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HomeMy WebLinkAbout01 - Appendix D Part 1APPENDIX D SITE REMEDIATION AND HAZARDOUS MATERIALS Prepared for Newport Banning Ranch LLC 3030 Saturn Street Brea, California 92821 DRAFT REMEDIAL ACTION PLAN (FOR INFORMATION AND PLANNING PURPOSES ONLY) NEWPORT BANNING RANCH CITY OF NEWPORT BEACH ORANGE COUNTY, CALIFORNIA Prepared by Geosyntec D consultants engineers I scientists I innovators 2100 Main Street, Suite 150 Huntington Beach, California 92648 Telephone: (714) 969-0800 Fax (714) 969 -0820 www.geosyntec.com Project Number HR1018 August 2009 TABLE OF CONTENTS Ge os yntec D T Page 1. INTRODUCTION AND PURPOSE ...................................... ..............................1 2. SITE BACKGROUND AND HISTORICAL USES ............ ............................... 3 3. REGULATORY OVERSIGHT FRAMEWORK ................ ............................... 6 3.1 Existing Regulatory Oversight ..................................... ............................... 6 3.2 Wetland and Habitat Considerations ............................ ............................... 6 4. SITE ASSESSMENTS AND INVESTIGATIONS .............. ............................... 8 4.1 Overview ....................................................................... ............................... 8 4.2 Phase II Site EA Investigation ...................................... ............................... 8 4.3 Updated Phase I ESA .................................................. ............................... 10 4.4 Past Soil Cleanup Activity .......................................... ............................... I 1 5. PROPOSED REMEDIATION SCOPE AND PROCESS ... .............................12 5.1 General .......................................................................... .............................12 5.2 Expected Environmental Impacts and Volumes — Soils, Asphalt andConcrete ............................................................... ............................... 12 5.3 Expected Environmental Impacts — Methane and VOCs .......................... 13 5.4 Remediation Process Approach .................................. ............................... 13 5.43 General ........................................................... .............................13 5.4.2 Methane and VOC Mitigation ..................... ............................... 14 5.4.3 Clean -Up Levels and Re -Use of Materials .. ............................... 15 5.4.4 Remediation Areas and Methods ................. ............................... 16 5.4.5 Verification and Documentation .................. ............................... 18 6. SUMMARY AND CONCLUSIONS ..................................... .............................19 REFERENCES APPENDIX A: ORANGE COUNTY FIRE AUTHORITY GUIDELINE C -08 Combustible Soil Gas Hazard Mitigation, January 1, 2008 HR101&7VBA09 -07 RPT 1 8/21/2009 Ge os yntec D T TABLE OF CONTENTS (continued) TABLES Table 1: Summary of Environmental Sampling/Testing /Assessment History Table 2: Potential Environmental Conditions Table 3 (within the text): Range of Soil Sample Results — EA 2001 Table 4 (within the text): Range of Groundwater Sample Results — EA 2001 Table 5: Summary of Historic Cleanup Levels FIGURES Figure 1: Site Location Figure 2: Topographic Areas and Features Map Figure 3: Historical Oilfield Impacts Figure 4: Oil Consolidation Areas Figure 5: PEC Location Map Figure 6: Estimated Remedial Excavation Areas HR101&7VBA09 -07 RPT ii 8/21/2009 Ge os yntec D T TABLE OF CONTENTS (continued) GLOSSARY OF ABBREVIATIONS ASTM — American Society for Testing and Materials BMP — Best Management Practice BTEX — Benzene, Toluene, Ethylbenzene, and Xylenes CAO — Cleanup and Abatement Order CCA — California Coast Act CCC — California Coastal Commission DFG — Department of Fish and Game DOGGR — Division of Gas and Geothermal Resources dRAP — Draft Remedial Action Plan EA — Environmental Assessment EPA — Environmental Protection Agency ESA— Environmental Site Assessment FWS — US Fish and Wildlife Service HDLLC — Horizontal Drilling, LLC MCL — Maximum Contaminant Level NBR — Newport Banning Ranch NBRLLC — Newport Banning Ranch, LLC OCHCA — Orange County Health Care Agency PEC — Potential Environmental Condition RAP — Remedial Action Plan REC — Recognized Environmental Condition RSL — Regional Screening Level RWQCB -SA — Regional Water Quality Control Board, Santa Ana Region SVOC — Semi - Volatile Organic Compound SWPPP — Storm Water Pollution Prevention Plan TPH — Total Petroleum Hydrocarbons TRPH — Total Recoverable Petroleum Hydrocarbons TTLC — Total Threshold Limit Concentration USACE — US Army Corps of Engineers VFH— Volatile Fuel Hydrocarbons VOC — Volatile Organic Compound WNOC — West Newport Oil Company HR101&7VBA09 -07 RPT 111 8/21 12009 Ge os yntec D T 1. INTRODUCTION AND PURPOSE This document presents a draft Remedial Action Plan (dRAP) for the approximately 400 ac Newport Banning Ranch property (the Site, Figure 1). The purpose of this document is to: • Describe the scope of the oil field remediation project and the processes and methods that are anticipated to be used at the Site if the proposed development project is approved; and • Describe the regulatory framework for approval of a final Remedial Action Plan (to be submitted at a later date) and the monitoring and approval process to be followed during field remediation work. Environmental investigations and some limited restoration/remediation work have been performed at various times over the past 20 years at the Site. The Site landowner has proposed a development plan for the Site that includes a mix of residential, commercial, and open space. On 6 November 2006, the City of Newport Beach adopted its updated General Plan and listed two designations for the Site: • Priority Alternative — Site to be made available for purchase as open space, • Second Alternative — Site to have at least 50% preserved as open space, limited development to be permitted on the upper portion of the Site (residential, resort, commercial, and community parks). The topographic area and features of the site and vicinity are shown in Figure 2 which highlights the division of the property between a near sea level lowland area and higher elevation uplands areas. One of the significant benefits of an approved Site development project would be the consolidation of current active oil production operations (which currently effectively utilize the entire 400 -acre Site) into two interconnected oil consolidation areas totaling approximately 20 acres (Figure 3). This consolidation would free up the remainder of the Site for restoration, development, and public use. The dRAP will apply to those areas outside of the two oil consolidation areas and the interconnecting pipeline and access areas. As is the normal process, a final Remedial Action Plan will be submitted to the Site environmental oversight agencies at a later date once the permitting and development planning process is further along and there is a better understanding of the potential of the oil field consolidation actually occurring in a specified timeframe. If the HR101&7VBA09 -07 RPT 1 8/21/2009 Ge os yntec D T development project does not move forward the current oil field operations are expected to continue as -is pushing abandonment and remediation work out potentially 30 to 40 years. This early dRAP is presented for informational and scoping purposes only. A key assumption in all development planning is that any residential construction will be contingent upon the completion of the remediation work and agency closure of each residential planning area. HR701817VBA09 -07 RPT 2 8/21/2009 Ge os yntec D T 2. SITE BACKGROUND AND HISTORICAL USES The Site is approximately 400 acres in extent and is located east of the mouth of the Santa Ana River near the Huntington Beach — Newport Beach city boundary in Orange County, California. A map showing the location of the Site is presented in Figure 1. The Site is currently operated as a crude oil and gas production facility. The Site oil and gas production operations are being managed by Horizontal Drilling, LLC (HDLLC) and their operating affiliate, West Newport Oil Company (WNOC). The surface estate is managed by NBRLLC, a partnership including Aera Energy LLC, Cherokee Investment Partners, LLC, and Brooks Street. Oil operations including exploration, development, and production have been conducted continuously within the boundaries of the Site since 1944. Most of the Site has been heavily impacted by these historic oil operations and the related access roads and work areas. The majority of the Site is still used today in active oil and gas production operations. There are currently over 470 producing /potentially producing and abandoned oil wells at the Site, together with related roads, transport pipeline networks, above - ground crude oil storage tanks and processing equipment, service buildings and other facilities (see Figure 3). Other historical Site uses have included: agriculture, military coast watch station, equipment storage and maintenance, and miscellaneous peripheral operations (including areas leased to welders, pipe storage, and equipment operators). The oilfield operator, WNOC, has approximately 90 active /idle wells available for oil operations with approximately 50 operating at any one time. The City of Newport Beach operates approximately 16 wells and an oil processing facility located at the West Coast Highway entrance area (located at the southern oil operations site shown in Figure 4). Figure 3 provides a composite picture as to the extent of the Site that has been impacted by both historic and current oil wells, pipelines, utility poles, and related facilities, as well as oilfield operation work areas like graded roads and equipment areas surfaced with gravel, asphalt, crude oil, or crude oil tank sediments, and historic sumps which held produced oil and fluids within in- ground surface impoundments. This map was assembled from a variety of in -field evaluations, technical maps, aerial photography, and other sources, and illustrates that the over 65 years of oil producing operations have resulted in substantial impacts to the Site. Additional small impacts, currently unknown, may be encountered during the facility abandonment, remediation, and grading programs. This is typical of remediation of oilfields of this size. These oil field use areas will be the focus of Site remediation efforts and both known and potential HR101817VBA09 -07 RPT 3 8/21/2009 Ge os yntec D consulumts impacts have been accounted for in the scope and schedule of the remediation effort, and in the biological technical and mitigation evaluations. As shown on Figure 3, over 470 individual well -site pads have been cleared, cut, and leveled as part of oilfield operations; miles of supporting service roads between the well sites and facilities have been constructed; and numerous power poles and facility and equipment areas required in oil and gas operations have been cleared and constructed. There currently remains over 40 miles of pipelines throughout the Site for the conveyance of oil, water, and gas produced from the wells to various separation and treatment facilities on the Site. Figure 3 shows that these operations are spread across both the upland and lowland areas of the Site. These oil field operations areas will be the primary focus of the remediation program and can be generally described as follows: • Oil Wells and Pads — The surface locations of the existing or abandoned oil wells. A typical oil well pad generally includes an area of 10 to 30 feet around each oil well that contains pipelines, concrete pads, pumping and power equipment, and the work area for large workover rigs, trucks, and tanks. • Oil Pipeline Corridors — Areas where one or more pipelines exist, or existed, to convey oil, water, and gas from each well to larger group lines, and then on to each processing facility. Most lines are above ground with some sitting on pipeline support structures that are cemented into the ground to raise the actual pipeline above the ground surface. Some older fines may still exist below the surface. • Utility Poles — Power poles to support the electrical system throughout the field. These treated wood poles support transformers, power lines, electrical panels, and other equipment to serve the oil operations. Poles were often left in place (even at abandoned well locations) to support potential future drilling. • Oilfield Operations Areas — All areas historically used in the oil- and gas - producing operations. This includes roads, wells, and surrounding wellpads, tanks and facilities, pipeline and utility corridors and general staging and work areas. These areas have generally been graded and may be surfaced with gravel, asphalt, crude oil, crude oil tank sediments, or other materials. There are numerous facility areas throughout the Site. These vary from large facility areas that include extensive piping, oil separation and processing tanks, power facilities, mechanics and workshops, and other equipment, to smaller HRI0I&7VBA09 -07 RPT 4 8/21/2009 Ge os yntec D T individual tanks, vessels, equipment storage yards, sheds, and staging areas. In some cases vegetation has grown around or amongst these facilities and surface materials. These same areas are typically targeted for demolition and removal during an oilfield abandonment process and may require additional soil work as part of the remediation process. • Historic Oil Sumps — In- ground produced oil and fluids storage locations identified from a 1947 aerial photograph (also included in Figure 3). This photograph showed the widest extent of sumps identified during a review of site aerial photographs. • Continuing Oil Operations Areas — Areas containing oil tanks piping and processing equipment. These include two oil consolidation sites, and a related access road and utility corridor, which are proposed to become the only on- going oil production areas with the Site, prior to the remediation, restoration, and /or development of the other areas within the Site (Figure 4). Because the oil operations predated the establishment of the California Coastal Act (CCA) and other related regulatory definitions and codes, oilfield operations at Newport Banning Ranch were granted a permit exemption by the California Coastal Commission (CCC) in 1973 that covers ongoing and future oil production operations and also includes abandonments and equipment/pipeline removals and cleanup as exempt activities. • portion of the original oilfield has already undergone abandonment and remediation. • parcel of the original lowland oilfield property (92 acres along the westerly edge adjacent to the Santa Ana River) was purchased by the U.S. Army Corps of Engineers (USACE) in the late 1980s as part of the USACE Santa Ana River Flood Control Project [Mitech, 1988; USACE, 1988]. The parcel was converted to a tidally - influenced coastal wetland habitat by the USACE by the early 1990s as a wetland off- set or mitigation measure for work completed elsewhere along their project corridor. This conversion involved similar abandonment and remediation activities that are outlined in this dRAP. HR701817VBA09 -07 RPT 5 8/21/2009 Ge os yntec 0 T 3. REGULATORY OVERSIGHT FRAMEWORK 3.1 Existing Regulatory Oversight The actual oil field operations are governed by regulations of the California Department of Conservation, Department of Oil, Gas, and Geothermal Resources ( DOGGR). The DOGGR has specific guidelines for the abandonment, or reabandonment if necessary, of oil wells. DOGGR also has a process called the Construction Site Review that must be followed for oilfields that are abandoned for future development purposes. The Site has a history of environmental oversight by both the state Regional Water Quality Control Board - Santa Ana Region (RWQCB) and the Orange County Health Care Agency (OCHCA). Since about 1992 both agencies have been involved with oversight of certain aspects of cleanup activities and site operations. Currently, the lead regulatory agency for the site (RWQCB) has approved a Remedial Action Plan [Geosyntec, 2002c; RWQCB, 2003] and is overseeing remediation efforts to recover an isolated pocket of crude oil located on top of the shallow brackish groundwater in the main drillsite area (northern portion of the consolidation areas identified on Figure 4). No other area of the Site currently requires remediation under its present use as an operating oilfield. The nature and extent of future remediation for this and other areas of the Site will depend on the ultimate reuse of the property. This existing oversight structure is expected to continue through field abandonment and remediation activity as both agencies have the most experience of any agencies with oilfield -to- development type projects. There have been many such projects in Orange County over the years and these agencies have had the lead for environmental resource and human health matters. In the case of the NBR Site where there are no hazardous wastes or levels of contaminants, and where the groundwater levels in the lowlands are shallow and of prime importance to the State, it is expected that the RWQCB will continue to be the lead agency until the Site receives closure. 3.2 Wetland and Habitat Considerations Since the late 1980s when the USACE was involved in the restoration of the parcel between the Santa Ana River and the current Site area, biological resource agencies, specifically the California Department of Fish & Game (DFG) and the United States Fish & Wildlife Service (FWS) have been involved in wetlands, sensitive habitat and species determinations. HR701817VBA09 -07 RPT 6 8/21/2009 Ge os yntec D T As part of the project, biologists have conducted general biological surveys for the property, recording flora and fauna observed on Site, as well as recording sensitive species/habitat locations, and mapping Site vegetation [Glenn Lukos, 2009a]. Impacts from the abandonment and remediation of existing, and potentially encountered environmental impacts, were considered in these studies. Biologists have also conducted habitat assessments for special- status animals and plants, including species listed or proposed for listing as endangered or threatened by the federal or state government [Glenn Lukos, 2009b]. The resource agencies actively provide input on sensitive areas not to be disturbed during specific times of the year. These agencies will be consulted for similar determinations prior to and during the site -wide abandonment and remediation, when it occurs. HR701&7VBA09 -07 RPT 7 8/21/2009 Ge os yntec D T 4. SITE ASSESSMENTS AND INVESTIGATIONS 4.1 Overview Numerous environmental sampling and testing events occurred as part of the historic oil and gas production activities between 1986 and 2000 providing basic field assessment information. In late 2000, the landowners commissioned a comprehensive, site -wide Phase II Environmental Assessment (EA) [Geosyntec, 2001] with field sampling conducted between May and August 2001. This study was a comprehensive field investigation of the impacts from the historic oil operations. The final report was submitted to the Regional Water Quality Control Board — Santa Ana Region in November 2001. More recently an updated Phase I Environmental Site Assessment (ESA) Report [Geosyntec, 2008] was completed as part of the development proposal studies. Table 1 provides a brief history of environmental sampling activities performed at the Site. 4.2 Phase II Site EA Investigation In 2000, the overall Site Environmental Assessment (EA) work plan was developed. The objective of the EA was to characterize the nature and extent of potential impacts to soil and groundwater at areas determined to be a potential environmental concern (PECs), and to evaluate location and potential volumes of impacted materials that may require remediation (Figure 5). The EA fieldwork was then completed in phases during 2001 and consisted of collecting and evaluating over 550 samples from 222 test pits/borings, 10 ground water monitoring wells, surface water, and soil gas sampling points [Geosyntec, 2001]. The excavated test pits also allowed for visual observations of hydrocarbon impacts, as well as soils that did not appear to be impacted by hydrocarbons. The EA incorporated results of the previous sampling events, providing a more comprehensive Phase lI characterization in key areas. Twenty three (23) areas were identified as PECs. As anticipated, the Site is impacted primarily by petroleum hydrocarbons. Only 7 of the 23 PECs investigated showed any significant hydrocarbon impacts beyond surface areas. During the soil evaluation, soil gas was observed (i.e., bubbling) in a lowland pond near PEC #02 — Main Site Tank Farm. Samples were collected using Tedlar bags. Analytical results indicated elevated methane concentrations (up to 73.2 percent). No hydrogen sulfide was detected. This area is adjacent to the future Main Drillsite and not within the development area. There were no indications of soil gas observed in the upland areas (e.g., odors indicating a release from soils or abandoned wells). HR701&7VBA09 -07 RPT 8 8/21/2009 Ge os yntec D T At each of the areas tested, no contaminant levels were found to exceed the hazardous waste criteria (i.e., concentration levels defined by state and federal guidelines). The state Hazardous waste levels are provided in the California Code of Regulations (CCR), Title 22. Table 3 provides a summary of the soil sample analytical results from the Phase II Environmental Assessment [Geosyntec, 2001]. The hydrocarbon impacts observed were generally confined to the upper soil layers (i.e., within approximately 6 feet of the surface). These types of impacts are consistent with other oil fields of this age and similar to other oil fields that have been remediated for residential development. Aera has engaged in clean -up operations at other oil fields in Southern California, including Yorba Linda, Brea, and Bolsa Chica. TABLE 3 RANGE OF SOIL SAMPLE RESULTS — EA (2001) Contaminant Range Comments TPH 0 — 6,000 ppm Typically weathered crude oil, limited areas of high saturation SVOCs 0 — 3 ppb No SVOCs detected above residential or industrial soil RSLs VOCs 0 —1,700 ppb No VOCs detected above residential or industrial soil RSLs Pesticides 0 — 11 ppb No pesticides detected above residential or industrial soil RSLs or residential or industrial soil CHHSLs PCBs 0 — 290 ppb PCBs were detected in two samples at concentrations above the residential, but below the industrial soil RSL and industrial soil CHHSL Metals No Metals detected above TTLC The groundwater beneath the site is a shallow (in the lowland area), non - potable brackish zone that is tidally influenced. Table 4 provides a summary of the groundwater sample analytical results from the Phase H Environmental Assessment. One area, at the existing oil operations tank farm (northern extent of the future oil consolidation area — Figure 4), encountered crude oil as free - product on the shallow groundwater in one monitoring well. The free- product well is bounded by other wells thus the impact is contained and isolated. HR1018/NBA09 -07 RPT 9 8/21/2009 Ge os yntec 0 T TABLE 4 RANGE OF GROUNDWATER SAMPLE RESULTS — EA (2001) Area (PEC No.) Contaminant Range Comment Main Site Tank Farm, TPH N/A — Free Wells within former sump (PECO2) product area Main Site Tank Farm, TPH 0 — 26 ppm Perimeter Wells (PECO2) Methylene 0 — 91 ppb Methylene Chloride Chloride detected above MCL Maintenance Shop / Benzene 0 — 1.1 ppb Benzene, Methylene Warehouse (PEC01) Chloride, and Vinyl Methylene 0 — 100 ppb Chloride detected above Chloride MCLs Vinyl Chloride 0 — 15 ppb Former Sump / Methylene 0 — 25 ppb Methylene Chloride Clarifier (PEC08) Chloride detected above MCL This impact area has since been submitted into the RWQCB -SA voluntary cleanup program and after approval of an initial area - focused free - product Remedial Action Plan [Geosyntec, 2002c] has been undergoing free - product removal and monitoring since 2001. Additional free - product recovery wells and monitoring wells have been installed in that interim time and the pumping system has been upgraded to two solar powered skim pumps. The second phase of the free- product Remedial Action Plan includes removal of the deeper crude oil impacted soils once the adjacent operating facilities are abandoned and demolished. While this site is located within one of the oil consolidation areas and is not directly associated with the development project, it is anticipated that additional work would be done here at the same time as the field consolidation abandonment and remediation program upon the development approval. 4.3 Updated Phase I ESA The most recent Phase I ESA [Geosyntec, 2008] served to update the EA with issues, testing and cleanups that were conducted between 2001 and 2008. Based on modifications to the process by which Phase I environmental site assessments are performed as well as evaluating areas on Site that were subleased, the number of identified Recognized Environmental Conditions (RECs) included a total of 27 on -site HR70I&7VBA09 -07 RPT 10 8/21/2009 Ge os yntec 0 consulumts RECs, three historical RECs, and four off -site facilities as RECs. The on -site RECs are shown on Figure 5 (for the purposes of this draft RAP they are identified as Potential Environmental Conditions — PECs) and additional background information on the identified RECs is presented in Table 2. The total number of PECs has been adjusted slightly over the years due the changing methods used to define PEC. For example, the list of RECs (per the definition of Recognized Environmental Conditions by the American Society for Testing and Materials, ASTM, classification in standard Phase I ESA guidance) identified in the Phase I ESA included the 21 PECs (Potential Environmental Conditions) and three additional "historical RECs" per the updated ASTM guidance. The three historical RECs include the Cement Return Area, Wetland Fill Area, and Storm water /surface water quality issues. These historical RECs have been addressed and closed by the current Site owner and operator. 4.4 Past Soil Cleanup Activity During the low oil price environment of the 1990's and in conjunction with earlier development planning, the oil operator, WNOC, embarked on a program to abandon the least productive wells of the time. As part of this effort, and based on results of the early 1986 to 2000 site testing, a basic hydrocarbon cleanup plan (initially referred to as the Environmental Restoration Plan) was developed to cleanup soils associated with abandoned oil wells. The plan outlined basic hydrocarbon cleanup levels (Table 5) and a bio- remediation pilot scale treatment area to remediate impacted soils. The plan was initially submitted to the OCHCA who approved it in October 1992. The plan was also submitted to and reviewed by the RWQCB and other agencies including the DFG and the FWS. The plan was updated in 1994 and was used to excavate and manage well abandonment soils from 1994 to about 2001 [Geosyntec, 2001]. As outlined in previous sections, the 2008 Phase I EA Update discusses additional focused areas of the Site (or issues) that were remediated and closed. These efforts were under the direction of the RWQCB who recommended cleanup levels similar to those used in the Yorba Linda Oil Field which was also converted to residential development (Table 5). HRI0I&7VBA09 -07 RPT 11 8/21/2009 Ge os yntec 0 T 5. PROPOSED REMEDIATION SCOPE AND PROCESS 5.1 General Comprehensive oil facilities consolidation, abandonment, and remediation at the Site will be a multiple -step process that will likely span a period of approximately two to three years. The remediation portion of this process is expected to take the bulk of that time, however remedial efforts will actually occur in all of the three major early phases of the approved development project. These include oil field facility demolition, full field remediation, and development area grading. The discussion in this dRAP assumes that the oil field facility demolition phase has been completed. The impacted areas outlined in the Phase II EA report, along with estimated depths and volumes, will provide the basis and scope of the Remediation cleanup plan. Figure 6 shows the expected remedial excavation areas of the Site. In addition to the PEC areas it is expected that additional impacted soils will be identified during the oilfield facility demolition phase. The removal of all pipelines, facilities, power poles, and other structures will be monitored by third party environmental consultants to identify and document further indications of impacts for the remediation phase. Also, as development area grading is the most comprehensive type of visual confirmation possible, environmental monitoring will be present at that time also to address signs of smaller impacts. An estimate of these expected impacts from these phases is included in the total volume numbers. 5.2 Expected Environmental Impacts and Volumes — Soils, Asphalt and Concrete Investigations and testing indicate the Site is predominantly impacted by petroleum hydrocarbons, specifically degraded and weathered crude oil. No hazardous levels of any materials were found during the sampling events and assessments. The Site also includes road materials made up of varying amounts of gravel, asphalt, crude oil, or crude oil tank sediments, and large amounts of concrete used in oil field operations and facilities. These materials are expected to be addressed during the remediation phase. Table 2 shows a summary of the types of impacts that were found at the PECs and the estimated remediation volumes at those sites. The table also includes current estimates of additional soils at oil wells, pipelines and the free- product site. The current estimate is that approximately 246,000 cubic yards of materials will be addressed during the remediation. Of this, approximately 138,000 cubic yards are hydrocarbon impacted soils and an additional 108,000 cubic yards are surface road materials and concrete. As HR1018/NBA09 -07 RPT 12 8/21/2009 Ge os yntec D T with all remediation projects these estimates can vary substantially when actual removals begin. 5.3 Expected Environmental Impacts — Methane and VOCs The crude oil produced in the Site oil operations is a heavy, high gravity oil that has very little associated methane gas. Though no indications of soil gas in the uplands were observed, one site in a lowland wetland pond was observed to have small amounts of soil gas emanating from the water. That site was not near an oil well and is assumed to be a natural occurrence in the wetlands. There were no VOCs detected in soil samples above residential RSLs. Very low levels of VOCs were detected in subsurface water in isolated locations in the lowlands. Though no significant areas of VOC impacted soil or groundwater exists at the site, all the low -level detections are associated with facility areas that are targeted for remediation thus will have full verification sampling conducted to confirm health based levels are attained. 5.4 Remediation Process Approach 5.4.1 General Abandonment and Remediation of the historic oil field operations areas will be a tremendously complex and costly undertaking. Upon initiation of the consolidation process, plugging and abandoning of the approximately 90 remaining active /potentially active lowland and upland wells will commence, together with demolishing and removing the pipelines, utility poles, and other related production equipment, buildings, and road surface materials. These activities will not only clear the Site for the remediation phase but they may also expose, identify, and verify the existence of additional smaller impacts requiring remediation. It is expected that the remediation program will follow shortly after the well and facility demolition and abandonment process. Significant efforts will be made at the Site to recognize the "big picture" impacts of such operations in order to minimize impacts to resources, especially potential Special Status Habitats, both within the Site and in surrounding areas. These efforts will include such things as minimizing what is disposed of in landfills, which, in turn, will minimize both traffic impacts and the resulting emissions from large transportation truck usage. Impact avoidance and potential mitigation efforts for the development related project work is addressed in the project biological studies. HR101817VBA09 -07 RPT 13 8/21/2009 Ge os yntec 0 T The following are guiding strategies for both the oilfield abandonment and remediation effort: Recycle or reuse all salvageable materials. 2. Remediate soils on -site, whenever feasible, using natural bio- remediation processes. 3. Remove heavy hydrocarbons from the site and recycle into offsite roadway materials. 4. Reuse remediated soils and restored materials in development fills whenever possible. 5. Minimize off -site traffic, hauling, and disposal. 6. Work in collaboration with appropriate regulatory stakeholders and resource agencies to limit disturbance to desirable on -site vegetation whenever possible. In addition, as described earlier, the oil field abandonment activities are managed in accordance with DOGGR regulations, and the potential for combustible gases in the subsurface will be evaluated and mitigated according to OCFA Guideline C -03. 5.4.2 Methane and VOC Mitigation Both methane and VOC impacts, at levels of significance, could pose vapor intrusion concerns for overlying developments. The two accepted approaches to these concerns are source remediation and engineering controls. Though no significant levels of either methane or VOCs have been detected at the Site, both source remediation and engineering controls are proposed to be used for added measures of safety. In the uplands, all the detected low -level impacts and potential sources are targeted for remediation. These include facility areas and all immediate well sites. There are no indications that groundwater underlying the upland future development area is impacted by VOCs. Similarly, in the lowlands, all the detected low -level impacts and potential sources are targeted for remediation. This includes facility areas, well sites, and the isolated water impacts. There were no significant levels detected in groundwater and those areas with low -level impacts are isolated, contained, and do not extend under the upland area. HR701817VBA09 -07 RPT 14 8/21/2009 Ge os yntec 0 T Engineering controls, or mitigation, for both methane and VOCs are essentially identical for structures. Though no indications of soil gas or significant VOC impacts by the oil field operations were observed in the upland area, full mitigation measures, as defined in the Orange County Fire Authority Guideline C -03 [OCFA, 2008] — Combustible Soil Gas Hazard Mitigation document will be implemented throughout the development area. This well - established guidance (Appendix A) provides detailed designs for mitigation of potential impacts due to methane and vapor intrusion in and around developments and has been implemented in most Orange County developments with former oil field operations. These designs include subsurface oil well venting systems, structure sub -slab barriers, structure vent guidelines, and surface vent guidelines. As part of the OCFA Guideline, a hazard gas assessment must be conducted at the beginning of the process. This assessment will be conducted once the potential sources are remediated and will include a screening of VOC components. 5.4.3 Clean -Up Levels and Re -Use of Materials Previous cleanups have established RWQCB and OCHCA regulatory- approved clean- up levels for each constituent of concern or Site area (Table 5). The established TRPH clean-up levels vary based on a multi -depth approach considering depth below final grade and final site use (commercial or residential or open space). The currently applicable levels are those provided in the first page of Table 5 (based on 2001 correspondence with RWQCB). The final RAP will propose clean -up levels for the full field remediation and development and may include additional levels for other non- TRPH constituents of concern at the site. Proposed clean-up levels in the final RAP will consider: • historic and regulatory suggested levels; • approved clean -up levels from other oil field development sites; • risk -based calculations; and • EPA Regional Screening Levels. Certain, agency- approved materials may be re -used as part of Site development. For specific materials that result from the demolition and remediation activities, such as treated soil and concrete, these materials may be used as fill. The materials will meet clean up criteria similar to approved standards for this project, based on depth of placement below grade. For example treated soils may be used 10 feet below final grade, and crushed concrete below 15 feet. These materials will also be subject to appropriate geotechnical criteria needed for development. HR7018/NBA09 -07 RPT 15 8/21/2009 Ge os yntec D T 5.4.4 Remediation Areas and Methods The remediation process consists of two distinct components: remediation of known areas of impact, and remediation of areas encountered during the consolidation and grading of the Site. In the known areas of impact, it is estimated that over 138,000 cubic yards of soil will require some degree of remediation due to non - hazardous hydrocarbon (i.e., crude oil) impacts. These are the known impacts (Table 3). The majority of these soils are lightly impacted from the crude oil operations. Some areas will have an older, heavier accumulation of weathered crude oil from historical operations. Removals and excavation sites will be tested and verified to meet the RAP criteria by third party State - approved laboratories. No hazardous levels (per state and federal concentration criteria) of any materials were found at the Site in the EA. The potential for soil gas impacts will be addressed primarily through the application of the OCFA Guideline C -03. Based on the groundwater assessments performed at the site, there were no historical groundwater impacts detected under or in the immediate vicinity of the development area. Table 4 provides a summary of the groundwater sample analytical results compiled from the Phase II Environmental Assessment [Geosyntec, 2001]. Groundwater impacts were noted in the following areas of the site: the mechanics shop, the Main Site Tank Farm (also referred to as the Main Drill Site), and a former sump location to the south of the Main Drill Site. Groundwater impacts detected near the Main Drill Site area are currently being remediated through the implementation of an agency- approved Remedial Action Plan [Geosyntec, 2002c]. The low level groundwater impacts in the other areas will be addressed in the final RAP. Under the past approved cleanups, hydrocarbon impacted soils have been successfully bioremediated in a pilot -scale bioremediation cell (i.e., biocell). Thus, a continuation of the soil bioremediation method to treat and clean hydrocarbon impacted soils is appropriate. The bioremediation of hydrocarbon containing materials generally consists of: siting and layout of large treatment areas, construction of containment and handling areas, and operation of the treatment area. The actual bioremediation process involves the control of moisture in the soils as they are periodically mixed and turned. This process aerates the soils and encourages the growth of the indigenous hydrocarbon reducing bacteria. The process is monitored by periodic sampling of the treated soil, until the agency- approved clean -up levels are achieved. Upon approval of the oversight agencies, the treated soils are removed and re -used. Details of this process including location of the on -site treatment areas, stormwater control and design details, as well as HR701817VBA09 -07 RPT 16 8/21/2009 Ge os yntec D T maintenance and closure specifications will be provided in the final RAP for these impacts. The PECs where some remediation is likely to be required are listed in Table 2. In general, the remediation process will consist of: 1. Sampling materials within known areas of impact to evaluate the extent of removal needed in each area (note that this may conducted simultaneously with remedial excavation operations). 2. Impacted materials will be removed and stockpiled in specified areas of the site. Materials will be stockpiled with respect to their potential for re -use as fill on site, or potential for haul off (dependent on concentration and nature of impacts, i.e., ability to be bioremediated on- site). Areas will be contained to limit erosion and runoff issues from stockpiling operations. 3. For materials that are not likely to be effectively treated by on -site bioremediation (e.g., highly weathered crude oil), these materials will be segregated near transportation access points for recycling at an approved off -site facility. Materials identified that have constituents exceeding hazardous criteria will be stockpiled and handled separately (note that no materials having concentrations exceeding hazardous criteria have yet been identified). 4. The stockpiles will be adjacent to treatment locations (i.e., biocells). Materials will be spread and handled to enhance natural biodegradation of petroleum hydrocarbons. 5. Confirmation sampling will occur within the biocell areas. Samples of soil will be collected at a specified frequency and agency - approved treatment batch volume. These samples will be subjected to laboratory analysis. Based on the results, materials will either continue to be treated, or moved to re -use areas if sample results indicate that agency- approved criteria have been achieved. As described previously, this will be a time - intensive and complex process. For example, soils with very heavy hydrocarbon impacts may be isolated for longer tern, more intense bioremediation, may be taken off -site to acceptable recycling units, or may be treated on -site by thermal methods to the appropriate cleanup level. These options recognize the overall goal to remediate and/or recycle impacted materials onsite to the greatest extent possible, thus reducing overall regional impacts such as the transportation burden to local streets and the associated air emissions that would be HR701817VBA09 -07 RPT 17 8/21/2009 Ge os yntec D T experienced with mass soil export, or the use of landfill capacity for otherwise recyclable resources. Material export options would be used sparingly as appropriate. Development of portions of the Site will require substantial grading for road infrastructure, geotechnical stability work, and for general site improvements. In the event that some impacts are encountered during development, similar remediation procedures will be enacted pursuant to contaminants found. In some of the open space and road areas requiring backfill, treated and lightly impacted soils may be recycled into the substructure. The abandoned oil wells in the development areas will be managed per DOGGR regulations, and the potential for combustible gases in the subsurface will be mitigated in the development areas according to OCFA Guideline C -03. 5.4.5 Verification and Documentation As remediation and restoration activities are concluded in each area, a verification sampling program will be performed. This sampling program is designed to verify that the area meets the agency- approved criteria for environmental closure. This will involve collection of samples from appropriate environmental media (e.g., soil, groundwater, surface water) in each area, laboratory analysis of specified constituents, and evaluation of the results. This will likely be an iterative process, whereby additional targeted remediation and verification sampling may need to be performed until verification samples meet agency - approved criteria. In addition, the remediation activities will be monitored to evaluate compliance with appropriate Site dust, odor and emission control requirements. Following approval of the development project, a Storm Water Pollution Prevention Plan ( SWPPP) will be prepared prior to initiating site -wide remediation activities. The SWPPP will document best management practices (BMPs) that will be in place and monitored during the course of remediation activities. The results of the verification process will be documented and submitted to the agencies in a Cleanup and Closure Report for their review and approval. Each area will be deemed complete when the environmental Oversight Agencies approve the Report and grant closure or No Further Action. HR701817VBA09 -07 RPT 18 8/21/2009 Ge os yntec D T 6. SUMMARY AND CONCLUSIONS Since actual remediation activities are dependent on the final approved development alternative, this dRAP is for informational and planning purposes only. As is the normal procedure, a formal and detailed RAP will be finalized and submitted to the environmental oversight agencies at a later date when: 1. there is a better understanding of the potential of the development permitting and of the oil field consolidation actually occurring, and 2. there is a better understanding of the timeframe in which the oil field consolidation and remediation may actually happen after approvals are granted. HR1018/NBA09 -07 RPT 19 8/21/2009 Ge os yntec D T ASTM E 1527 - 05, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, American Society for Testing and Materials, Philadelphia, PA, November 2005. California Department of Conservation, Division of Oil, Gas, and Geothermal Resources, "Abandonment /Reabandonment Guidelines," undated. California Department of Water Resources, "Progress Report on Ground Water Geology of The Coastal Plain of Orange County," July 1967. California Department of Water Resources, "Sea -Water Intrusion: Balsa Sunset Area, Orange County," 1968. California Regional Water Quality Control Board (Santa Ana Region), Letter from Ms. Dixie Lass to Mr. Leonard Anderson, dated 28 September, 1995. California Regional Water Quality Control Board (Santa Ana Region), Letter to Leonard Anderson, West Newport Oil Company, "Leachability Study and Proposed Environmental Plan for Asphalt -Like Materials," 28 September 1995. California Regional Water Quality Control Board (Santa Ana Region), Letter from Gerard J. Thibeault, Executive Office to Mr. Robert Armstrong (Armstrong Petroleum) and Mr. George Bayse (Aera Energy, LLC) transmitting Clean -Up and Abatement Order No. 07 -77, dated 12 July 2001. California Regional Water Quality Control Board (Santa Ana Region), Clean -Up and Abatement Order No. 01 -77 for West Newport Oil Company, Armstrong Petroleum Corporation, Aera Energy, LLC, and Rancho Santiago Partnership, Newport Beach, California, 12 July 2001. California Regional Water Quality Control Board (Santa Ana Region), Clean-Up and Abatement Order No. 01 -77 Status Letter. 15 October 2003. Department of Conservation Division of Oil, Gas, and Geothermal Resources, excerpts from A Study of Abandoned Oil and Gas Wells and Methane and Other Hazardous Gas Accumulations," 10 October 1986. Department of Water Resources, Santa Ana Gap Salinity Barrier, Orange County: Bulletin No. 147 -1, 178 pp., 1966. HR101&7VBA09 -07 RPT 20 8/21/2009 Ge os yntec D consulumts GeoScience Analytical, Inc., A Study of Abandoned Oil and Gas Wells and Methane and Other Hazardous Gas Accumulations, Department of Conservation, Division of Oil and Gas, Roberti Bill, SB 1458, Methane Gas Study, Contract Number 2 -5098, 10 October 1986. Geosyntec Consultants (formerly GSI Environmental), "Santa Ana River Marsh Environmental and Geotechnical Sampling and Study Report," prepared for U.S. Army Corps of Engineers, Los Angeles, California, Sept. 1989. Geosyntec Consultants, "Phase I Environmental Site Assessment, Newport Banning Ranch, West Newport Oil Company, Orange County, California," 10 October 1993. Geosyntec Consultants, "Draft Summary Report, Environmental Restoration, Newport Banning Ranch, West Newport Oil Company, Newport Banning Ranch, Orange County California," prepared for West Newport Oil Company, Costa Mesa, California, 31 January 1996. Geosyntec Consultants, "Draft Report, Phase I Description, Environmental Restoration, Newport Banning Ranch, West Newport Oil Company, Orange County California," prepared for West Newport Oil Company, Costa Mesa, California, 31 January 1996. Geosyntec Consultants, "Summary Report, Environmental Restoration Project (SRER), Newport Banning Ranch, Orange County, California," 31 January 1996. Geosyntec Consultants, "Environmental Assessment, Newport Banning Ranch, Orange County, California," prepared for West Newport Oil Company, Costa Mesa, California, Vol. 1 and 2, November 2001. Geosyntec Consultants, "Environmental Assessment Summary and Remedial Action Plan, Cement Returns Area, Newport Banning Ranch, Orange County, California," prepared for West Newport Oil Company, Costa Mesa, California,) July 2002a. Geosyntec Consultants, "Lowland Stockpile Assessment and Remedial Action Plan, Newport Banning Ranch, Orange County, California," Report prepared for West Newport Oil Company, prepared by GeoSyntec Consultants and Glenn Lukos Associates, dated 2 December 2002b, transmitted to RWQCB -SA under cover letter dated 26 November 2002 by West Newport Oil Company. Geosyntec Consultants, "Environmental Assessment Summary, Remedial Action Plan, Free Product Area, Newport Banning Ranch, Orange County, California," prepared for West Newport Oil Company, Costa Mesa, California, 2 December 2002c. HR701817VBA09 -07 RPT 21 8/21/2009 Ge os yntec D T Geosyntec Consultants, "Remedial Action Progress, Cement Returns Area, Newport Banning Ranch, Orange County, California," Letter to Mr. Leonard Anderson of West Newport Oil Company, 4 December 2002d. Geosyntec Consultants, "Table 1, Summary of Analytical Results, Surface Water Sampling and Laboratory Data — Surface Water," Transmittal to the California Regional Water Quality Control Board dated 3 March 2003. Glenn Lukos and Associates, "Biotechnical Report for the Newport Banning Ranch," 22 April 2009a. Glenn Lukos and Associates, "Habitat Restoration Plan for the Newport Banning Ranch," 22 April 2009b. Mitech, "Sampling and Chemical Analysis Study on Material to be Excavated and Disposed of from the Santa Ana River Marsh, Lower Santa Ana River Channel Area, California," prepared by Mitech, Santa Ana, California, for the U.S. Army Corps of Engineers, Los Angeles, California, dated February 1988. Orange County Health Care Agency, letter from Mr. Luis Lodrigueza to Mr. Leonard Anderson, dated 20 December 1993. Orange County Health Care Agency, letter from Mr. Luis Lodrigueza to Mr. Leonard Anderson, dated 21 April 1994. U.S. Army Corps of Engineers Design Memorandum No. 1, "Phase II GDM on the Santa Ana River Mainstream, Including Santiago Creek," 1988. HR101817VBA09 -07 RPT 22 8/21/2009 Ge os yntec D consukants Tables HRIOI&7VBA09 -07 RPT 8/21/2009 Geosyntee Consultants TABLE 1 SUMMARY OF ENVIRONMENTAL SAMPLING /TESTING /ASSESSMENT HISTORY NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA APPROXIMATE SUBJECT /SCOPE COMMENTS SAMPLING DATE March 1986 Soil and Surface Water Up to 14% petroleum hydrocarbons in soil samples. Low metals concentrations in soil and Assessment (lowland surface water samples. Low to non - detectable hydrocarbons concentrations in surface water western portion of the site) samples. Low detection of VOC in surface water. No detection of polychlorinated biphenyls (PCBs). June 1986 Surface Water and Shallow No VOC detected in surface water samples. One chlorinated compound, vinyl chloride detected Ground Water Assessment at 40 µg/1 in a groundwater sample collected from the vicinity of the maintenance building sump. (lowland western portion of Several aromatic compounds (ethylbenzene, toluene, and xylenes) detected in three groundwater the site) samples at concentrations below I ppm near the Maintenance Shop. August 1990 Tank Bottom Materials and Up to 32% hydrocarbons in samples, BTEX detected in some soil samples, though when Asphalt -Like Materials hydrocarbon concentrations were below 1000 ppm, BTEX concentrations were below 0.1 ppm. Assessment (lowland western portion of the site) July 1991 Tank Bottom Materials Tank Bottom Materials do not exhibit the properties of a hazardous waste Assessment (lowland western portion of the site) HR 1018INBA09 -07 TI.DOC 1 of 4 7/15/2009 Geosyntee Consultants TABLE 1 (continued) SUMMARY OF ENVIRONMENTAL SAMPLING /TESTING /ASSESSMENT HISTORY NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA APPROXIMATE SUBJECT /SCOPE COMMENTS SAMPLING DATE October 1993 Phase I Environmental Site The following recognized or potentially - recognized environmental conditions: petroleum - (Geosyntec Consultants) Assessment impacted soils, solid waste and debris, above ground- storage tanks, underground storage tanks, parts - cleaning troughs, oil- production wells, empty 55 gallon drums, non - operative motor vehicles, construction debris, surplus equipment, a sewer main, and septic tanks. November 1993 Soil Gas Survey (various Organic vapors in oil well sumps and in storage tanks. site locations) December 1994 Baseline Ground Water and Up to 2,000 ppm hydrocarbon concentration in soil samples, metals concentrations were within Soil Study (lowland western the typical range of metals concentrations in soils, benzene detected at a concentration of 0.6 µg/1 portion of the site) (0.1 µg /1 above the laboratory detection limit) in one of four groundwater samples. May 1995 Leachability of Asphalt- No VOC, SVOC, or hydrocarbon detected in the extract from the leached asphalt -like material. Like Materials Barium was detected at a concentration of 0.8 ppm. June 1995 Drilling Mud Pit Evaluation Metals concentrations were within the typical range of metals concentrations in soils, VOC and (limited locations) SVOC not detected, hydrocarbons concentrations below 1,000 ppm. September 1995 Soils beneath NBR Statistical sampling indicated that VOCs were not detected below natural gas pipelines, sulfite Pipelines (primarily not detected below steam pipelines, metals concentrations were within the typical range of metals southern portion of the site) concentrations in soils. HR1018INBA09 -07 TI.DOC 2 of 4 7/15/2009 Geosyntee Consultants TABLE 1 (continued) SUMMARY OF ENVIRONMENTAL SAMPLING /TESTING /ASSESSMENT HISTORY NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA APPROXIMATE SUBJECT /SCOPE COMMENTS SAMPLING DATE July 1996 Soils Below Drill Site Vertical extent of impact below the tank footprints is generally less than 8 ft (2 m). The average Tank Farm Area (adjacent TRPH detected ranged from approximately 12 ppm to 41,000 ppm. VOC and SVOC not to tank footprints) detected and metals were representative of typical background concentrations November 2001 Environmental Assessment This report includes a description of the comprehensive site investigation activities conducted (Geosyntec Consultants) May through August 2001. The report presents the nature and extent of potential impacts to soil and groundwater at each of the PEC areas. Earlier VOC detections in groundwater (1986) confirmed. Also identified a free- product area on top of groundwater at the Drill Site Tank Farm and soil gas bubbling to the surface near the Tank Farm. July 2002 Site Assessment of Cement Performed in response to the CAO issued by the RWQCB -SA. Based on the results of this (Geosyntec Consultants) Return Area (near Drill Site preliminary evaluation, approximately 750 yd' of stained soil requiring mitigation was present in Tank Farm) the cement return area. Area was mitigated and closed per RWQCB -SA. December 2002 Lowland Stockpile Performed in response to the CAO issued by the RWQCB -SA. A total of 2.87 acres may have (Geosyntec Consultants) Assessment been disturbed at the Site by either concrete debris or soils, or clearing areas of vegetation. Area was mitigated and closed per RWQCB -SA. December 2002 Environmental Assessment Summarizes the status of investigation in the Drill Site Tank Farm Area and proposes a remedy (Geosyntec Consultants) Summary, Remedial Action to address the presence of free product floating on top of groundwater. Area currently being Plan, Free Product Area mitigated in accordance with RWQCB-SA- approved plan. HR1018INBA09 -07 TI.DOC 3 of 4 7/15/2009 Geosyntec Consultants TABLE 1 (continued) SUMMARY OF ENVIRONMENTAL SAMPLING /TESTING /ASSESSMENT HISTORY NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA APPROXIMATE SUBJECT /SCOPE COMMENTS SAMPLING DATE March 2003 Surface Water Sampling performed in response to the CAO issued by the RWQCB -SA. This transmittal documents that (Geosyntec Consultants) and Laboratory Data surface water quality is within acceptable standards. Issue is closed per RWQCB -SA. March 2008 Environmental Site Report for the owner /developer partnership for the purpose of updating historical (Geosyntec Consultants) Assessment Update information and listing Site activities occurring between 2005 through early 2008. Notes: Certain of the sampling events or data compilation activities were not documented in a formal report or study; highlights of selected sampling events are provided herein. VOC = Volatile Organic Compound SVOC = Semi - Volatile. Organic Compounds ppm = parts per million mg /1= milligrams per liter ug /I = micrograms per liter yd' = cubic yards BTEX = Benzene, Toluene, Ethylbenzene, and Xylenes RWQCB -SA = Regional Water Quality Control Board, Santa Ana Region HR1018INBA09 -07 TI.DOC 4 of 4 7/15/2009 Geosyntee Consultaats TABLE 2 POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE TI EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT UPDATE NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 01 Maintenance Shop / Warehouse • waste oil sump • 5,500 • stockpiled transformers • hazardous chemicals and petroleum hydrocarbons in use • abandoned vehicles • 2001 testing program results indicated localized areas of soil impacts and the presence of low concentrations of VOCs in groundwater 02 Drill Site Tank Farm • above ground storage tanks • 44,500 • oil and gas dewatering operations • natural gas treatment • underground sump • 2001 testing program results indicated areas of deep soil impacts (to groundwater) and the presence of free product in groundwater HRIO18INBA09 -07 T2.DOC 1 Of 9 7/l5/2009 Geosyntee Consultants TABLE 2 (continued) POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE II EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 03 Air Compression Plant (currently above ground storage tanks • 2,000 inactive) • vehicle fueling area (near) • parts cleaning trough • underground sump • 2001 testing program results indicated localized areas of soil impacts 04 Steam Generation Plant (currently . possible chemical spills and /or leaks from past • 1,000 inactive) operations • 2001 testing program results indicated localized areas of soil impacts 05 Water Softening Plant (currently • above ground storage tanks • 0 inactive) • possible chemical spills and /or leaks from past operations • 2001 testing program results did not indicate impacts at this location HR101817VBA09 -07 72.DOC 2 of 9 7/15/2009 Geosyntee Consultants TABLE 2 (continued) POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE II EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 06 Secondary Tank Farm (currently out- above ground storage tanks • 1,500 of- service) • oil and gas dewatering operations • natural gas treatment • underground sump • 2001 testing program results indicated localized areas of soil impacts and no groundwater impacts 07 Pilot -Scale Bioremediation Cell • bio- treatment cell area • 5,000 • stockpiled, unlined, impacted soil • treated soil stockpile canyons (near) • 2001 testing program results indicated localized areas of soil impacts 08 Former Sumps and Clarifiers (south of • possible leaching of crude oil from the sumps /clarifiers • 19,500 the Drill Site Tank Farm) to the ground • 2001 testing program results indicated areas of soil impacts and no groundwater impacts HR101817VBA09 -07 72.DOC 3 of 9 7/15/2009 Geosyntee Consultants TABLE 2 (continued) POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE II EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 09 Electrical and Transformer Storage possible PCB leaks from electrical transformers 50 • 2001 testing program results indicated localized areas of hydrocarbon soil impacts - PCBs were not detected 10 Transformer Mounts • possible PCB leaks from electrical transformers • <2 • 2001 testing program results indicated localized areas of hydrocarbon soil impacts - PCBs were detected at levels exceeding residential preliminary remediation goals (PRGs) at this location I 1 Offices / Changing Rooms • septic wastes • 0 • possible solid waste disposal areas (near) • 2001 testing program results did not indicate impacts at this location HR101817VBA09 -07 72.DOC 4 of 9 7/15/2009 Geosyntee Consultants TABLE 2 (continued) POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE II EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 12 Area immediately adjacent to City of above ground storage tanks • <2 Newport Beach Tank Farm (boundary . oil and gas dewatering operations conditions) . natural gas treatment • underground sump • 2001 testing program results indicated localized areas of soil impacts 13 Not Applicable a this PEC was grouped with another PEC • NA 14 Not Applicable . this PEC was grouped with another PEC • NA 15 Underground Storage Tanks and Fuel . possible gasoline leaks from UST, however UST was • <2 Pump closed per regulations • 2001 testing program results indicated a localized area of soil impacts 16 Coast Watch Station • miscellaneous debris and municipal solid waste, • 0 although no evidence of this material currently exists 2001 testing program results did not indicate impacts at this location HR101817VBA09 -07 72.DOC 5 of 9 7/15/2009 Geosyntee Consultants TABLE 2 (continued) POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE II EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 17 Oil and Gas Production Equipment possible teaching of materials from the equipment to the • 0 Storage ground • 2001 testing program results did not indicate impacts at this location 18 Concrete Cellar Stockpile and . possible leaching of materials from the debris to the • 0 (petroleum impacts) Miscellaneous Debris Stockpiles ground . 15,000 (concrete) • 2001 testing program results indicated that additional testing would be needed in this area following concrete debris removal 19 Abandoned Shack • possible chemical spills and /or leaks from past • 0 operations 2001 testing program results did not indicate impacts at this location HR101817VBA09 -07 72.DOC 6 of 9 7/15/2009 Geosyntee Consultants TABLE 2 (continued) POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE II EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 20 Miscellaneous Debris and Soil possible leaching of materials from the equipment and • 2,000 Stockpiles debris to the ground • 2001 testing program results indicated impacts to stockpiled soils awaiting treatment 21 Miscellaneous Debris Stockpiles . possible leaching of materials from the equipment and • 0 debris to the ground • 2001 testing program results indicated that additional testing would be needed in this area following debris removal 22 Soil Stockpiles • possible leaching of materials from the soil to the ground • 0 • 2001 testing program results did not indicate impacts at this location HRI018/NBA09 -07 T2.DOC 7 of 9 7/15/2009 Geosyntee Consultants TABLE 2 (continued) POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE II EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 23 Equipment Storage possible leaching of materials from the equipment to the • 0 ground • potential oil leaks • 2001 testing program results indicated that additional testing would be needed in this area following equipment removal 24 Main Office • septic wastes • 0 • possible solid waste disposal areas (near) • 2001 testing program results did not indicate impacts at this location 25 Oil Well Pads and Linear Features • tank bottom materials • 52,500 (petroleum soils) (roadways and pipelines) • ail- impacted soil • 93,000 (asphalt /roads) • concrete cellar • debris • Previous testing program results indicated localized soil impacts along these features HR101817VBA09 -07 72.DOC 8 of 9 7/15/2009 Geosyntee Consultants TABLE 2 (continued) POTENTIAL ENVIRONMENTAL CONDITIONS IDENTIFIED IN PHASE II EA AND PHASE I ENVIRONMENTAL SITE ASSESSMENT NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA (March 2008) PEC DESIGNATION ORIGINAL RATIONALE FOR PEC LISTING ESTIMATED SOIL TO BE MANAGED (cubic yards) 26 Drilling Mud Sumps / Oil Well Sumps oil - impacted soil • 4,500 • drilling mud • debris • Previous testing program results indicated localized soil impacts 27 Sublease Areas • impacted soil • unknown • 2001 testing program results did not focus on sublease areas PRELIMINARY ESTIMATE OF MATERIAL QUANTITIES TO BE REMEDIATED (approximate) 138,000 (petroleum soils) 108,000 (concrete, asphalt/road material 246,000 Total HR101817VBA09 -07 72.DOC 9 of 9 7/15/2009 Geosyntec Consultants TABLE 5 SUMMARY OF HISTORIC CLEANUP LEVELS NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA LAND USE DEPTH FROM CHEMICAL CONSTITUENT ALLOWABLE FINAL GRADE AND EPA METHOD USED TO CONCENTRATION (below ground VERIFY CONCENTRATION* (mg/kg) surface) 2001 RWQCB -SA Residential 0 -15 feet TRPH (EPA 418.1) 100 (screening tool only) TPH (EPA 8015M w/ carbon chain 100 /1,000 * ** (Impacted & Remediated identification from C13 -C23 inclusive) Soil) BTEX (EPA 8021b) ** B =ND, T =0.1, E =0.68, X =1.75 VFH (EPA 8015M) ND > 15 feet TRPH (EPA 418.1) 5,000 TPH (EPA 8015M w/ carbon chain 5,000 identification from C13 -C23 inclusive) BTEX (EPA 8021b) ** B =0.10, T =10, E =681 X =175 VFH (EPA 8015M) 100 Non — 0 —15 feet TRPH (EPA 418.1) 1,000 (screening tool only) Residential TPH (EPA 8015M w/ carbon chain 1,000 (Impacted & identification from C13 -C23 inclusive) Remediated BTEX (EPA 8021b) ** B =ND, T =0.1, E =0.68, X =1.75 Soil) VFH (EPA 8015M) 100 > 15 feet TRPH (EPA 418.1) 15,000 TPH (EPA 8015M w/ carbon chain 5,000 identification from C13 -C23 inclusive) BTEX (EPA 8021b) ** EPA Residential PRGs B =0.65, T =520, E =230, X =210 VFH (EPA 8015M) 500 Notes: Based on the type of hydrocarbon impact encountered one or more of these analyses may be required ** Positive results confirmed with EPA Method 8260) **" 1,000 mg/kg allowed if the soil has no apparent hydrocarbon odor or stain; if odor or staining is apparent, 100 mg/kg will be used TRPH = Total Recoverable Petroleum Hydrocarbons TPH = Total Petroleum Hydrocarbons BTEX = Benzene, Toluene, Ethylbenzene, and Xylenes VFH = Volatile Fuel Hydrocarbons mg/kg = milligrams per kilogram ND = Non - detect PRG = Preliminary Remediation Goal (EPA Region IX) C13 -C23 = Carbon Chain length (numbers indicative of number of carbon atoms in the hydrocarbon chain) Asphaltic Fill Materials and Remediated Soil will be placed at least 15 feet below Final Grade Greater than 25 feet below Final Grade — concentrations shall meet EPA Residential PRGs, TRPHrrPH up to on -site concentrations, VFH not to exceed 500 mg/kg HRI018INBA09 -07 TS.DOC 1 of 2 7/15/2009 Geosymee Consultants TABLE 5 (continued) SUMMARY OF HISTORIC CLEANUP LEVELS NEWPORT BANNING RANCH ORANGE COUNTY, CALIFORNIA LAND USE DEPTH FROM CHEMICAL CONSTITUENT ALLOWABLE FINAL GRADE AND EPA METHOD USED TO CONCENTRATION (below ground VERIFY CONCENTRATION* (mg/kg) surface) 1996 Agency — Approved Residential 0— 10 feet TPH (method not specified) 100 > 10 feet TPH (method not specified) 10,000 (OCHCA Review Required) TPH (method not specified) 10,000 - 20,000 (RWQCB -SA Review Required) TPH (method not specified) >20,000"' (OCHCA & RWQCB -SA, Review Required) Commercial 0— 3.5 feet TPH (method not specified) 1,000 or Open Space >3.5 feet TPH (method not specified) 10,000 (OCHCA Review Required) TPH (method not specified) 10,000 — 20,000 (RWQCB -SA Review Required) TPH (method not specified) >20,000") (OCHCA & RWQCB -SA, Review Required) Notes: OCHCA = Orange County Health Care Agency RWQCB -SA = Regional Water Quality Control Board, Santa Ana Region (l) Areas having values of soil TPH > 20,000 mg/kg would require gas monitoring with methane ¢5% Lower Explosive Limit to remain in -place HRIO18INBA09 -07 T5.D0C 2 Of 2 7/15/2009 Ge os yntec D consukants Figures HRIOI&7VBA09 -07 RPT 8/20/2009 COUNTY OF LOS ANGELES SEAL IlBQJNT➢NG7EIDN ]B]EACII3[ NEWPORT BEACH NEWPORT BANNING RANCH N.13F III h urs ��I• Mils �nl.11 IIAGUNNA "K,, ]BEACH P A C I F I C 0 C E A N 22 h'y SUNSET <D5 l/ APARKIC a ti aII BEACH COASTAL SUNSET BEACH ZONE BOUNDARY COSTA HUNTINvIIO14 1>1 UTZA BEACH HUNTINGTON BEACH PIER NEWPORT PACIFIC BANNING OC OCEAN RANCH NEWPORT BEACH COUNTY OF SAN BERNARDINO ORANGE COUNTY CALIFORNIA COUNTY OF RIVERSIDE Clevelnnd NotjoY,M Forest \ LAKE �'C P�OII$07 x 4 SAN DQJAN CAMSTRANO COUNTY OF SAN DIEGO SAN C]LEME,N7E EWPORT DUNES Figure 1 NEWPORT BANNING RANCH Site Location Map REMEDIAL ACTION PROGRAM I I ® G2OSjRltCC� OFUSCOE City of Newport Beach - California D OCT mmultmts ...I..... r-'N� Figure 2 NEWPORT BANNING RANCH Topographic Areas and Features Map REMEDIAL ACTION PROGRAM I I I 1 GOOSjTtBC D FUSC i j1 City of Newport Beach - California r .. 900 consultants .. .. .. 07 -14-2009 SWImn%moks stre lRg \lR9001b8yis�pmd=sS p x�VOpo Bk11 NOP1914mxd �j 1d C o 0 c� 0 0 VWM�N I 6, •r, Z • — o,-1lw� i�71 °aro .� to o`e� �• or.iMlr�j� /I o j%i•i IN to o•_. �K -'r • o� Cam• •�I.� ,, �• • oo, r Ahern o�• - -� _ , iF- LEGEND Plan Boundary ® Abandoned Oil Wells Active I Potentially Active Oil Wells Utility Poles Oil Pipeline Corridors 1947 Oil Sumps _ Offield Operation Areas t R :.Am r -TI , L Figure 3 NEWPORT BANNING RANCH Historic Oilfield Impacts Map REMEDIAL ACTION PROGRAM n1 GeOSyIAWC(� fomv� City of Newport Beach - California o soo t,2oo cnnsuita,ns FUSCOE 07• 1a•zoos s,a'j_Wa M—t M0714 -m ---------- - - - - -- 9 — — - - - - - -- Street it it a j ji �.' ,etnnraat –..------------------ ` ,a e 3 —Oil Consolidation Site ti „ _ t s t rea - -- ACOe t Wetlands _-[I,. NewM1all Straet Restoration Area 16 M Street —. -_ Oil Access Road — — V tr_ "r '�traat -Oil Operation Site hr I Sunset Ridge Park 9 C H (-Ni Figure 4 NEWPORT BANNING RANCH Oil Consolidation Areas REMEDIAL ACTION PROGRAM r 1 li City of Newport Beach - California ` J �OSjrTl1.8C .` FUSCOE 0 900 consultants .. , .. , . , . , m -14-2009 $\tlle moka_stred ingNIM9001108yWpmdu srr p xdlvil areas 8k11_4090110.md � x 17 e s e / c ti Q / m .+ 1 :T s �.� 4 4 AcoE 23 •. Wetlands 2 ` _ P Restoration`'' 3 15 Area R 19th Street r 1 7J Sri— . i-Allkliftl _- +c ,- ewhall street' iu, 1 Sw Sir \ 10 Approximate Location of Edison Transformers 21 I _ 11 Personnel Changing Room and Showers I''y r', • 12 Salim 12 City of Newport Beach Oil Operations _ 15 Gasoline UST 18 '� 16 Coast Watch Station :; ,,' •, - 17 Oil / Gas Production Equipment Storage 22 \' ' .EGEND Soil Dallas Stockpiles �_ � 1 � 19 0 Plan Boundary Park �, Preliminary Environmental Conditions r •n. 1 Maintenance Shop /Warehouse 9 ' 2 Main Site Tank Farm (Active) "�� , t 3 Air Compressor Plant ' e 4 Steam Generation Plant 5 Water Softeners 6 City of Newport Beach Tank Farm (Abandonec ) ,- 6 7 Pilot Scale Biotreatment Cell/ Stockpiled Soil �;. �'��' 16 6 Former Sump /Clarifier: 9 Utility Shack Transformer Storage ��* • t'+. 19th Street r 1 7J Sri— . i-Allkliftl _- +c ,- ewhall street' iu, 1 Sw Sir \ 10 Approximate Location of Edison Transformers 21 I _ 11 Personnel Changing Room and Showers I''y r', • 12 •' 12 City of Newport Beach Oil Operations _ 15 Gasoline UST �, '� F 24 '� 16 Coast Watch Station :; ,,' •, - 17 Oil / Gas Production Equipment Storage ` • • 27 ' 18 Soil Dallas Stockpiles �_ I cunset Ridge 19 Storage Shack �. Park 20 Sail / Debris Stockpiles 21 Sail / Debris Stockpile 22 Treated Soil Stockpile Area 23 Equipment / Debris Stockpiles h 24 Field Offices 27 Sublease Area r PECS formerly designated as #13 & #14 have been grouped with other Non- specif ic area PECs: PEC #25 — Oil Well Pads and Linear Features (roadways /pipelines) PEC 426 — Drilling Mud Sumps / Oil Well Sumps r.cr� Figure 5 NEWPORT BANNING RANCH PEC Location Map REMEDIAL ACTION PROGRAM I I I I I rf1 Geosyntec "' FoliN1� City of Newport Beach - California 91 FUSCOE 0 900 consultants . I ..... 07-14-2009 Wclientsibmoks street 112511 n9001W8,iWpmduds4epMWSlpec 8x11_h000714.mxd Figure 6 NEWPORT BANNING RANCH Estimated Remedial Excavation Areas REMEDIAL ACTION PROGRAM I I I I Geosyntec° 46-610 FolilVV� City of Newport Beach - California FUSCOE 0 900 consultants ......... 0] - 14.2009 Wdie Wb.ks street_ Bxi1 _fs099714,mxd Ge os yntec D consukants Appendix A Orange County Fire Authority Guideline C -08 Combustible Soil Gas Hazard Mitigation HRIOI&7VBA09 -07 RPT 8/20/2009 ORANGE COUNTY FIRE AUTHORITY Planning & Development Services Section 1 Fire Authority Road, Building A Irvine, CA 92602 714 -573 -6100 www.ocfa.org Combustible Soil Gas Hazard Mitigation Approved and Authorized by Guideline C -03 Laura Blaul Fire Marshal / Assistant Chief Date: January 1, 2008 Serving the Cities of. Aliso Viejo, Buena Park • Cypress • Dana Point • Irvine • Laguna Hills • Laguna Niguel • Laguna Woods • Lake Forest • La Palma • Los Alamitos • Mission Viejo • Placentia • Rancho Santa Margarita • San Clemente • San Ivan Capistrano • Seal Beach • Stanton • Tustin • Villa Park Westminster • Yorba Linda • and Unincorporated Areas of Orange County Orange County Fire Authority Page I of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 Combustible Soil Gas Hazard Mitigation This document is intended to serve as Orange County Fire Authority (OCFA) guidance for the scientific investigation, remediation, and /or mitigation of potentially hazardous concentrations of combustible soil gases associated with the construction and occupancy of a building or structure located within the areas specified herein. These guidelines shall apply to all of the following locations: 1. Any location within an administrative boundary or a distance less than or equal to 100 feet beyond the administrative boundary of any oil/gas field that has been defined by the Division of Oil, Gas, and Geothermal Resources (D.O.G.G.R.). 2. A distance less than or equal to 100 feet from any active or abandoned oil/gas well that is not located within the administrative boundary of an oil field as defined by the D.O.G.G.R. Exception: This guideline shall not apply to any Hydrocarbon Free Oil /Gas Well as defined in these guidelines when complete surface to total depth data has been provided to D.O.G.G.R. for review and certification and such certification is provided to the OCFA. 3. A distance of less than or equal to 300 feet from any gas seepage zone. 4. For locations within the city of Yorba Linda, refer to Yorba Linda Policy 26.• Methane Gas Investigation and Mitigation for Existing Homes Undergoing Expansion or OCFA Informational Bulletin 05 -03. 5. A distance less than or equal to 1000 feet from the refuse footprint of any existing or new disposal site or Class II or III Municipal Solid Waste Landfill Unit described in Title 27 CCR, Chapter 2. The landfill or disposal site may be operating or closed, abandoned or inactive. 6. Any other location identified by the OCFA as being subject to gas migration from a potential source of a combustible gas. The following definitions are provided to facilitate the consistent application of this guideline: Abandoned Oil /Gas Well - A well that has been plugged and abandoned to D.O.G.G.R. standards. Rev. 01 -08 Orange County Fire Authority Page 2 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 Active Methane Detection - A system of components designed to detect specified concentrations of combustible gas within a structure and to warn the occupants via audible /visual alarms when such concentrations are detected. Administrative Boundary - The boundary delineating the surface area which is underlain or reasonably appears to be underlain by one or more oil and/or gas pools as defined by the State of California, Division of Oil, Gas, and Geothermal Resources (D.O.G.G.R.). Forced Air Venting System - A mechanically operated ventilation system designed to provide the necessary number of air changes/hour for the purpose of maintaining combustible gas concentrations at a safe level within a building. Gas Membrane Barrier - A barrier installed beneath a structure's slab foundation for the purpose of minimizing the intrusion of combustible soil gas. Gas Seepage Zone — Any location where natural gas emerges at the surface from a subsurface source. Hydrocarbon Free Oil /Gas Well - Any well drilled with the expectation of, but not finding, hydrocarbon accumulations in any quantity. Mitigation Plan - A site specific plan prepared by a Registered Professional Engineer for the purpose of defining measures necessary for construction to take place within a location presenting a potential hazard due to the presence of combustible soil gases. Registered Professional - A California Registered Professional Engineer or Registered Professional Geologist or other credentialed professional with demonstrated proficiency in the subject of soil gas investigation and mitigation and found acceptable to OCFA. Soil Gas Investigation - A scientific investigation reviewed and approved by OCFA, conducted by a Registered Professional for the purpose of determining the locations and concentrations of combustible soil gas. Sub -Slab Passive Venting - A non - powered system of components located beneath and/or within a structure and designed to vent accumulations of combustible soil gas to the atmosphere. Well - Any well defined in California Public Resources Code Division 3, Chapter 1, section 3008(a)(b) and Chapter 4, section 3703, as described below: 3008 (a): "Well" means any oil or gas well or well for the discovery of oil or gas; any well on lands producing or reasonably presumed to contain oil or gas; any well drilled for the purpose of injecting fluids or gas for stimulating oil or gas recovery, repressuring or pressure maintenance of oil or gas reservoirs, or disposing of waste fluids from an oil or gas field; any well used to inject or withdraw gas from an underground storage facility; or any well drilled within or adjacent to an oil or gas pool for the purpose of obtaining water to be used in production stimulation or repressuring operations. (b): Rev. 01 -08 Orange County Fire Authority Page 3 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 "Prospect well" or "exploratory well" means any well drilled to extend afield or explore a new, potentially productive reservoir. 3703. "Well' means any well for the discovery of geothermal resources or any well on lands producing geothermal resources or reasonably presumed to contain geothermal resources, or any special well, converted producing well or reactivated or converted abandoned well employed for reinjecting geothermal resources or the residue thereof. 1. Building Restriction Zone To the maximum extent feasible, the slab or foundation for a proposed building shall not be constructed over or within 10 feet of an abandoned oil /gas well. If specific site characteristics make such a setback unfeasible, construction of structures may be allowed within the Building Restriction Zone provided that the following mitigation measures are incorporated. The proposed construction of one- or two- family dwellings within the Building Restriction Zone shall be subject to further evaluation and/or mitigation. A. A soil gas investigation and report, meeting the criteria contained herein, shall be conducted in the immediate vicinity (25 foot radius) of any abandoned oil /gas well that will be located within the Building Restriction Zone. The report shall be submitted to OCFA. B. The Mandatory Procedures for Mitigation specified in Section 4 of this guideline shall be applied. C. A Registered Professional shall review the soil gas investigation report and building plan and recommend soil gas mitigation measures, if any, that may be required for the site beyond those contained in this guideline. Any additional mitigation measures recommended shall be included in the Mitigation Plan. D. The abandonment of oil /gas wells located within the Building Restriction Zone shall have the current approval of the D.O.G.G.R. Their website is www.conservation.ca.gov /dog /for operators/Pages /construction site review faqs.aspx. The current approval shall meet the requirements applied by D.O.G.G.R. at the time the Mitigation Plan is submitted for review to OCFA. ** THE OCFA ADVISES AGAINST THE CONSTRUCTION OF ANY STRUCTURE OVER ANY WELL ** 2. Soil Gas Investigation A proposed building located within the areas specified in this guideline shall be approved only after a soil gas investigation has been completed and a report submitted to OCFA for review and approval. Rev. 01 -08 Orange County Fire Authority Page 4 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 A. The investigation and report shall be prepared by and conducted under the direct supervision of a Registered Professional. B. The report shall contain a detailed description of the site investigation including the methodology and the data collection techniques utilized. C. To the degree possible, the source(s) of any anomalous levels of methane shall be identified. D. The soil gas investigation report shall be subject to review and approval by a third party Registered Professional, if deemed necessary by OCFA. The applicant shall pay fees charged for the third party review. 3. Soil Gas Concentrations A. If the soil gas investigation report identifies combustible soil gas concentrations of 5,000 ppm or greater at any location(s), the Mandatory Procedures for Mitigation, as contained herein, shall be applied to all buildings within 300 feet of the affected location(s). B. If combustible soil gas concentrations in excess of 12,500 ppm are identified at any location(s), all buildings within 300 feet of the affected location(s) shall have a specific soil gas mitigation plan approved by a Registered Professional. C. The Mandatory Procedures for Mitigation pertaining to buildings located within the prescribed distances from abandoned oil /gas wells are required to be implemented regardless of the combustible soil gas concentrations identified during the soil gas investigation. D. Mitigation plans shall be subject to review and approval by third party Registered Professional, if deemed necessary by OCFA as stated above. 4. Mandatory Procedures for Mitigation Design and installation criteria for soil gas mitigation systems have been established and are detailed below. However, these criteria are not intended to limit the engineered design for any specific site (see Attachments 2 through 8 for examples). Prior to the installation of a soil gas mitigation system, plans shall be submitted to the OCFA for review /approval. All proposed designs shall be reviewed/stamped by a California Registered Professional Engineer. Proposed designs that vary significantly from the criteria below may be subject to review by a third party California Registered Professional Engineer. A. Source Removal: If all sources of combustible soil gas, such as crude oil impacted soil or oil field sumps, have been removed, isolated, or remediated such that no potential threat to buildings due to methane generation or migration remains, then no further mitigation in that area shall be mandatory unless recommended by a Registered Professional. All remediation shall be under the oversight and approval of Orange County Health Care Rev. 01 -08 Orange County Fire Authority Page 5 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 Agency, Environmental Health. B. Passive Venting of Abandoned Oil /Gas Wells: All abandoned oil/gas wells within 25 feet of any proposed building shall be vented. All wells within 300 feet of a proposed building that are also under or within five feet of a paved road, paved parking lot, or other continuous impermeable surface barrier where the continuous impermeable surface barrier is within 25 feet of the proposed building, shall be vented. In the event sufficient findings are made that well venting is not feasible, the OCFA (with D.O.G.G.R. concurrence) may allow a waiver of the venting requirement provided that additional mitigation measures described in section 4.F be made a part of the mitigation plan. NOTE: Mitigation systems may not be installed within the public right of way without prior approval from the City /County Engineer or Public Works Department. See Section 5 of this guideline. C. Sub -slab Passive Venting: A passive venting system shall be installed beneath the slab or foundation of a proposed building that is within: 1) 25 feet of an abandoned oil /gas well. 2) 25 feet of a continuous impermeable surface barrier (e.g.. paved road or parking lot) covering an abandoned oiUgas well that is located less than 300 feet from the building. 3) 300 feet of an active gas seep zone. 4) 300 feet of other anomalous combustible soil gas areas as identified in the Soil Gas Investigation Report, except as mitigated by source removal or remediation or except as identified in the Soil Gas Investigation Report as not posing a safety threat to occupied buildings due to its characteristics. D. The design for the sub -slab venting system shall be approved by a California Registered Professional Engineer. The design and installation shall be in accordance with the Uniform Building, Mechanical, and Plumbing Codes and meet the following criteria: 1) Ventilation trenches shall be placed such that no portion of the foundation is more than 25 feet from a ventilation trench. Trench cross section dimensions shall not be less than 12 inches by 12 inches. Ventilation trenches shall be back filled with pea gravel (approximately 3/8 inch in diameter) or other material of similar size and porosity. 2) Ventilation trenches shall be provided with perforated pipe of not less than 4 inches in diameter. The total pipe perforation area shall be at least equal to 5% of the total surface area of the pipe. Perforated pipe shall be located a minimum of 4 inches beneath the foundation. 3) Where piping transitions through building footings, the penetration shall be Rev. 01 -08 Orange County Fire Authority Page 6 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 accomplished in compliance with the Uniform Building Code and with the approval of the Building Official. 4) Perforated pipe shall be connected to vertical ventilation pipe. Vertical ventilation pipe shall be not less than 3 inches in diameter and shall be constructed of materials specified by the Uniform Plumbing and Mechanical Codes. All joints shall be tightly sealed with approved materials. Ventilation pipe may be located within walls /chases or shall be similarly protected from physical damage. Ventilation pipe shall be constructed in a manner that will allow it to be connected to an active venting system, if necessary, without modification or damage to the structure (e.g. Capped TEE fitting located near the foundation). Ventilation pipes shall terminate at a height determined acceptable by the designing engineer but not less than 18" above the adjacent level. Ventilation pipes shall be located at least three feet from a parapet wall. Ventilation pipes shall terminate at a distance of at least 10 feet from any building opening or air intake and at least four feet from any property line. Any ventilation pipe located within an open yard shall terminate at a height of not less than 10 feet above adjacent grade. 5) The termination of all ventilation pipes shall be provided with a "T" connection or other approved rain cap to prevent the intrusion of rainwater. 6) Ventilation pipe shall be clearly marked to indicate that the pipe may contain combustible gas. This may be accomplished through stencils, labels or other methods. Pipes shall be marked near their termination point and at five -foot intervals along the remainder of the ventilation pipe. This includes sections encased within walls or other enclosures. An acceptable identifier would be the words "METHANE GAS" printed in two -inch letters. 7) All underground electrical conduit penetrating the slab or foundation of the building shall be provided with a seal -off device as normally found on classified electrical installations. This device is intended to prevent the travel of gas into the occupied portion of the structure through conduit runs. Any device installed shall meet the applicable requirements of the California Electrical Code. E. Active Methane Detection/Forced Air Venting: A structure that will be built over an abandoned oit/gas well and where the ground floor is not naturally vented may be required to have an active interior methane detection system equipped with an audible alarm and /or additional mitigation measures based on the recommendation of the Registered Professional conducting the site specific soil gas mitigation review, which may include an active interior methane detection/forced air venting system capable of providing a minimum of four air changes per hour in the event methane concentrations within the building exceed 20% of the methane Lower Explosive Limit (LEL). F. Gas Membrane Barrier: Any building to be constructed in the areas specified by item #1 below shall be provided with a gas membrane barrier. Gas membrane barriers may be required for locations specified in items #2 through #4 unless a review and Rev. 01 -08 Orange County Fire Authority Page 7 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 recommendation by the Registered Professional states that a gas membrane barrier is not necessary. Exception: The building is of a structural design that provides natural ventilation to prevent the accumulation of combustible gas (e.g. an open parking garage at grade level). 1) 10 feet of an abandoned oil or gas well. 2) 25 feet of a continuous impermeable surface barrier (e.g. paved road or parking lot) that covers an abandoned oil/gas well that is less than 300 feet from the building. 3) 300 feet of an active gas seepage zone. 4) 300 feet of other anomalous combustible soil gas level areas identified in the Soil Gas Investigation Report except as mitigated by source removal or remediation or except as identified in the Soil Gas Investigation Report as not posing a safety threat to occupied buildings due to its characteristics. 5. Mitigation Plan Approval All reports, work plans, and mitigation plans shall be subject to the approval of the OCFA. Any methane mitigation system located within a public right of way shall also be subject to the approval of the City or County Engineer or Public Works Department. Many local agencies will restrict or prohibit the installation of methane mitigation systems within a public right of way. A public right of way includes any street, parkway, sidewalk, open space or similar area that has been or will be dedicated to a city or county. 6. Well Abandonment Oil and gas wells to be abandoned or re- abandoned shall be done so in accordance with the current requirements of the D.O.G.G.R. The abandonment requirements will be those applied by D.O.G.G.R. at the time the mitigation plan is submitted for review to the OCFA. Documentation of final abandonment approval from the D.O.G.G.R. shall be provided to the OCFA and the building department before occupancy is approved. 7. Construction Inspection Responsibility A Registered Professional Engineer shall perform the inspection of all gas control measures. In order to document the inspection process properly, the following signed and stamped certification shall be submitted to the OCFA prior to use of the building or OCFA's final approval of the project: • I am a Registered Professional Engineer in the State of California and I am knowledgeable in the field of combustible soil gas control and mitigation systems. • The soil gas control and mitigation systems installed within this project have been constructed under my direct supervision and in accordance with the plans reviewed by the OCFA. As -built plans are included with this statement. • The building has been tested and determined to be free from any concentration of gases that the control system was designed to mitigate. A copy of the test results is included Rev. 01 -08 Orange County Fire Authority Page 8 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 with this statement. In order to facilitate the construction approval process, periodic correspondence may be required to be provided to the field inspector representing OCFA or to the respective building department of the city in which the project is located. Such correspondence shall be provided at intervals required by the inspector and provide updated information regarding the status of inspection activities completed by the engineer responsible for the gas control system. 8. Gas Control System Maintenance and Testing The maintenance of all soil gas control systems shall remain the responsibility of the property owner. All systems shall be maintained as installed and as recommended by the manufacturer and/or system designer. The owner of the property shall be provided with written instructions stating the required service maintenance and testing for the soil gas mitigation systems installed. For systems requiring specialized testing to ensure proper operation, the property owner shall obtain the services of qualified personnel to accomplish such tests. Written documentation verifying that such tests were accomplished shall be retained by the property owner for a period of not less than five years and made available to the OCFA upon request. The OCFA may require any property owner to accomplish additional tests when there is reason to believe that the concentration of gas within or near the structure is elevated above the levels recorded at the time of the original soils gas investigation. 9. Additional Requirements of the California Fire Code This document is not intended to address the requirements of the California Fire Code pertaining to the location of a building in relation to an active oil /gas well. These requirements are found in Chapter 35 of the California Fire Code. The OCFA Planning & Development Services Section may be contacted for additional information. Rev. 01 -08 Orange County Fire Authority Page 9 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 ATTACHMENT 1 COMBUSTIBLE GAS STUDY CHECKLIST (to be completed by applicant) PROJECT INFORMATION Project Name: Primary Contact: Site Address (if available): Tract /Map #: Parcel Map Number: DEVELOPMENT AREA Development Density: Open Space: GEOLOGY /HYDROLOGY Oil Field Name: Groundwater Basin/Recharge Area Phone Number: City: Assessor's Parcel #: Area (acres): Paved Area: Number of Wells in Development Area: Producers: Steam Injectors: Water Injectors: Idle: Abandoned: Abandoned to Current Regulations: Depth (ft. BGS) of: Shallowest producing zone: Shallowest Oil or Gas Zone: Shallowest groundwater: Shallowest drinking water:_ Number of surface expressions of fault zones: (Show on map) Number of oil /gas seep zones: (Show on map) 1. Has a hazardous gas assessment been completed? 2. Is the hazardous gas assessment attached hereto? 3. Has the hazardous gas assessment included soil probes? 4. If yes, to what depth have the soil probes penetrated? 5. Has the hazardous gas assessment included soil borings? 6. If yes, to what depths have the soil boring penetrated? 7. The highest soil gas methane concentration identified was: 8. The background soil gas methane concentration identified was YES / NO YES / NO YES/ NO feet YES / NO feet ppm (v /v) ppm (v /v) 9. Is the applicant requesting any waivers from required mitigation? YES/ NO 10. If yes, what waiver(s) is being requested: Rev. 01 -08 Orange County Fire Authority Page 10 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January 1, 2008 COMBUSTIBLE GAS STUDY CHECKLIST (Continued) (to be completed by applicant) Summary of Gas Assessment Conclusions Area (Correlate to Map) Methane Level (ppm v/v range) Source Potential to Migrate (Yes/No) Migration (Note re uired actions) Source Structures Date Rev. 01 -08 Applicant Orange County Fire Authority Page 11 of 17 Guideline C-03 Combustible Soil Gas Hazard Mitigation January I, 2008 Lb G7 a W W Rev. 0 1 -08 ATTACHMENT 2 4v MIN, GRADE ST NIIN. 12. IV - € UT SLOPES PER "I OSHA AND PER SLVLS' T n_ €Ni3N�t °5 RIEPUR:IIf _ REC*OMWENO.ATIONS 11= 1111�-� -I U) ILC3J 7 .0 Hl. 711-1 TRIS ®IACHFILL :I EY GRADING 1d r] 111 -FI WNITRAGWR PER SPECWICATION•S _II - JI P II Bob 1 a BARRIER, III- _ "1- -1 dfEL1E&6N I.1 II IIII PER SPEC S A j .PIPE kI1 Al �1V 11 �1! _ a II 1 cq•4• ° 0 _II I !MIN, ^a'.0 OpE1d L i. o 'ro'n : '_ UTA: VAAIE =S 'PER SPIED 51 �I oa �o o II 1 ���� O - = 4` -0' MIN. CAP @L1T I Al OF PIPE. 3_ 12" MIN: CJi31NG °' - r e 111 - f $f4° ROOK SfilE —l1P Tm a till 0 — =m, -11x1 tr r� DW BRILL'HOLE 7111 101A. 'VARIES. REQUIRES I THIS 'VENT WITHIN I 16-01 OF FROG. E>a819N,6 PROPERLY C4 NG ABANQUNED W1" DIA, Fl -F. w 11 S3�orr VAR1EB PER lboO.G -G.R. STANDAROSz 411TH STEEL PLATE WEL02,0 COVER TOP- ELL HEAD 1 I,T'* NOT TO -GALE / GUIDELINE ONLY THIS (DRAWING Ig 1SWED @T� 111E WUMT6'OF 19RANGL FOR GUIDANCE AND IINFORWATI)F ONLY, NO WQ* AS I1E" p Hi1REW WILL EX DCNE EWCEPT AS RLV EWJ5 AND M€ ,LCo BY A PROFESSIONAL ENUNEEIR Md 15 APPROPRIATELY P[M.TE,REQ IN THE, STIATE 4F CAILIFOR, Orange County Fire Authority Page 12 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January I, 2008 J 7 a Rev. 0 1 -08 ATTACHMENT 3 VQn_AL AWN FLOOR � P�AlEliiAllQl'I� WALL SLAB PER END'S SPR�C'S 'WALL =i`il _ Illy_ I!- I_;IIV? FOanNG 1111= 1111.— illllll'I , MEM RtAN€ eecel:l..�9. e. 'RE. CARRIER FABRIC FW} 5PRAY ON MEMBRAN E; OEOTOTILIE C-USHICW OR 2r SmD ORA5 ium FOR :SHEET PLASTIC MEMBRANE L @ IPREP.ARm EARTH:SURCRA➢E } ISQUETRIO VIE METHANE BARRIER HOT TO WAUE f GUIDELPWE OKLY IA1S GRAVING L5 ISSUED BY TKE CCMTY Of GRANGE F� CE d2lCE AM 11:F�RUEATION CNLY_ HO B'fOK ia5 DESURWD HF PON SMALL BE OCKE EXCEPT AS WIWMO AND SEA5E0 EW A PROFEMONAL E7i[m1 m *0 15 APFROP818T€EY Rt m_fOmD IH TI;E %mw OF amirGR ". Orange County Fire Authority Page 13 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January I, 2008 ATTACHMENT 4 SLAB --%, �'FINISH FLOOR 1111- = -Illi � IIII- 1111 =1111_ MEMBRAdNE —jI IVV PER PERFORATED III 1= 1011 =_ PaP?cPEC'S fdNANWL1iR k8A'TERIAL II . —_ 9a° �aN. PER SPECIFICANONS TR£N._� ICH USE TWS DUAL - MOT IRWW IS !MAT tlP G04MAL U11UTIY TRDIM VENT PIPE IN TRENCH NOT TO SCALE / GUd@€LINE W-Y FINISH FLOOR — ..MEMBRANE -SLAB ANY SLEEhTNG THROUGH 17,007INGS TO BE APPROVED 1 ,_ PERFORATED PIPE BY STRUCTLIRAL — PER SPE,E "S ENGINEER. - _- - PIPING THIS WKWNG IS ISSUED BY THE CMMTY OF ORANGE FOk DANCE AND kR)R. NATION ONLY. NU WQW, AS UE D NER£ON WALL BE DOME D(CEPT'AS REVOU AM SCALED BY A PROFEW9"AL ENDMER *W IS APP.IR MANLY RVM3110n IN W SKATE CF CAU�IX Rev. 0 1 -08 Orange County Fire Authority Page 14 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January I, 2008 uT e4 J 7 Rev. 0 1 -08 ATTACHMENT 5 a' DR)f MIX 1 PART BENTMITE - 00 FINE kATI ERIAL WIV IWT RBM$T p OL'WS OR CI022LEs THEN WAYM TO CET AA 199 rLOMG MIXTURE O=BE PLACEMENT IN TRENCH AS SMOW0, 01M Ci57.M ECR ON FLANS. GRACE — E'ARTH ®ACXFI L TO M - - tt _ I - 8911 =1111 Q . 18INTONITE PLUG IFROM TOP OF a TRENCH TO -ONE H' � � - SAND BEI➢! - - - AREA. OF SANG, RM in INI BENCH WdTH0117 PLUG. PL SHALL EXTEN +LiM 6 3' O F TRENCH L€"7H- TRENCH TIRENCH f 9 NOT 'TO SCAU f tdi DII-IINt 0my THM DRAWING IS ISSUED [BY THE. MINTY W GRAN "FpR M11YALE AND i okwktow oNar. NO NOW A�- DESI*60 iREWSW Sl1 RE'DOIE EXCEPT N_4 REWOW AND SEALED 'BY A PIRMEMOWAL DiIW41EER WW 15 TFE' STATE OF C•k ff5kmik.. Orange County Fire Authority Page 15 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January I, 2008 ANY AR, RAN GUAFM OR SPARK 3' IA9N- ARRESTOR IF REOUIRCOI FRW FACE 'OF OLG?" ROOF JACK PER ARCHITECT PIPE, L €,6€NU � PUC9?ATU PLASTIC PIPE IP'EF: SPEC'S ® YFTAL OR PLASM PIPE: lam WPC AM SPEC'S 9.15.. AS 'GAS' ,lD154 9DNTIRACTOR. a°'11ALL VERIFY DACT 'T'eFE OFF CONSTRUCTION AT EACH 'YFWT RISER CALLED GUT M ME ?LAIN& RIEAR5 MUST AMP, 'dHINTTM. AIND WUST INOT IEE INST&LE6 %HERE .MUCTURAIL WEWS6RS P90H1®IT. FoR RIRE c-AST IN COAC1 %RAiP NMTH 'PILUMUTdS 9J4' THICK S,TxRCFOAIA TAP€ - FW% 2' YBM@ R&LL& OR 8UILDM DEPT. REVS AIMPTOR, OR IRp@UCEIR PER SLAB spffs- ATTACHMENT 6 t PIRA IN 5F.W WALL 4PA. PER spre _ AIL NkTIMIAL4 .. PER LII II PLULIHING OWE: Y€IA941" P7C fll9[ _i= lm=- �IlI =IIII =1111 =1111 X11_ IIIlY11 �- !IT =IIiI -!III° PEW PRPRJG 5_U. ea Y c? DIA- PER SPWS VENT R1j R J NOT TD S ALL / GUIVIA NE DNLY 3 7It95; DTAMIG IS A5s1 -LFEP BY THE CUAirr DF ORAA_GE FQR 0 AMP !Y#@} .IA11AFi LILY. 11,16 INDW AS 14F;'d7]HeRO- HM& SHid'LL K WK Fklri 7 AS iRE E110 AUD MALM TY A PROVE -EMMAL EKWCU: WHO e5 ARPROPMATILT IREMSTEf® IN THE STATE OF CALIEeIilIA. Rev. 0 1 -08 Orange County Fire Authority Page 16 of 17 Guideline C -03 Combustible Soil Gas Hazard Mitigation January I, 2008 AA IIiILOJGE OR WWOK 3; AROW MY ADAC047 j; i�f-7FIlQtd�. 24 ON YO SCHEI 413 - TiHRE TM mmimm a" M}�E IM"." ITT POPE LeGENO PLASM PER' 5PEC'S G &VA -NZEp STEEL, Bl.Wcx OR WRMVB. Si'.E-EL E4 i i � � a�Eer I F*z9H GRAD€ Ai1.AF'TER Fi TTING 4 "0 PIPE 4R' DU f PER PLAN5 .AND SPECIMAITRWS as J Rev. 01-08 4 "V RED1JiEER RP7 WANF€R ALL ARC g:_O ;. ATTACHMENT 7 IRAQ aR R F#IIAL I WARD 0 FIPT TAP AND PLUG 0 VIP 9CRED_ 410 Tmflrp SCREEN 12 MEEK .was newt= 6n I IIIF -1111 IKL"1111�I111 F 4 "P THIS DRAWING IS LSSUED BY T3E'01XATY OF QRAMX- FOR "y- .xu%e':X AND IINF0111VATfM QKY. NO W= SAS Dryer r�tiM13H �spULL BBE�.W D=!!PPT A$ REMPIM 6A IM sl�i�xM y19Y A p'.._Y!AL i-�°Ifl'.^- RY is A 11"!YTT_'�`�'1a69 m` efts I'CP , im im .11119E cF :W19' swA. Orange County Fire Authority Page 17 of 17 Guideline C-03 Combustible Soil Gas Hazard Mitigation January I, 2008 IF PRW 15 INi W.1 AWA MIN: Ountm *#AM wite oft,mr aim mm, be ww oz :vi l F Nam m M SL%-k UfAgL, CWINUT IN IRAN (W DD OUT ww.: Imm No MWT rs,wmw w*m wau wr auH A. FOLINIM WN KV DMI OuNt-WOML *-mm In mm- Omu 9W1 Em NOWA m Qw 94OW F-Im L9Fqw- ATTACHMENT 8 IMETMAW NIDWTO� I ZTATM DO NDT;BLCXX WME PRW 0 151 PARqWft.AMk -M WKT 79 WkLK P%-r 244H V 4N Q4W. A-I'LMM NUK WAII&T-AL DOM'M iOMOk. YW PLYr DeRA%W PUkSK LuUmM w,-m mm9E 00 xrnm OR FED Fan OU*L OR If UIAL EAMI WMUW AWHALIF wm PRm Nm a 00" fff%MPM UFt MEMCIARGR 'wave �-ftf Kuw 040srUm Iffi-mv ryIEWUL. mtfwf�S may W, Imum. PA j 03! al METHANg PS E NOT TO !SCAU Ir RMIUKE ONLY 11415 DRAVANC F, M&JFD 19Y TRF OXMITY Off O4rMQ17 FOR'QUAMCE AW, NFORMA7-N CINLI- m D ww. As mwRium Hum* amLL BE.Dm ExcuT & wamm.-AND- saLm BY A MOFE5,�A[11 9AR4EER MM 19. APPROPMAM-Y §WWfLRO IM HE V7AijC OF CALF"A. Rev. 01 -08