Peaty

Part LA Dist -Luton Center

300 Westmont On de

San Pedro, Calrzorma

FIGURE

1 -1

eituo7pJ'alPad ties

a ua Jua1+4seM 00E

a*OarJ La4n91490 V1 Jad

kleal.l 4301110e18

asua y*Bnosyl, sse`y go 1a?.Ua3 auazua8

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aaad 41 qezS

ssa413oJaiUaa ^

VIeCUOY'c y.adod

i.-, /6",

r r

saeleui g

30%

25%

20%

15%

10%

Figure 2 -2

2 -Phase Vs. 3 -Phase Residual Saturation

(3 phase is usually much smaller)

SAND SANDY

LOAM

DRAFT

for Discussion Purposes Only

Confidential, Prepared ai the Request of

Counsel

LOAM SANDY

CLAY SILTY

CLAY

Saturated Zone Oil

Vadose Zone Oil

J. Parker, 1994

ß AQUI -YER, INC.

16.0

14.0

Ñ- 10.0

:_-

AQUI-VER, lNC.

Htdrogeatogy; iWaaerReararcar ared Daa Szrvi.t

Figure 2 -3

Initial and Residual LNAPL Saturation Measurements

i Initial LNAPL Saturation

Final LNAPL Saturation

2.+

0.0

SCS-B3-170' SCS-B1-99.0' SCS-B2-112.0' SCS-B3-91.0' SCS-B2-98.0'

CF203562 G8llNOrfi =CO W.t %EYvk Ow, LTRAM PS.4î56i54624 Fa..435455

100

Applied P

Aßll &VE1b.PNG

HydmgeabS3; Water

Rexmrees ama Data Senkes

Figure 2-4

sure Vs. LNAPL Saturation for OS - 3.6 Darcy Materials

-*-Sand, ki = 1.9 D

Sand, ki = 2.3 D

x Sand, ki = 3.6 D

Silty sand, ki = 0.8 D

0.01

0.00

This example is not fro

o 10 20

he subject site

30 40

LMAPL Saturation (%

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60 70 80

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40-

30-

20 4.rera3egrovrdrster

e-,eoanan{W82011j

Sn<O1% T ;Pt RO <50

200 250 390 350

Weighted Average Wavelength (nM)

05 415 425 4

500 ,-00 750

DISTANCE (ft)

250

Note Piur e Tmrfs to the NE inferred

eased non -detect TFH

-GPC e, ARAM 3

1050 X100 .150 1200 1250 1300 1350 1400 1450 1505

AQUI -VER, INC.

Southwest to Northeast LtF Waveform Cross Section A -N: Laser Induced

Fluorescence where Laser Induced Fluorescence is Above Threshold

BleelsRodc Realty

Pert LkOiseibc5ce Center.

300 Wesencnetttee

San Pedro. Cantor/lie

CURE:

2 -6

Elevation

above

Oil/Water

(rn)

ca a

AQUI-VER, INC.

XjrìrogroFag, Water RrSearce.v and Than Senicra

Figure 3 -2

Generalized Benzene Change over Time Under Cleanup Conditions

0.01

1.00E

+00

lld5S5ressAis.d':

Baseline Benzene

a Benzene after Skimming

Benzene after Pumping

-Benzene after ¡AS

1.00E +01 1.00E +02 1.00E +03

Time {y+rs)

687t P'acfi22GU West tBFPak.Cmr.L]'Stp98 Ph.355fS5-SC^A Eaz435.5t5-8926

1.00E +04 1.00E +05

1.0E+10

1.0E+09

.flE+fl8

:E; 1.0E+07

t 1.0E+06

E+05

1.0E +04

Figure 3 -3

Chemical Component Stripping By S JAS

Benzene

Toluene

p -Xylene

i- Dodecane

0.0 1.0 2.0 3.0

Time (years)

4.0 5.0

Ci AQUI-VER, INC.

10.00

9.00

8.00

Ratio of Dissolved

A@te-VER, 1kC

$zpUugeoWgµ IGm:urRVO wsundCMVerSerúrV

Figure 3-4

Benzene to Ethylbenzene Overlapping IAS /SVE: M

7.00 y = -0.0034x + 125 23

R2 = 0.8489

6.00

ta 5.00

4.00

3.00

2.00

t Ratio B/EB

IAS/SVE Start

-IAS/SVE End

1.00 -i

0.00

1/31/1993

FP hytlropgraphs.xh

6/15/1994 10/28/1995 3/11/1997 7/24/1998 12/6/1999 4/19/2001

äß7t N ç t 1200 Wm. 4 &T Psk C 435 655-5026

Figure 3 -5

Image of TAS In -Situ Stripping Distribution in a Fine Sand

(by Electromagnetic Tomography)

o 20 min. 2 hours 48 hours

Q 5

air o

4.6m Lundergard et al., 1995

Figure 3-6: IAS Stripping Cone Estimate

(based on field test data, measured parameters, & multiphase cales)

Original Water Table

Lateral stripping estent --- 2m

NOTES:

Figure Represents 2 -D cross -

section of a 3 -D radial domain.

2 4 ô i3 10

Meters

ß 0.35 0.70

Air Saturation Change O AQUI-VER, INC.

4Q01-Vea,INC.

iqmn6M,Ir,Xr, w I<r Remnrvun,e i

APPENDIX 1 -1

EVALUATION METHODOLOGY

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AQUIVER, INC.

lpdrnyanlugy. ¿VolerltesmmWs & lkiM$Rrvl

GROUNDWATER PLUME ASSESSMENT METHODS

A set of evaluation methods have been developed that use site groundwater data to estimate

plume conditions, stability, and longevity. The following sections discuss the approach that

Is applied to sites affected by petroleum releases under relatively simple and conservative

conditions. In summary, the approach includes evaluations of plume stability and

attenuation (mass loss). This evaluation process builds extensively on contaminant fate and

transport concepts outlined in the 2002 American Petroleum Institute Publication 114715.

EVALUATION OF PLUME STABILITY & MASS THROUGH TIME

Plume stability refers to a lack of observable geographic spreading through time after some

known or unknown period ofinitial spreading. "Plume" as used here refers to the dissolved-

phase footprint of any compound of concern, with different compounds often exhibiting

different footprints at a site When a stable plume condition is present, it provides a static

environmental management footprint. Expanding plumes generally require different and

more dynamic evaluation and management approach. For the purposes here, geographic

stability can also include plume contraction whereby the boundary pertaining to a given

dissolved -phase chemical is shrinking through time. A stable or contracting plume allows

for simple and conservative estimates of potential impacts to the waters of the State and

other receptors, as applicable.

Plume stability or contraction is caused by a variety of attributes in the subsurface

hydrogeologic and chemical system, Biodegradation of amenable compounds is often a key

facet to stability. Nonlinear sorption of chemicals to certain mineral and organic materials

in saturated soil can remove mass from the dissolved-phase plume system. Dispersion and

transport of chemicals in aquifer materials will dilute a compound plume to lower

concentrations on the plume periphery. Abiotic reactions are also possible (hydrolysis,

oxidation, photolysis, etc.) but generally are not important in near- surface aquifer conditions.

Plume stability as a function of all these dynamic transport and attenuation processes can be

simply evaluated by spatial statistics: These analyses consider the total relative dissolved -

phase mass of a particular compound as observed from monitoring data through time First,

the If the maximum plume

boundary is not expanding after some maximum distribution time stamp, the relative plume

mass through time can be inspected for mass losses.

If the integrated dissolved -phase mass of the plume is decreasing in the footprint, th

clearly losing mass with an accoittingly diminishing threat to the waters of the

Related to this analysis is a center -of -mass evaluation. If the center-of-mass is not moving

downgradient significantly, then this too is an indicator that the plume center is stable,

Often, this stable mass represents a small residual chemical source in diffusion- limited

zones, imparting small but persistent mass to clean groundwater that moves into the area

froth an upgradient direction.

The calculation methodology produces a dissolved -phase mass that ìs generally

82411 Ocean Avon üu.SPia uFfa4.CA l'h.5M12MAIM

AQULV6141NC

FI}.Gogunfog@J4alar FYYOIif4tYN 0114 5cN!M 2

conservative, and more importantly, is used to compare mass at different times. The

dissolved -phase mass is used as an indicator of plume conditions, while recognizing that

there may be additional sorbed or residual mass in soil that feeds this dissolved- plume. The

total mass in the system is typically greater than the dissolved -phase mass alone. The

maximum volume of impacted groundwater is estimated. The volume is derived froni the

areal extent of impacts determined through site characterization and dissolved -phase plume

tracking through time The dissolved -phase plume thickness is estimated from site data

where available, or conservatively assumed if data are not available. The porosity of the

saturated zone is based on site data if available, or estimated from literature values based on

the described soil types at a site. The relative dissolved -phase mass is then estimated by

integrating the spatial concentrations over the volume of contaminated groundwater. That

total dissolved mass, divided by the total water volume in the area of integration, equals the

integrated average concentration that can be used in flux estimates. The changes in mass are

relative comparisons. The total mass is a function of the volume of groundwater that is

impacted. The changes in mass are independent of the total mass,

ESTIMATION OF TEMPORAL CONCENTRATION DECREASES

In addition to the spatial plume evaluations above, the temporal concentration trends at key

wells along the plume axis are determined; the nature and distribution of the site specific

plume(s) determine the wells selected for analysis. These temporal trends allow a forward

estimate of the time to reach State MCL for any particular compound of concern at a

particular location when statistically decreasing trends are present. It is often observed that

central "core" wells will exhibit a longer expected chemical lifespan than peripheral wells

where transport processes and degradation act to reduce plume concentrations.

The temporal evaluations for key chemicals of concern are conducted using statistical trend

analysis consistent with the form of chemical transport and decay equations (exponential

form). The trends are plotted with the associated 95% confidence interval to ensure that a

downward, upward, or stable trend at a specific monitoring well is identified in context with

the data confidence. Obviously, an increasing or flat trend will not result in estimates of

plume longevity, and other analysis methods are then required to derive those estimates and

eire not part of the work presented herein. Downward trends, when present, are used to

estimate the time required to reach MCLs at that location under the implicit assumption that

past plume decay processes will continue in the future. In general, this last assumption is

conservative as plume decay processes, particularly biodegradation, often improve as

chemical loading to the system decreases along with the increasing assimilative capacity of

the aquifer and /or vadose zones.

POTENTIAL IMPACTS TO GROUNDWATER USE

The potential impacts to groundwater use can be assessed using a conservative flux -based

analysis for stable or contracting plumes. Using the integrated plume concentrations

discussed above for each compound of concern, a potential worst -case chemical flux can be

estimated by combining those data with sitegroundwaterflow estimates. In this evaluation,

it is conservatively assumed that integrated plume concentration is allowed to propagate into

Armaa, San( b

AQUI-Vp.Ii,INC.

17)Mbgeuloµ. Hitter ltnminmv k Dam

the aquifer system with no attenuation or other mass losses. This results In a conservatively -

high mass loading of compounds of concern to the aquifer, That mass loading is then

evaluated in context with potential groundwater pumping rates to estimate the maximum

potential groundwater concentrations at hypothetical pumping locations. Lossesofeltemical

mass as a result of all forms of natural attenuation are not considered. if a plume is stable

or contracting, it is clear that there are actually no relevant mass fluxes into the aquifer

system past the non- detection boundary. As a result, the calculation is a highly conservative

determination of mass flux from the defined area of impacts and is intended as a

conservative screening method, and not as a realistic set of transport or flux conditions. The

value used for hydraulic conductivity was I 1 feet per day.

The groundwater flow through the aquifer is estimated from Darcy's Law using the

measured or assumed aqul for hydraulic conductivity and the average groundwatergrádi

That groundwater flow /unit area (Damian Velocity) is then combined with the integrated

concentration data at the most recent plume time stamp to determine the mass flux, Then,

using the width and depth of the plume used in the statistical spatial analysis as the cross -

sectional area, the total mass loading to the system is estimated. This mass flux is then

allowed to be fully captured by a hypothetical groundwater production well pumping at

pumping rates ranging from 100 to 1,000 gallons per minute. The calculation results in a

value for the concentration of a compound of concern in the pumped groundwater as a

function of the applied pumping rate, This maximum potential concentration of the

compounds of concern in produced groundwater are compared to State maximum

contaminant levels (MCLs) in drinking water, or notification levels where MCLs have not

been determined.

ß290 Cecnn Memm, Buoi Gmell. CA 11,N2296499ú rat 562 733 á6O5

Aqui -Ven, ¡Nt,

Hydrogenloz WUkr&Warce ST, fa Services

APPENDIX 1 -2

DISSOLVED PRASE BENZENE PLUME MAPS

68716464h Yaeyuól' Vh.n2S63Sa10fln I3A 6

AQIIINER,INC.

H/druEUOlu¿IV. IF ilur Moaner a Duty Stir vim

APPENDIX I -3

DISSOLVED PHASE TBA STATISTICAL TRENDS

6871 Nmib 2280 81.180, 1181' 611. á7565.540/I FAX 875

3C}ß Westmont Dr., San Pedro, CA

TBA vs. Time at MW -9R

with 95% upper confidence bound

0.1

3.758E+024 * e(-o.00n2rx)

i/2006 6/17/2007 2/22/2008 10/29/20{}8 7/6/24019 3/13/2010 11/18/2010 7/26/2011

Date AQUI -VER, INC.

1000

100

0.1

300 Westmont Dr., San Pedro, CA

TBA vs. Time at MW -101R

with 95% upper confidence bound

1.277E+ 4. e(-0.0006909*x) TBA = ND

1011 006 17/2007 2/2212008 10129/2008 7/6/2009 3/13/2010 11118/2010 7126/2011

Date AQUI-VER, INC.

AQUI-VER, irvC.

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APPENDIX I -4

FLUX ESTIMATE CALCULATIONS

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APPENDIX 1 -5

R MODEL INPUT AND RESULTS

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Port LA Drstnbubon

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BIOSCREEN Natural Attenuation Decision Support System

Air Force Center

for Environmental Excellence Version 14

1 HYDROGEOLOGY

Seepage Velocity'

Hydraulic Conductivity

Hydraulic Gradient

Porosdy

Vs k 101 IrtUyr)

,T or

3 5E-04 (em/sec)

O.007 (fllftj

025 ()

2- DISPERSION

Longitudinal Dfspersrvity

Transverse Dispersivey'

Vertical Dispersivity'

Estrnated Plume Length

alpha

alpha y

atpha z

50-0

T or

3 ADSORPTION

Retardation Factor R

Soil Bulk Density

Partition Coefficient

Fraction O rga n icC arbon

Koc

foc

'1` or

5 7E-5

4 131ODEGRADATION

1st Order Decay Coeff` lambda

Solute Half -Life f -hatf

orInstantaneous Reaction Mode

Delta Oxygen' DO

Delta Nitrate` NO3

Observed Ferrous Irons Fe2+

Delta Sulfate' SO4

Observed Methane CH4

1 5E-1

T or

4.50

1 65

166

22 4

(R)

(N)

(fr)

(ft)

(-1

(kg/1)

Pig)

()

(per yr)

(year)

(mg2)

(mgfi-)

(mgt)

(mg/L)

(mg2)

Run Name

5. GENERAL

Modeled Area Length'

Modeled Area Width'

Simulation Time

2000

1000

(ff) t

(ft)

(Yr)

Data Input Instructions.

115 I 1. Enter value directly. or

T or 2 Calculate by Ring to grey

1 0 02 I cells below (To restore

fonndlas, hit button below)

Variable Data used directly in model

Value calculated by model

(Don't enter any data)

6 SOURCE DATA

Source Thickness in Sat Zone

Source Zoner

Width ' ft Con

25 (¡t) Vertical Plane Source Look at Plume Cross -Section

and Input Concennatrons & Widths

I _ for Zones 1, 2, and

SourceHalftrfe see Hel )

or r l (yr)

InstReact T 1st Order

Soluble Ma 10000000 (Kg)

In Source NPPL, Soil

7 FIELD DATA FOR COMPARISON

Concentration (mgIL 1a 4 1 0

Dist from Source (ft)

8. CHOOSE TYPE OF OUTPUT TO SEE

RUN

CENTERLINE

View Output

View of Plume Looking Down

Observed Centerline Concentrations at Monitoring Wells

if No Data Leave Blank or Enfer "0"

RUN ARRAY

View Output

Help Recalculate This

Sheet

Paste Example Dataset

Restore Formulas for Vs,

D.spersivities R, lambda, other

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

TYPE OF MODEL 0 200

No De radatíon "a 2,C0 5 525

1st Order Dec .8 LOG 1 885

inst. Reactio S S %9 0 OC G

Oútaace

front Source {fiJ

400 600 800 1000 1200 I 1400 1600 ¢ 1800 2000

; 2% C 01,2 C J:7 G COCO ; C vCfl ; 0 000 5 COO I 9 OCC

0 051 0 000 0 000 C 000 : 0 000 0 000 ; 0 000 0 000 , 0 000

C 000 C 000 C 000 ; O 000 ; O J00 0 06O 1 0 9CC

Field Data from Site 18 400 1 CCG 0.100

20 000

_ 15 000

A 0000

111IstOrderDecay instantaneous Reaction eNo Degradation :: Fred Data from Site

5 000 }

U 000

Calculate

Animation

500 1000 1500 2000 2500

Distance From Source lft)

Tune.

15 Years Return to

Input I,

Recalculate This

Sheet

ARm.Vren, INC.

/Qx?aRPOhp)t IWUm lner,mrcnR A(aria Services

APPENDIX 2-

CAPILLARY PARAMETER RIVATIONS

rlh32U0t4ns,,ildR PI,. I Vnte

><eo.vsx i.+e.

Nytrvealow

,s.urA ,,s, aeasa$n.ua

TABLE 7

SUMMARY OF CAPILLARY TEST RESULTS

SCS S2-98 0 3.50E -03 1.75 0 19 7030 0 988 122E -02

SCS B2 -

112.0 2..70E -03 1.56 0.22. 35.20 0.996 4.33E -03

Noies:

alpha (áL p, residual water saturation (SC) and. saturated {total} water content (Sr( are capiilary parameters defined by the following equation (van Gesuchten, 1980),

with m = 1 -1,tn, S = water

saturation, and h = capillary head (cmy:

:iJ = S [(r Sr

S - ) ! (t + (. °)

1.E+04

1.E+03

.,..e AQUC:ke,

AiJmR^`pA. WurvRe.nu

VAN GENUCHTEN CAPILLARY CURVE FIT

CoreLab; SCE Sample, SCS B2 -98.0

1.E +00

1.E-01

0.00

Notes:

The residual saturation is estimated by visual inspection of the data.

An iterative solver is then used to lit the van Genuchten alpha and n to the data.

Cc200562 .bst 1) graph I

0.20 0.40 0.60

Water Saturation

óknl N 2240AkRktF,P26; Ciey.Uñ 655

0.80 1.00

1.E-1- 4

.E+0

9._,) 1 .E+02

2_5 1 E +01

C-)

.E+00

1.E-0

CF2C0552xLs12) grksh 1

AQUa-VER, 87C.

yai.DRerXecr_ WateriTt.surtes °SD= Semen

VAN GENUCHTEN CAPILLARY CURVE FIT

CoreLab; SCE Sample,

SCS 82-112.0

= u SCS 82-112M -Van Genuchten Model

--- Notes:

The residual saturation n is estimated by visual inspection of the data.

An iterative solver is then used to fit the van Genuchten alpha and n to the data

0.00 0.20 0.40 0.60

Water Saturation

UPI P22OOWeS PPF,Par3 City. W !1 Pb. 435555-5034 Fop 133 555-3026

0.80 1.00

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40402000

..... ell

Lalo n

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101flalVliar)

2264

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100

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1000

3530 100

14040 000 042

30t30 0l3 0 717

100 0914

t0510 042 0000

4t 048 0400

176100 040 0349

241340 030 02711

4 in 0 i 0300

40Y040 020 -2>tn 4 2555

7734f0 024 9301

008750

8811

1.078.00

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® 0 0000200 á2Y0 0170 0J0á

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--.--- 1609 0414 02/6

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AQUI-VEX,INC.

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

9:00

8_00

7.00

6.00

5.00

4.00

3.00

2.00

1.00

0.00

AQiì1-VER, INC.

H)viregemhg>; Wflfer *feswirce.v amd lMdc Serzices

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

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

5.00

4 -00

Groundwater Elevation

LNAPL Observed r

3.00 -o

2.00

elation = 0.78

1.00

-1.00. 0.00

Jan- Jan- Jan- Dec- Jan- Jan- Jan- Dec- Jan- Jan- Jan- Dec- Jan- Jan- Jan- Dec- Jan

94 95 96 96 98 99 00 00 02 03 04 04 06 07 08 08 10

FP_írytlmrephsxJs 6471 944444 2365 Weye ö SF Faci Ci L 84098 Ph. 435E954OZ4 Fas 435653-85:5

LNAPL Thickness (ft)

Ì`'`+ o °n 0

C3 ri G Ó G7 Ó CQ

(Is

o o 06

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 D1 F4YA35ag5.NUz

Executive Summary - Saturation and Volume

Site Name: Port LA Distribution Center

Project Manager: SCS Engineers.

Date of Analysis: 8/26/2011

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

Initial Conditions; Soil &. Flow

Simulation.

BASELINE CONDITIONS

Number Layer Soil Type

van Genutchen

Alpha (11m)

Selected Sro

(%0)

Medium Sand 0.136

Simulation

Number LNAPL Type

LNAPL Zone

Thickness (m) Saturation Condition

Gasoline 6.25 Vertical Equilibrium

Results

% Interval

Simulation Type Area Greater than

Number Volume (cu m) Field Sro Max So Average

Specific

Volume

(cu mime)

3.13E03 31.82 2.04E -01 9.48E -02 3.13E -01

User Input Parameters

Soil Properties

Simulation.

Number Layer Soil Type

van van

Genutchen Genutchen

Alpha (11m) n Srw Total

Sro K (mid) Porosity

1 1 Medium Sand 0.31 1.66 0.205 0.136 3_00E-01: 0.40

* Only apply to multiple layer sail nditbn

Repon Greeted. on 8/26120 Page 1 of 2

Source Area Input Parameters

Vertical Depth to Top Length of Width of

Simulation Formation of LNAPL LNAPLZone LNAPL Zone BASELINE CONDITION

Number Thickness (m) (an) (m) (m)

6 25 27.40 100.00 100.00

LNAPL Properties

Simulation

Number Product Type

O°il(Water IFT OïUAir WT

(dyneslcm) (dynesTCm)

Oil Density

(gmfcc) Viscosity

(cp)

Gasoline 25.00 25.00 0.81 1.50

Method Used to Calculate LNAPL Saturation Input Pa e

Simulation

Number Method Used To Calculate LNAPL Saturation Criteria For Minimum

Source Volitilization Mobility (mlday)

Equilibrium LNAPL Dístributio Volatilization Included 8.64E -04

Report Created on 8052011 Page 2 of 2

Executive Summary - Source Zone Co position Through Time

Site Name: Port LA Distribution Center

Project Manager:

Date of Analysis:

SCS Engineers

August26., 2011.

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

initial Conditions; Soil & Flow

Simulation

BASELINE CONDITIONS

Number Soil Layer Soil Type van Genutchen

Alpha (1fm)

Sel d Sra

1 Medium Sand 0.31 0.136

Simulation Initial VEQ LNAPL

Number Thickness (m) Initial Pe

C51

615 2.04E -01

a Initial Specific Volume

(eu Wm')

3.73E -01

Results (Simulation Number 1)

Original

Compound of Concern Concentration.

(agil)

Concentration at

1 Year

(ugll)

Concentration.

10 Years

(ugh)

ncentration a

20 Years

(agil)

Concentration at

100 Years

(ug11)

Benzene 3.29E+03 3 29E +03 3.29E

+03 328E

+03 324E +03

Et iyl Benzene 6.93E

+02 6.93E+02 6.92E +02 6.92E +02 6.97E +02

Toluene 2.30E +01 2.30E +01 2.30E +01 2.30E

+01 2 29E

+01

Xylene 1 86E+02 1.85E +02 1.85E +02. 1.85E +02 1.85E +02

Report Created on 826/2011 Page 1 of 3

User input Parameters

Soil Properties

BASELINE CONDITIONS

Simulation

Number Layer Soil Type

van van

Genutchen Genutchen

Alpha (11m) n Srw Total

Sr* If (mid) Porosity

1 Medium and 0.31 1.66 0.205 0.136 3.00E-01 0.40

Only apply to multiple layer s s

Groundwater Condition Input

"Pa .eters

Simulation

Number

Groundwater

Darcy Flux Lin

(mid ay) Velocity

day)

Groundwater

Gradient

(min))

1.98E -03 6.23E

-03 fr.60E-03

Source Area input Pa rame

Vertical Depth to Top

Simulation Formation of LNAPL

Number Thickness (m) (m)

Length of

LNAPL Zone

(m)

Width of

LNAPL Zone

(m)

LNAPL Properties

Simulation

Number Product Type OillWater IFT OIIfAIr IFT Oil Density

(dynes /cm) (dyneslcm) (gm /cc) Viscosity

(cp)

Gasoline 25_ùO 25.00 130

Method Used to Calculate LNAPL Satu n Input Parameters

Simulation

Number d Used To Calculate LNAPL Saturation Criteria For Minimum

Source VoliUliization Mobility (mlday)

Equilibrium. LNAPL. Distribution Vofa .ization Included 8:64E-04

Repon Created çrn Page 2 of 3

Solute Transport Properties Input Parameters BASELINE CoNlTIDNS

Horizontal Vertical Vapor

Longitudinal Transverse Transverse Fractional Diffusion

Simulation Effective Dispersivity Dispersivity Dispersivity Carbon Efficiency

Number Porosity (in) (m) (m) Content Coefficient

0.318 3.00E+00 101E -01 1.00E

-02 3.00E -03 2.50E

-62

Report Created on 8/26/2011 Page 3 of 3

Executive Summary - Satu ion and Volume

Site Name:

Project Manager:

Date of Analysis:

Port LA Distribution Center

SCS Engineers

8/26/2011

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

Initial Conditions; Soii & Flow

SKIMMING CONDITIONS

Simulation

Number Layer Soil Type

van Genutchen Selected Sro

Alpha (11m) ( °Je)

Medium Sand 0.31 fl_136

Simulation

Number LNAPL Type

LNAPL Zone

Thickness (m) Saturation Condition

Gasoline 625 After Fixed Period of Remediation

Results

% Interval

Simulation Type Area Greater than

Number Volume {cu mi Field'. Sro Max So Average

Specific.

Volume

(cu mime)

3.11E+03 31.06 2.02E-01 9.41 E-02 111E-01

User Input Parameters

Soil Properties

Simulation

Number Layer Soil Type

van van

Genutchen Genutchen

Alpha (11m) n Srw Total

Sro K (mid) Porosity

1 Medium Sand 0.31 t66 0.205 0.136 3.00E-01 GAO

' Only apply to multiple la soil conditions

Report Created on 8726/2011 Page 1 of 2

Source Area input Parameters

Simulation

Number

Vertical Depth to Top

Formation of LNAPL

Thickness (m) (m)

Length of

LNAPL Zone

(m)

Width of

LNAPL Zone

(m)

6.25 27.40 100.00 i boo0

LNAPL Properties

SK.Í513MIN CONDITIONS

Number Product Type (dynes /cm) (dynes/cm) (gm /cc)

Gasoline 25_00 25.00 0.81 1.50

Method Used to Calculate LNAPL Saturation Input Parameters

Simulation Criteria For Minimum

Number Method Used To Calculate LNAPL Saturation Source Volitilization Mobility (rnlday)

Distribution After Fixed Period of Remedietion Volatilization Included 8.64E -04

Report Created on 8/26M20 Page 2 of 2

Executive Summary - Source Zone Composition Through Time

Site Name:

Project Manager:

Date of Analysis:

Title of Simulations:

Port LA Distribution Center

SGS Engineers

August 26, 2011

Port LA Distribution Center, Fo

Initial Conditions; Soil & Flow

er Western Fuel Oil

SKIMMING CONDITIONS

Simulation

Number Soil Layer on Type van. Genutchen Selected Sm

Alpha (1 /m) ( %)

and 0.31 0.136

Simulation Initial VEQ LNAPL

Number Thickness (m)

1 6.25

Initial Peak So

1 %i

2 02E-01

Initial pecific Volume

(eu mim)

3.51E -01

Results {Simul tion Number 1)

Compound of Concern

Original

Concentration.

(ug/I)

Concentration at Concentration at Concentration at

1 Year 10 Years 20Years

(ugh) (ugR) (ug/1)

Concentration at

100 Years

(vg

/1)

'IBenzene 3.29E +03 3.29£+03 3.28E+03 3.27E+03 3.18E +03

Ethyl Benzene 6.93E +02 6.93E +02 6.92E+02 6.92E+02 6.9ÓE +02

Toluene 2.30E +01 2.30E +01 2;30E+01 230E+01 2 28E +01

Xylene 1.86E

+02 1.85E +02 1.85E+02 1.85E+02 1.85E +02

Report Created on 8126/2011 Page 1 of 3

User Input Paramete

Soil. Properties

Simulation

Number Layer Soil Type

van van

Genutchen Genutchen

Alpha (11m) n Sro Total

K (mid) Porosity

1 1 Medium Sand 0.31 1.66 0205 3.00E -01 0.40

a lay ñl ndiEío

Groundwater Condition input Parameters

Simulation

Number

Groundwater

Darcy Flux

(mlday)

Groundwater

Linear Velocity Gradient

(mlday) (mim)

1.98E -03 6.23E -03 6.60E -03

Source Area Input Parameters.

Vertical

Simulation Formation

Number Thickness (n)

Depth to Top Length of

of LNAPL LNAPL Zone

(m) (m)

Width of

LNAPL Zone

(m)

625 27.40 t 00.00 100:00

LNAPL Properties

SKIMMING CONDITIONS

Simulation

Number Product Type Oil/Water IFT Oil/Air IFT Oil Density

(dynes/cm) (dynes/cm) (gmicc) Viscosity

(cp)

Gasoline 25.00 25:00 0.81 1.50

Method Used to Calculate LNAPL S oration Input Parameters

Ligation

rober Method Used To Calculate LNAPL Saturation Criteria For Minimum

Source Voliti lization Mobility(nlday)

Distribution After Fixed Period of Re Volatilization Included 6.64E -04

Report Created on 8/26/2011 Page 2 of 3

Solute Transport Properties input Parameters

Simulation

Number Effective

Porosity

Longitudinal

Dispersivity

(m) -

Horizontal

Transverse

Dispersivity

(m)

Vertical

Transverse

Dispersivity

(m}

Fractional

Carbon

Content

Vapor

Diffusion

Efficiency

Coefficient

SKIMMING CONDITIONS

1 0318 3.00E+00 1.50E-01 1.00E-02 100E-03 1.00E+00

Report Created on 812 Page 3of3

Executive Summary - LNAPL Recovery

Site Name:

Project Manager:

Date of Analysis:

Port LA Distribution Center

SOS Engineers

8/26/2011

SKIMMING CONDITIONS

Initial Conditions

Simulation

Number Soil Type van Genuchten

Alpha (11m overy Method Recovery Initial VEQ LI

Time (yrs) Thickness (m) Sele Initial

Peak So

Inital Specific

Volume

(cu mine)

Medium Sand Skimming Recovery 625 0.136 020 3.11E -01

Results

Time to 15% of Time to 50% of Time to 99% of Residual

Simulation Recoverable Recoverable Recoverable Thickness

Number (Sirs} (Yrs) (Sirs) (m} 3 -Month Rate 1 -Year Rate

(cu mfday) (cu mfday) 3-Year Rate

(cu mfday)

Final Specific

Volume

(eu mire

Na Na 6.19E +00 5.55E -02 5.51E-02 5.41E-02 4.14E+03

User Input. Parameters

Soil Properties

Simulation

Number Soil Type van Genutchen van Genutchen

Alpha (1/m) n Srw Sro K (mld) Total Poro

fuiedium Sand 6.31 1.66 0205 0.136 3.00E -01 0.40

Groundwater Condition Input Parameters

Simulation

Number

Groundwater

Darcy Flux

{mfday}

Groundwater

Linear Velocity Gradient

(mfday) (Eft)

1.98E-03 ú23E -03 6.60E -03

Report Created on 8/26/2011 Page 1 of 2

Source Area Input Parameters

Simulation

Number

Vertical Depth to Top

Formation of. LNAPL

Thickness (m) (m)

Length of

LNAPL Zone

(m)

Width of

LNAPL Zone

(m)

t 6.25 2740 100.00 100.00

LNAPL Properties

SKIMMING CONDITIONS

Simulation Oi'IANater IFT Oil/Air IFT

Number Product Type (dynes!cm) (dynes/cm)

Oil Density

(gmlcc)

Viscosi

(cp)

Gasoline 25.00 25.00 0_Sf 1.50

Method Used to Calculate L. Sa n Input P ameters

Simulation

Number Method. Used. To Calcula NAPL Saturation. Criteria For Minimum

Source Volitilization Mobility (mlday)

Distribution After. Fixed. Pero. mediati -on. Volatilization Included 8.64E-04

Skimming Recovery input Parameters.

Period of

Simulation Recovery Number of

Number (Yrs) Wells

Ratio of Radius of

Influence 1 Radius of

Well (LNAPL) (m)

5.0 50.0

Rep orf Created on 8126/2011 Page 2 oft

Executive Summary - Saturation and Volume

Site Name: Port LA Dist bution Center

Project Manager: SCS Engineers

Date of Analysis: 8126(2011

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

Initial Conditions; Soil. & Flow

Simulation

PUMPING CONDITIONS

Number Layer Soil Type

van Genutchen

Alpha (11m)

Selected Sro

(%)

Medium Sand 031 0.136

Simulation

Number LNAPL Type

LNAPL Zone

Thickness (m) Saturation Condition

Gasoline 625 After Fixed Period in Remediation

Results

% interval

Simulation Type Area Greater than

Number Volume (cu m) Field Sro Max So Average

Specific

Volume

(cu mime

3.02Eí-03 27.27 1 93E -01 9.16E -02 3.02E -01

User Input Parameters

Soil Properties

Simulation

Number Layer Soil Type

van van

Centric hen Genutchen

Alpha (11m) n Srw Sra Total

K.(mld) Porosity

1 Medium Sand 1.66 0205 3:00E-01

' Gnñ} apply to mullipié di ans.

Report Created an 8126/2011 Page 1 of 2

Z /o Z aSed l LdZl9Z/8 UG paleaia.lrodal

6(-369'8 papn!oul uo!lezg9e10A. teol}e!pawa o poPacl P

(JteplW) Jrn!iigoiq uo!lezq!lyvA awnog

wnw!um Jod eualuO uogesn;es ldtlN1 aleinaJe'J of paskl Poglaihi minim

uapeinw!s

sualawwed indui uo!letn;eg ldtlNl alelnaleO pasfl Po4laW

(do)

Apsoasrn (33¡w6) (wa¡sauRp) (waisaullp)

A!suaa i!o -Iltl/l!o id! Jalem!!o adAlmposd JaqwnN

uone!nw!g

satlaadoid 1dVN1

SNOliIaNOO JNldWfid (w) (to) (w) (w)ssaun!a!yl JaqwnN

10 gip!M }o qi6ual dalolgldaa !ea!haq

saa pump d;ndul eaJ+ aaun

Executive Summary - Source Zone Composition Through Time

Site Name:

Project Manager:

Date of Analysis:

The of Simulations;

Port LA Distribution Center

SCS Engineers

August 26, 2011

Port LA Distribution Center, Former Western Fuel Oil

PUMPING CONDITIONS

Initiai Conditions; Soil & Flow

Simulation

Number Soil Layer Soil Type

van Genutchen

Alpaa (llml Selected Sri,

(%)

Medium Sand o:31

Simulation Initial VEQ LNAPL Initial Peak So

Number Thickness (in) t's)

Initial Specific Volume

{eu mlm2)

6.25 1 93E-01 3.02E -01

Results (Simulation Number 1)

Original Concentration at Concentration at Concentration a Concentration at

Concentration 1 Year 10 Years 20 Years 100 Years

Compound of Concern ( tigli) fug/I) Owl) (ugll) (ugll)

Benzene 3.29E +03 3.29E +03 3.28E+03 3.27E +03 318E+03

Ethyl Benzene 6.93E+02 6.93E +02 6.92E +02 6.92E +02 6.90E +02

Toluene 2.30E +01 2.30E +01 2.30E +01 2.30E +01 2 28E +01

Xylene 1.86E +02 1.85E +02 1.85E +02 1.85E +02 1.85E +02

Report Created on 812 Page 1 of 3

User Input Parame

Soil Properties

Simulation

Number Layer Soil Type

van

Genutchen

Alpha (11m)

van

Genutchen

n Srw Total

Sra K (mid) Porosity

1 Medium. Sand 0.31 1.66 0:205 0.136 3.00E-01 0.40

Only apply to multiple layer

Soil conditions

Groundwater Condition Input Parameters

Simulation

Number

Groundwater

Darcy Flux

(miday)

Linear Velocity

Ida y)

Groundwater

Gradient

(Wm)

1.98E

-03 6.23E -03 6.60E -03

Source Area Input Parameters

Vertical Depth to Top

Simulation Formation of LNAPL.

Number Thickness (ni) (m)

Length of Width of

LNAPL Zone LNAPL Zone

(in) (m)

6.25 27.40 00.00 100.00

LNAPL Prop

PUMPING CONDITIONS

Simulation Oi.UWater IFT OiUAir lFT

Number Product. Type (dyneslcrn) (dynes/cm)

Oil Density

(gm /cc)

Viscosity

(cp)

Gasoline 25.00 25.00 0.81 1.50

od Used to Calculate LNAPL Satu ion Input Parameters

Simulation

Number Method Used To CalculateL Criteria For Minimum

PL Saturation Source Vtrlitilization Mobility (mlday)

Disàrzbutlon After Fixed Period of R dìation Volatilization Included &64E

-04

Report Created on 8/26/2 Page 2 of 3

Solute Transport Properties Input Parameters

Horizontal Vertical Vapor

Longitudinal Transverse Transverse Fractional Diffusion PUMPING CONDITIONS

Simulation Effective Dispersivity Dispersivity Dispersivity Carbon Efficiency

Number Porosity (m) (m) (m) Content Coefficient

1 0.318 3.00E+00 1.50E-01 1.00E-02 3.00E-03 1.00E+00

Report Created on 8725/2011. Page 3 of 3

Executive Summary - LNAPL Recovery

Site Name:

Project Manager:

Date of Analysis:

Port LA Distribution Center

SOS Engineers

/2612 01 1

Title of Simulations: Port LA Distribution Center, Forme estern Fuel Oil

initiai Conditions

PUMPING CONDITIONS

Simulation

Number Soil Type van Genuchten

Alpha (1 /m) Recovery Method Recovery Initial VEQ LNAPL Selected Initial

Time (yrs) Thickness (m) Sm Peak So

Inital Specific

Volume

(cu m /mf)

Medium Sand 031 Dual Pump Extraction 10 6.25 0.19 3.02E-01

Results

Simulation

Number

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

Recoverable Recoverable Recoverable

(yrs} (yrs) (yrs)

Residual

Thickness

(m)

3 -Month Rate 1 -Year Rate 3 -Year Rate

(cu in/day) (cu m

/day) (cu m/day)

Final Specific

Volume

(cu Wm)

Na Na Na 5.94E+00 1.48E

-01 t.46E-01 1.41E

-01 3.75E +03

User Input Parameters

Soil Properties

Simulation

Number Seil'. Type

van Genutchen an Genutchen

Alpha (1 /m) n Srw Sro K (m

/d) Total Porosity

Medium Sand 0.31 1.66 1205 0.136 300E -01 0.40

Groundwater Condition Input Parameters

Simulation

Number

Groun. dwater

Darcy Flux

(m/day)

Groundwater

Linear Velocity Gradient

(m /day) (Wm)

.98E -03 6.23E -03 6.60E -03

Report Created on 8/2612011 Page 1 of 2

Source Area Input Parameters

Simulation

Number

Vertical Depth to Top

Formation of LNAPL

Thickness (m) (m)

Length of

LNAPL Zone

(m)

5.25 27.40 100.00

Width of

LNAPLZon

(m)

100.00

LNAPL Properties

PUMPING CONDITIONS

Simulation Oil/Water iFT OillAir IFT

Number Product Type (dyneslcm) (dyneslcm) Oil Density

(gm /cc) Viscosity

(cp)

Method. Used to Calculate LNAPL Saturation Input. Parameters

Simulation

Number Method Used To Calculate LNAPL Saturation Criteria For Minimum

Source Volitilization Mobility (mlday)

Distribution After Fixed Period of Remediation Volatilization Included 8.64E-04

Dual Pump Extraction Recovery Input Parameters

Simulation Period of Number

Number Recovery Wells

Fluid {LNAPL and Ratio of Radius of Ratio of Radius of Water

Water) Saturated Influence / Radius Influence / Radius Production Rate

Screen Length (m) of Well (LNAPL (m)) of Well (Water) (m) (cu mldaylwell)

Water Production

Rate Calculation

Method

10.0 1.0 70.0 50.0 500.0 9.6 Program

Repart Created on 8i2612011 Page 2 of 2

Executive Summary - Source Zone Composition Through Time

Site Name:

Project Manager:

Date of Analysis:

Port LA Distribution Center

SCS Engineers

August 26, 2011

Title of Simulations: Port LA Distribution Gen

Initial Conditions; Soil & Flow

Simulation

SPARGING CONDITIONS

este m Fuel Oil

Number Soil Layer Soit Type

van Genutchen

Alpha (11m)

Selected Sro

(° %a)

i Medium Sand 031 0.136

Simulation Initial VEQ LNAPL

Number Thickness (m)

nitial Peak So Initial Specific Volume

lcu m /m2)

625 2 E 3.13E -01

ResuE Simulation Number 1)

Originai

Concentration Concentration at

1 Year Concentration at

10 Years Concentration at

20 Years Concentration at

100 Years

Compound of Concern (ugü) fug /l) (ugll) Ogg) (ugh])

Benzene 3.29E+03 3.29E+03 3.29E +03 3.28E +03 324E+03

Ethyl Benzene 6.93E+92 6.93E+02 6.92E +02 6.92E +02 6.92E+02

Toluene 2.30E+01 2.30E+01 2 30Ey01 2.30E +01 229E+01

Xyiene 1.86E+p2 1.85E+02 1.85E +02 1.85E +02 1 85E+02

Report Created on 8(26/2011 Page 1 of 3

User Input Parameters

Soil Properties

Simulation

Number Layer Sail Type

van van

Genutchen Genutchen

Alpha (11m) n Srw Total

Sro K (mid) Porosity

1 1 Medium Sand Oil 1..66 0.205 Q136 3.00E -01 0.40

OnBy apply to multi e toyer soil conditions

Groundwater Condition Input Parameters

Groundwater Groundwater

Simulation Darcy Flux Linear Velocity Gradient

Number (miday) (rn day) (tnlm)

7.98E

-03 623E -03 6.60E

-03

Source Area Input Parameters

SPARGING CONDITIONS

Vertical Depth to Top Length of Width.. of

Simulation Formation of LNAPL LNAPL Zone LNAPL Zone

Number Thickness (m) (rn) (m) (m)

625 27.40 100.00 100.03

LNAPL Prapertïe

Simulation Oil/Water IFT Oíl /Air IFT Oil Density Viscosity

Number Product Type (dyneslcm) (dynes/cm) (gm /cc) (cp)

1 Gasoline 25.00 25.00 0.81 1.50

Method. Used to Calculate LNAPL Saturation Input Parameters

Simulation. Criteria For Minimum

Number Method Used To Calculate LNAPL Saturation Source Volitilization Mobility (mlday)

Equilibrium LNAPL Distribution Volatilization Included 8.64E-04

Report Created on 82612011 Page 2 of 3

Solute Transport Properties Input Parameters

Longitudinal

Horizontal

Transverse Vertical

Transverse Fractional Vapor

Diffusion SPARGING CONDITIONS

Simulation Effective Dispersivity Dispersivity Dispersivity Carbon Efficiency

Number Porosity (m) (in) (m) Content Coefficient

0.318 3.00E +00 1.50E -01 1A0E -02 300E -03 2.50E

Report Created on 812 011 Page 3 of 3

Port LA Distribution Center

Appendix B

March 14, 2014 Addendum to Dissolved- and LNAPL Plume

Stability Evaluations and Discussion of Cleanup Implications

Aqul -Ver. Inc.

I 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

to the:

LA. 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

EXECUTIVE SUMMARY ES -I

INTRODUCTION ........ .................. ........ ........ ........ . ......... .I

RECENT DATA COLLECTION 1

Conditions Since 2011 AVI Reporting

MW -24 - Decreasing Benzene & Increasing DRO 2

PetroleumImpacts at MW 3

REQUEST FOR SITE CLOSURE .................. ..............................4

REPORT CLOSURE

REFERENCES ,,,.,,, .................... ..............................7

LIST OF FIGURE,

Figure I: Site Plan

Figtire 2: MW-24 - Benzene and Diesel Concentration Trends

Figure 3: PIANO Analytical Results, MW -10R vs, MW -29

Figure 4: Gas Chromatographic Results, MW-10R, MW -26, MW -27, MW -29

Figure 5: Groundwater Geochemistry Results, MW- IOR vs. 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, 1

EXECUTIVE SUMMARY

L15-1

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 non-

recoverable 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.

I) .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 I NAP, 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

within the ranges of prior conditions, with 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.

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 I 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.

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

MW-24 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 I 3/20 I 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).

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 MW-

29 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.

2. 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.

3. 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.

4. 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,

6. 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.

7, 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.

8. 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.

áÁ9i N 220owa 429 FAX.I3S 11024

AI{IIVRN,INC.

O»#rugealogy. IVIOPr MUMMY A DOM SFYVI6N, 7

RRS+RRINCES

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

Business Center, 300 Westmont Drive, San Pedro California 90733. y.

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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Appendix C

Zymox Port D. C. Report

February 28, 2014

T n 1 cul Report m Site Glasure 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 S. Andreasen Drive, Suite B, Escondido, CA 92029

28 February 2014

TABLE OF CONTENTS

INTRODUCTION

METHODOLOGY

HYDROCARBON CHARACTERIZATION AND

COMPARISON

CONCLUSIONS 6

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 In the sample, The

following analyses were performed:

1. Co -Cio gasoline range hydrocarbon concentration by GC /MS

2. Fuel oxygenates by GC /MS

3. C,o -C40 alkane analysis by GC /MS

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

Ft t ^X RC:, Page 3

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 ni i 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. l 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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Pori D,C. Pcrf,>c: 5

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

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.

MW -29 contains a different gasoline with the fuel oxygenate DIM, This gasoline Is

from a different source than MW-10R.

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 In MW -26,

MW-27, or MW -29.

Port D.C. Page 6

FL200 A2313petitionpart2

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