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 13
Marcel Moreau Site Specific Report
(Tulare Exxon) Excerpts


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

Exxon, Tulare Ave.
4594 East Tulare Avenue, Fresno

Note: Site is also known as Beacon #620, Arco #620, Circle 6 Food & Go, Circle 6 Valero.

MAJOR MILESTONES
March 1985

Arco 620 had been operating for nine months at the site and had four
USTs containing unleaded, leaded and premium gasoline, and diesel.
A soil boring investigation concluded that no contamination due to
gasoline or diesel leakage existed around the USTs. There was
another station at the site prior to this one, and it was not known if
the existing tanks had been used at that station. [Later documents [12
15 1998] indicated the USTs dated from 1978.]

Nov 12, 1992

The USTs at the site were described as four 10,000 gallon single
walled (SW) bare steel, unlined USTs. The tanks had no corrosion
protection (CP), spill containment or overfill prevention. The piping
was SW galvanized steel.

March 16, 1993

An existing 10,000 gallon diesel tank was converted to a gasoline tank.

Jan 19, 1999

Four 10,000 gallon USTs, 20 years in age, and eight fuel dispensers
were removed from the site. Soil samples indicated a release of
petroleum product constituents into the subsurface had occurred.
MtBE was detected in soil samples.

Feb 9 10, 1999

Approximately 250 cubic yards of soil was excavated from the former
UST area and stockpiled on site.

March 1999

Two USTs, one 12,000 gallon and one 6,000 gallon/6,000 gallon split
tank, were installed.

Nov 1, 2004

Monitoring wells were installed, MtBE was detected in groundwater
samples, and quarterly groundwater monitoring was initiated.

Oct 17, 2007

Diesel piping was removed; soil samples were collected.

Exxon Tulare Ave, Fresno

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May 4, 2009

Results of the First Quarter 2009 Groundwater Monitoring Event.
There were no constituents detected in groundwater during this
quarter, and none detected throughout 2008.

Aug 5, 2010

SVE system was put into operation. [4/6/2011]

Sept 21, 2010

Results of the Second Semi Annual Groundwater Monitoring Event.
From Aug 2010 through Sept 2010, the SVES operated at an average
flow rate of approximately 74 cubic feet per minute (cfm). The SVES
removed approximately 499.37 lbs of VOCs from the soil. Given that
one gallon of product weighs 6.18 pounds, 81 gallons of product had
been removed as soil vapor since start up of the SVES.

May 16, 2011

From CRWQCB following review of Results of the First Semi Annual
Groundwater Monitoring Event and Compliance Air Quality Monitoring
Report, dated 4/6/2011. No free phase petroleum product was
detected in any of the wells. Groundwater samples contained no
constituents above the laboratory detection limits. The SVE system
was estimated to have removed approximately 2,400 lbs
(approximately 400 gallons) of TPHg during the period.

IDENTIFICATION OF MTBE RELEASES
Tank Area Releases
During removal of the storage tanks in January of 1999, MtBE was detected in five of eight soil
samples from beneath the storage tanks. After over excavation of the tank field in February of
1999, MtBE contamination was still present in soils at depths ranging from 20 to 29 feet.
Releases from storage tanks are common, often originating from spills during deliveries and
leaks from submersible pumping systems. The timing of the releases is not known, but the
releases likely occurred between the fall of 1992 when MtBE was required to be in Fresno
County gasoline1 and the time when the tanks were removed in 1999. The volume released is
not known.
In July of 2004, MtBE was detected in soil boring B 8 adjacent to the UST field in all the samples
taken from 20 to 65 feet except one. Releases associated with storage tanks are common.
Because secondary containment was part of the new storage systems installed in 1999, it is
likely that this contamination was associated with releases from the pre 1999 storage tanks.
The volume released is not known.
1

“Areas Participating in the Oxygenated Gasoline Program,” Energy Information Administration, Department of
Energy, http://www.eia.gov/steo/special/oxy2.html#Original, accessed on 9/15/2011.
Exxon Tulare Ave, Fresno

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Piping and Dispenser Area Releases
During removal of the storage systems in January of 1999, MtBE was detected in three of ten
soil samples from beneath the dispensers. One of two soil borings advanced to 20 feet in the
area of the former western dispenser island in February of 1999 detected MtBE at 20 ft depth.
Releases from dispensers are common (see general report in this case). The releases were
intermittent, and likely occurred between the fall of 1992 when MtBE was required to be in
Fresno County gasoline2 and the time when the tanks were removed in 1999. The volume
released is not known.
In January of 2001, a piping leak was identified in dispenser #2. When the release started is not
known. The volume released is not known. MtBE was likely present in gasoline in 2001. Under
dispenser containment was present at this time, and it was determined to be tight on May 26,
2004, so it is not likely that this release contributed to the MtBE contamination at this facility.
In July of 2004, MtBE was detected in soil boring B 7 adjacent to a dispenser at all depths
sampled from 20 to 55 feet. Releases from dispensers are common. Because under dispenser
containment was present beneath the dispensers installed in 1999, it is likely that this
contamination was associated with releases from the pre 1999 dispensers. The volume
released is not known.
Tank and/or Dispenser Releases
Between July 2004 and April 2007, 16 borings, 3 monitoring wells, and one vapor recovery well
were installed near the eastern edge of the facility. MtBE contamination was detected in many
of the soil samples taken in the course of these investigations. Whether the releases that
produced this contamination originated from the dispensers or the tank area could not be
determined. Both dispensers and tanks are common sources of releases, and both dispensers
and tanks are about equidistant from the contaminated area. The timing of the releases is not
known, but they probably occurred between the fall of 1992 when MtBE was required to be in
Fresno County gasoline3 and the end of 2003 when MtBE was removed from California gasoline.
The total volume released is not known, but approximately 400 gallons were recovered through
soil vapor extraction.
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 at this facility.

2
3

Ibid.
Ibid.

Exxon Tulare Ave, Fresno

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