In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 3626

DECLARATION of Connelly in Support re: (157 in 1:04-cv-04973-SAS) MOTION for Summary Judgment for Lack of Evidence Pertaining to Causation.. Document filed by Coastal Eagle Point Company, Coastal Chem, Inc.. (Attachments: #1 Exhibit #01, #2 Exhibit #02, #3 Exhibit #03, #4 Exhibit #04, #5 Exhibit #05, #6 Exhibit #06, #7 Exhibit #07, #8 Exhibit #08, #9 Exhibit #09, #10 Exhibit #10, #11 Exhibit #11, #12 Exhibit #12, #13 Exhibit #13, #14 Exhibit #14)Filed In Associated Cases: 1:00-cv-01898-SAS-DCF, 1:04-cv-04973-SAS(Allen, Brent)

EXHIBIT 12
Marcel Moreau Site Specific Report
(Beacon #3519) Excerpts


Excerpt from the Expert Site Specific Report of Marcel Moreau (Nov. 2, 2011), submitted on
behalf of Plaintiff City of Fresno, pertaining to Beacon #3519.

Beacon #3519
4591 East Belmont Avenue, Fresno

MAJOR MILESTONES
1961

Three 12,000 gallon USTs were installed [10/22/1998].

Dec 10, 1998

Three single walled (SW) steel, 12,000 gallon USTs, piping, and
dispensers were removed.

Jan 19, 1999

A Permit to Operate was issued for two 15,000 gallon unleaded tanks
with pressure piping. The tanks were installed in the same excavation
as the former USTs.

Feb 13, 2001

MtBE was detected in groundwater samples. Quarterly groundwater
sampling commenced.

July 10, 2003

Consultant concluded after two series of soil vapor extraction tests
that SVE was not a feasible alternative for remediation of soil beneath
the site. On behalf of Ultramar, the consultant requested CRWQCB to
grant a low risk closure for the site.

March 15, 2004

CRWQCB confirmed the completion of a site investigation and
corrective action for the USTs formerly located at the facility.

SPILL/LEAK EVENT CHRONOLOGY
Dec 10, 1998

UST Abandonment Inspection Report. Three 12,000 gallon USTs were
removed. Soil samples were collected from the tank excavations and
from beneath eight dispensers on two islands (only four dispenser
samples were reported in the removal report). Odors were observed
in the samples from the east side of Tank 2 (T2): strong odor, gray soil
in S5 (15 ft bgs) and medium odor, grayish soil in S6 (17 ft bgs). All
three tanks were in good condition, rusted, with no holes visible.
[12/10/1998]

Dec 11, 1998

An Unauthorized Release Report (URR) was filed by Fresno County for
the release of an unknown quantity of gasoline, discovered during tank
removals. The source was checked as unknown.

Beacon 3519, Fresno

Page 1 of 4

SOIL/GROUNDWATER CONTAMINATION CHRONOLOGY
Feb 18, 1999

Tank Removal / Closure Report. On Dec 10 11, 1998, three SW steel,
12,000 gallon USTs, product piping, and two dispenser islands were
removed from the site. Soil samples were collected for analysis of
TPHg, MtBE, and BTEX. Additional sidewall samples were collected on
12/14/1998 from the Tank 3 excavation.
USTs: The highest concentrations of TPHg (13,000,000 ppb) and MtBE
(110,000 ppb) were in the samples collected from the east end
(submersible end) of Tank 3 (15 and 18 ft bgs). Lower concentrations
of TPHg were detected in samples from T2 (1,900 to 9,700 ppb) but
not T1. MtBE was detected at all three tank locations (15 ppb to
110,000 ppb).
Product Line Trenches – No analytes were detected in the single
sample collected (3 ft bgs).
Dispenser Samples: TPHg (at 1,100 ppb) and MtBE (at 120 ppb) were
detected in the sample near the south end of the eastern dispenser
island (6 ft bgs). No analytes were detected in the other three
dispenser samples. Note: the site diagram indicates samples were
taken from beneath the piping adjacent to the dispensers, not directly
beneath the dispensers.

Feb 7, 2000

Two soil borings (B 1 & B 2) were drilled to 75 ft bgs and soil samples
were collected. B 1 was on the east side of the UST excavation, and B
2 was on the south side. TPHg was found only in B 1 samples, at a
maximum concentration of 13,000 ppb (45 ft bgs). MtBE was detected
in samples from both borings, with a high of 38,000 ppb at B 1 (31 ft
bgs) and 1,600 ppb at B 2 (31 ft bgs). The borings were grouted to 30
and 41 ft bgs, and vapor extraction wells were installed (VW 1 & VW
2). The consultant concluded that no gasoline constituents were
present within 20 to 30 ft of the estimated groundwater level (90 ft
bgs). [6/15/2000]

Dec 27 29, 2000

Three monitoring wells were installed to a depth of 115 ft bgs. MW 1
was located east of the UST excavation area, and MW 2 and MW 3
were located on the southern property boundary. [4/6/2001]

Feb 13, 2001

Groundwater samples were collected and analyzed. Quarterly
groundwater sampling commenced. [4/6/2001]

Beacon 3519, Fresno

Page 2 of 4

April 6, 2001

Results of Soil and Groundwater Investigation. Groundwater was
measured in site wells at 99 ft bgs, and reportedly flowed to the west
southwest. No TPHg or BTEX compounds were detected in the Dec
2000 soil boring samples. MtBE was detected in soil samples collected
from 10 to 85 ft bgs at the MW 1 boring, with a maximum
concentration of 16,000 ppb (40 ft bgs). The 85 ft bgs sample from
MW 1 also contained 6.5 ppb MtBE. The only MtBE detection at MW
2 was 5.6 ppb at 100 ft bgs. No MtBE was present in soil samples from
the MW 3 boring. In groundwater, only MtBE was detected: 59 ppb in
MW 1 and 6.6 ppb in MW 2. Other groundwater analytes that were
ND were TPHg, BTEX, DIPE, ETBE, TAME, TBA, DCA, DBA.

July 10, 2003

Soil Vapor Extraction Test Report and Request for No Further Action.
Consultant concluded after two series of soil vapor extraction tests
that SVE was not a feasible alternative for remediation of soil beneath
the site. Also noted was that no TPHg or BTEX had ever been detected
in groundwater samples, and no MtBE concentrations above 1 ppb had
been reported in groundwater since Dec 2001. A request was made
for low risk closure and permission to abandon the vapor extraction
and monitoring wells.

March 15, 2004

Case Closure Summary. Fifteen water supply wells were identified
within a 2,500 foot radius of the site. The closest well was
approximately 600 ft west of the site and was identified as City of
Fresno municipal Well #30A.
Summary and conclusions: A former release of petroleum
hydrocarbons at the site resulted in the degradation of the underlying
soils and groundwater. The extent of the impacted soils has been
adequately evaluated. Remediating the impacted soils via SVE
technology was evaluated and determined to not be a viable cleanup
alternative. Further investigation of the site does not appear
warranted. The results of groundwater monitoring and sampling
events conducted between 2001 and 2003 revealed that the
contaminant plume had stabilized and decreased. Groundwater
impacts diminished to nearly non detectable levels as of March 2002.
The residual petroleum hydrocarbons in the underlying soils are likely
to naturally degrade and are not anticipated to pose a threat to the
beneficial use of groundwater in the area.
CRWQCB confirmed the completion of a site investigation and
corrective action for the USTs formerly located at the facility.
[RWQCB FRESNO 016244]

Beacon 3519, Fresno

Page 3 of 4

May 11, 2004

Well Abandonment Report. Three monitoring wells and two VE wells
were pressure grouted. [5/11/2004]

IDENTIFICATION OF MTBE RELEASES
Tank Area Releases
MtBE contaminated soil was discovered at the bottom of the tank excavation in December of
1998 when three storage tanks were removed. The highest levels of MtBE contamination
(110,000 ppb) were associated with the submersible pump end of Tank 3, but all samples
except the sample from the fill end of Tank 1 were contaminated with MtBE at levels ranging
from 15 to 21,000 ppb. Contamination detected at the fill ends of the tanks was likely the
results of delivery releases, while contamination detected at the submersible pump ends of the
tanks was likely the result of releases from the submersible pumps and adjacent piping. The
releases were likely intermittent. The volume released is not known.
Piping and Dispenser Area Releases
MtBE contaminated soil was discovered beneath piping adjacent to the dispensers in December
of 1998 when the piping and dispensers were removed. Because of the proximity of the sample
to the dispensers, the releases that produced the contamination could have originated from the
piping or from the dispensers. Dispensers and adjacent piping are frequent sources of releases
(see general report in this case). The releases were likely intermittent. The volume released is
not known.
Customer Spills
Small spills are common during vehicle fueling activities and no doubt occurred throughout the
time this facility was in operation. Fueling spills may have contributed to the MtBE
contamination present in the dispenser area.

Beacon 3519, Fresno

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