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Hinchee: Rebuttal to Cabrera's Answer RE: Supposed Need For Groundwater Remediation/Cost. 2/3/09

Hinchee: Rebuttal to Cabrera's Answer RE: Supposed Need For Groundwater Remediation/Cost. 2/3/09

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Published by: TexacoEcuador on Dec 17, 2010
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11/14/2012

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REBUTTAL TO MR. CABRERA’S ANSWER REGARDING THE SUPPPOSEDNEED FOR GROUNDWATER REMEDIATION AND ITS COST
Prepared by: Robert E. Hinchee
 
Principal EngineerIntegrated Science and TechnologyPanacea, Florida, USAI am an environmental engineer with a Ph.D. in Civil and Environmental Engineeringfrom Utah State University and an expert in the assessment and remediation of petroleumcontaminated sites. I have worked in the petroleum contamination and remediationindustry for over 30 years and have been involved in characterization and remediation of over 1,000 sites worldwide. For example, I served as the Technical Director overseeingcharacterization and remediation of the Trecate oil well blowout near Milan, Italy. This15,000-cubic-meter blowout contaminated approximately 7 square kilometers of farmland with oil more than 1 meter deep in places. The remediation was the largest oilcontaminated soil clean-up in European history and has resulted in restoration of the landto agricultural use. I also worked in Saudi Arabia and Kuwait characterizing anddeveloping remedial approaches and cost estimates for dealing with the hundreds of square kilometers of land and shoreline contaminated with oil as a result of Iraqi actionsin the 1991 Gulf War, the largest oil spill in history. In this role, I testified to the UnitedNations and provided technical support to the United Nations. In addition, I haveauthored, co-authored, edited, and co-edited numerous publications including more than25 books, examples of which include
 Hydrocarbon Bioremediation
and
Cost-Effective Remediation and Closure of Petroleum-contaminated Sites
. I am the founding editor of the
 Journal of Bioremediation
. My complete resume is attached.
Certification by Author
This attached report accurately represents my knowledge and opinions on this matter.Signature:Date:
 
Signature:Date:
 
 Introduction
In his answer to Question 11 posed by Mr. Pablo Fajardo (attorney for the Plaintiffs) inthe document “Respuestas a las Preguntas de la Parte Demandante Relacionadas con elInforme Pericial,” Mr. Cabrera says “…additional research is needed in order to developa plan and to evaluate the cost of cleaning up the groundwater” and “This is why I amunable to define the cost of cleaning up the groundwater.” Nevertheless, despite the factthat Mr. Cabrera says he needs additional data and information in order to calculate thegroundwater remediation cost, and he presents no new data, he proceeds to present agrossly exaggerated and technically indefensible estimate of groundwater remediationcost. In doing so, Mr. Cabrera 1) ignores the facts showing the absence of groundwatercontamination in the former Petroecuador-Texaco concession area, and 2) usesinappropriate groundwater remediation technologies, remediation costs, and numbers of supposedly contaminated sites. This is explained in greater detail in the followingsections.
There are no impacts on drinking water from Texpet operations within the former Petroecuador-Texpet concession area, and no evidence of the need for groundwater remediation.
Comprehensive sampling done by the experts suggested to the court by the Defendant(134 samples at 32 sites) of actual drinking water wells in the proximity of pits found noexceedance of USEPA or WHO drinking water criteria for metals and hydrocarbons
1
.Additionally, the Chevron field team collected samples of drinking water from 28household wells located in the immediate vicinity of the sites visited by Mr. Cabrera andfound no evidence of impact by oilfield operations (Connor and Landazuri, 2008). Withrespect to supposed groundwater contamination in the former concession area, it isimportant to note that Mr. Cabrera:
 
took no samples of drinking water,
 
took no samples representative of groundwater,
 
collected 6
2
muddy water samples from open boreholes within pits, and the sourceof this water was more likely to be either runoff or perched water than agroundwater aquifer,
 
reported results for samples collected by other people without informing the courtor Chevron that such sampling was occurring, and Mr. Cabrera himself was notpresent at the sites for this sampling,
 
appears to have ignored the results of samples collected by the Defendant’sexperts during the judicial inspections, and
 
ignored the results of his own data, since his own data indicate that all his watersamples meet USEPA drinking water standards for the analyzed metals andhydrocarbons.
1One well located in the vicinity of SSF-45A had a very low estimated concentration of dibenoz(a,h)anthracene; this wellwas resampled at a later date and dibenzo(a,h)anthracene was not detected in this sample or in its duplicate. SSF-45Awas the location of a subsurface produced water leak from a Petroecuador injection well.2Table 2 in the expert report of Dr. Gregory Douglas (2008a) states that 5 muddy water samples were collected. This isbecause Dr. Douglas excluded the one “groundwater” sample from Mr. Cabrera’s sampling trip that occurred from August16 to August 24, 2007 because Mr. Cabrera failed to submit the chains of custody and laboratory reports. Mr. Cabreralater submitted this information to the court with his “muestras testigos” which allows this sample to be counted in thisreport.
 
Mr. Cabrera reported results for 69
3
samples that he calls groundwater, however, only 6
4
 of these samples were actually collected by Mr. Cabrera and he has since changed whathe calls the matrix of these samples to something other than groundwater (Baca andNewell, 2009)
5
. As described by Douglas (2008a and 2008b) there are serious dataquality issues associated with all of these samples. The 6 samples collected by Mr.Cabrera that he reports as “groundwater” were actually muddy water samples collectedfrom within pits. These samples were muddy sediment laden material collected fromshallow boreholes. Mr Cabrera installed no groundwater wells and collected no samplesfrom existing water wells. Mr. Cabrera also submitted results for 63 water samplescollected by other people when he was not present at the site. These samples werecollected without notification to the court or to Chevron that this field work was beingconducted. Therefore, Dr. Gregory Douglas considered these data inadmissible andhighly suspect. (NOTE: The 69 groundwater samples were not analyzed for all analytes.For example, some samples were analyzed for metals, but not PAHs. No explanation of this is provided by Mr. Cabrera.)Despite the problems with the data reported by Mr. Cabrera, I have compared the data tohealth based drinking water limits established by the USEPA and WHO. It is importantto note that the petroleum hydrocarbons of potential concern to human health are BTEXand PAHs. Heavy metals may also be of concern. Neither the USEPA nor the WHO hasestablished drinking water limits for TPH, since TPH measurements are not anappropriate indicator of risk to health.Mr. Cabrera reported metals results for 58 “groundwater” samples. He only analyzed oneof the 6 samples that he collected for metals and it did not exceed any USEPA or WHOdrinking water limit (in fact, no metals were detected in this sample). None of the 57samples collected by others contained any metals exceeding USEPA drinking watercriteria, and only 3 of the 58 samples (from two sites, CH-1 and AU-19) exceed the WHOcriterion for barium. In fact, barium was the only metal detected in any of the 58 samplesreported.Of the 6 samples Mr. Cabrera collected and called groundwater, he analyzed only 3 forPAHs and even if his analysis were correct, all met the USEPA and WHO drinking waterlimits (no PAHs were detected in two of the three samples). One of the samples haddetectable concentrations of naphthalene and phenanthrene, but it is notable that theanalytical results for his own “muestra testigos”
6
of this same sample showed no detectedPAHs. Mr. Cabrera reported the PAH results for 39 samples collected by other people,and all of these samples meet USEPA and WHO drinking water limits for PAHs (veryfew PAHs were even detected in only 6 of the 39 samples). A total of 41 groundwater“muestras testigos” from samples collected by others were analyzed for PAHs and noPAHs were detected in any of these samples. The inconsistencies between Mr. Cabrera’ssample results and his “muestras testigos” for PAHs, as well as numerous other issues
3This excludes the groundwater samples collected by Mr. Gomez. Mr. Cabrera was not present for the collection of thesesamples, and many were collected after September 28, 2007 which is the date that Mr. Cabrera concluded his fieldactivities.4Six samples is based on the number of “muestras testigos” that were collected and analyzed by Mr. Cabrera.5According to Baca and Newell (2009) 4 samples that Mr. Cabrera called “groundwater” in his original report he now calls“columna de agua.” Mr. Cabrera changed the matrix of one other “groundwater” sample to simply “agua.”6On October 3rd, 2007, the court directed Mr. Cabrera to collect duplicate samples and submit them to a “muestrastestigos” (witness sample) laboratory. The analytical results of these "muestras testigos" were to be used to confirm andcompare the results obtained by the laboratories used by Mr. Cabrera for the original samples (Labsu, Gruentec, andUmwelt) and upon which Mr. Cabrera bases his conclusions in his expert report.

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