Expert Report Addendum Paulsboro Terminal Site Paulsboro, New

7944 Wisconsin Avenue, Bethesda, Maryland 20814-3620 (301) 718-8900

Expert Report Addendum Paulsboro Terminal Site Paulsboro, New Jersey

S.S. PAPADOPULOS & ASSOCIATES, INC. Environmental & Water-Resource Consultants

May 3, 2013

7944 Wisconsin Avenue, Bethesda, Maryland 20814-3620 (301) 718-8900

Expert Report Addendum Paulsboro Terminal Site Paulsboro, New Jersey Prepared for: State of New Jersey Department of Environmental Protection

Prepared by: ____________________________ Dr. Harvey A. Cohen ____________________________ Michael T. Rafferty

S.S. PAPADOPULOS & ASSOCIATES, INC. Environmental & Water-Resource Consultants

May 3, 2013

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Table of Contents Page

List of Figures ............................................................................................................................................... ii

List of Tables ................................................................................................................................................ ii

List of Attachments ....................................................................................................................................... ii

Section 1 Introduction .............................................................................................................................. 1

Section 2 Opinions ................................................................................................................................... 2

Section 3 Bases of Opinions .................................................................................................................... 3

Facility History and Background ............................................................................... 3

Releases Resulting from Operations at Paulsboro Terminal ..................................... 3

Groundwater Conditions ............................................................................................ 5

Groundwater Contamination – Up to 1990 ........................................................ 6

Extent of Current Groundwater Contamination Attributable to Exxon ............. 7

Period from 1984 to 1988 ......................................................................... 7

Period from 1989 to 1990 ......................................................................... 8

Period from 1990 to 2013 ......................................................................... 8

Estimation of Plume Volume Attributable to Exxon ............................... 8

Soil Conditions ........................................................................................................... 9

Soil Contamination – Up to 1990 ...................................................................... 9

Soil Samples ............................................................................................. 9

Free Product .............................................................................................. 9

Soil Gas Surveys ..................................................................................... 11

Tank Bottom Disposal Pits ..................................................................... 12

Bioremediation Area .............................................................................. 12

Extent of Current Soil Contamination Attributable to Exxon .......................... 12

Soil Contamination Attributable to Exxon Acts as a Continuing Source to Groundwater ..................................................................................................... 12

Site Restoration ........................................................................................................ 13

Groundwater Control and Restoration ............................................................. 13

Soil Restoration ................................................................................................ 13

Site Restoration after Cessation of Site Operations ......................................... 14 References ................................................................................................................................................... 16

Figures

Tables

Attachments

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List of Figures

Figure 1 The Former Exxon Paulsboro Terminal and Vicinity

Figure 2 Areas of Groundwater Contamination at the former Exxon Site in Paulsboro, NJ

Figure 3 Evidence of Contamination Prior to 1990 at the former Exxon Site in Paulsboro, NJ

Figure 4 Conceptual Plan for Restoration of Soil and Groundwater at the former Exxon Site in Paulsboro, NJ

List of Tables

Table 1 Area of Contaminated Groundwater

Table 2 Summary of Estimated Restoration Costs

Table 3 Restoration Criteria

List of Attachments

Attachment A Curriculum Vitae for Dr. Harvey A. Cohen

Attachment B Curriculum Vitae for Michael T. Rafferty

Attachment C Estimated Restoration Costs

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Section 1 Introduction

Harvey A. Cohen and Michael T. Rafferty of S.S. Papadopulos & Associates, Inc. (SSP&A) were retained on behalf of the New Jersey Department of Environmental Protection (NJDEP) to evaluate contamination from historic and current operations at the Paulsboro Terminal site in Paulsboro, New Jersey. Operations at this facility have resulted in contamination of the soil and groundwater beneath the facility and migrating from the facility.

In November 2009, Mr. Rafferty and Dr. Cohen authored an expert report on the Paulsboro Facility that addressed the site’s complete history through its ownership by Exxon Corporation, GATX, and ST Services (Cohen and Rafferty, 2009). This current report supplements the 2009 document. For this report, Dr. Cohen and Mr. Rafferty were requested to address the soil and groundwater contamination that are attributable solely to Exxon’s tenure, from the 1950s to 1990.

SSP&A’s expertise includes the evaluation of the origin, distribution, fate, and transport of contaminants in the environment and the design of remedial actions for contaminated sites. Harvey A. Cohen is an Associate with a PhD in Geological and Geophysical Sciences from Princeton University (1992) and is a registered Professional Geologist in three states. Michael T. Rafferty is Vice-President and Principal Engineer at SSP&A and has over twenty-five years of professional experience. Mr. Rafferty is a Professional Engineer in several states, including New Jersey, license number 24GE04258400. Qualifications, publications, trial and deposition experience for Dr. Cohen and Mr. Rafferty are included in Attachments A & B.

In the preparation of this report, SSP&A has reviewed technical reports that describe facility characteristics, facility history, and conditions at the site. The documents upon which SSP&A has relied are the types of documents typically used by hydrogeology and engineering experts to evaluate the nature and extent of contaminants in the environment at a site and to design a set of conceptual remedial actions. Finally, Dr. Cohen and Mr. Rafferty have relied upon extensive education, training and experience in the fields of hydrogeology and engineering in formulating the opinions expressed in this report. SSP&A reserves the right to modify and supplement the opinions expressed in this report as additional information becomes available.

The purpose of this report is to provide an estimate of the volume of soil and groundwater affected by contamination from Exxon’s operations at the site and to calculate an associated cost of restoration of the site to pre-discharge conditions. The estimates are provided with a reasonable degree of certainty in the fields of hydrogeology and engineering.

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Section 2 Opinions

1. Numerous releases have occurred at the site resulting in the contamination of soil and groundwater beneath the facility. While many of these releases have been reported, additional unreported releases have occurred at the site that can be inferred from analytical results of soil and groundwater investigations.

2. Soil at the Paulsboro Terminal site is contaminated with petroleum-related contaminants, including total petroleum hydrocarbons (TPH), benzene, toluene, ethylbenzene, and xylene (BTEX), lead, and naphthalene; much of this contamination was detected prior to the end of 1989, or can be tied to releases prior to the end of 1989.

3. Groundwater at the Paulsboro Terminal site is contaminated with petroleum-related contaminants, including BTEX, methyl tertiary butyl ether (MTBE), lead, tertiary butyl alcohol (TBA), and naphthalene; much of this contamination was detected prior to the end of 1989, or can be tied to releases prior to the end of 1989.

4. Petroleum-related contaminants have been observed in groundwater monitoring wells since 1984.

5. Soils contaminated with petroleum products will act as a continuing source of contamination to groundwater while they are present at the site; soils contaminated by releases occurring prior to the end of 1989 continue to act as continuing sources of groundwater contamination today.

6. The volume of contaminated groundwater from 1984 to the present can be estimated from the available groundwater data, and information about the hydrogeologic environment.

a) For the period from 1984 through 1988, the volume is estimated to be 118 million gallons.

b) For the period from 1989 to the present, the volume is estimated to be 182 million gallons, coincident with the known continuing sources on the Paulsboro terminal and adjacent properties.

7. Primary restoration actions will restore groundwater to pre-discharge conditions. These actions will include groundwater pump-and-treat and soil vapor extraction activities while the site is in operation, followed by soil excavation after facility operations are discontinued.

8. The cost of primary restoration will be approximately $12.4 million in 2013 dollars.

9. Primary restoration of groundwater is estimated to be completed in 32 years following implementation of restoration activities.

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Section 3 Bases of Opinions

Much of the material presented below is repeated from the 2009 Expert Report (Cohen & Rafferty, 2009). It is reiterated here, as necessary, to support the opinions expressed in this report.

Facility History and Background The Paulsboro Terminal site is located at 3rd Street and Billingsport Road, Paulsboro

Borough, Gloucester County, New Jersey (Figure 1). The approximately 34-acre site is located in an industrial and residential area along the Delaware River. The Delaware River borders the site to the north and northwest. The Valero Refinery (formerly owned by Mobil) is located to the southwest of the site. Fort Billings Park, which is owned by the Borough of Paulsboro, is located on the west of the site. West of the park is the Sun Oil Company (Sun) Terminal. Residential properties are located to the south, east and northeast of the site (Handex, 2001).

The property has been operated as a bulk petroleum products storage terminal since the 1950s. Many of the large above-ground storage tanks were installed in 1953 and 1954 (Exxon, 1990a). Eight new above-ground tanks were installed at the site in 2009 during an expansion of the facility (Groundwater and Environmental Services [GES], 2009). Exxon Company U.S.A. (Exxon, now Exxon-Mobil Corporation) owned and operated the Paulsboro terminal from approximately 1950 to 1990. In 1990, the property was sold to GATX Terminals Corporation (GATX, now Kinder Morgan Liquid Terminals, LLC) who, having first operated part of the facility under a lease beginning in 1989, continued operations there until 2000 when the facility was sold to Kaneb Pipeline Partners, LP (Kaneb). Support Terminals Services, Inc. (ST Services), which was a wholly owned subsidiary of Kaneb, operated the facility until 2005 when Pacific Atlantic Terminals, LLC (PAT) began operations at the site (Flaster, Greenburg, 2006).

Exxon operated a bulk storage terminal that handled petroleum products including leaded and unleaded gasoline, home heating oils and jet fuel. GATX, ST Services and PAT continued terminal operations with storage of unleaded gasoline, ethanol, jet fuel, and heating oil. In 1992, GATX began the storage of neat MTBE though Exxon reportedly stored gasoline containing MTBE during its tenure at the site (Flaster, Greenburg, 2006). Jet fuels stored at the terminal were delivered, via pipeline, to the Philadelphia International Airport located across the Delaware River.

Releases Resulting from Operations at Paulsboro Terminal The first reported release by Exxon occurred at the site in 1985 when an estimated

130,000 gallons of heating oil leaked from a break in the underground piping near the loading rack (Handex, 1999). This release led to the discovery of a plume of free product in the loading rack area of the site.

Subsequent reported releases include:

1989: A leak was discovered at the base of Tank 182 and unknown quantity of ‘water bottoms’ and free phase petroleum was released (Handex, 1999 and 2001)

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1990-1992: Several small releases (<10 gallons) of fuel oil, kerosene and gasoline, near tank 178 and in unknown locations (NJDEP Incident Notification (INA) Database)

1992: 100 gallons of gasoline released into bay under truck; liquid entered oil/water separator (NJDEP Incident Notification (INA) Database)

1993: Release of 420 gallons of gasoline near Tank 164, (Pennoni Associates Inc., 1993)

1994-1995: Discovery of soil contamination associated with several USTs near the garage and near Tanks 166/167 (Anchor Environmental, 1995)

1997: Release of 15,000 gallons of Ethanol near the Delaware River (NJDEP Incident Notification (INA) Database and Versar, 2007)

2000: soil samples from beneath Tank 178 indicated a release of neat MTBE; in 2002, areas of MTBE impacted soil were detected surrounding Tanks 176, 177, 179, and 181 (Versar, 2002)

2003: release of approximately 50 gallons of pure product, or ‘neat’, MTBE leaked from a bleeder valve in a piping run to the neighboring Valero refinery (Versar, 2004b)

2003: investigation of soil below the loading rack found evidence for leaded gasoline releases east and north of the loading rack (Versar, 2007).

In addition to these releases, unreported releases occurred at the site predating the 1990 sale of the property. Documentation and evidence of these releases was found during various site investigation activities. Operational practices during Exxon’s tenure contributed to the contamination of soil and groundwater at the site. Exxon reported in 1990 that based on “site records and… interviews with facility personnel it was determined that historic tank cleaning activities incorporated on-site disposal of tank bottom solids. These materials commonly are comprised of solids derived from the storage tank itself (i.e., rust), grit derived from product transport, petroleum product precipitates and condensate.” These activities were “common industry practice during the 1950s and 60s” (ERM, 1990a). The disposal of tank bottom sludge in the subsurface of the site constitutes a release of contaminants to the soil and groundwater beneath the site. Site investigation and subsequent site work identified 14 disposal areas (tank bottom disposal pits) generally located adjacent to storage tanks. Eight of the identified tank bottom disposal pits were excavated during site remediation activities, though excavated soil from two of the pits remained on site with the intention of future remediation by bioremediation (Handex, 2001; ERM, 1992). The bioremediation program, however, was never implemented.

Additionally, Exxon reported that “a storm-water retention and collection system is located at the Site. This system consists of a series of catch basins and two retention ponds. The collected runoff is then distributed to an oil/water separator system and is then discharged directly to the Delaware River.” (Handex, 2001). Soil samples were collected from beneath the two ponds and from around each of the four oil-water separators. Concentrations above New Jersey soil criteria were found in both ponds and around two of the oil-water separators.

During investigation subsequent to the 1985 heating oil release, liquid phase hydrocarbons (LPHs), and groundwater and soil contamination were discovered at the site

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indicating additional releases prior to the 1985 heating oil release. The LPHs were discovered in the western part of the site. This plume, referred to as the ‘western NAPL plume’, was separate from the heating oil free product plume and consisted of a mixture of jet fuel, kerosene and gasoline (ERM, 1990a and 1990b; Handex, 1999). Results of soil sampling indicate on-site sources for this western NAPL plume.

In addition, within the loading rack area of the site, evidence of unreported releases from prior to 1990 has been found. In 1988, Exxon’s consultant, Product Recovery, Inc., indicated that there was a significant amount of free product from a separate source than the known heating oil spill that was present in the area and recommended additional remediation (Product Recovery, Inc., 1988). The additional remediation was not implemented and evidence reconfirming these unreported releases was found in 2005 when an investigation of contamination in the loading rack area indicated that at least two releases of leaded gasoline had occurred in the area in addition to the reported heating oil release (Versar, 2005).

The pre-1990 releases described above and historical operational practices resulted in the contamination of soil and groundwater at the Paulsboro Terminal site.

Groundwater Conditions The Paulsboro Terminal site is located in the Atlantic Coastal Plain physiographic

province of New Jersey. The Coastal Plain consists of Cretaceous to Miocene Age unconsolidated deposits of alternating sandy and clayey strata unconformably overlain by sediments of Pleistocene and Recent Ages. East-southeast dipping Cretaceous sediments beneath the site have been differentiated into the Magothy and Raritan Formations, consisting of alternating clay and fine to coarse grained sand and silt. These units comprise part of the Potomac-Raritan-Magothy regional aquifer system, a major source of groundwater in New Jersey. Underlying the Cretaceous and Quaternary strata is the mica schist/gneiss crystalline bedrock of the Precambrian Wissahickon Formation (ERM, 1988a). The total thickness of unconsolidated deposits adjacent to the site is approximately 300 feet.

Surficial sediments at the site consist predominantly of medium grained sand with some gravel lags (ERM, 1988a). Some discontinuous silty clay horizons are intercalated with the undifferentiated sands and gravels. The middle aquifer of the Potomac-Raritan-Magothy regional aquifer system sub-crops beneath these younger sediments (Barton & Kozinski, 1991). Soil sampling conducted during installation of monitoring well E-6 indicated the presence of a dense red clay approximately 6 feet thick, occurring at a depth of approximately 65.6 feet below grade (Versar, 2004a). Subsequently, a similar clay horizon was identified from about a dozen other locations across the site at depths ranging from 75 to ~110 feet (Sovereign Consulting, 2010). The lateral extent and continuity of this clay, and a “regional clay” reported at approximately 150 to 160 feet below grade (ERM, 1991) are, however, not clear from available data.

Shallow groundwater at the site is under unconfined (water-table) to semi-confined conditions. The depth to groundwater is approximately 30 feet under most of the site, with some areas of potentially perched groundwater. The existence of the perched water table near wells W-7, E-4, and E-5 was confirmed by the soil boring for well E-4, E-5, and SB-13 installed by ERM (ERM, 1988a). “A thin clay layer at an elevation of approximately 15-20 feet MSL [above mean sea level] occurs below the MTBE tankfield and appears to be relatively widespread and

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contiguous with the confining layer present in the western part of the terminal, below the mixed fuels tank areas” (Versar, 2004a).

Under natural (pre-development) conditions, the groundwater flow was generally northward, toward the Delaware River. Subsequent to 1984, however, a reversal in groundwater gradient was observed in response to remedial pumping at the nearby Valero refinery (Exxon, 1990b). Under certain Valero pumping conditions, the groundwater flows in generally southwesterly direction. While the majority of the submitted potentiometric surface maps did indicate the flow has been toward the southwest from 1990s through 20091, measurements from 2010-2012 no longer support the conclusion of flow toward the Valero extraction wells. These recent measurements indicate consistent loss of containment and flow of contaminants from the majority of the site to the northeast toward the Delaware River (Sovereign Consulting, 2013).

A capture zone map generated by Exxon’s consultants (NewFields, 2002) shows flow paths crossing the southern edge of the Paulsboro Terminal facility and converging southwestward on Valero recovery wells RW-6 and RW-5. The capture zone analysis, however, was based on extraction wells RW-5 (now RW-5A) and RW-6 each pumping 200 gallons per minute (gpm). In their subsequent monitoring reports, Exxon does not report or analyze the actual operational pumping rates from these Valero wells. For this analysis, Valero documents were reviewed and indicate that the pumping rates of these two wells have generally been significantly less than the 200 gpm used for the capture zone analysis (Mobil Oil Corporation, 1993; B&B Diversified Enterprises; 1998; Langan Engineering, 2000 – 2012). In addition, since 2009, Valero wells RW-5A and RW-6 have been operating at less than 100 gpm per well. These flow rates do not provide the conditions necessary for flow of contaminants away from the river, as indicated by recent mapping (Sovereign Consulting, 2013).

Based on hydraulic conductivity measurements from slug tests and geotechnical testing performed by ERM (1988), Handex (1999) estimated an average hydraulic conductivity of 97 feet per day (ft/day). They used an average gradient of 0.001 feet per foot (ft/ft) toward the Valero refinery, and an effective porosity of 0.26, to calculate a groundwater velocity of 136 feet per year (ft/year) for the site. For the least-retarded contaminant (MTBE), they calculated a transport rate of 130 ft/year (Handex, 1999). Examination of the groundwater measurements indicates, however, that the actual gradient may be as high as 0.002 ft/ft at some locations/times and the gradient is likely to increase in the vicinity of the Valero extraction wells. In addition, downward gradients have been significant during the period of site operation due to pumping in the regional aquifer (Barton & Kozinski, 1991; Sloto, 2003).

Groundwater Contamination – Up to 1990

Groundwater contamination at the site was likely present soon after operations began in the 1950’s, although it was first documented in 1984. Between 1984 and 1990 new groundwater monitoring wells were installed. The first samples of groundwater from monitoring wells at the Paulsboro facility were collected by Exxon in 1984. Data for six wells are reported for 1984 (Handex, 2001), whereas by the start of 1990, data were reported for a total of about 40 wells (Handex, 2001; ERM, 1990a; Groundwater Environmental Services, 2008; NJDEP, 2007a). As

1 Exceptions for the loading rack portion of the site are indicated on Exxon water level data and maps for November

1994 (Handex, 1995), November 1999 (Handex, 2000), August 2004 (Newfields, 2004), November 2007 (GES, 2008), and February 2008 (GES, 2008).

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the groundwater monitoring network was expanded through this time period, the apparent extent of groundwater contamination also expanded. By the end of 1989, wells with observed contamination (BTEX, naphthalene, MTBE, and lead) covered the majority of the Paulsboro terminal site, and included off-site locations in the Park to the west (Figure 2). In addition to dissolved contamination, free product had been observed across the site, with concentrations in the western tank farm, eastern tank farm, the loading rack area, near the garage, and the piping alley.

In 2001, Exxon applied for a Classification Exception Area (CEA) determination (Handex, 2001). The application designated an area of approximately 44 acres as contaminated. The southern boundary of this area was apparently designed with the assumption that offsite migration is contained by Valero’s pumping well RW-5A, excluding any contamination originating from the Eastern Tank Farm area. The northern edge of the plume is the Delaware River. The western edge of the plume is the boundary between the Park and the adjacent Sun Oil Terminal where the plume from the site would intercept plumes from neighboring sites.

Extent of Current Groundwater Contamination Attributable to Exxon

While releases of contaminants to groundwater occurred after Exxon’s tenure at the Paulsboro terminal, it is still possible to identify groundwater contaminated as a result of Exxon’s activities. The following factors make this determination possible:

Soil contamination detected prior to 1990 with petroleum hydrocarbons at depths above the water table indicate that release of petroleum hydrocarbons occurred during Exxon’s tenure.

Free-phase hydrocarbons released by Exxon remain as both free product and residual soil contamination

This residual contamination serves as a continuing source of groundwater contamination, expressed as persistent concentrations of volatile organic compounds in groundwater

Leaded gasoline was not stored on-site by parties other than Exxon. Lead detected in groundwater has been identified in the form of tetraethyl lead (Versar & Trillium, 2005). Dissolved lead at concentrations exceeding the regional background persists to the present day (Sovereign Consulting, 2013).

From 1990 to about 2009, groundwater flow directions at the site remained consistently southwestward towards Valero’s extraction wells.

To estimate the extent of groundwater contamination over time, the period from 1984 to the present was broken down into the following periods:

Period from 1984 to 1988

During this period, the first groundwater monitoring wells were installed, and the groundwater flow direction was first influenced by remedial pumping at the Valero facility. Data from the years 1984 to 1987 do not cover the entire Paulsboro Terminal site, and do not address all the contaminants of concern. In 1988, however, 36 wells were sampled, at least once, allowing for a better delineation of on-site contamination. Analytes included BTEX, MTBE and naphthalene. We have assumed that the 1988 delineation is a reasonable approximation of the on-site contamination for the entire 1984 to 1988 period. We used the spatial interpolation method called indicator kriging to delineate the plume of 1988 groundwater contamination; this

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corresponds to an area of 17.3 acres covering portions of the Paulsboro Terminal site and adjacent properties (Figure 2).


In 1989, the Park wells were sampled for the first time (ERM, 1990a) providing additional information on the extent of the western plume. These data were incorporated into a 1989 delineation, using the same kriging methodology as for the earlier period (Figure 2). For the purposes of this report, the western edge of Exxon’s contamination has been set as the western edge of the Park because the actual edge of contamination was not fully delineated by Exxon. Similarly, the extent of contamination in the northeast corner of the facility has been clipped to be coincident with the facility boundary and the proposed CEA (Handex, 2001). Prior to 1984, groundwater flow would have carried dissolved contaminants from the Loading Rack across the facility boundary in a northeasterly direction. Despite the fact that wells such as W-2 and R-6 were contaminated in the late 1980s, Exxon never installed off-site monitoring wells to evaluate the extent of this contamination. Therefore, the extent of any residual off-site contamination following Exxon’s free product removal actions remains undocumented.


Between 1989 and 2013, the extent of monitoring wells showing contamination expanded across the facility. By 1995, groundwater flow toward the Valero facility was established, and groundwater wells over the entire 34 acre Paulsboro Terminal site and the adjacent Park showed evidence of contamination with the contaminants of concern above pre-discharge levels. Some of this contamination is directly attributable to post-Exxon releases such as the MTBE associated primarily with the eastern Tank Farm area, and the gasoline release near Tank 164. Nonetheless, in the western plume, the loading rack and garage areas, the persistence of volatile organic compounds and free product or sheens on groundwater, indicate the presence of a continuing source.

Neither Exxon nor its successors at the site have completed sufficient investigations to adequately quantify either the loading of dissolved contaminants to groundwater over time, or the degradation rates of soluble compounds over time. Consequently it is difficult to extrapolate the extent to which Exxon’s groundwater contamination extends downgradient and mingles with subsequent sources.

The extent of post-1990 contamination attributable to Exxon is estimated here as the same as the 1989 footprint of contamination with the following changes:

A small portion of the site for which there are few data between well W-3 and the Delaware river is included, as it is for the CEA developed by Exxon’s consultant (Handex, 2001);

A portion of the site likely to be dominated by the release near Tank 164 / Well W-6 is excluded; and

The off-site contamination northeast of well W-2 is excluded because it cannot be reasonably quantified with existing data.

Estimation of Plume Volume Attributable to Exxon

The volume of groundwater containing organic compounds at concentrations greater than pre-discharge levels is referred to as the plume. To estimate the extent of groundwater contamination over time attributable to Exxon, the following approach was used:

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1984 to the end of 1988: We have assumed that the 1988 delineation is a reasonable approximation of the on-site contamination for the entire 1984 to 1988 period. The volume of this plume is based upon the known vertical extent of contamination, as indicated by persistent petroleum-related compounds in well E-9 (Table 1). The area of contaminated groundwater can be estimated to be 17.3 acres. Using reasonable estimates of the contaminated aquifer thickness (60 feet) and total porosity for a medium sand (0.35), this translates to a volume of 118 million gallons.

1989: For the purposes of this report, the extent of 1989 contamination is calculated as 24.4 acres, which translates to a volume of 182 million gallons of water using the same assumptions as above.

1990 to 2013: For the purposes of this report, the extent of 1990-2013 contamination is calculated to be 24.4 acres, which translates to a volume of 182 million gallons of water using the same assumptions as above.2

Soil Conditions In this section, the soil contamination observed on-site is reviewed.

Soil Contamination – Up to 1990

Soil contamination prior to 1990 was widespread throughout the site. Soil sampling results are limited from this time period and are not sufficient to be used on their own for delineation of soil contamination. Additional information, including the presence of free product, locations of tank bottom pits, and, to lesser extent, the results of soil gas surveys conducted prior to 1990 were used to estimate the extent of soil contamination resulting from pre-1990 sources and confirm the presence of on-site sources to groundwater contamination. The various lines of evidence of site contamination are shown on Figure 3.

Soil Samples

Soil sample data for the site through the present time are limited and are not sufficient to delineate the vertical and lateral extent of soil contamination. Large areas of the 34-acre site have no soil data and vertical extent of contamination is poorly characterized. From the data collected before 1990, it can be seen that impacts occurred throughout the site and that soil contamination was present above and below the water table. Based on a review of site groundwater elevation maps, a recent high water table elevation of 4.5 feet MSL, measured in October 2011, (Sovereign Consulting, 2013) was used as an estimate of a high water table elevation. Soil contamination above this elevation, as shown on Figure 3, is indicative of on-site sources to groundwater and soil at the site.

Free Product

Extensive free product, or light non-aqueous phase liquids (LNAPL), was present in the subsurface at the Paulsboro facility prior to the end of 1989, and residual product remains today

2 While the volumes for 1989, and post-1989 are identical at the precision used here, this is a coincidence, as the

areal extents of contamination differ.

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as a continuing source of groundwater contamination. Free product was documented in separate areas of the site before Exxon’s sale of the facility (Figure 3). The main areas of free product include the loading rack area, the western plume, and the piping alley. Reported thicknesses ranged from a film to about 8 feet (Exxon, 1985), with greatest thicknesses at well R-1 in the loading rack area. Though the areal extent of free product at the end of 1989 is shown on Figure 3, the volume of free product remaining in the subsurface at that time is difficult to estimate.

Free product in the loading rack area has primarily been attributed to the 1985 heating oil release though evidence of additional releases in the area have been documented, as discussed earlier. Recovery of free product in the loading rack area was initiated in October 1985 by Exxon’s contractor, Product Recovery, Inc. (Exxon, 1985). Through May 1986, approximately 84,000 gallons of product had been recovered (Product Recovery, Inc. 1986) and approximately 110,000 gallons of heating oil were recovered by 1987 (Exxon, 1987; Handex, 2001; NewFields, 2003). The recovery rate declined over time, but in 1988, Product Recovery, Inc. reported that the plume of free product in the Piping Rack area was not contained by groundwater extraction at well RW-2, and was likely migrating southward (Product Recovery, Inc. 1988); however, pumping for product recovery was discontinued in 1989 (Versar, 2005).

In the loading rack area, Exxon’s reports suggest that all but 6,500 gallons of free product had been removed before the sale of the property (ERM, 1988a). This estimate is a significant underestimate. The estimate of 6,500 gallons was based on a calculated ‘true’ product thickness in site monitoring wells determined using a methodology characterized by U.S. Environmental Protection Agency (U.S. EPA) to have limited success3 (Newell et al, 1995 and U.S. EPA, 1996). A more likely volume can be estimated using the measured volume of product recovered during operation of the recovery system. Experts have estimated that, at most, approximately 50 percent of petroleum released to the subsurface can be recovered. This means that 50 percent of amount released is retained in the subsurface (Becket and Lundegard, 1997). In fact, the NJDEP’s LNAPL Initial Recovery and Interim Remedial Measures Technical Guidance document (NJDEP LNAPL Technical Guidance, NJDEP, 2012), states:

3It appears that ERM used the results of bail down recovery tests to determine the ‘true’ thickness. EPA

relevant guidance document (Newell et al, 1995) states,

Methods used to estimate mobile LNAPL thickness in the formation have included studies referred to as bail-down, recovery, or recharge tests (e.g., Hughes et al., 1988; Gruszczenski, 1987). These tests involve monitoring LNAPL recharge to a well following its removal by pumping or bailing. The mobile LNAPL thickness in the formation at each well is then estimated by various interpretations of depth-to-product, depth-to-water, and product thickness as a function of time. Several potential sources for error exist in the performance and interpretation of these tests. In general, these procedures have not been adequately proven in a variety of field situations (Testa and Paczkowski, 1989) and do not provide information concerning LNAPL trapped by capillary forces (Durnford et al., 1991). However, the performance of such tests may provide qualitative information concerning the potential for LNAPL recovery using conventional pumping technology (API, 1989).

In addition, the NJDEP LNAPL Technical Guidance Document (NJDEP, 2012) states:

The relative measure of apparent thickness of LNAPL in a well, while indicative of LNAPL presence, has been shown to be a poor indicator of the magnitude, mobility or recoverability of LNAPL in the vicinity of the well.

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Under the most favorable conditions, only a fraction of the total release will be recoverable. Recoverable volumes typically range from 20 to 50 percent of the total release.

Using the reported total product recovered in 1987, 110,000 gallons, and using the highest recoverable percentage from literature, 50% recoverability, a minimum of 110,000 gallons are estimated to remain in the subsurface in the loading rack area. With no active soil remediation, this residual contamination remains as a continuing source of contaminants to groundwater.

This estimate is a minimum for the northeastern part of the site. In 1988, Exxon’s consultant indicated that there was a significant amount of free product from a separate source than the known heating oil spill that was present in the area and was not being contained by the recovery system. At that time they recommended additional remediation (Product Recovery, 1988). This additional remediation was apparently not implemented and the free product recovery system reportedly only operated until 1989 (Versar, 2005). No estimates of total product recovered at the time of system shut-down were found in documents reviewed.

In addition to the accumulation of product in the loading rack area, The Hydrogeologic Investigation (ERM, 1988a) estimated that 150,000 gallons of product existed beneath the northwestern corner of the property known as the western plume. This estimate was again based on the calculated ‘true’ product thickness in site monitoring wells and is likely an underestimate of product in the area. Based on this information it is estimated that a minimum of 150,000 gallons of product remained in the western plume area at the time of the 1990 transfer of the property. Limited product recovery and passive product collection systems have been implemented in the western plume and piping alley free product areas but no cumulative volume of product recovered in these areas was found in the documents reviewed. Site documents indicate that Exxon considers all remaining free product to be immobile residual product. (GES, 2012).

Soil Gas Surveys Three soil gas surveys were conducted at the site prior to 1990. These surveys are consistent

with the areas of contamination determined by the free product and soil sample data that are shown on Figure 3.

A soil gas survey was conducted at the site in November 1986 (Target Environmental, 1987). Samples of soil gas were collected from 4 feet below ground surface (ft bgs) in 90 locations at the site, generally located along the western portion of the site and the in the adjacent park. A subset of approximately 12 of the samples were collected in the northern portion of the site in the area extending from the piping alley to the loading rack. The results of the survey indicated soil gas anomalies in the areas of the loading rack, western plume and piping alley

Two additional soil gas surveys were conducted prior to 1990. One, conducted in 1988 around tanks 178-181 was used as a basis for selecting locations for wells E-4 and E-5 (ERM, 1988a). Information on the depths of the vapor samples was not given in the report but the results indicated distinct areas of elevated BTEX concentrations in the vicinity of well W-7. The report described two distinct areas, however the data included in the report would indicate a third area existed as well. The soil gas survey conducted in 1989 for tanks 165-172 consisted of 28 sampling locations, each with samples collected at 4 ft bgs and 8 ft bgs (ERM, 1990a). Results of this survey

12

were reportedly used to help determine the area where Exxon planned to implement bioremediation of soil. This remediation, which was never implemented, is discussed below.

Tank Bottom Disposal Pits

As discussed earlier, historic site practices included disposal of waste from tank cleaning activities into pits located near the tanks “These materials commonly are comprised of solids derived from the storage tank itself (i.e., rust), grit derived from product transport, petroleum product precipitates and condensate.” Exxon originally identified 14 suspected tank bottom disposal pit locations although one of these original locations was later removed from consideration. In 1992, however, another pit was discovered near Tank 180. The 14 confirmed pit locations are shown on Figure 3. Eight of the identified tank bottom disposal pits were excavated. The excavated soil from two of these pits remained on site with the intention of future remediation by bioremediation (Handex, 2001; ERM, 1992). The bioremediation program was not implemented.

Soil contamination and spread of contaminants from these disposal pits would have occurred from the 1960s until they were excavated in the 1990s.

Bioremediation Area

An area requiring soil remediation was reportedly determined using the results of the limited soil gas and soil boring programs described above (Figure 3, ERM 1993b). In 1993, additional soil requiring remediation from two of the excavated tank bottom disposal pits was placed in this area. The remediation was never implemented and the contaminated soils in the bioremediation area remain on site, presumably in the same location, though now beneath the liner installed by GATX in the mid-1990s.

Extent of Current Soil Contamination Attributable to Exxon

With the exception of the eight excavated tank bottom disposal pits and various excavations performed to remediate small spills since 1990, there has apparently been no significant effort to remediate soils at the site. The extent of soil contamination attributable to Exxon remains almost unchanged since 1990.

Soil Contamination Attributable to Exxon Acts as a Continuing Source to Groundwater

The extent of soil contamination attributable to Exxon includes significant areas of residual product. Product that remains in the subsurface, even product remaining after the recoverable product is removed, can act as a long-term source of contaminants to groundwater. Compounds that will continue to be a source of groundwater contamination include aromatic compounds such as BTEX and naphthalene, and lead.

While Exxon’s consultants report that the residual product is not contributing volatile fractions to the groundwater (GES, 2012), evidence that the pre-1990 free product continues to act as a source of contaminants to groundwater can be seen in the results of site monitoring.

Using Exxon’s representation of the groundwater flow for the site (from 1984 to 2009), contaminants released from the northern edge of the property would have moved away from the river, south across the site toward Valero extraction wells RW-5(A) and RW-6. The majority of this area is then upgradient or cross-gradient to significant post-1990 releases. Despite this, BTEX concentrations above Class IIA GWQC and detections of free product persist in the wells

13

in this area. Groundwater samples collected since 2005 indicate all of the wells sampled in the northern portion of the site have had detections of BTEX, naphthalene and lead greater than Class IIA GWQC. The persistence of BTEX in this area indicates that pre-1990 releases continue to act as an ongoing source of contaminants to groundwater.

Site Restoration In light of the extensive historic detections of free-phase petroleum, and the high

concentrations of BTEX, MTBE, lead and other compounds dissolved in groundwater, significant efforts will be required to achieve primary restoration. The restoration efforts include actions that can be implemented while the terminal remains in operation.

The restoration approach developed to address the contamination attributable to pre-1990 site operations is described below and shown on Figure 4. While the facility remains in operation, a combination of on-site groundwater extraction to maintain hydraulic control of site groundwater and soil vapor extraction/bioventing in the pre-1990 free product areas can be implemented. Additional restoration efforts will be required to achieve primary restoration after the facility operations have ceased, including soil excavation and additional groundwater extraction. For purposes of the cost estimate, we assumed the facility would operate for 30 more years. Estimated costs of the restoration plan described below are shown in Table 2.

Soil Restoration

Significant residual free product from pre-1990 releases is present at and above the water table at the site. To minimize the ongoing source of contamination to groundwater from these free product areas, soil vapor extraction/bioventing will be implemented in the areas shown on Figure 4. The pre-1990 free product area located in the southeastern portion of the site will be actively treated with the soil vapor extraction system already approved for the area in the vicinity of Tanks 176-181 (Versar, 2005 and 2011). Therefore, no additional soil treatment is proposed for this portion of the site.

A total of 14 vapor extraction well pairs will be installed at the site, based on a radius of influence of 125 feet (ft). Each nested well pair will consist of a deep and a shallow well with deep wells extending to approximately 30 ft bgs and shallow wells to 15 ft bgs. Extraction system off-gas will be treated in an on-site treatment system initially using a catalytic oxidizer system and later with a vapor phase granular activated carbon system as contaminant concentrations decrease. It is assumed the vapor extraction and treatment system will operate continuously for three years followed by two years of pulsed operations. The wells will then be operated intermittently as a bioventing system for approximately 5 years.

Groundwater Control and Restoration

As discussed earlier, the groundwater extraction system at the neighboring Valero site has been unable to maintain gradients sufficient for containment of the contaminated portions of the Terminal site. Additional, on-site extraction wells are required to provide containment of site contaminants attributable to Exxon and prevent flow of contaminated groundwater to the river. The groundwater extraction and treatment system will also remove mobile free product and dissolved hydrocarbons in groundwater.

14

The on-site groundwater extraction and treatment system will consist of seven extraction wells. The footprint of the extent of pre-1990 free product was used to determine the area in which the extraction wells will be installed. Three extraction wells will be located in the western plume portion of the property, two in the loading rack area, and two in the vicinity of wells E-8 and W-4 (Figure 4). The wells will be approximately 55 to 60 feet deep, with 8-inch diameter casings and 25 to 30 feet of screen length extending approximately 5 feet above historic water levels in the area. Because these wells are in areas impacted by free phase hydrocarbons, the wells will be designed to remove separate phase hydrocarbons with dual phase pumping. The groundwater extraction rate at each well is estimated to be 50 gpm. The extraction rate was selected to contain contamination on site while limiting withdrawal of significant amounts of water from the Delaware River and minimizing withdrawal from areas with groundwater with elevated concentrations of MTBE. The number of wells needed to address dissolved contamination is in part a function of the background groundwater gradient. As there is considerable uncertainty in the future groundwater gradient – these estimates of the number of wells were established assuming that groundwater gradients resembled those prior to the onset of Valero’s pumping.

The extracted groundwater will be treated in an on-site groundwater treatment system. It is expected that the treatment system will consist of an oil/water separator, filters, an air stripper, and vapor and liquid phase granular activated carbon (GAC) treatment. Treated groundwater will be discharged to the river or storm drain under an NPDES permit.

The groundwater extraction and treatment system will operate on site until such time as the facility is no longer in operation and source areas can be removed or restored. It is expected; however, that a reduction in the required extraction rate can be implemented over the duration of its operation. Following the same methodology for “batch flush” calculations described in Cohen and Rafferty, 2009, we estimate that if the contaminant source were removed today, an estimate of 20 pore volumes of groundwater would require extraction by ‘pump-and-treat’ methods to address levels of contaminants in groundwater attributable to Exxon4.

At a pumping rate of 350 gpm, to achieve 20 pore volumes would require about 20 years of groundwater extraction system operation. For purposes of the cost estimate, it is assumed that after 20 years of groundwater extraction operations and the implementation of soil restoration actions as previously described, a portion of the groundwater extraction system will no longer be necessary and only extraction to control groundwater in the more persistent areas of residual free product will continue. This source area control will be achieved by 3 wells operating at a total flow rate of 150 gpm, which will continue until cessation of facility operations and removal of source areas.

Site Restoration after Cessation of Site Operations

When site operations cease and tanks and piping are removed, a comprehensive investigation will be required to determine the extent of hydrocarbons above and below the water table that still require remedial action to achieve site restoration and to identify areas where groundwater is above restoration criteria. For groundwater restoration, we have assumed that the pre-discharge levels as described in the 2009 expert report (Cohen and Rafferty 2009, Table 3)

4 Naphthalene was used for the estimate based on its high retardation factor since other contaminants of concern

would be removed from the aquifer in a shorter time-frame. This estimate assumed no degradation and is applicable primarily to restoration of areas where there is no ongoing source.

15

will be achieved and for soil restoration criteria, we have assumed that soil with concentrations of chemicals of concern in excess of the default New Jersey Impact to Groundwater Soil Cleanup Criteria (IGWSCC, Table 3) will require restoration actions.

The soil investigation will define the areas that require excavation as well as areas of persistently elevated groundwater concentrations. The investigation will consist of membrane interface probe (MIP) or other probe testing methodology to characterize contaminants continuously to 60 foot depths throughout the area determined by the extent of historical groundwater contamination. The probe investigation will be conducted initially using 100-foot spacing. In areas around probe or monitoring well locations with detections of contaminants, additional investigations using borings for collection of soil and groundwater samples will be implemented to further define the areas of soil and groundwater impacts.

Following the investigation, soil with concentrations in excess of the New Jersey IGWSCC will require excavation. It is expected that not all the soil throughout the entire depth of the excavations will exceed soil restoration criteria. For purposes of the cost estimate it was assumed that after the remedial actions have been implemented over 30 years, only 5 percent of the 28-acre area of contamination (determined by the total historical extent of groundwater contamination attributable to pre-1990 sources) would require excavation. In the excavation areas, a significant amount of uncontaminated overburden soil will likely require removal. For example, to access the soil at depth where free product has been found at the water table. Soil exceeding restoration criteria and non-contaminated soil would be managed separately i.e., through off-site disposal for soil above restoration criteria and on-site re-use for uncontaminated soil.

Limited groundwater extraction and treatment will be required for dewatering during excavation activities as well as for an estimated two years after source removal in areas where groundwater with contaminant concentrations above the pre-discharge level remain.

Groundwater monitoring costs for the restoration projects are based on installing 15 new wells during initial implementation of soil and groundwater restoration activities, with semi-annual sampling of 25 wells for 34 years: 30 years during groundwater control, and four years of post-excavation monitoring (including two years contiguous with the post-excavation groundwater extraction and an additional two years to confirm that groundwater concentrations do not rebound above pre-discharge concentrations).

Restoration costs are presented in Attachment C and summarized in Table 2. The cost for installing and operating the soil restoration using SVE is estimated to have a net present value (NPV) of $3.1 million. The NPV for installing and 30 years of operation of the groundwater extraction and treatment system is $5.6 million. The NPV of conducting the investigation and soil excavation program after operations cease and the tank facilities are removed, including the associatiated groundwater extraction and treatment costs, is $2.5 million. The NPV for installing the additional monitoring wells and conducting monitoring for 34 years is $1.2 million. The total NPV of site restoration is $12.4 million.

16

References

Anchor for GATX Terminal Corp. 1995. Underground Storage Tank System Closure Site Investigation Closure Report. Prepared for GATX Terminal Corporation. June. 24.

Barton, C., and J. Kozinski. 1991. Hydrogeology of the Region of Greenwich Township, Gloucester County, New Jersey. Water Investigations Report 90-4198. U.S. Geological Survey, New Jersey Department of Environmental Protection.B&B Diversified Enterprises, 1998, Semi-Annual ACO Report, July 1998 through December 1998, Mobil Oil Paulsboro Refinery.

Becket, G. D. and Lundegard, Paul. 1997. Practically Impractical – The Limits of LNAPL Recovery and Relationship to Risk. Proceedings of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water Prevention, Detection, and Remediation Conference - November 12-14, 1997 - Houston, TX. 16. November 12-14.

Cohen, Harvey A. and Michael T. Rafferty. 2009. Expert Report, Paulsboro Terminal Site, Paulsboro, New Jersey, November 20.

Environmental Resources Management Inc., 1988. Hydrogeologic Investigation, Paulsboro Terminal, Paulsboro, New Jersey. November.

Environmental Resources Management Inc., 1990a. Addendum, Hydrogeologic Investigation, Exxon Paulsboro Terminal, ECRA Case #89947, Vol. I, Section 1 through Section 4. January.

Environmental Resources Management Inc., 1990b. Proposed Clean Up Plan, Exxon Paulsboro Terminal, ECRA Case #89947. January.

Environmental Resources Management Inc., 1991, Revised Hydraulic Monitoring Program, Former Exxon Company U.S.A. Terminal, Paulsboro, New Jersey. April 15.

Environmental Resources Management Inc., 1992. Letter from James F. Wait to John Kosher, NJDEP. Regarding: Confirmation to Reuse Stockpiled Soils, Former Paulsboro, New Jersey Terminal, NJPDES Permit NJ0004197. December 30.

Exxon Company, USA. 1985. Subsurface Oil Recovery Status Report, Paulsboro Terminal. December 27.

Exxon Company, USA. 1987. Subsurface Oil Recovery Status Report. April.

Exxon Company, USA. 1990a. Letter from Frank J. Marchhart to Michael Mandracchia, NJDEP. Enclosing: Site Evaluation Submission for Paulsboro New Jersey Site, ECRA Case Number 89947. January 12.

Exxon Company, USA. 1990b. Letter from F. J. Marchhart to Mike Infanger, NJDEP. Regarding: Exxon Paulsboro Terminal, NJDEP Case #89947. June 28.

Flaster Greenburg, J.S.K., Esq., 2006, Letter Re: In the Matter of ST Services and the Paulsboro Terminal, ISRA Case #E89947-M01 (includes attachments 9/04 Report - Site Invest/Rem. Rpt 7/03 MTBE Spill Area in Pipe Rack and 6/05 Site Inv. Rpt - Soil Sampling Investigation of Loading Rack). February 8..

17

Groundwater and Environmental Services Inc. 2008. Remedial Investigation Progress Report For Period November 1, 2007 through April 30, 2008. Prepared for ExxonMobil Environmental Services Company. April 30. 157.

Groundwater and Environmental Services, Inc. 2009. Remedial Investigation Progress Report for Period May 1 through September 30, 2009, Former ExxonMobil Terminal #3045, Paulsboro, NJ, ISRA Case #E89947. October 30.

Groundwater and Environmental Services, Inc., 2012. Free Product Interim Remedial Measures Report, Former ExxonMobil Paulsboro Terminal, Third Street and Billingsport Road, Paulsboro, Gloucester County, New Jersey. March 1.

Handex. 1995. Water-Level Elevation Map, November 8, 1994. January 25.

Handex. 1999. Assessment of Hydrocarbon Occurrences and Transport Rates, Former Exxon Terminal, Paulsboro, New Jersey. July.

Handex. 2000. Remedial Action Report for Period 10/1/99 through 12/30/99. Prepared for Exxon Company U.S.A. January 12. 108.

Handex, Inc. 2001. Remedial Action Workplan for the Former Exxon Mobil Terminal #3045, Paulsboro, New Jersey, ISRA Case #E89947. January 2.

Langan Engineering, Inc. 2000, Semi-Annual NJDEP ACO Report, Volume 1 of II, July 31., Mobil Oil Paulsboro Refinery.

Langan Engineering, Inc. 2001, Semi-Annual NJDEP ACO Report, Volume 1 of II, January 30., Mobil Oil Paulsboro Refinery.










18


Langan Engineering, Inc. 2006, Semi-Annual NJDEP ACO Report, July 27., Mobil Oil Paulsboro Refinery.

Langan Engineering, Inc. 2007, Semi-Annual NJDEP ACO Report, January 30., Mobil Oil Paulsboro Refinery.







Langan Engineering, Inc. 2011, LNAPL Free Product Interim Remedial Measures Report, February 24., Mobil Oil Paulsboro Refinery.

Langan Engineering, Inc. 2012, LNAPL Free Product Interim Remedial Measures Report, February 1., Mobil Oil Paulsboro Refinery.

Mobil Oil Corporation. 1993. NJPDES Semi-Annual Report and Combined ACO, Mobil Oil Paulsboro Refinery. December 31. 49.

Newell, C., S. D. Acree, R. R. Ross, and S. G. Huling, 1995, Light Nonaqueous Phase Liquids, EPA/540/S-95/500.

NewFields Princeton, Inc. 2002. ExxonMobil Response To NJDEP RAW Comment Letter Dated: November 16, 2001, NJDEP Correspondence Dated: April 02, 2002, Former ExxonMobil Terminal #3045, Paulsboro, New Jersey, ISRA Case #E89947. August 8.

NewFields Princeton, Inc. 2003. Baseline Ecological Evaluation, Former ExxonMobil Terminal #3045, Paulsboro, New Jersey, ISRA Case #E89947. October 31.

NewFields - Princeton LLC. 2004. Remedial Action Report For Period May 1, 2004 through October 30, 2004, Former ExxonMobil Terminal #3045. Prepared for ExxonMobil. Paulsboro, New Jersey October 30. 143.

New Jersey Administrative Code. 2011. N.J.A.C. 7:26E. Technical Requirements for Site Remediation. October 3

NJDEP. 2007a. Communication Center Notification Report. June. 236.

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NJDEP. 2007b. Land Use Standards, Water Monitoring and Standards, Notice of Administrative Change, Ground Water Quality Standards, Modification of the Specific Criteria in NJAC. 7:9C Appendix Table 1 for Barium and Toluene. August 20.

NJDEP. 2012. Light Non-aqueous Phase Liquid (LNAPL), Initial Recovery and Interim Remedial Measures Technical Guidance, New Jersey Department of Environmental Protection, Site Remediation Program. June 29.

Pennoni Associates, Inc. 1993. Letter from Wesley P. Fitchett and James G. Gallagher to Randolph Ciurlino, NJDEP. Regarding: Remedial Action Report, GATX Terminal – Paulsboro, New Jersey. August 16.

Product Recovery, Inc. 1986. Subsurface Oil Recovery Status Report, February 1 –May 31.

Product Recovery, Inc. 1988. Letter from Verne Farmer, Jr. to Mr. Cieri, Exxon Company, Inc. Regarding: Product Recovery Project, Paulsboro Terminal. December 13.

Sloto, R. A., 2003, Historical Ground-Water-Flow Patterns and Trends in Iron Concentrations in the Potomac Raritan-Magothy Aquifer System in Parts of Philadelphia, Pennsylvania, and Camden and Gloucester Counties, New Jersey, in U.S. Department of the Interior, ed., Water-Resources Investigations Report, p. 43.

Sovereign Consulting, Inc. 2010. Remedial Investigation Progress Report for the period 1 April 2010 through 30 September 2010, Former ExxonMobil Terminal #3045, 3rd Street & Billingsport Road, Paulsboro, Gloucester County, New Jersey, ISRA Case No. 89947. October 29.

Sovereign Consulting, Inc. 2013. Remedial Investigation Progress Report for the period 1 August 2011 through 31 December 2011, Former ExxonMobil Terminal #3045, ISRA Case No. 89947. January.

Target Environmental Services. 1987. Soil Gas Survey, Exxon Terminal #3045. Paulsboro, NJ. May. 27.

U.S. EPA. 1996. How to Effectively Recover Free Product At Leaking Underground Storage Tank Sites, A Guide for State Regulators. September.

Versar, Inc. 2002. Site Investigation Report, Tanks 176-182, ST Services Bulk Storage Terminal, 3rd Street and Billingsport Road, Paulsboro, New Jersey. December 2.

Versar Inc., 2004a, Soil Sampling and Analysis Work Plan, Loading Rack Investigation. February 27.

Versar Inc., 2004b, Site Investigation/Remediation Report, July 03 MTBE Spill Area in Pipe Rack, ST Services Terminal. September 28.

Versar, Inc. 2005. Soil Vapor Extraction Pilot Test, Historical MTBE Tank Area (Tanks 176-181) Paulsboro Petroleum Storage Area, Paulsboro, NJ. September 8.

Versar, Inc. 2007. Remedial Action Work Plan, Replacements for Groundwater Monitoring Wells Displaced by New Tank Construction at the Pacific Atlantic Terminal, 3rd Street and Billingsport Road, Paulsboro, New Jersey. March 9.

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Versar, Inc. 2011. Groundwater Compliance Monitoring and Soil Vapor Extraction System Plan for the Eastern Tank Field, Paulsboro Petroleum Storage Terminal, Paulsboro, New Jersey. November 23.

Versar, Inc. and Trillium, Inc. 2005. Site Investigation Report, Soil Sampling Investigation of the Truck Loading Rack, ST Services Petroleum Storage Terminal. June 27.

FIGURES

Delaware River

PaulsboroTerminal

Sun OilFacility

ValeroFacility

Fort Billings Park

Billing

sport

Rd

5th St

4th St

3rd St

Linco

ln Av

e

Clonmell Rd

Ferry Rd

King St

Sheri

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ve

Riverfront Ave

Benners Ave

Queen St

Blacks Terr

N Delaware St

³

0 250 500Feet

Figure 1 The Former Exxon Paulsboro Terminal and Vicinity

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0 250 500Feet

Figure 2 Areas of Groundwater Contamination at the former Exxon Site in Paulsboro, NJ

Post-1989 Plume1989 Plume1988 Plume

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175 176177

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Figure 3 Evidence of Contamination (Excluding Groundwater Samples) Prior to 1990 at the former Exxon Site in Paulsboro, NJ

") Free Product Detected Prior to 1990 Pre-1990 Soil Sample with TPH Detection

Above 4.5 feet MSL!( Below 4.5 feet MSL

Bioremediation Area

Tank Bottom Disposal Pit LocationsTotal Volatiles > 20ppb 1986 Soil Gas SurveyTotal Volatiles > 20ppb 1989 Soil Gas SurveyTotal BTEX > 20ppb 1988 Soil Gas Survey

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Figure 4 Conceptual Plan for Restoration of Soil and Groundwater at the former Exxon Site in Paulsboro, NJ

# Proposed Groundwater Extraction Well") Free Product Detected Prior to 1990

Soil Vapor Extraction / BioventingImplementation Area

0 250 500Feet

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TABLES

TABLE 1 Areas and Volumes of Contaminated Groundwater

YearTotal Area

(acres)

VolumeContaminatedGroundwater

(millions of cubic feet)

VolumeContaminatedGroundwater

(millions of gallons)

1984 17.3 15.8 1181985 17.3 15.8 1181986 17.3 15.8 1181987 17.3 15.8 1181988 17.3 15.8 1181989 26.6 24.4 1821990 26.6 24.4 1821991 26.6 24.4 1821992 26.6 24.4 1821993 26.6 24.4 1821994 26.6 24.4 1821995 26.6 24.4 1821996 26.6 24.4 1821997 26.6 24.4 1821998 26.6 24.4 1821999 26.6 24.4 1822000 26.6 24.4 1822001 26.6 24.4 1822002 26.6 24.4 1822003 26.6 24.4 1822004 26.6 24.4 1822005 26.6 24.4 1822006 26.6 24.4 1822007 26.6 24.4 1822008 26.6 24.4 1822009 26.6 24.4 1822010 26.6 24.4 1822011 26.6 24.4 1822012 26.6 24.4 1822013 26.6 24.4 182

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TABLE 2Summary of Estimated Restoration Costs

ItemYear(s)

ImplementedCost at Year Implemented

Present Value Total Present Value

Soil RestorationSVE Capital 0 $1,370,000 $1,370,000SVE (Continuous) Annual O&M 1 - 3 $451,000 $1,276,000SVE (Pulsed) Annual O&M 4 - 5 $128,000 $224,000Bioventing Annual O&M 6 - 10 $54,000 $213,000

Total PV Soil Restoration $3,083,000

Groundwater Control and RestorationGroundwater Treatment Capital 0 $1,595,000 $1,595,000Groundwater Treatment (Full) Annual O&M 1 - 20 $233,000 $3,466,000Groundwater Treatment (Limited) Annual O&M 21 - 30 $116,000 $548,000

Total PV Groundwater Control and Restoration $5,609,000

Site Restoration after Cessation of OperationsSoil Investigation 30 $956,000 $394,000Soil Excavation and Disposal 31 $4,361,000 $1,744,000Post-Excavation Groundwater Treatment Capital 31 $671,000 $268,000Post-Excavation Groundwater Treatment Annual O&M 31 - 32 $63,000 $48,000

Total PV Site Restoration after Cessation of Operations $2,454,000

Groundwater MonitoringGroundwater Monitoring Capital 0 $184,000 $184,000Groundwater Monitoring Annual O&M 1 - 34 $50,000 $1,057,000

Total PV Groundwater Restoration Cost $1,241,000

Total Present Value for Restoration (Capital Costs + O&M) $12,387,000

Note:

1) Discount rate asssumed at 3%

��

TABLE 3 Restoration Criteria

Notes:

1. Pre-discharge levels are considered to be reporting limits for groundwater sampling of well W-9 on February 24, 2009.

2. PQL- Practical Quantitation Limits 3. Class II-A GWQC- New Jersey Department Environmental Protection Class IIA

Ground Water Quality Criteria, July 27, 2011 4. IGWSCC-default Impact to Groundwater Soil Cleanup Criteria, revised

December 2008. 5. ug/l- micrograms per liter 6. mg/kg- milligrams per kilogram 7. MTBE- methyl tertiary butyl ether 8. TBA- tertiary butyl alcohol

Analyte

Groundwater Soil

Pre-Discharge Levels1

PQL2

Class II-A GWQC3

IGWSCC4 Benzene 1 ug/l5 1 ug/l 0.2 ug/l 0.005 mg/kg6 Toluene 1 ug/l 1 ug/l 600 ug/l 4 mg/kg Xylene 1 ug/l 2 ug/l 1000 ug/l 12 mg/kg Ethylbenzene 1 ug/l 2 ug/l 700 ug/l 8 mg/kg Naphthalene 5 ug/l 2 ug/l 300 ug/l 16 mg/kg MTBE7 1 ug/l 1 ug/l 70 ug/l 0.2 mg/kg Lead (total) 3 ug/l 5 ug/l 5 ug/l 59 mg/kg TBA8 25 ug/l 2 ug/l 100 ug/l 0.2 mg/kg

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Attachment A Curriculum Vitae for Dr. Harvey A. Cohen

HARVEY A. COHEN Hydrogeologist

AREAS OF EXPERTISE

Contaminant Fate and Transport Water Resources Evaluations Brownfields Investigation/Remediation

Risk-Based Corrective Action Environmental Database Management Litigation Support and Expert Testimony

SUMMARY OF QUALIFICATIONS

Dr. Cohen provides quantitative evaluation of water resources and environmental contamination, including site investigation and remediation, brownfields redevelopment, risk-based corrective action, and groundwater modeling. Dr. Cohen has led water resources and geological investigations throughout the United States and in Turkey. For the United Nations Development Programme (UNDP), he completed the first-ever comprehensive environmental assessment of Cyprus’ largest copper mining and mineral processing complex. Dr. Cohen has also served as an expert witness in cases related to groundwater contamination with MTBE and chlorinated solvents. In addition to his research and case-study publications, Dr. Cohen is co-editor of the American Geological Institute’s Geoscience Handbook (AGI Datasheets, 4

thEdition).

REPRESENTATIVE EXPERIENCE

S.S. Papadopulos & Associates, Inc., Bethesda, Maryland

District of Columbia Water and Sewer Authority (DCWASA) – As part of the Blue Plains Tunnel Combined Sewer Overflow (CSO) project, worked with Dr. Papadopulos in developing a dewatering plan for Deep Shaft construction; developed specifications for the dewatering project and oversaw construction of wells and aquifer testing to develop final design (ongoing, 2013).

Pavilion, Wyoming – For the Independent Petroleum Association of America, was the lead author in a comprehensive review of USEPA’s draft report on groundwater contamination in the town of Pavilion Wyoming. Evaluated the geologic and geochemical evidence for a link between hydraulic fracturing activities and groundwater contamination. Determined that EPA key evidence for such a link was unreliable due to the lack of baseline and background data, severe problems with well construction and the natural conditions of the Wind River Basin, wherein the hydrocarbon-bearing zones occur within the same geologic unit as the aquifer of concern.

Maryland Department of Environment (MDE) – Developing Source Water Protection Plans for eight (8) communities, ranging in population from fewer than 1,000 to almost 200,000 individuals, in Frederick, Carroll, Harford, Cecil and Anne Arundel Counties; tasks included updating of Source Water Assessments, analyzing local hydrogeology, and providing recommendations for land use controls, public outreach, zoning modifications, local ordinances and funding sources to assist each community (ongoing, 2013).

YEARS OF EXPERIENCE:15+

EDUCATION

PhDGeological Sciences

Princeton University, 1992

BA (cum laude) Geology

Cornell University, 1985

REGISTRATIONS

Professional Geologist

Pennsylvania: PG003936 Nebraska: G-0322 Registered Geologist

Missouri: 2004013522

PROFESSIONAL HISTORY

S.S. Papadopulos & Associates, Inc. 1996 to present Princeton University – CLAAMP

Laboratory, 1996 Royal Holloway University of London 1993 to 1996 Mobil Research & Development

Corporation

1990 ICF Technology Inc.

1985 to1987

HARVEY A. COHEN Hydrogeologist Page 2

Gasoline Contamination Litigation in Maryland

o Jeff Alban et al. vs. ExxonMobil Corporation et al. Served as an expert witness, providing opinions on hydrogeologic aspects of a 26,000-gallon gasoline release in Jacksonville, MD. Contributed to the mapping and interpretation of groundwater contamination with benzene, MTBE and other gasoline-related contaminants. Testified to these opinions in a jury trial.

o Jerilyn Allen et al. vs. ExxonMobil Corporation et al. Provided expert opinions on hydrogeology of the Jacksonville, MD area, and the extent and migration of contamination associated with a 26,000-gallon gasoline release in 2006.

o Santiago Ayala et al., vs. Citgo Petroleum Corporation et al. Provided expert opinions on the extent and physical properties of gasoline contamination associated with the Green Valley Citgo station in Monrovia, MD. Addressed mechanisms of impact to groundwater, properties of MTBE, and hydrogeology of the area.

New Jersey Department of Environmental Protection (NJDEP) vs. Atlantic Richfield Company et al. – For a Natural Resources Damages Claim related to MTBE contamination in the state of New Jersey, provided technical support to the Plaintiffs in developing the scope of their case; collected, reviewed, produced and queried environmental stored in Plaintiff’s databases; managed data in SQL Server, Access and legacy database formats.

Brownfields Redevelopment for the Kansas City Port Authority, Missouri (1) Developed a detailed strategic plan for management of portions of the former Richards-Gebaur Air Force Base under Missouri’s Voluntary Cleanup Program (VCP), MDNR's Federal Facilities Section, and the BRAC and FUDS programs. In conjunction with the USAF, USACE and site developers, worked on achieving closure and/or modified land use management to allow site redevelopment while preserving environmental protection.

New Jersey Department of Environmental Protection (NJDEP) vs. ExxonMobil Corporation et

al. For the NJDEP evaluated the extent of groundwater contamination associated with historical operations by ExxonMobil, Kinder Morgan and GATX at the Paulsboro Terminal. Expert reports and testimony focused on MTBE migration from on-site sources and the extent (area, depth, and volume) of Natural Resource Damages.

Washington DC Depts. Of Health and Environment Conducted a Vapor Intrusion and Corrective Action Study of the Riggs Park neighborhood that is situated over a mixed groundwater plume of gasoline-related contaminants and PCE. Sampled ambient air, indoor air, sub-slab and soil vapor from 120 homes. Evaluated the resulting data set for evidence of vapor intrusion from the subsurface. Final deliverables included individualized reports to each homeowner, identification of homes recommended for remedial action, and proposed remedial actions to address vapor intrusion.

U.S. Environmental Protection Agency (USEPA), Region V Evaluated the effectiveness of remediation activities at state-led Superfund (CERCLA) sites in Michigan, Illinois and Ohio. At former industrial sites and landfills that had soil and groundwater contamination (typically VOCs and/or chromium), mapped contaminants; evaluated groundwater capture, SVE system operation, feasibility of MNA as a remedial measure; and provided recommendations for optimizing remedial programs. Provided continuing technical support to EPA in oversight and negotiations with PRPs.


FAR-MAR-CO Subsite of the Hastings, Nebraska Superfund Site Provided ongoing technical

oversight of the Interim Remedy for a plume of carbon tetrachloride and ethylene dibromide in groundwater. Shepherded development and implementation of the Final Remedy from Feasibility Study through Record of Decision (ROD). Worked with USPEA Region 7 in submission and approval of all work plans for direct-push groundwater investigation, monitoring well installations, ongoing pump-and-treat, and source-area remediation by enhanced biodegradation using emulsified vegetable oil as a substrate. Provided field oversight for all activities in the ROD Statement of Work.

Deer Creek Watershed Study, Susquehanna River Basin Commission (SRBC) Developed and executed a water availability study of the Deer Creek Watershed of Maryland and Pennsylvania. Compiled regional water-use and aquifer information, completed extensive stream-gaging in Deer Creek and its tributaries, oversaw development and utilization of a MODFLOW model of groundwater and surface-water interaction. Presented SRBC with a comprehensive analysis and projections of water availability, population growth until 2025, and allocatable resources using MDE permitting assumptions.

Alexandria Tech Center, Alexandria, VA Evaluated the causes of the flooding of Cameron Run and associated property damages from a major storm event in 2006. Analyzed past and current flood zone documentation, completed flood frequency calculations, and modified an existing HEC-RAS model to simulate impacts of recent sediment aggradation on predicted flood levels. The results of this investigation were cited by the US Army Corps of Engineers in their evaluations of the same flood event.

Maryland Department of Environment (MDE) Managed the Source Water Assessment (SWA) for more than 400 small public water systems in Baltimore and Cecil Counties, Maryland. More than 500 groundwater sources (wells) and hundreds of potential contaminant sources were identified, assigned GPS coordinates, and incorporated into county-wide GIS records. Water-quality data and groundwater conditions were evaluated for each system, based upon its hydrogeologic setting. For the smaller systems, regional susceptibility analyses were completed. For larger systems, individual susceptibility analyses were completed using MODFLOW models volumetric constraints and time-of-travel criteria.

Lefka-Xeros Mining Area, Northern Cyprus For the United Nations Development Programme (UNDP), completed a comprehensive environmental assessment of Cyprus’ largest copper mining and mineral processing complex. Provided strategic guidance to the UN and local authorities regarding short-term risks and long-term remedial options. Prepared detailed specifications for investigations of groundwater, soil, surface water, sea water, mine tailings, stability of tailings ponds, and preservation of historical documents from the site.

Brownfields Redevelopment for the Kansas City Port Authority, Missouri (2) Under Missouri’s Voluntary Cleanup Program (VCP), investigated soil and groundwater contamination associated with former riverfront Manufactured Gas Plant (MGP) and pitch distillery. Utilized techniques including CPT and LIF ROST tool to define extent of contamination and to quantify volume of material for costing of excavation, disposal, and other remedial alternatives. Provided oversight, technical guidance, and interaction with MDNR’s VCP during site remediation to facilitate site redevelopment.

C-Aquifer, Arizona and New Mexico To evaluate the environmental impacts of a proposed well field in the arid southwest, managed development of a 3-D, transient groundwater flow model (using MODFLOW). Historical pumping, surface-water flows/diversions, and spring discharges were used as calibration targets with PEST, to ensure that the future pumping scenarios would adequately reflect aquifer behavior. Developed the conceptual model of water resource use, aquifer behavior historical trends, and managed the conversion of geologic and hydrogeologic inputs into digital form.


Waste Disposal Sites, University of Missouri-Columbia Under Missouri’s voluntary Cleanup

Program (VCP), investigated two former waste disposal areas containing organic and mixed organic-radioactive laboratory wastes. Achieved closure under Missouri’s Risk-Based Corrective Action program.

Gasoline Release Site, University of Missouri-Columbia Managed the remediation of a subsurface gasoline release under Missouri’s Tank Program with soil vapor extraction and groundwater containment. Achieved closure under Missouri’s Risk-Based Corrective Action program.

Flooding Limestone Quarry, West Virginia At an operating quarry that was experiencing severe flooding, provided geologic expertise in siting of monitoring wells. Also interpreted geophysical data to define interactions between quarry, groundwater, adjacent river and karstic features. Monitored and evaluated site conditions during year-long remediation activities.

Mediation Support - Confidential Client As consultant to party in mediation, evaluated over 40 facilities for history, timing, and magnitude of releases of contaminants to groundwater. Managed database of well, water quality, and facility history data for integration with groundwater flow and contaminant transport numerical models. Negotiated with contesting parties and regulatory agencies to identify participants and quantify their share of contribution to groundwater contamination.

Superfund Site, Pennsylvania Designed and completed a natural attenuation evaluation of chlorinated solvents and acetone in karstic limestone bedrock. Contributed to the design and implementation of baseline groundwater sampling program prior to startup of pump-and-treat groundwater remediation system.

Princeton University-

40Ar/

39Ar Laboratory, Princeton, New Jersey

In collaboration with Exxon Production Research, studied the argon isotope systematics of detrital and diagenetic clays by using micro-encapsulation and laser step-heating techniques. Designed and constructed a new ultra-high vacuum (uhv) line for the laser-ablation and extraction of oxygen isotopes from groundwater and rock samples.

Royal Holloway University of London (Sun Postdoctoral Fellowship), England In affiliation with the Fault Dynamics Project (sponsored by ARCO, BP, Brasoil, Conoco, Mobil, and Sun), planned and conducted research into the origins, evolution, and three-dimensional structure of petroleum reservoirs.

PROFESSIONAL SOCIETIES

Association of Groundwater Scientists and Engineers (AGWSE/NGWA) American Geophysical Union (AGU) Geological Society of America (GSA)

AWARDS AND HONORS

Postdoctoral Fellowship, Royal Holloway University of London, 1992-1995 Fellow of the Geological Society of London, 1992-1995 Outstanding Student Research Proposal, Geological Society of America, Sedimentary Geology Division, 1989 Meeker Fellowship, Department of Geological and Geophysical Sciences, Princeton University, 1988-1990 Harry Hess First Year Prize, Department of Geological and Geophysical Sciences, Princeton University, 1987 Chester Buchanan Memorial Prize, Department of Geology, Cornell University, 1985


APPOINTMENTS

2008 present: External Advisory Committee, Department of Earth/Atmospheric Sciences, Cornell University

1999 2012: GeoRef Advisory Committee, American Geological Institute

PUBLICATIONS AND PRESENTATIONS

Cohen, H.A., T. Parratt, and C.B. Andrews, 2013. Comment on "Potential Contaminant Pathways from Hydraulically Fractured Shale to Aquifers", Groundwater. v. 51, pp. 317-319.

Cohen, H.A. and N. Love, 2011. Investigation of Vapor Intrusion from an Urban Gasoline Plume in Washington DC Reveals Anomalous Behavior of Tetrachloroethylene (PCE). Groundwater: Cities, Suburbs, and Growth Areas – Remedying the Past and Managing for the Future – National Groundwater Association Meeting, August 8-9, Los Angeles.

Cohen, H.A. and M. Karanovic, 2010. The Cameron Run Flood of June 25, 2006 – Hydrologic Response to Sediment Aggradation in a Flashy Urban Stream, northern Virginia. GSA Denver Annual Meeting, October 31 – November 3, 2010. Vol. 42, No. 5, p. 327. Denver: Geological Society of America. v. 18.

Cohen, H.A., J. Choi, J. Hau, and J. Pippin, 2010.Geological Control of Baseflow in the Deer Creek Watershed, Lower Susquehanna River Basin, Pennsylvania and Maryland. Northeastern Section (45th Annual) and Southeastern Section (59th Annual) Joint Meeting (13-16 March 2010), Geological Society of America Abstracts with Programs, v. 42, no. 1, p. 107.

Cohen, H.A. and M. Rafferty, 2010, The Former Richards-Gebaur Air Force Base, Kansas City – Strategies and Practice for Risk-Based Corrective Action (RBCA) and Closure of Contaminated Sites. Air Force Restoration and Technology Transfer Workshop, April 6-9, 2010, San Antonio, TX.

Cohen, H.A., Susquehanna River Basin Commission, 2008, Deer Creek Water Availability Study. Publication no. 256, p. 84.

Wilson, D.H., H. Cohen, M. Tonkin, and D. Dougherty, 2008, Superfund Remedies - Evaluating Vital Signs with U.S. EPA's Region 5 Groundwater Evaluation and Optimization System (GEOS). AFCEE Technology Transfer Conference, San Antonio, Texas, March 11-14, 2008.

Cohen, H.A., M. Tonkin, D. Wilson, and D. Dougherty, 2007, A Systematic Data-Driven Approach to Evaluating Hydraulic Capture at Superfund Sites in USEPA Region 5. GSA Denver Annual Meeting, October 28-31, 2007. v. 39, no. 6. Denver: Geological Society of America.

Cohen, H.A., 2007, Site Remediation - 2006 Annual Report. In Environment, Energy, and Resources Law: 2006 The Year in Review. M.E. Mansfield, editor. American Bar Association, pp. 101-102.

Cohen, H.A., and C. Neville, 2006. Chapter 8: “Fate, Transport, and Modeling of Perchlorate in Groundwater. ”in Perchlorate: A Scientific, Legal, and Economic Assessment.(1st ed.). Hagstrom, E.L., editor. Tucson, AZ: Lawyers & Judges Publishing Company, pp. 267-294.

Walker, J.D., and H. Cohen, 2006.The Geoscience Handbook: AGI Data Sheets (4th ed.). Alexandria, VA: American Geological Institute, p. 302.

Cohen, H.A. 2004. Groundwater Impacts from Five Millennia of Copper Mining -- The Lefka-Xeros Area of Cyprus. Presented at The Geological Society of America Annual Meeting & Exposition, Denver, Colorado, November 7-10, 2004. In Abstracts with Programs - Geological Society of America, v. 36, no. 5. Pp.567, 243-35, BTH 58.


Cohen, H.A., and S. Cousins, 2003.Source Water Assessment of Small Public Water Systems in

Baltimore County, MD - Maximizing GIS-Database Linkages for Effective Management. Maryland State-County Ground Water Symposium, September 25, Baltimore. In Proceedings of the Maryland State-County Ground Water Symposium, p. 6.

Cohen, H.A., S. Cousins, J. Pippin, and N. Vollentine, 2003. Source Water Assessment of Small Public Water Systems in Baltimore County, Maryland: Preliminary Results. Association of Ground Water Scientists and Engineers (AGWSE) Annual Meeting, “Ground Water in Coastal Zones: Availability, Sustainability, and Protection, ”Orlando, FL, December 9-12. In Proceedings of the Association of Ground Water Scientists and Engineers (AGWSE) Annual Meeting, Ground Water in Coastal Zones: Availability, Sustainability, and Protection, pp. 19-20.

Lolcama, J.L., H. Cohen, and M. Tonkin, 2002. Deep Karst Conduits, Flooding, and Sinkholes: Lessons for the Aggregates Industry. Engineering Geology, v. 65, no. 2-3, pp. 151-157.

Cohen, H.A., 2001. Degradation of Chlorinated Solvents in Karst: Constraints and Examples from an Abandoned Landfill Plume. Presented at the Geological Society of America Annual Meeting, Boston, November 2001.

Barka, A., H. Akyüz, H. Cohen, and F. Watchorn, 2000. Tectonic Evolution of the Niksar and Tasova-Erbaa Pull-Apart Basins, North Anatolian Fault Zone: Their Significance for the Motion of the Anatolian Block: Tectonophysics, v. 322, no. 3-4, pp. 243-244.

Cohen, H.A., M. Tonkin, and C. Neville, 2000. Determination of Hydraulic Conductivity Distribution in a Heterogeneous Glacial Sand Aquifer: Correlation between Estimates Based on Impeller Flow Meter Data and Grain Size Distributions. Poster presentation at the Society for Sedimentary Geology/International Association of Sedimentologists Research Conference, Environmental Sedimentology: Hydrogeology of Sedimentary Aquifers, Santa Fe, New Mexico, Sept. 24-27, 2000.

Lolcama, J.L., and H. Cohen, 1999. Sinkholes and Land Development: Planning to Avoid Costly Failure: Land Development ,v. 11, no. 3, pp. 9-11.

Lolcama, J.L., H. Cohen, and M. Tonkin, 1999. Deep Karst Conduits, Flooding, and Sinkholes: Lessons for the Aggregates Industry. Hydrogeology and Engineering Geology of Sinkholes and Karst--1999, Proceedings of the Seventh Multidisciplinary Conference on Sinkholes and the Engineering and Environmental Impacts of Karst, Harrisburg / Hershey, Pennsylvania, April 10-14, 1999.

Lolcama, J.L., and H. Cohen, 1997.Karst Hydrogeology for the Aggregates Industry. Presentation to members of the Maryland Aggregate Association, June 11.

Cohen, H.A., and S. Hardy, 1996.Numerical Modeling of Stratal Architectures Resulting from Differential Loading of a Mobile Substrate. In Salt Tectonics. Alsop, G., D. Blundell, and I. Davison, editors. Geological Society Special Publication 100pp. 265-273.

Cohen, H.A., and K. McClay, 1996. Sedimentation and Shale Tectonics of the Northwestern Niger Delta Front: Marine and Petroleum Geology, v. 13, pp. 313-328.

Onstott, T.C., H. Cohen, C. Miller, and J. Golden, 1996.Applications for UV Laser Microprobe to 40Ar/39Ar Dating of Fine-Grained Diagenetic Minerals. Presented at the American Geophysical Union Spring Meeting, Baltimore, May 20-24, 1996. In Eos, v. 77, p. 92.

Cohen, H.A., 1995. Salt and Shale Tectonics in Continental Margin Settings. Presentation at the Structural Interpretation in Sedimentary Basins, Fault Dynamics Short Course, July 24-28, 1995.


Cohen, H.A., C. Dart, H. Akyuz, and A. Barka, 1995.Syn-Rift Sedimentation and Structural Development

of the Gediz and Buyuk Menderes Graben, Western Turkey: Journal of the Geological Society of London, v. 152, pp. 629-638.

Cohen, H.A., C. Hall, and N. Lundberg, 1995. 40Ar/39Ar Dating of Detrital Grains Constrains the Provenance and Stratigraphy of the Seymour Canal Formation, Gravina Belt, Southeastern Alaska: Journal of Geology, v. 103, pp. 327-337.

Cohen, H.A., F. Watchorn, H. Akyuz, and A. Barka, 1995.Sedimentation Patterns in the Niksar and Erbaa-Tasova Pull-Apart Basins, North Anatolian Fault Zone, Turkey. Presentation at the American Association of Petroleum Geologists Annual Meeting, Houston, March 5-8, 1995.

Dart, C.J., H. Cohen, H. Akyuz, and A. Barka, 1995.Basinward Migrating Rift Border Faults: Implications for Facies Distribution and Preservation Potential. Geology, v. 23,pp. 69-72.

Cohen, H.A. 1994. Counter-Regional Faulting in Response to Salt and Shale Tectonics: Examples from the Gulf of Mexico and Western Africa. Presentation at the Fault Dynamics Project Workshop, Egham, England, March 28-30, 1994.

Cohen, H.A., and S. Hardy, 1994. Differential Loading of Mobile Substrates: Constraints from Nature and Computer Modeling. Presentation at the Fault Dynamics Project Workshop, Egham, England, March 28-30, 1994.

Cohen, H.A., C. Dart, H. Akyuz, and A. Barka, 1994. Structural Development of the Gediz and Buyuk Menderes Graben, Western Turkey: Effect of Basinward Migration of Faulting on Half-Graben Sedimentation. Presentation at the American Association of Petroleum Geologists Annual Meeting, June 12-15, 1994, Denver, Colorado.

Hardy, S., and H.A. Cohen, 1994.Numerical Modeling of the Effect of Delta-Induced Differential Loading on a Mobile Substrate. Presentation at the Salt Tectonics Meeting of the Petroleum Group of the Geological Society, London, September 14-15, 1994.

Cohen, H.A., F. Watchorn, H. Akyuz, and A. Barka, 1994.Plio-Pleistocene Sedimentation in the Erbaa-Tasova and Niksar Strike-Slip Basins, North Anatolian Fault Zone, Turkey. British Sedimentological Research Group, Geological Society of London Annual Meeting, December 18-20, 1994.

Cohen, H.A., R. Cumbest, and T. Onstott, 1993. Alumina Ceramic as a Mounting Medium for Electron Microprobe Analysis and

40Ar/

39Ar Laser Microprobe Dating of Mineral Grains: Chemical Geology, v.

106, no. 3-4,pp. 443-452.

Cohen, H.A., and N. Lundberg, 1993. Detrital Record of the Gravina Arc, Southeast Alaska: Petrology and Provenance of Seymour Canal Formation Sandstones: Geological Society of America Bulletin, v. 105,pp. 1400-1414.

Cohen, H.A., and K. McClay, 1993.Shale Tectonics and Sedimentation on the Northwestern Niger Delta Front. Presentation at the Geological Society of America Annual Meeting, Boston, October 1993.

Cohen, H.A., 1992. Stratigraphic, Sedimentologic, and Provenance Constraints on Evolution of the Gravina Belt, Northern Southeast Alaska. PhD Dissertation, Princeton University, 275 p.

Cohen, H.A., R. Cumbest, and T. Onstott, 1992.Alumina Ceramic Adhesive as a Mounting Medium for Microprobe Analysis, Irradiation, and

40Ar/

39Ar Laser Dating of Loose Mineral Grains. Presentation at

the American Geophysical Union 1992 Spring Meeting, Montreal, Canada, May 12-16, 1992. In Eos,v. 73, no. 14, Supplement, p. 364.


Hanger, R.A., and H. Cohen, 1992.Reworked Cleiothyridina sp. in the Seymour Canal Formation

(Jurassic-Cretaceous), Southeastern Alaska. Paleobios ,v. 14,pp. 1-2.

Cohen, H.A., N. Macleod, and N. Lundberg, 1991. Cretaceous ChertClasts in the Gravina Belt, Southeast Alaska: Evidence for a Contemporaneous Oceanic Source Terrane. Presentation at the Geological Society of America Annual Meeting, San Diego, CA, November 1991.

Cohen, H.A., and N. Lundberg, 1990. Jura-Cretaceous Sedimentation on the Eastern Slope of the Wrangellian Microcontinent: Lithofacies of the Seymour Canal Formation, Gravina Belt of Northern Southeast Alaska. Presentation at the Geological Society of America, Cordilleran Section, 86th Annual Meeting, Tucson, Arizona, March 14-16, 1990. In Abstracts with Programs - Geological Society of America, v. 22, no. 3, p. 3.

Cohen, H.A., and N. Lundberg, 1990. Sandstone Petrology of the Seymour Canal Formation (Gravina-Nutzotin Belt): Implications for the Accretion History of Southeast Alaska. Presentation at the Geological Society of America Annual Meeting, Denver, CO, October 1990.

Cohen, H.A., T. Onstott, N. Lundberg, and C. Hall, 1990.40/39Ar Laser Probe Dating of Detrital Phenocrysts to Constrain the Age of Volcanism, Gravina Belt, Southeast Alaska. Presentation at the American Geophysical Union 1990 Fall Meeting, San Francisco, CA, December 3-7, 1990. In Eos, v. 71, no. 43, p. 1617.

Cohen, H.A., and A. Gibbs, 1989. Is the Equatorial Atlantic Discordant?:Precambrian Research, v. 42 pp. 353-369.

DEPOSITION AND TESTIMONY EXPERIENCE

DEPOSITIONS

2010 New Jersey Department of Environmental Protection; The Commissioner of the New Jersey Department of Environmental Protection; and the Administrator of the New Jersey Spill Compensation Fund vs Exxon Mobil Corporation f/k/a Exxon Corporation and Kinder Morgan Liquids Terminals, LLC a/k/a GATX Terminals Corporation. Superior Court of New Jersey.

2009 Morrison Enterprises and the City of Hastings, Nebraska vs. Dravo Corporation. U.S. District Court for the District of Nebraska. No. 4:08-CV-3142. July 24.

2008 Jeff Alban et al. vs. ExxonMobil Corporation et al. Circuit Court of the State of Maryland, County of Baltimore.03-C-06-010932. August 21.

TESTIMONY

2008 Jeff Alban et al. vs. ExxonMobil Corporation et al. Circuit Court of the State of Maryland, County of Baltimore.03-C-06-010932. October 16.

Attachment B Curriculum Vitae for Michael T. Rafferty

MICHAEL T. RAFFERTY Engineer

AREAS OF EXPERTISE Soil and Groundwater Remediation Treatment System Design Hazardous Waste Management

Remediation Cost Estimates Project Management Expert Witness

SUMMARY OF QUALIFICATIONS Mr. Rafferty has extensive experience in the design, construction, and operation of groundwater treatment, soil treatment, and oil and chemical process facilities. He has been responsible for the design of process systems (including equipment, piping, and instrumentation); construction, startup, and operation of treatment plants; project material control; and various construction-related activities. He has managed site characterization and remediation programs in compliance with federal, state, and local regulatory guidelines for a wide variety of sites where the soil or groundwater was affected by metals, chlorinated organic compounds, and petroleum hydrocarbons as well as non-aqueous phase liquids (NAPLs). Mr. Rafferty has been directly responsible for all phases of these projects, including soil and groundwater investigations; conceptual remedial design studies; development of design drawings and specifications; bid document preparation and evaluation; construction management; field supervision and inspection, and report preparation. He has been an expert witness and has provided technical input for mediation, arbitration, and litigation of environmental and construction claim cases. Mr. Rafferty is Office Manager of SSP&A’s San Francisco, California office. REPRESENTATIVE EXPERIENCE S.S. Papadopulos & Associations, Inc., San Francisco, California

Former Pesticide Manufacturing Site, East Palo Alto, California – Served as Project Manager for the remediation of a site impacted by approximately 100 tons of arsenic and related compounds. Responsible for coordinating two Feasibility Studies and Remedial Action Plans according to federal and state requirements. The work included evaluation of treatment technologies and the development, screening, and selection of remedial action alternatives. Coordinated extensive hydrogeologic and soil investigations, risk assessments, and a long-term groundwater monitoring program required for this site by the California Regional Water Quality Control Board and U.S. Environmental Protection Agency. Remediation to date includes excavation of over 5,000 cubic yards of soil for disposal at a hazardous waste landfill, treatment of over 18,000 cubic yards of arsenic-containing soil, and installation of a three-layer asphalt cap. Special features of this project involved evaluation of environmental exposure to a nearby sensitive wetland environment, restoration of a nearby salt pond, remediation of residential and school properties, and use of

YEARS OF EXPERIENCE: 30+

EDUCATION MS, Civil Engineering, University of

California, Berkeley, 1987 BS, Chemical Engineering, Cornell

University, 1979

REGISTRATIONS Professional Engineer:

California No. C44916 Arizona No. 24299 Colorado No. PE 35978 Tennessee No. 00114477 Oregon No. 16372 New Jersey No. GE42584 Maryland No. 26732 Nebraska No. E-12748 Texas No. 89969 Washington No. 41213 U.S. Virgin Island No. 901219

PROFESSIONAL HISTORY S.S. Papadopulos & Associates, Inc.

Vice President and Principal Engineer, 1999 to present

Geomatrix Consultants Project to Principal Engineer, 1987 to 1999

University of California, Berkeley Research Assistant, 1986 to 1987

Bechtel Corporation Project/Senior Field Engineer, 1980 to 1985

Aerojet Corporation Engineer, 1979 to 1980

MICHAEL T. RAFFERTY Engineer Page 2

vegetation (phytoremediation) to control arsenic-affected groundwater.

Natural Resource Damage Claims, New Jersey – Served as an expert witness for five cases brought by the State against responsible parties, seeking damages for groundwater contamination. Testimony focused on the cost and time to remediate groundwater to cleanup levels below MCLs.

Groundwater Treatment Facilities – Served as Project Manager for groundwater and soil remediation at several facilities where chlorinated solvents were found in the subsurface. These projects involved soil aeration, design and installation of soil vapor extraction systems, groundwater extraction and containment, and groundwater treatment by aeration, air stripping, oxidation, and activated carbon adsorption. Responsibilities included design, negotiation of permits, field supervision, documentation and inspection, as well as all aspects of contract administration. Example: An aging groundwater treatment system at a CERCLA site in Cupertino, California utilizing air stripping was scheduled for replacement by the site owner. A new activated carbon system was instead proposed, reducing operating costs and increasing reliability of the treatment to meet discharge goals. Mr. Rafferty was the engineer of record for the design, and he and other SSP&A staff oversaw construction and startup of the plant.

Sediment Remediation, Southern California – Served as Project Manager for a diverse team of engineers, geochemists, ecological risk assessors and surface water and sediment modelers evaluating client’s liability and potential remediation costs at two ship repair facilities in Southern California. Issues included the age of sediments at depth and fingerprinting sources of PCBs, tin, lead and other contaminants. Assisted client with negotiations regarding lease closeout at one facility, and represented client in negotiations with other responsible parties regarding mediation of cleanup order at the other site.

Insurance Litigation for Remediation Costs – Served as a testifying and non-testifying expert for both insurance companies and responsible parties in cases involving insurance claims for soil and groundwater remediation costs. Issues included identifying an accurate definition of the claim and the amounts spent, verifying the veracity of the claims, and examining the reasonableness of the costs claimed relative to other cleanup sites. Several cases involving mining wastes in Arizona and chlorinated solvent and rocket propellant releases in California involved claims in excess of $100 million.

U.S. Department of Justice – Served as an expert witness for several environmental litigation cases. Examples: the quantification of damages due a contractor and redevelopment agency for buried asbestos and debris discovered during residential construction at a former Air Force base; the evaluation of the cost of remediating a bleaching agent released in a desert environment; and the remediation for the release of chlorinated solvents at several military base that had moved into and adjacent residential area.

Former Pesticide Manufacturing Site, Bound Brook, New Jersey – Designed, constructed and operated a pilot passive surface water treatment system for contaminated runoff containing high levels of dissolved arsenic. Also served as a technical reviewer for remediation documents, including extensive grading and cap designs for the site.

Spring Discharges Containing PCBs, Tennessee – Project manager for the design of a treatment plant to treat variable spring flows containing PCBs from historic natural gas compressor station operations. Design flows range from 10 to 500 gallons per minute, and effluent must meet state NPDES requirements.

Abandoned Sites – Served as Project Manager for projects involving the investigation and cleanup of sites abandoned by former lessees. Work included debris and building removal, soil-gas surveys, shallow groundwater surveys, well installation, excavation of impacted soil, and hazardous waste removal. These projects resulted in extensive negotiations with government agencies due to the rigorous permitting requirements to accomplish the work. Example: At a


former metal recycling facility in Santa Rosa, California, segregated, categorized and disposed of abandoned hazardous materials; removed hundreds of cubic yards of scrap metal from the site; removed several underground tanks; conducted an extensive site investigation, and installed and operated a groundwater extraction and treatment system incorporating 14 onsite and offsite extraction wells that pump to an air stripper to remove chlorinated VOCs.

Petroleum Hydrocarbon Contaminated Sites, California – Served as Project Manager on several studies at petroleum product storage facilities that involved tank removal, site characterization, and remediation of diesel, gasoline, and solvents. Designed remedial action alternatives in compliance with state and local regulatory agency requirements. Projects involved shallow groundwater surveys to evaluate the extent of contamination in groundwater, soil vapor extraction and bioremediation of soil containing hydrocarbons.

Interstate Technology & Regulatory Council (ITRC) – Served as a member of several ITRC teams, including the Remediation Risk Management team, the Solidification/Stabilization team, and the Remediation Process Optimization team. Conducted numerous online training classes over a period of three years. Awarded the Industry Recognition Award for his service.

Habitat for Humanity – Conducted pro bono environmental assessments and assisted with permitting and geotechnical issues for several new residential construction projects located in San Francisco. Work included soil sampling, preparing reports and managing field work including excavation of contaminated soils. Assisted Habitat in arranging for pro bono and at-cost services from drilling and remediation contractors and landfills.

PROFESSIONAL SOCIETIES

National Council of Examiners for Engineering and Surveying Groundwater Resources Association of California

PUBLICATIONS

Root, R.A., D. Vlassopoulos, N.A. Rivera, M.T. Rafferty, C. Andrews, and P.A. O'Day. 2009. Speciation and Natural Attentuation of Arsenic and Iron in a Tidally Influenced Shallow Aquifer: Geochimica et Cosmochimica Acta, ScienceDirect: 26.

Binard, K., K. Chiang, M. Rafferty, P. Greer, and J. Semion. 2008. Vegetation Coverage in Cooley Landing Salt Pond Restoration Area. 2006 South Bay Science Symposium for the South Bay Salt Pond Restoration Project, June 6, 2006, San Jose State University, San Jose, California [Edited and Compiled November 12, 2008]. Trulio, L., editor.

Illera, V., P.A. O'Day, S. Cho, N.A. Rivera, R. Root, M. Rafferty, and D. Vlassopoulos. 2006. Immobilization of Arsenic in a Contaminated Soil Using Ferrous Sulfate and Type V Portland Cement. Poster presentation at the 232nd American Chemical Society National Meeting, September 10-14, San Francisco, California. San Francisco, California.

Vlassopoulos, D., D. Sorel, T. Luong, M. Karanovic, M. Tonkin, K. Chiang, M. Rafferty, and M. Riley. 2006. Assessment of Potential Perchlorate Impacts from Use of Safety Flares Along California Roadways. Presented at the Groundwater Resources Association (GRA) 16th Symposium in the Contaminants in Groundwater Series--Perchlorate 2006: Progress Toward Understanding and Cleanup, January 26, 2006, Santa Clara, California.

Vlassopoulos, D., N. Rivera, P.A. O'Day, M.T. Rafferty, and C.B. Andrews. 2005. Arsenic Removal by Zerovalent Iron: A Field Study of Rates, Mechanisms, and Long-Term Performance. In Advances in Arsenic Research: Integration of Experimental and Observational Studies and Implications for Mitigation. O'Day, P.A., D. Vlassopoulos, X. Meng, and L.G. Benning, editors. ACS Symposium Series Vol. 915. Washington, DC: American Chemical Society. 344-360.


Illera, V., P.A. O'Day, N. Rivera, R. Root, M.T. Rafferty, and D. Vlassopoulos. 2005. Soil Remediation of an Arsenic-Contaminated Site With Ferrous Sulfate and Type V Portland Cement: EOS Transactions American Geophysical Union. 86, no. 52, Fall Meeting Supplement: Abstract B31A-0954.

Levison, W., M. Rafferty, D. Sorel, and K. Binard. 2004. Phytoremediation in the San Francisco Bay Area: Using Plant Materials for Environmental Restoration-Part II: Western Arborist. 30, no. 4.

Rafferty, M.T., K. Binard, M. Orr, and J. Haltiner. 2003. Successful Design for Wetland Restoration in the San Francisco Bay. 2003 American Water Resources Association Annual Conference, November 3-6, 2003, San Diego, California. Oral Presentation Session 49. November 5.

Rafferty, M.T., C.B. Andrews, D. Vlassopoulos, D. Sorel, and K.M. Binard. 2003. Remediation of an Arsenic Contaminated Site. Presented at the 226th American Chemical Society National Meeting, September 7-11, 2003, New York City, New York.

Vlassopoulos, D., C.B. Andrews, M. Rafferty, P.A. O'Day, and N.A. Rivera Jr. 2003. In Situ Arsenic Removal by Zero Valent Iron: An Accelerated Pilot Test Simulating Long-Term Permeable Reactive Barrier Performance. Presented at the 226th American Chemical Society National Meeting, September 7-11, 2003, New York City, New York.

Sorel, D., C.J. Neville, M.T. Rafferty, K. Chiang, and C.B. Andrews. 2002. Hydraulic Containment Using Phytoremediation and a Barrier Wall to Prevent Arsenic Migration. In Proceedings of the Third International Conference on Remediation of Chlorinated and Recalcitrant Compounds, May 20-23, 2002, Monterey, California. Gavaskar, A.R., and A.S.C. Chen, editors. Battelle Press.

Vlassopoulos, D., J. Pochatila, A. Lundquist, C.B. Andrews, M.T. Rafferty, K. Chiang, D. Sorel, and N.P. Nikolaidis. 2002. An Elemental Iron Reactor for Arsenic Removal from Groundwater. In Proceedings of the Third International Conference on Remediation of Chlorinated and Recalcitrant Compounds, May 20-23, 2002, Monterey, California. Gavaskar, A.R., and A.S.C. Chen, editors. Battelle Press.

Levison, W., M. Rafferty, and K. Binard. 2001. Phytoremediation in the San Francisco Bay Area: Using Plant Materials for Environmental Restoration-Part I: Western Arborist. 27, no. 4.

Tossell, R.W., K. Binard, and M.T. Rafferty. 2000. Uptake of Arsenic by Tamarisk and Eucalyptus Under Saline Conditions. Proceedings of the Second International Conference on Remediation of Chlorinated and Recalcitrant Compounds, May 22-25, 2000, Monterey, California. In 2000 Second International Conference on Remediation of Chlorinated and Recalcitrant Compounds. Wickramanayake, G.B., and A.R. Gavaskar, editors. Bioremediation and Phytoremediation of Chlorinated and Recalcitrant Compounds (C2-4) of 7. Battelle Press.

Tossell, R.W., K. Binard, L. Sangines-Uriarte, M.T. Rafferty, and N.P. Morris. 1998. Evaluation of Tamarisk and Eucalyptus Transpiration for the Application of Phytoremediation. Proceedings of the First International Conference on Remediation of Chlorinated and Recalcitrant Compounds, Monterey, California, May 18-21, 1998. In 1998 First International Conference on Remediation of Chlorinated and Recalcitrant Compounds. Hinchee, R.E., editor. Bioremediation and Phytoremediation: Chlorinated and Recalcitrant Compounds (C1-4) of 6. Battelle Press.

Tossell, R.W., N.P. Morris, L.P. Kapustka, K. Binard, and M.T. Rafferty. 1997. Phytoremediation as an Alternative to Control Flow of Arsenic-Bearing Groundwater. Proceedings of the International Business Communications' Second Annual Conference on Phytoremediation, Seattle, Washington, June 18-19, 1997.

Johl, C.J., L. Feldman, and M.T. Rafferty. 1995. Put Risk-Based Remediation to Work: Environmental Engineering World. 1, no. 5, September-October.


Yang, D.S., S. Takeshima, T.A. Delfino, and M. Rafferty. 1995. Use of Soil Mixing at a Metals Site. 88th Annual Meeting of the Air and Waste Management Association, San Antonio, Texas, June 1995.

Chu, P., M.T. Rafferty, T.A. Delfino, and R.F. Gitschlag. 1991. Comparison of Fixation Techniques for Soil Containing Arsenic. In Emerging Technologies in Hazardous Waste Management II. Tedder, D.W., and F.G. Pohland, editors. ACS Symposium Series. 468.

DEPOSITION AND TESTIMONY EXPERIENCE

Deposition

2012 Commissioner of the Department of Planning & Natural Resources, et al. v. Century Alumina, et al., District Court of the Virgin Islands, Division of St. Croix, Civil No. 2005-0062, July 26-27, 2012.

2010 New Jersey Department of Environmental Protection, et al. vs. Exxon Mobil, et al,. Superior Court of New Jersey, Saddlebrook, New Jersey. GLOL106307. May 27-28.

2010 New Jersey Department of Environmental Protection, et al. v. Essex Chemical Corp., Superior Court of New Jersey Law Division – Middlesex County, Docket No.: MID-L-5685-07. March 12.

2008 New Jersey Department of Environmental Protection vs. Saint-Gobain Performance Plastics Corporation et al. Superior Court of New Jersey. L-1685-05. March 6.

2007 Kay Ryan Corley and Allen Corley vs. Colonial Pipeline Company et al. Circuit Court of Hale County, Alabama. CV-2005-138. September 13.

2006 Richmond American Homes of Colorado, Inc., Metropolitan Development IV, LLC, Metropolitan Builders, Inc., Standard Pacific of Colorado, Inc., and Touchstone Homes, LLC v. United States of America. U.S. Court of Federal Claims. 05-280C. May 10.

2004 Horton et al. vs. United States of America. U.S. District Court for the District of Colorado. Civil Action No. 00-MK-2126 (BNB). February 24.

2002 Inspiration Consolidated Copper Company and Phelps Dodge Miami, Plaintiff/Counter-Defendant vs. The American Insurance Company et al., Defendants/Counter-Plaintiffs. Superior Court of the State of Arizona in and for the County of Maricopa. Case No. CV98-00530. May 14 and 15, September 19, 20 and 27.

1999 Robert W. McMahon vs. The United States. U.S. District Court for the Southern District of Texas, Laredo Division. Case No. L-99-009. December 1.

Testimony

2010 New Jersey Department of Environmental Protection, et al. v. Essex Chemical Corp., Superior Court of New Jersey Law Division – Middlesex County, Docket No.: MID-L-5685-07. March 23.

2009 Carla M. Clark, et. al v. The City of Santa Rosa et al. Sonoma County Superior Court Case #SCV227896. July 7.

2003 Robert W. McMahon vs. The United States. U.S. District Court, Southern District of Texas, Laredo Division. Civil Action No. L-99-009. February 11.

Attachment C Estimated Restoration Costs

TABLE C-1Soil Vapor Extraction and Bioventing Costs

Capital Costs Qty Unit $ Subtotal Total

SVE System CapitalMob/demob 1 5,000$ 5,000$ Trenching, pipe installation, backfill (lf) 2200 40$ 88,000$ SVE System, installed (ea) 4 60,000$ 240,000$ Installation of Offgas Treatment Sysem (ea) 4 10,000$ 40,000$ Soil vapor extraction wells 14 4,000$ 56,000$ Wellhead vault instrumentation 14 2,000$ 28,000$ Treatment pad/enclosure 4 45,000$ 180,000$ Electrical Drop, Wiring and Connections 4 20,000$ 80,000$ Monitoring System 4 20,000$ 80,000$

Subtotal SVE System 797,000$ Design and Construction OversightDesign @ 10% of Construction 79,700$ Planning and Permitting @10% of Construction 79,700$ Coordination, Oversight, and Startup @ 15% of Construction 119,550$ Reporting and O&M Manual (ls) 20,000$

Total, Design and Oversight 299,000$ Subtotal 1,096,000$

Other CostsProject Management @ 5% of subtotal - - 54,800$ Contingency @ 20% of subtotal 219,200$

Total, Other Costs 274,000$ TOTAL CAPITAL COST 1,370,000$

ANNUAL O&M - Continuous Operation Qty Unit $ Subtotal Total

SVE O&MElectrical Power (kwh/yr) 279225 0.10$ 27,923$ Offgas Treatment ($/yr) 4 50,000$ 200,000$ Misc. Parts and Supplies (ls) 1 10,000$ 10,000$ SVE Operation and Maintenance Labor (hrs) 480 100$ 48,000$ SVE System Laboratory Analysis (sample) 240 173$ 41,400$ Data Compilation and Reporting (hrs) 280 120$ 33,600$

SVE Subtotal 361,000$ Other CostsProject Management @ 5% of subtotal - - 18,050$ Contingency @ 20% of subtotal 72,200$

Total, Other Costs 90,000$ TOTAL ANNUAL SVE O&M - CONTINUOUS 451,000$

ANNUAL O&M - Pulsed Operation Qty Unit $ Subtotal Total

SVE O&MElectrical Power (kwh/yr) 69806 0.10$ 6,981$ Offgas Treatment ($/yr) 4 12,000$ 48,000$ Misc. Parts and Supplies (ls) 0.25 10,000$ 2,500$ SVE Operation and Maintenance Labor (hrs) 160 100$ 16,000$ SVE System Laboratory Analysis (sample) 80 173$ 13,800$ Data Compilation and Reporting (hrs) 120 120$ 14,400$


Total, Other Costs 26,000$ TOTAL ANNUAL SVE O&M - PULSED 128,000$

ANNUAL O&M - Bioventing Qty Unit $ Subtotal Total

SVE O&MElectrical Power (kwh/yr) 27923 0.10$ 2,792$ Offgas Treatment ($/yr) 0 -$ -$ Misc. Parts and Supplies (ls) 0.25 10,000$ 2,500$ Bioventing Operation and Maintenance Labor (hrs) 120 100$ 12,000$ Bioventing System Laboratory Analysis (sample) 64 173$ 11,040$ Data Compilation and Reporting (hrs) 120 120$ 14,400$


Total, Other Costs 11,000$ TOTAL ANNUAL BIOVENTING O&M 54,000$

PRESENT VALUE ANALYSISDiscount Rate 3%Number of Years of continuous SVE Operation 3Number of Years of pulsed SVE Operation 2Number of Years of Bioventing Operation 5PV for 3 Years Continuous SVE O&M 1,276,000$ PV for 2 Years Pulsed SVE O&M 224,000$ PV for Bioventing O&M Years 6-10 213,000$ TOTAL PRESENT VALUE (CAPITAL + O&M) 3,083,000$

TABLE C-2Groundwater Extraction and Treatment Costs


GW System CapitalMob/demob 1 5,000$ 5,000$ Trenching, 4" gw pipe installation, backfill (lf) 1800 40$ 72,000$ Conduit for power and controls 1800 25$ 45,000$ GW extraction wells, 55' depth 7 20,000$ 140,000$ Wellhead vault instrumentation 7 5,000$ 35,000$ Groundwater pumps 7 4,000$ 28,000$ Floating product skimmer with collection system 7 5,000$ 35,000$ Oil Water Separator 1 75,000$ 75,000$ Influent Filter, installed (ea) 1 50,000$ 50,000$ GW Air Stripper System, installed (ea) 1 150,000$ 150,000$ Liquid Phase GAC Sysem, installed (ea) 1 60,000$ 60,000$ Offgas Treatment Sysem, installed (ea) 1 30,000$ 30,000$ Treatment pad/enclosure 1 100,000$ 100,000$ Electrical Drop, Wiring and Connections at treatment system 1 20,000$ 20,000$ Electrical connections for wells 7 5,000$ 35,000$ Monitoring and Control System 1 50,000$ 50,000$

Subtotal Dual Phase GW System 930,000$ Design and Construction OversightDesign @ 10% of Construction 93,000$ Planning and Permitting @10% of Construction 93,000$ Coordination, Oversight, and Startup @ 15% of Construction 139,500$ Reporting and O&M Manual (ls) 20,000$




Annual O&M - Full Scale Qty Unit $ Subtotal Total

GW O&MElectrical Power (kwh/yr) 233235 0.10$ 23,324$ GAC Replacement (lbs) 20000 2.00$ 40,000$ Offgas Treatment (1000 gal water treated/year) 183960 0.20$ 37,000$ Misc. Parts and Supplies (ls) 1 20,000$ 20,000$ Well rehabilitation (well) 7 2,000$ 14,000$ GW Operation and Maintenance Labor (hrs) 192 100$ 19,200$ GW System Laboratory Analysis (sample) 96 173$ 16,560$ Data Compilation and Reporting (hrs) 136 120$ 16,320$

GW O&M Subtotal 186,000$ Other CostsProject Management @ 5% of subtotal - - 9,300$ Contingency @ 20% of subtotal 37,200$

Total, Other Costs 46,500$ TOTAL ANNUAL GW O&M FULL-SCALE 233,000$

Annual O&M - Limited Scale Qty Unit $ Subtotal Total

GW O&MElectrical Power (kwh/yr) 174105 0.10$ 17,411$ GAC Replacement (lbs) 5000 2.00$ 10,000$ Offgas Treatment (1000 gal water treated/year) 78840 0.20$ 16,000$ Misc. Parts and Supplies (ls) 1 7,000$ 7,000$ Well rehabilitation (well) 3 2,000$ 6,000$ GW Operation and Maintenance Labor (hrs) 144 100$ 14,400$ GW System Laboratory Analysis (sample) 48 173$ 8,280$ Data Compilation and Reporting (hrs) 112 120$ 13,440$


Total, Other Costs 23,250$ TOTAL ANNUAL GW O&M - LIMITED SCALE 116,000$

PRESENT VALUE ANALYSISDiscount Rate 3%Number of Years of full-scale GW Operation 20Number of Years of limited-scale GW Operation 10PV for GW O&M full-scale 3,466,000$ PV for GW O&M limited-scale 548,000$ TOTAL PRESENT VALUE (CAPITAL + O&M) 5,061,000$

TABLE C-3Soil Investigation, Excavation, and Dispsoal Costs

Investigation Costs Qty Unit $ Subtotal Total

Investigation for DelineationMob/demob (ls) 1 2,000$ 2,000$ MIP Investigation (days) 36 4,000$ 144,000$ Soil boring Investigation (days) 71 3,000$ 213,000$ Screening and Logging by Geologist (days) 107 1,000$ 107,000$ Laboratory Analysis (sample) 497 173$ 86,000$

Subtotal Investigation 552,000$ Design and OversightDesign/Workplan @ 10% 55,200$ Planning and Permitting @10% 55,200$ Coordination and Oversight @ 15% 82,800$ Reporting (ls) 20,000$

Total, Design and Oversight 213,000$ Subtotal 765,000$


Total, Other Costs 191,000$ TOTAL CAPITAL COST 956,000$

Excavation Costs Qty Unit $ Subtotal Total

Excavation and Onsite Treatment & DisposalMob/demob (ls) 1 50,000$ 50,000$ Site preparation and construct staging areas (ls) 1 100,000$ 100,000$ Sheetpiling - install, pull, and salvage (sf) 16,500 11$ 181,500$ Excavate soil (cy) 74,800 5$ 374,000$ Haul and stockpile soil at staging areas (cy) 74,800 4$ 299,200$ Dewatering - pumps and temp storage (days of exc) 19 500$ 9,350$ GW Treatment and disposal of treated water (1000 gal) 8,078 15.00$ 121,176$ BackfillImport and place gravel backfill to water table (cy) 6800 18$ 122,400$ Place and compact stockpiled overburden soil (cy) 56100 9$ 504,900$ place, and compact imported fill (cy) 11900 14$ 166,600$ Transport and DispsoalSampling and TPH/BTEX/MTBE Anaylsis (sample) 150 200$ 29,920$ Load contaminated soil into trucks (cy) 18700 5$ 93,500$ Transport soil to offsite disposal site (load) 1301 200$ 260,200$ Disposal as non-RCRA waste (ton) 29920 25$ 748,000$

Subtotal Excavation 3,061,000$ Design and OversightDesign @ 5% of Construction 153,050$ Planning and Permitting @ 3% of Construction 91,830$ Coordination, Oversight @ 5% of Construction 153,050$ Reporting (ls) 30,000$




PRESENT VALUE ANALYSISDiscount Rate 3%Years to Investigation 30Years to Excavation 31PV for Investigation 394,000$ PV for Excavation 1,744,000$ TOTAL PRESENT VALUE 2,138,000$

TABLE C-4Post-Remediation

Groundwater Extraction and Treatment Costs


GW System CapitalMob/demob 1 5,000$ 5,000$ Trenching, 2" gw pipe installation, backfill (lf) 1200 35$ 42,000$ Conduit for power and controls 1200 25$ 30,000$ GW extraction wells, 55' depth 4 20,000$ 80,000$ Wellhead vault instrumentation 4 5,000$ 20,000$ Groundwater pumps 4 4,000$ 16,000$ Influent Filter, installed (ea) 1 15,000$ 15,000$ Liquid Phase GAC Sysem, installed (ea) 1 45,000$ 45,000$ Treatment pad/enclosure 1 70,000$ 70,000$ Electrical Drop, Wiring and Connections at treatment system 1 20,000$ 20,000$ Electrical connections for wells 4 5,000$ 20,000$ Monitoring and Control System 1 20,000$ 20,000$

Subtotal Dual Phase GW System 383,000$ Design and Construction OversightDesign @ 10% of Construction 38,300$ Planning and Permitting @10% of Construction 38,300$ Coordination, Oversight, and Startup @ 15% of Construction 57,450$ Reporting and O&M Manual (ls) 20,000$




Annual O&M Qty Unit $ Subtotal Total

GW O&MElectrical Power (kwh/yr) 32850 0.10$ 3,285$ GAC Replacement (lbs) 2000 2.00$ 4,000$ Misc. Parts and Supplies (ls) 1 7,000$ 7,000$ GW Operation and Maintenance Labor (hrs) 144 100$ 14,400$ GW System Laboratory Analysis (sample) 48 173$ 8,280$ Data Compilation and Reporting (hrs) 112 120$ 13,440$


Total, Other Costs 12,500$ TOTAL ANNUAL GW O&M - LIMITED SCALE 63,000$

PRESENT VALUE ANALYSISDiscount Rate 3%Number of Years to Implementation 31Number of Years of Post Remedial GW Operation 2PV for Capital Cost 268,000$ PV for GW O&M 48,000$ TOTAL PRESENT VALUE (CAPITAL + O&M) 316,000$

TABLE C-5Groundwater Monitoring Costs


GW System CapitalAdditional Well Installation 15 7,000$ 105,000$

Subtotal, Well Installation 105,000$ Design and Construction OversightDesign @ 10% of Construction 10,500$ Planning and Permitting @10% of Construction 10,500$ Coordination, Oversight @ 15% of Construction 15,750$ Reporting and O&M Manual (ls) 5,000$




Groundwater Monitoring Operation and Maintenance Qty Unit $ Subtotal Total

Semi-annual Sampling and Analysis (sample) 50 500$ 25,000$ Well Maintenance/Replacement (well) 25 200$ 5,000$ Data Management and Reporting (hours) 80 120$ 9,600$


Total, Other Costs 10,000$ TOTAL ANNUAL GW MONITORING O&M 50,000$

PRESENT VALUE ANALYSISDiscount Rate 3%Number of Years of GW Monitoring 34PV for GW Monitoring O&M 1,057,000$ TOTAL PRESENT VALUE (CAPITAL + O&M) 1,241,000$

Documents

Expert Report Addendum Paulsboro Terminal Site Paulsboro, New