Lawrence Livermore National Laboratory Report Survey

Prepared by GRA Technical Committee

GRA is currently evaluating the Lawrence Livermore National Laboratory (LLNL) report entitled, Recommendations to Improve the Cleanup Process for California’s Leaking Underground Fuel Tanks (LUFTs) and a companion document entitled, California LUFT Historical Case Analyses. We have prepared this survey to provide our membership with the opportunity to comment on the methods, conclusions and recommendations contained in these reports. This information would then be used to assist GRA in developing a position on the report. Results of the survey will be presented in our next edition of Hydrovisions.

Background
LLNL was contracted by the California State Water Resources Control Board (SWRCB) to perform a historical evaluation of the fate and transport characteristics of petroleum leaks in California. Information acquired through this evaluation was to assist the decision making process for LUFT cleanup policies. The LLNL report made three primary recommendations:

1. Passive bioremediation should be used as a remedial alternative whenever possible.
2. SWRCB policies should be modified to allow for risk-based decision making for LUFT cleanup.
3. LUFT cleanups that emphasize passive bioremediation should require risk-based decision making.

For this survey, we have listed key sections of the LLNL report and are requesting that respondents circle a number from 1 to 5 where provided, with a 1 representing a Strongly Disagree and a 5 representing a Strongly Agree with the LLNL report. Questions listed under LLNL Study Conclusions have been subdivided to permit the respondent an opportunity to comment on the specifics of the LLNL study and/or their experience. Respondents are encouraged to provide additional comments as needed either on the form or on a separate sheet.

1. Strongly Disagree
2. Somewhat Disagree
3. Undecided
4. Somwhat Agree
5. Strongly Agree

LLNL Study Design
The LLNL study approach included an evaluation of LUFT procedures, environmental fate and transport of petroleum constituents, and applicable LUFT cleanup characterization and cleanup technologies.
Was the approach thorough? 1 2 3 4 5

The evaluation methods included a comprehensive review of scientific literature, evaluation of available information from various agencies and institutions, evaluation of white papers submitted to the SB 1764 Advisory Committee, and analyses of e studies.
Were the Study methods appropriate? 1 2 3 4 5

The study included historical case analyses. These were conducted following development of criteria to collect specific sites for analysis, development of a database to organize key data, and statistical analysis of the data.
Do you agree with the methods used to evaluate existing LUFT data? 1 2 3 4 5

LLNL Study Conclusions
The LLNL arrived at several conclusions based on their evaluation of 271 study sites that met data quality criteria for the study. Each conclusion is listed below for your consideration. Is the conclusion "Fuel Hydrocarbons Have Limited Impacts On Human Health Or The Environment" supported by the research conducted during the study? 1 2 3 4 5

Has your experience been consistent with this conclusion? 1 2 3 4 5

Does the report demonstrate that The Cost Of Cleaning Up LUFT Fuel Hydrocarbons Is Often Inappropriate When Compared To The Magnitude Of The Impact On California’s Groundwater Resources? 1 2 3 4 5

Has your experience been consistent with this conclusion? 1 2 3 4 5

Does the report support the conclusion that LUFT Groundwater Cleanup Requirements Are Derived From Policies That Are Inconsistent With The Current State Of Knowledge And Experience? 1 2 3 4 5

Has your experience been consistent with this conclusion?1 2 3 4 5

Does the report support the finding that Current Understanding Of Passive Bioremediation Processes In The Subsurface Environment Is Not Reflected In The Present LUFT Cleanup Process? 1 2 3 4 5

Has your experience been consistent with this conclusion? 1 2 3 4 5

Does the report confirm that There Are Few Situations Where Pump And Treat Should Be Attempted? 1 2 3 4 5

Is it Technologically and Economically Infeasible to reach Maximum Contaminant Levels (MCLs) of 1.0 ppb for benzene using pump and treat or other actively engineered groundwater remediation alternatives? 1 2 3 4 5

Has your experience been consistent with this conclusion? 1 2 3 4 5

Does the report substantiate A Risk Based Corrective Action (RBCA) Framework Offers a Common Decision-Making Process to Systematically Address LUFT cleanup? 1 2 3 4 5

Has your experience been consistent with this conclusion? 1 2 3 4 5

Do you agree that Modifications Would Be Necessary For The ASTM RBCA Framework To Be Used In California? 1 2 3 4 5

Do you agree that A Common, Systematic Decision-Making Process Using Standard Procedures Will Reduce Inconsistencies In Soil Cleanup Requirements? 1 2 3 4 5

Do you agree that TPH Measurements Should Not Be Used To Predict Benzene Concentrations? 1 2 3 4 5

Lastly, on a related topic, but one that is not discussed in the LLNL report: What are your thoughts on the recent focus of regulatory agencies on Methyl Tert Butyl Ether (MTBE) an oxygenated fuel additive used to burn cleaner fuels, that is very persistent and advects with groundwater? Apparently, MTBE plumes in groundwater are larger in maximum concentrations, larger in areal extent, and have a greater mobility than the typical Benzene, Toluene, Ethylbenzene and Total Xylene (BTEX) plumes. Agencies are currently considering requiring that soil and groundwater samples at UST sites be tested for MTBE, and that MTBE plumes be characterized. Please provide your written thoughts.

Some Information About You

Your professional focus, such as regulatory agency, regulated industry, water purveyor, environmental consultant, attorney, academia, etc.:
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Number of years in this profession:_____________________________________________________________________________

Your GRA Branch:________________________________________________________________________________________

Percentage of work that involves USTs:_________________________________________________________________________

Additional Comments (attach additional sheets as needed)
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Thank you very much for participating in this survey. Please send your completed survey response to:
LLNL Survey Response, GRA
P.O. Box 1446
Sacramento, CA 95812

Members can also respond to the survey via GRA's web page at http://www.garc.org