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Baca/Newell: Groundwater Sampling Errors and Misinterpretation of Data by Cabrera. 1/23/09

Baca/Newell: Groundwater Sampling Errors and Misinterpretation of Data by Cabrera. 1/23/09

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GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA

Oriente Region, Ecuador

Maria Aguinda et al., versus Chevron-Texaco Corporation,
Superior Justice Court of Nueva Loja, Ecuador Case No. 002-2003

Muddy sample from pit 1, well LA-01, designated initially by expert Cabrera as a “groundwater” sample and later as a “water column” originating from pit 1.

January 23, 2009

Ernesto Baca, P.E. and Charles J. Newell, Ph.D., P.E.

GSI Environmental, Inc.
2211 Norfolk, Suite 1000, Houston, Texas 77098-4054 Tel: (713) 522-6300 Fax: (713) 522-8010

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
Maria Aguinda et al., versus Chevron-Texaco Corporation
Superior Justice Court of Nueva Loja, Ecuador Case No. 002-2003

Prepared for: Chevron Corporation Prepared by: GSI Environmental Inc. 2211 Norfolk, Suite 1000 Houston, Texas 77098-4054 U.S.A. 713/522-6300 Issued: January 23, 2009

Groundwater Sampling Errors and Misinterpretation of Data by Expert Cabrera
Ernesto Baca, P.E. Environmental Engineer - Consultant GSI Environmental, Inc. Houston, Texas, U.S.A.

Engineer Baca is an environmental consultant for GSI Environmental Inc. (GSI), and has more than 28 years of professional experience in environmental engineering projects, with a specialization in forensic environmental studies, groundwater and surface water modeling, geophysical surveys, risk evaluation, and design and implementation of remedial actions. He is a licensed Professional Engineer in the State of Texas (60781) and has been an Auxiliary Editor for the Ground Water Journal since 1991. He obtained his Bachelor of Science degree in Environmental Engineering in 1978 from Rensselaer Polytechnic Institute (RPI), New York, U.S.A. and his Masters of Science degree in Environmental Engineering in 1981 from Rice University, Texas, U.S.A. where he also worked as a research scientist in 1980 and 1981, before working for Woodward-Clyde Consultants’ Houston office from 1981 to 1985 as a Senior Engineer. He has worked as an environmental engineer in various groundwater and surface water project in the United States, as well as in 6 other countries around the world. He has also testified as an expert witness in various legal cases since 1992. He is fluent in Spanish and English.

Certification by Eng. Ernesto Baca: The attached report accurately reflects my knowledge and opinions in this matter.

Ernesto Baca, P.E.

Date:

Groundwater Sampling Errors and Misinterpretation of Data by Expert Cabrera
Charles J. Newell, Ph.D., P.E. Environmental Engineer – Vice President, GSI Environmental GSI Environmental, Inc. Houston, Texas, U.S.A.

Dr. Newell is a Vice President of GSI Environmental, Inc. He is a member of the American Academy of Environmental Engineers, a NGWA Certified Ground Water Professional, and an Adjunct Professor at Rice University, Houston. Dr. Newell has co-authored three EPA publications, five environmental decision support software systems, numerous technical articles, and two books: Natural Attenuation of Fuels and Chlorinated Solvents and Ground Water Contamination: Transport and Remediation. His professional expertise includes site characterization, groundwater modeling, non-aqueous phase liquids, risk assessment, natural attenuation, bioremediation, non-point source studies, software development, and long-term monitoring projects. He has taught graduate level groundwater courses at the University of Houston and Rice University, Houston.

Dr. Newell was the Principal Investigator for the project that developed the BIOPLUME III and BIOSCREEN models, and is also an expert in modeling methods and their appropriate application. Furthermore, he is familiar with the RITZ and other numerical models for the simulation of groundwater transport. Dr. Newell was awarded the 2001 Wesley W. Horner Award by the American Society of Civil Engineers for his article titled “Modeling Natural Attenuation of Fuels with BIOPLUME III”.

Certification by Eng. Charles J. Newell:
The attached report accurately reflects my knowledge and opinions in this matter.

Charles J. Newell, Ph.D., P.E.

Date:

Issued: January 23, 2009 Page 1 of 8

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
Attorney Fajardo, in his Question 291, asks expert Cabrera to describe how he collected the groundwater samples that he presents in his March 2008 report2. In his response, expert Cabrera simply refers to his Annex3 where he presents his “Groundwater Sampling Plan.” However, the attached Annex is not expert Cabrera’s sampling plan (which he presented in Appendix C of Annex B of his March 2008 Expert Report4) but a word for word copy of the text from one of his collaborators, Doctor Gómez (specifically Appendix D of Annex B of the same expert report5). It is hard to understand why, in his answer to attorney Fajardo, expert Cabrera refers to the sampling plan of another person, which does not have anything to do with his own sampling procedures or his own results. Expert Cabrera only collected 6 samples, of supposedly “groundwater”, analyzing only 5 of them. Nevertheless, expert Cabrera reports results for 108 other water samples collected by others who were not part of the judicial process. Two secret sampling teams who conducted fieldwork without notifying the Court or the defendants collected the other 108 samples. Expert Cabrera was not present for this sampling nor did he sign the chains of custody for the corresponding samples. These invalid water samples were collected by the secret sampling teams that included Mauricio Naranjo and Luis Antonio Gómez, and represent 93% of the water data presented by expert Cabrera. Further complicating any interpretation of expert Cabrera’s water data, he reclassifies all of his “groundwater” samples, in his response to attorney Fajardo. This reclassification of samples is an acknowledgement by expert Cabrera that his samples are not representative of groundwater, therefore, without samples he cannot say anything about the groundwater in the area, but, as we will see ahead, he incorrectly does any way. Furthermore, Doctor Gómez’ Sampling Plan, which the expert incorrectly attributes to himself, includes Section 1.1.5 Hypothesis, which pretends to present the “verified hypotheses” or conclusions of his studies. The inclusion of conclusions in this Sampling Plan clearly indicates the bias by the Cabrera/Gómez team and their complete lack of scientific objectivity. An appropriate sampling plan simply serves to specify the methodology to be used to reach valid and objective conclusions and such conclusions cannot be presented before the collection and data analysis, especially without any proof, as it is done by Doctor Gómez’ Sampling Plan. Establishing conclusions (or verified hypotheses) before the collection of any data
Responses to the Plaintiffs’ Questions Related to the Expert Report, Question/Answer 29, November 2008, p. 24 of 51. 2 Summary Report of Expert Examination, by: Eng. Richard Stalin Cabrera Vega, Superior Justice Court of Nueva Loja Expert, Expert Report, March 24, 2008. 3 Responses to the Plaintiffs’ Questions Related to the Expert Report, Annex. Groundwater Sampling Plan, November 2008. 4 Annex B: Evaluation of the Use of Information; Appendix C Expert Cabrera’s Quality Control Information: Operating Procedures for Laboratory Methods and Quality Control Criteria and Example of a Chain of Custody, See Operating Procedure PO-003 Sampling Plan, Operating Procedure PO-002 Groundwater and Surface Water Sample Collection, and Operating Procedure PO-001 Soil Sample Collection. 5 Annex B: Evaluation of the Use of Information; Appendix D Dr. Gómez Quality Control Information: Field Sampling Plan and Examples of Chains of Custody and Laboratory Sheets (CORPLAB).
1

Issued: January 23, 2009 Page 2 of 8

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
demonstrates that the sampling plan is of no use to determine the actual conditions of a site but only serves to support the obvious bias of the author. Worse yet, the 7 conclusions by Doctor Gómez and adopted by expert Cabrera and presented in Section 1.1.5 Hypothesis of his Sampling Plan are incorrect and do not have any technical basis, as is explained below. 1“The soil contains hydrocarbons which are above the relevant Ecuadorian norms.”

Expert Cabrera, in his sampling plan for “groundwater” concludes that the “soils” are contaminated. Expert Cabrera confuses the environmental matrices. Since the discussion presented below relates only to groundwater, soils will not be discussed. The team Cabrera/Gómez alleges that high concentrations of hydrocarbons have been found in the groundwater samples. This statement is false and not trustworthy for the following reasons: i) these samples were collected from pit interiors, and therefore, are not representative groundwater samples from the area, as expert Cabrera himself recognizes in his answer to attorney Fajardo when he changes the matrix designation of his samples (see Tables 1 and 2)6; ii) the samples were not collected properly, since many of them presented significant quantities of sediments, which is unrepresentative of a water source but instead represents mud; iii) the witness samples analyzed by Corplab, which supposedly confirm the measurements made by Labsu and Gruntec, in fact, do not have any relationship between them generating a low level of confidence regarding these results, which supposedly were split between the different labs; iv) the quality control reports from the three laboratories used (Corplab, Labsu, and Gruntec) are of such poor quality that they do not allow for the verification of results, and v) the water sampling trip (trip 6 – Naranjo) as well as Doctor Gómez’ sampling were done in hiding, without notification to the Court, and without any witnesses that could verify the sampling events. These topics have already been discussed in previous rebuttals (for example, Douglas, 2008a)7.

For example, sample LAG01-PIT1-SD3-AF was designated as “groundwater” in expert Cabrera’s report and then as “water column” from a pit, Responses to the Plaintiffs’ Questions Related to the Expert Report, Annex. Field Sampling and Analysis, November 2008. 7 Douglas, G., 2008a. “Rebuttal to Mr. Cabrera’s Analytical Data and Evaluation of the Validity of his Sampling and Analytical Programs.”

6

Issued: January 23, 2009 Page 3 of 8

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
Table 1: Changes to the sample matrix designation in expert Cabrera’s reports (Sampling trips where expert Cabrera was present for the collection of samples before September 28, 2007). See Appendix A for more details. Original matrix designation in the Expert Report (March 2008) “groundwater” “surface water” “water” New matrix designation – Responses to attorney Fajardo (Nov. 2008) “water column” “water” “water” “water column” Number of samples with corresponding matrix changes 4 1 2 1 8 Total number of samples 4 1 2 1 8 Sampling Trips (July to September 2007) 1, 3, and 4 5 3 2 1 through 5

Sample Location – Source Pits Pit Pit / Swamp [No stated source]

TOTAL Note: See notes in Table 2.

Table 2: Changes to the sample matrix designation in expert Cabrera’s reports 8 (Sampling trips outside of the judicial process and therefore invalid). See Appendix B for more details. Original matrix designation in the Expert Report (March 2008) New matrix designation – Responses to attorney Fajardo (Nov. 2008) Number of samples with corresponding matrix changes Total number of samples Sampling Trips (September through November 2007)

Sample Location (Source) Pits (6), Swamps (5), Creeks (4), Well (1), Other (9) Pits and “Between Pit 1 and Pit 2” Swamps Pits and Swamp Swamp Pit-Swamp Pits Pit-Swamp

“groundwater”

0

25

6

“groundwater”

“water column” “water” “pit water” “surface water” “groundwater” “pit water” “surface water” TOTAL

29 2 6 1 1 2 0

29 2 6 1 1 2 1

6 6 6 6 6 6 6

“surface water”

41 67 6 Notes: 1) During the sixth sampling trip (October-November 2007) expert Cabrera was absent, and Doctor Gómez’ samples (September-October 2007) were done outside of the judicial process (see footnote 8), thus all of the samples collected during these sampling trips are invalid.
8

The sixth sampling trip took place without notification to: i) the Court, ii) the plaintiffs, or iii) the defendants; it was done in secret, and the samples were collected after the 28th of September, 2007, date when expert Cabrera declared his sampling activities as concluded.

Issued: January 23, 2009 Page 4 of 8

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
2) 63 samples were designated, in expert Cabrera’s Expert Report (March 2008), as groundwater during the sixth sampling trip. 3) 26 samples were designated as groundwater in expert Cabrera’s responses to attorney Fajardo (November 2008). 4) A more detailed version of Tables 1 and 2 is presented in Appendices A and B of this report.

2-

“Migration is possible.” The Cabrera/Gómez sampling plan states that migration is possible, without specifying: the location of such migration; the extent of the supposed migration; the direction in which the supposed contaminants are moving; the chemicals that migrate; the responsible party of the contaminant source; and many more details. Therefore, this statement is totally without foundation and, as such, has no value. The supported fact is that the sampling results performed during the judicial inspections have demonstrated that there is no such migration, since all of the water wells, domestic and public, located in the vicinity of the petroleum installations are free of petroleum crude or production water impacts.

3-

“The hydrocarbons are not completely degraded nor immobile.” Soil analytical results from remediated pits at petroleum installations demonstrate that the petroleum crude is highly degraded and constitutes an inert and immobile residue.9 Cabrera/Gómez’ own results regarding the hydrocarbon fractions highlight this high level of degradation. Specifically, expert Cabrera presents “fingerprinting” results or TPH fractions10 for 3 samples (from Charapa-01 (CH01), Aguarico-5 (AG-05) and Aguarico-10 (AG-10)). In the samples from CH-01 and AG-05, their own results show that more than 92% of the hydrocarbon mass is heavy (in other words >C18), and corresponds to compounds of very low solubility and mobility in soil or water. In the case of AG-10, expert Cabrera tries to deceive the Court when he describes the sample as “free crude in an area outside pit 1 in the platform of well AGUARICO 10.”11 In reality, this sample was not associated with a pit, but it is a crude sample taken directly from the wellhead pipeline, in other words, fresh crude that belongs to Petroecuador, and not from a Texpet spill as expert Cabrera tries to imply (see the sampling photographs below).

Expert Reports presented by the Defendants during the Judicial Inspections of the 45 sites inspected, August 2004 to November 2006. 10 Summary Report of Expert Examination, by: Eng. Richard Stalin Cabrera Vega, Superior Justice Court of Nueva Loja Expert, Expert Report, March 24, 2008. Annex RSS (U-4) Site by Site Results, Charapa-1: Figure 188, Tables 47, 6.1, and 141, Graphic 3 and Fingerprinting 1 (pp. 160, 205, and 231-232); Aguarico-5: Figure 203, Tables 77, 6.16, y 206, y Graphic 18 (pp. 175, 212, and 298); and Aguarico-10: Figure 206, and Tables 83, 6.19, and 223, and Graphic 22 (pp. 178, 214, and 314-315). 11 Ibid, p. 314.

9

Issued: January 23, 2009 Page 5 of 8

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
Crude sampling photographs from oil well AG-10

Crude sample collection from well AG-10 operated by Petroecuador

Placing crude sample collected from the AG-10 well pipeline in a container

As expected, this sample of fresh crude is lighter and is not degraded, but expert Cabrera preferred to omit this most important detail regarding this sample with the purpose of deceiving the Court. Effectively, the sample was collected from a pipeline that originates from a Petroecuador well. This type of trickery is unprofessional and confirms once more the bias and lack of ethics of expert Cabrera. In conclusion, expert Cabrera presents no evidence regarding the supposed mobility of degraded crude in soils or groundwater of the sites he visited. 4“The material around the pits is not totally impermeable and permits transport.” Transport of any liquid in the subsoil is a function of the soil permeability and the properties of the liquid. In the case of crude in Ecuadorian soils, the most important variables are the properties of the crude, especially if the crude is degraded. This topic was presented in a Congress in Asunción, Paraguay, on September 2006, where the technical reasons that explain this behavior are explained.12 As revealed in that study, the analysis of degraded crude that is found in the soils of petroleum installations in the Oriente demonstrate that the crude is not mobile and cannot be dissolved in groundwater. In addition to the technical basis presented by O’Reilly and Molano (2006), expert Cabrera generally avoided taking samples from around the pits, always trying to obtain samples from points within the pits only. Also, he did not make any measurements or presented any information regarding the hydraulic permeability of the soils that surround the pits. Contrary to expert Cabrera’s statements, according to scientific studies, the majority of the subsurface soils in the former Concession are principally clayey,13 which allow them to act as a natural liner,
12

O’Reilly, K.T., and C.E. Molano, “A Method for Predicting Whether Oil-Impacted Soil is a Risk to Groundwater: A Case Study Using Soil and Groundwater Samples at Oil Production Sites In Ecuador”, presented at the VIII Latin-American Subterranean Hydrogeology Congress, Asunción, Paraguay, September 25 to 29, 2006. 13 González, A.; Maldonado, F.; Mejía, L.; “General Soils Map of Ecuador Legend,” Sociedad

Issued: January 23, 2009 Page 6 of 8

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
preventing the infiltration of hydrocarbons. Once more, expert Cabrera does not have a technical basis to support his conclusion of migration away from the pits. 5“There is groundwater contamination.” Once more the Cabrera/Gómez team presents statements without any proof and distorts their own data. For the purpose of this discussion, sampling trip 6 and that of Doctor Gómez’ will not be considered. In this analysis the first 5 sampling trips were considered since expert Cabrera was present during the sampling and the samples were collected before September 28, 2007. Of the 8 samples analyzed and designated in the Expert Report as groundwater, surface water, or simply water, collected by expert Cabrera during the first five sampling trips, all meet the USEPA and WHO guidelines for drinking water. Nevertheless, the 8 samples analyzed were collected from within pits and in a swamp, and therefore none can be considered as representative of groundwater or a valid sample, due to its inappropriate sampling method. This topic has already been discussed above under item 1 of this report. The statement from Cabrera/Gómez regarding this point is only an attempt to distort the truth. 6“The plume behavior can be fitted to a predictive model.” In Section 1.1.3 Analytical parameters considered, the team Cabrera/Gómez states that “migration was evaluated by modeling: RITZ, BIOPLUME III, BIOSCREENING” which, according to this bullet point, resulted in a “predictive model.” RITZ is a model that is used to simulate transport in the unsaturated zone. BIOPLUME III and BIOSCREEN (note that there is no model named “BIOSCREENING” as stated by the Cabrera/Gómez team) are contaminant transport models in groundwater, of which BIOPLUME III represents the more sophisticated numerical model and BIOSCREEN is a screening-level analytical model. I, Dr. Charles Newell, coauthor of this report, was the Principal Investigator for the project that developed the BIOPLUME III and BIOSCREEN models, and I am also an expert on the appropriate methods to use and apply such models. In addition, I am familiar with the RITZ model. To apply a groundwater model one must follow a number of steps and procedures to ensure confidence in the prediction, and the correct application of the models. Typical steps include the following (see references at the end of this report): Development of a conceptual site model, Determination and justification of input parameters, Model calibration to site data, Sensitivity analysis and key assumptions, and Documentation of the modeling process and model results.

None of expert Cabrera’s reports show that these steps were performed. There are no modeling results to support any of the hypotheses presented in Section 1.1.5 of the Cabrera/Gómez team Sampling Plan. Aside from what one may conclude from a model, expert Cabrera does not even test the existence of groundwater impacts, and even less the existence of a plume. Consequently, the hypotheses presented have not been proven, and therefore, do not constitute
Ecuatoriana de la Ciencia del Suelo [Ecuadorian Society of Soil Science], Quito, 1986.

Issued: January 23, 2009 Page 7 of 8

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
evidence of the supposed migration of petroleum compounds in soils or groundwater. 7“There is a quantifiable risk to the environment and human beings because of the presence of chemicals at the site.” The simple presence of chemicals does not mean that there is a risk to the environment and human beings. For potential risk to exist the following three components of risk must be met: i) a potential source of toxic substances must exist, ii) there must be an exposure route, and iii) there must be a receptor. Simply, if one of these factors were not to present itself it would imply an absence of risk. Although expert Cabrera mentions a quantifiable risk, he has not quantified the alleged risk. Neither has he demonstrated the presence of toxic substances, nor has he identified possible routes of exposure, nor persons that could be exposed to affected soils or water. On the contrary, he only discusses the presence of detectable TPH concentrations, which in no way is evidence of toxicity, but simply the presence of hydrocarbons, including natural sources such as vegetation. Expert Cabrera only analyzed for one category of potentially toxic compounds, the collection of polycyclic aromatic hydrocarbons (PAHs), in their first 5 sampling trips. Their data in groundwater showed that there was only 1 groundwater sample with a detection of PAHs, and that muddy sample was collected from the interior of a pit at well Lago Agrio 114, which clearly is not representative of groundwater. The expert refused to take representative samples outside the pits or from domestic wells, which would have demonstrated the absence of crude contamination. It seems that expert Cabrera’s only purpose, in presenting these baseless conclusions, is to deceive the Court. Evidently, expert Cabrera does not understand the difference between baseless statements and scientific proof, or simply has elected to ignore that difference at his convenience and bias, which demonstrates a total lack of professional ethic in conducting his work as an expert. References ASTM, 1995. “Standard Guide for Developing Site Conceptual Models”, Publication E1689-95(2003)e1. American Society for Testing and Materials E 168995(2003)e1, West Conshohocken, PA, 1995. ASTM, 1998. “Standard Guide for Application of a Ground-Water Flow Model to a Site-Specific Problem”, American Society For Testing And Materials D 5447-93, Philadelphia, PA, 1998. ASTM, 1998. “Standard Guide for Comparing Ground-Water Flow Model Simulations to Site-Specific Information”, American Society for Testing and Materials D 549093, Philadelphia, PA, 1998. ASTM, 1998. “Standard Guide for Defining Boundary Conditions in Ground-Water
Summary Report of Expert Examination, by: Eng. Richard Stalin Cabrera Vega, Superior Justice Court of Nueva Loja Expert, Expert Report, March 24, 2008. Annex RSS (U-4) Site by Site Results, Table 6.2 (p. 206), Sample ID: LAG01-PIT1-SD3-AF, Sample of water collected from pit 1, yellowish muddy water with hydrocarbon odor,
14

Issued: January 23, 2009 Page 8 of 8

GROUNDWATER SAMPLING ERRORS AND MISINTERPRETATION OF DATA BY EXPERT CABRERA
Flow Modeling”, American Society For Testing And Materials D 5609-94, Philadelphia, PA, 1998. ASTM, 2002. “Standard Guide for Defining Initial Conditions in Ground-Water Flow Modeling”, American Society For Testing And Materials D 5610-94, Philadelphia, PA, 2002. ASTM, 1998. “Standard Guide for Conducting a Sensitivity Analysis for a GroundWater Flow Model Application”, American Society For Testing And Materials D 5611-94, Philadelphia, PA, 1998. ASTM, 2000. “Standard Guide for Documenting a Ground-Water Flow Model Application”, American Society For Testing And Materials D 5718-95, Philadelphia, PA, 2000. ASTM, 2000. “Standard Guide for Subsurface Flow and Transport Modeling”, American Society for Testing and Materials D 5880-95, Philadelphia, PA, 2000. ASTM, 1998. “Standard Guide for Conceptualization and Characterization of GroundWater Systems”, American Society For Testing And Materials D 5979-96, Philadelphia, PA, 1998. Bedient, P. B., H.S. Rifai, C.J. Newell, 1999. Groundwater Contamination: Transport and Remediation, 2nd ed., Prentice-Hall, 1999. Newell, C.J., J. Gonzales, and R. McLeod, 1996. BIOSCREEN Natural Attenuation Decision Support System, U.S. Environmental Protection Agency. EPA/600/R96/087, August 1996. Rifai, H.S., C.J. Newell, J.R. Gonzales, S. Dendrou, L. Kennedy, and J. Wilson, 1997. BIOPLUME III Natural Attenuation Decision Support SystemVersion 1.0, U.S. Environmental Protection Agency, EPA/600/R-98/010, January 1998. www.epa.gov/ada/csmos/models.html Spitz, K. and J. Moreno, 1996. A Practical Guide to Groundwater and Solute Transport Modeling, John Wiley and Sons, Inc., New York, New York. Wiedemeier, T.H., Rifai, H.S., Newell, C.J., and Wilson, J.W., 1999. Natural Attenuation of Fuels and Chlorinated Solvents, John Wiley & Sons, New York. Zheng, C. and G.D. Bennett, 1995. Applied Contaminant Transport Modeling, Van Nostrand Reinhold, New York, New York.

PRELIMINARY Issued: January 23, 2009 Page A-1 of A-2

APPENDIX A CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

This table presents the details of the groundwater samples collected by expert Cabrera. These samples were collected during the, so called, “Sampling Trips” 1 through 5 of 2007. Notes and statistics regarding these water samples are presented below. General information regarding the sampling trips: Trip 1 – July 4 through 12, 2007 - Sampled by expert Cabrera Trip 2 – July 22 through 31, 2007 - Sampled by expert Cabrera Trip 3 – August 16 through 25, 2007 - Sampled by expert Cabrera Trip 4 – September 3 through 12, 2007 - Sampled by expert Cabrera Trip 5 – September 20 through 28, 2007 - Sampled by expert Cabrera Expert Cabrera reported analytical results for 8 water samples from Trips 1 through 5. Expert Cabrera changed the matrix of all of his 8 water samples reported during these sampling trips.

PRELIMINARY Issued: January 23, 2009 Page A-2 of A-2

APPENDIX A CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008) Groundwater Groundwater Water Groundwater Water Superficial Water Superficial Groundwater Groundwater

1 1 2 3 3 3 4 5 TOTAL

LA-01 LA-12 LA-20 SSF-46 AG-08 AG-09 AU-19 SA-056

LAG01-PIT1SD3-AF LAG12-PIT1SD2-AFNF(110)CM LAG20-PIT4SD1-AI SSF46-PIT1SD1-AF AGU8-A1-AS AGU9-PIT1-AS AUC19-PIT1SD1-AF-NF 30 CM SAC56-PIT1SD2-AF 8

New matrix designation – Responses to attorney Fajardo (November 2008) Water Column Water Column Water Column Water Column Water Water Water Column Water

Sample Site (Source)

Was there a matrix change ?
Yes Yes Yes Yes Yes Yes Yes Yes

Comments by expert Cabrera

Pit Pit -Pit Swamp Pit Pit Pit

Water sample collected from Pit 1, yellowish muddy water with hydrocarbon odor. Water sample collected from Pit 1, yellowish muddy water with hydrocarbon odor. Infiltrated water sample, muddy yellowish, with light concentration and hydrocarbon odor. Water sample collected from Pit 1, somewhat muddy and with light hydrocarbon odor. Water sample collected from area 1, muddy yellowish with slight hydrocarbon odor. Water sample collected from Pit 4, light turbidity and hydrocarbon odor. Water sample collected from Pit 1, muddy yellowish, with hydrocarbon odor. Water sample collected from Pit 1 boring 2, muddy with hydrocarbon odor.

PRELIMINARY Issued: January 23, 2009 Page B-1 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

This table presents the details of the water samples that were NOT collected by expert Cabrera but by others and Doctor Gómez. These samples include, the so called, “Sampling Trip 6” and the sampling by Doctor Gómez in 2007. Notes and statistics regarding these water samples are presented below. General information regarding the sampling trips: Trip 6 – October 15 through November 3, 2007 - Expert Cabrera absent during sampling. - Expert Cabrera did not sign the chains of custody. - The Court, the defendant, and the plaintiffs were not notified. - Samples were collected after September 28, 2007. - Invalid data; outside the judicial process. September 15 through October 10, 2007 Trip - Sampled by Doctor Gómez. - Expert Cabrera did not sign the chains of custody. - The Court, the defendant, and the plaintiffs were not notified. - 28 of the 41 samples were collected after September 28, 2007. - Invalid data; outside the judicial process.

67 water samples were collected during Trip 6 (63 groundwater and 4 surface water). Expert Cabrera changed the matrix of his water samples in 42 of 67 samples collected during Trip 6. Expert Cabrera changed the matrix of his groundwater samples to other matrices in 39 of 63 samples (for example, water column, pit water, swamp, creek, an others). Expert Cabrera changed the matrix of his surface water samples to other matrices in 3 of 4 samples (pit water and groundwater). Doctor Gómez collected 41 water samples (36 groundwater and 5 surface water).

PRELIMINARY Issued: January 23, 2009 Page B-2 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008) Groundwater Groundwater Groundwater Groundwater

New matrix designation – Responses to attorney Fajardo (November 2008) Water Water Pit Water Pit Water

Sample Site (Source)

Was there a matrix change ?
Yes Yes Yes Yes

Comments by expert Cabrera

6 6 6 6

AT-01 SSF-55 AG-05 AG-09

6

CH-01

6

CH-01

6

CH-01

ATA01-A1SD1-AF1-NF(5) SSF55-A1SD1-AF1-NF(0) AGU05-PIT3SD1-AF1-NF(5) AGU09-PIT1SD1-AF1NF(200) CHA1-PIT2SD1-AF1NF(10) CHA1-PIT3SD1-AF1NF(10)-1 CHA1-PIT3SD1-AF1NF(10)-2

Swamp Swamp Pit Pit

Water sample collected outside of Pit 2, slightly turbid water, swampy area below the goose neck. Water sample collected from swampy area, slightly clear water, little sediment present. Water sample collected from Pit 3, yellowish water, oily sheen on surface and crude. Water sample collected from the open water pit, open water, slightly turbid water, vegetation on its surface. Water sample collected from Pit 2, yellowish turbid water, crude drops, hydrocarbon odor, oil sheen. Water sample collected from Pit 3, turbid water, dark brown with sediment, crude drops, hydrocarbon odor, oil sheen. Water sample collected from Pit 1, yellowish turbid water, crude drops, hydrocarbon odor, oil sheen.

Groundwater

Pit Water

Swamp

Yes

Groundwater

Pit Water

Pit

Yes

Groundwater

Pit Water

Pit

Yes

PRELIMINARY Issued: January 23, 2009 Page B-3 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Pit Water

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6

YUL-01

6

SSF-35

6

AT-05

6

AT-05

YUL01-PIT1SD1-AF1NF(30) SSF35-A1POZ1-AF1NF(800) ATA05-A1SD1-AF1NF(120) ATA05-A1SD2-AF1NF(80) ATA05-A2SD1-AF1-NF(5) AUC05-A1SD1-AF1-NF(0)

Groundwater

Pit 30m from pit 3 Swamp

Yes

Water sample collected from the open crude Pit, turbid water, hydrocarbon odor, oil sheen. Water sample collected at well from inhabited house, chlorine was added to the well, clear water. Water sample collected from the edge of the area below Pit 1, reddish turbid water. Water sample collected from the edge of the area below Pit 1, reddish turbid water. Water sample collected from edge of creek, yellowish turbid water yellowish with surface oil, hydrocarbon odor. Water sample collected from the area outside Pit 2, dark brown turbid water, hydrocarbon odor, oil sheen.

Groundwater

Groundwater

No

Groundwater

Groundwater

No

Groundwater

Groundwater

Swamp

No

6

AT-05

Groundwater

Groundwater

Creek

No

6

AU-05

Groundwater

Groundwater

Pit

No

PRELIMINARY Issued: January 23, 2009 Page B-4 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Groundwater

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6

AUS01 AUS01 CH-01 GU-04

6 6 6

AUCS01-A2SD1-AF1NF(120) AUCS01-A2SD2-AF1NF(100) CHA1-A1-SD1AF1-NF(10) GTA04-A1SD1-AF1NF(50) GTA08-A1SD1-AF1NF(50) LAG05-A1SD1-AF1NF(10)

Groundwater

Pit Next to a Pit Swamp 15m from pit 1 100m N of pit 1

No

Water sample collected outside of Pit 2, clear water, slight hydrocarbon odor, no oil present. Water sample collected from Pit 2 goose neck exit, clear water, hydrocarbon odor, oil present. Water sample collected from swamp area next to Pit 2, water slightly turbid. Sample collected in area outside Pit 1, yellowish turbid water. Water sample collected from the corn field near the well platform, water with hydrocarbon odor, yellowish turbid, crude stains on its surface, oil sheen. Water sample collected from the area outisde Pit 2, whitish-yellowish turbid water.

Groundwater Groundwater Groundwater

Groundwater Groundwater Groundwater

No No No

6

GU-08

Groundwater

Groundwater

No

6

LA-05

Groundwater

Groundwater

Creek

No

PRELIMINARY Issued: January 23, 2009 Page B-5 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Groundwater Groundwater Groundwater

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6 6 6

LA-20 LA-20 LA-01

6

LA-12

6

LA-16

6

LA-16

LAG20-A1SD1-AF1NF(450) LAG20-A1SD1-AF1-NF(5) LAG01-A1SD1-AF1NF(10) LAG12-A1SD1-AF1NF(90) LAG16-A1SD1-AF1NF(10) LAG16-A2SD2-AF1NF(90) LAG35-A1SD1-AF1-NF(5)

Groundwater Groundwater Groundwater

Pit Creek Creek Between pit1 and pit2 Pit

No No No

Water sample collected from the area outside closed Pit 1, whitish-yellowish water little turbid. Water sample collected from edge of the creek, yellowish turbid water with oily sheen. Water sample collected from an area outside the flare pit, oil sheen on surface, hydrocarbon odor. Water sample collected from an area outside Pit 1, yellowish turbid water. Water sample collected from Pit 1 goose neck exit, dark turbid water with oil sheen. Water sample collected from swampy area next to Pit 1, dark turbid water with oil sheen. Water sample collected from an area outside Pit 1, yellowish turbid water, hydrocarbon odor, oil sheen.

Groundwater

Groundwater

No

Groundwater

Groundwater

No

Groundwater

Groundwater

Pit

No

6

LA-35

Groundwater

Groundwater

Pit

No

PRELIMINARY Issued: January 23, 2009 Page B-6 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Groundwater

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6

RON01 RON01 RU-1

6

6

6

SA-056

6

SSF-33

6

SSF-33

RON01-A1SD1-AF1NF(30) RON01-A1SD2-AF1NF(10) RUM01-A1SD1-AF1NF(50) SAC56-A2SD1-AF1NF(10) SSF33-A1POZ1-AF1NF(500) SSF33-A2SD1-AF1NF(50)

Groundwater

Swamp

No

Water sample collected from swampy area, yellowish water, hydrocarbon odor, oily drops, oil sheen. Water sample collected from swampy area, yellowish water, slight hydrocarbon odor, oil sheen. Water sample collected from the area outside Pit 2, reddish turbid water. Water sample collected from en el Creek near Pit 1, whitish-yellowish water. Water sample collected from well located outside Pit 1, clear water. Water sample collected from an area outside Pit 2, yellowish turbid water.

Groundwater

Groundwater

Swamp Between Pit and Creek Next to a Creek Well 50m S of pit 1

No

Groundwater

Groundwater

No

Groundwater

Groundwater

No

Groundwater

Groundwater

No

Groundwater

Groundwater

No

PRELIMINARY Issued: January 23, 2009 Page B-7 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Groundwater Surface Water Water Column Water Column Water Column Water Column

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6 6 6

SSF-35 AG-08 AG-05

SSF35-A2POZ1-AF1NF(1000) AGU08-A1SD1-AF1-NF(0) AGU05-PIT2SD1-AF1NF(10) AGU08-PIT1SD1-AF1NF(10) AGU10-PIT1SD1-AF1NF(40) AGU10-PIT2SD1-AF1NF(140)

Groundwater Groundwater Groundwater

35m from pit 4 Swamp Pit

No Yes Yes

Water sample from well at abandoned house, clear water. Water sample collected from swamp near Pit 1, yellowish turbid water, hydrocarbon odor. Water sample collected from Pit 2, yellowish water, slight hydrocarbon odor. Sample collected from Pit 1, water at the boring point has overflowed onto the surface, oil sheen was found on the surface. Water is yellowish turbid. Water sample collected from en la Pit 1, semitransparent water, hydrocarbon odor, surface hydrocarbon stains. Water sample collected from closed Pit 2, turbid water.

6

AG-08

Groundwater

Pit

Yes

6

AG-10

Groundwater

Pit

Yes

6

AG-10

Groundwater

Pit

Yes

PRELIMINARY Issued: January 23, 2009 Page B-8 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Water Column Water Column Water Column Water Column Water Column Water Column

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6

AG-10

6

AU-05

6

AU-07

6

AU-07

6

AU-15

6

AU-19

AGU10-PIT3SD1-AF1NF(20) AUC05-PIT1SD1-AF1NF(30) AUC07-PIT1SD1-AF1NF(30) AUC07-PIT2SD1-AF1NF(30) AUC15-PIT1SD1-AF1NF(20) AUC19-PIT1SD1-AF1NF(20)

Groundwater

Pit

Yes

Water sample collected from Pit 1, brown turbid water, hydrocarbon odor. Water sample collected from Pit 2, yellowish turbid water, hydrocarbon odor, oil sheen. Water sample collected from Pit 1, yellowish turbid water. Water sample collected from Pit 2, yellowish turbid water. Water sample collected from Pit 1, yellowish turbid water. Water sample collected from Pit 1, turbid water.

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater

Pit

Yes

PRELIMINARY Issued: January 23, 2009 Page B-9 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Water Column Water Column Water Column Water Column Water Column Water Column

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6

GU-04

6

GU-08

6

GU-08

6

LA-05

6

LA-20

6

LA-12

GTA04-PIT1SD1-AF1NF(50) GTA08-PIT1SD1-AF1NF(250) GTA08-PIT1SD2-AF1NF(280) LAG05-PIT2SD1-AF1NF(200) LAG20-PIT3SD1-AF1NF(30) LAG12-PIT1SD1-AF1NF(100)

Groundwater

Pit

Yes

Water sample collected from Pit 1, slightly yellowish water. Water sample collected from Pit 1, reddish turbid water, hydrocarbon odor, oily sheen on the surface. Water sample collected from Pit 1, reddish turbid water, hydrocarbon odor, oily sheen on the surface. Water sample collected from Pit 2, slightly turbid water with hydrocarbon odor. Water sample collected from closed Pit 3, dark turbid water, hydrocarbon odor, presence of oil sheen. Water sample collected from Pit 1, turbid water with sediment.

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater

Pit Between pit1 and pit2

Yes

Groundwater

Yes

PRELIMINARY Issued: January 23, 2009 Page B-10 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Water Column Water Column Water Column Water Column Water Column Water Column Water Column

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6

LA-16

6

LA-16

6

LA-35

6

SA-018

6

SA-018

6 6

SA-018 SA-029

LAG16-PIT1SD1-AF1NF(250) LAG16-PIT1SD2-AF1NF(140) LAG35-PIT2SD1-AF1NF(120) SAC18-PIT1SD1-AF1NF(50) SAC18-PIT2SD1-AF1NF(100) SAC18-PIT2SD2-AF1NF(100) SAC29-PIT1SD1-AF1-NF(5)

Groundwater

Pit

Yes

Water sample collected from Pit 1, whitish turbid water, oil sheen, hydrocarbon odor. Water sample collected from Pit 1, yellowish turbid water. Water sample collected from Pit 1, reddish turbid water. Water sample collected east of Pit 1, yellowish turbid water, oil sheen, hydrocarbon odor. Water sample collected from Pit 2, yellowish turbid water, hydrocarbon odor. Water sample collected from Pit 2, yellowish turbid water, oil sheen, hydrocarbon odor. Water sample collected from Pit 1, yellowish turbid water.

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater Groundwater

Pit Pit

Yes Yes

PRELIMINARY Issued: January 23, 2009 Page B-11 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008)

New matrix designation – Responses to attorney Fajardo (November 2008) Water Column Water Column Water Column Water Column Water Column Water Column Pit Water

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6

SA-029

6

SA-056

6

SSF-46

6 6 6

SSF-46 SSF-50 SSF-55

6

SSF-56

SAC29-PIT1SD2-AF1NF(40) SAC56-PIT1SD1-AF1NF(150) SSF46-PIT1SD1-AF1NF(40) SSF46-PIT2SD1-AF1NF(60) SSF50-PIT1SD1-AF1-NF(5) SSF55-PIT1SD1-AF1-R(20500) SSF56-PIT1SD1-AS1-R(30100)

Groundwater

Pit

Yes

Water sample collected from la Pit 1, yellowish turbid water, hydrocarbon odor, oil sheen y crude stains. Water sample collected from Pit 1, yellowish turbid water, slight oil sheen. Water sample collected from Pit 1, brown turbid water. Water sample collected from Pit 2, clear water. Crude sample collected from open Pit 3, yellowish turbid water, oil sheen on the surface. Water sample collected from Pit 1, accumulated rainwater, boring to verify the filtration capacity of the ground in this Pit. Water sample collected from open oil Pit, yellowish water, hydrocarbon odor, crude drops.

Groundwater

Pit

Yes

Groundwater

Pit

Yes

Groundwater Groundwater Groundwater Surface Water

Pit Pit Pit

Yes Yes Yes

Pit

Yes

PRELIMINARY Issued: January 23, 2009 Page B-12 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008) Surface Water Surface Water Surface Water

New matrix designation – Responses to attorney Fajardo (November 2008) Pit Water

Sample Site (Source)

Was there a matrix change ?

Comments by expert Cabrera

6

YU-09

6 6 TOTAL

YU-09 AUS01

YUC09-PIT1SD1-AS1-R(30100) YUC09-PIT2SD1-AS1-R(30120) AUCS01-A1AS1-R(20-120) 67

Pit Pit Swamp Pit Swamp

Yes

Water sample collected from Pit 1, whitish-reddish turbid water, oil sheen on the surface. Water sample collected from open crude Pit 2, yellowish water, hydrocarbon odor, oil sheen. Water sample collected from a spill area, yellowish turbid water, hydrocarbon odor, oil sheen.

Groundwater Surface Water

Yes No

PRELIMINARY Issued: January 23, 2009 Page B-13 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008) Water Water Water Water Water Water Water Water Water

Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez

AU-04 AU-04 AU-04 AU-04 AU-04 AU-04 AU-04 AU-04 AU-04

AU-04-P10-A1 AU-04-P12-A1 AU-04-P13-A1 AU-04-P1-A1 AU-04-P2-A1 AU-04-P3-A1 AU-04-P4-A1 AU-04-P5-A1 AU-04-P7-A1

New matrix designation – Responses to attorney Fajardo (November 2008) Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned

Sample Site (Source)

Was there a matrix change?
Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable

Comments by expert Cabrera

Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown

----------

PRELIMINARY Issued: January 23, 2009 Page B-14 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008) Water Water Water Water Water Water Groundwater Groundwater Groundwater Groundwater

Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez

AU-04 SA-090 SA-090 YU-03 YU-03 YU-03 LA-20 LA-20 LA-20 LA-20

AU-04-P8-A1 SA-090-P1-A1 SA-090-P9-A1 YU-03-P5-A1 YU-03-P7-A1 YU-03-P8-A1 LA-20 CO1 M1 LA-20 P1 M1 LA-20 P1 M2 LA-20 P1 M5

New matrix designation – Responses to attorney Fajardo (November 2008) Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned

Sample Site (Source)

Was there a matrix change?
Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable

Comments by expert Cabrera

Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown

-----------

PRELIMINARY Issued: January 23, 2009 Page B-15 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008) Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater

Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez

LA-20 LA-20 LA-20 LA-20 LA-20 SA-090 SA-090 SA-090 SA-090 SA-090

LA-20 P1 P3 LA-20 P4 A1 LA-20 P6 M1 LA-20 P8A1 LA-20 P9 M1 SA-090-P11-A1 SA-090-P7-A1 SA-090-P8-A1 SA90POZART1 SA90POZART2

New matrix designation – Responses to attorney Fajardo (November 2008) Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned

Sample Site (Source)

Was there a matrix change?
Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable

Comments by expert Cabrera

Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown

-----------

PRELIMINARY Issued: January 23, 2009 Page B-16 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008) Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Surface Water Surface Water Surface Water

Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez Gómez

SSF-61 YU-03 YU-03 YU-03 YU-03 YU-03 YU-03 SSF-61 SSF-61 SSF-61

SSF-61 P7 A1 YU-03-P11-A1 YU-03-P1-A1 YU-03-P2-A1 YU-03-P3-A1 YU-03-P4-A1 YU-03-P6-A1 SSF-61 P1 A1 SSF-61 P4 A1 SSF-61 P6 A1

New matrix designation – Responses to attorney Fajardo (November 2008) Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned Not mentioned

Sample Site (Source)

Was there a matrix change?
Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable

Comments by expert Cabrera

Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown

-----------

PRELIMINARY Issued: January 23, 2009 Page B-17 of B-17

APPENDIX B CHANGES TO THE SAMPLING MATRIX DESIGNATION BY EXPERT CABRERA

Sampling Trip

Site

Sample ID

Original matrix designation in the Expert Report (March 2008) Surface Water Surface Water

Gómez Gómez TOTAL

YU-03 YU-03

YU-03-PIS2-A1 YU-03-PIS3-A1 41

New matrix designation – Responses to attorney Fajardo (November 2008) Not mentioned Not mentioned

Sample Site (Source)

Was there a matrix change?
Not applicable Not applicable

Comments by expert Cabrera

Unknown Unknown

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