DSHW-2024-007783

RCRA Operation and Maintenance Report
At
Former Pennzoil Roosevelt Refinery
The Pennzoil-Quaker State Company (PQS)
d.b.a. SOPUS Products (Shell Oil Products US)

EPA# UTD073093874

State of Utah Hazardous Waste Management Program
August 13, 2024

Prepared by
Hao Zhu

Utah Department of Environmental Quality
Division of Waste Management and Radiation Control

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OPERATION AND MAINTENANCE REPORT
Dates of Inspection: June 25-26, 2024

Facility: The Pennzoil - Quaker State Company
d.b.a. SOPUS Products
Approximately 1312 West Highway 40,
Roosevelt, Utah 84066
Duchesne County, Utah
EPA# UTD073093874

Facility Contact: Buddy Bealer
Shell Oil Products US (SOPUS)
[e-mail]

Facility Consultant: James Carrino, Project Manager
AECOM
[e-mail]

Notification: RCRA Post-Closure Permit

Applicable Regulations: State-issued RCRA Post-Closure Permit, 2014, as modified.
Utah Hazardous Waste Management Rules, Utah Admin. Code
(UAC) R315

Type of Inspection Operation and Maintenance Inspection
Report of Annual Groundwater Monitoring

Participants: Hao Zhu, Utah Division of Waste Management and Radiation
Control (DWMRC)
Ethan Upton, DWMRC
Quinn Walker, AECOM
Nathan Nicolodemos, AECOM

Weather: Sunny, 80s-90s oF

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I. CREDENTIALS, PURPOSE AND SCOPE

Staff of the Division Waste Management and Radiation Control (DWMRC) conducted a
Resource Conservations and Recovery Act (RCRA) Operation & Maintenance (O&M)
inspection on June 25-26, 2023 of the former Pennzoil Refinery (Site), in accordance with
the Post-Closure Permit issued jointly to Pennzoil Quaker State Company d.b.a. SOPUS
Products (Pennzoil) and Roosevelt Land Investment, LLC (RLI). This inspection was under
the authority of Utah Solid and Hazardous Waste Act 19-6-109.

Upon arrival on the morning of June 25, 2024, the DWMRC inspectors met Quinn Walker and
Nathan Nicolodemos of AECOM, consultant to Pennzoil, who were performing the groundwater
monitoring and Site inspection activities at the Site. The purpose and scope of the O&M
Inspection was explained to the AECOM personnel as the evaluation of the annual groundwater
sampling requirements and the Site conditions in accordance with the requirements of the former
refinery's Post-Closure Permit (permit) that was first issued to Pennzoil in 1993 and renewed in
2004 and 2014. The current permit issued in 2014 added RLI as a co-permittee.

The AECOM personnel also briefed the inspectors on their sampling/inspection plan and
provided an update of the field work completed before the inspectors’ arrival. The June 2024
field activities included the semi-annual Site inspection, groundwater level measurements and
light non-aqueous phase liquid (LNAPL) measurements. The scope of the field activities also
included collection of the groundwater samples for annual morning required by the permit

II. FACILITY DESCRIPTION AND SITE BACKGROUND

The Site is located west of Roosevelt City in Duchesne County of Utah. The site location map is
shown in Figure 1. Please note that the report figures are extracted from the 2023 Annual
Groundwater Monitoring and Site Management Report (DSHW-2023-009831). The geographic
location is Section 29, T2S, R1W, Uinta Special Base and Meridian (USBM), approximately at
latitude 40o16'48" North and longitude 110o01'02" West.

The Site is mostly vacant at the present time, except for the portions inside the former refinery
area used for parking of vehicles and storage of equipment, and the front area including an office
building and a maintenance shop along US Highway 40 which are leased to Foreland
Transportation from RLI, the current property owner. Foreland Transportation is an oil energy
company that handles oil-field materials and equipment. Foreland Transportation had leased the
property from Pennzoil since 1990s after the refinery was closed. It appears that Foreland has
continued to lease the property from RLI since RLI purchased the property from Pennzoil in
2006.

The former petroleum refinery operated from 1968 to 1994 processing 5,000 to 7,500 barrels of
oil per day while producing gasoline, diesel fuel, fuel gas, butane, and propane. The crude oil

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was a low sulfur stock produced locally in the nearby Altamont and Bluebell fields of the Uinta
Basin and was known as Altamont-Bluebell crude.

In September 1994, Pennzoil ceased operations at the refinery and began to dismantle the
process units and equipment. The property was first sold to Inland Resources, Inc. (Inland) in
1998. Inland transferred ownership to Silver Eagle Refining. On May 10, 2006, the property
was sold to the current ownership of RLI and Western View Partners LLC. Pennzoil retains the
environmental liability for contamination relating to its operations prior to the 1998 sale to
Inland. This liability was transferred to Pennzoil-Quaker State Company d.b.a. SOPUS Products
when Pennzoil was sold in 2002.

As a result of past operations, the refinery generated a number of contaminated areas impacted
primarily by petroleum hydrocarbons and other contaminants. During the RCRA Facility
Assessment (RFA) and RCRA Facility Investigation (RFI) processes, these impacted areas were
further identified as 40 Solid Waste Management Units (SWMUs). The SWMU descriptions can
be found in 2009 Corrective Action Plan (CAP) prepared by Malcolm Pirnie, Inc. Figures 2 and
3 depict the former refinery layout and the two significant SWMUs that are further described in
the below paragraphs.

SWMU-P-4, is also known as the Waste Disposal Cell (WDC), a permitted hazardous waste
management unit (HWMU), as shown in Figure 3, which consists of the former hazardous waste
surface impoundments that were used to treat all refinery wastewater. Figure 3 also shows
SWMU 5, named the Hydrocarbon Seep, which was identified as the source area of the Site-
wide groundwater contamination during the facility RFI process.

The WDC was closed as a HWMU in place with a clay cover and is currently managed under the
facility's Post-Closure Permit which was last reissued by the DWMRC in 2014. The Post-
Closure Permit includes requirements for monitoring the shallow perched groundwater in six
wells located upgradient and downgradient of the WDC, requirements for monitoring the Site-
wide wells, and other ongoing Site management and activities to ensure protection of human
health and the environment. The permit also includes post-closure care of the WDC and semi-
annual Site inspections. The WDC groundwater monitoring well locations, and Site-wide well
and piezometer locations are shown in Figure 3.

As required by the permit, Pennzoil developed and submitted by its consultant the final CAP for
remediating and managing the SWMUs in June 2009. The objective of the CAP was to complete
the corrective action process, as required by the post-closure permit, by establishing cleanup
objectives, identifying corrective actions, and outlining monitoring requirements for the Site.

Prior to the development of the CAP, multi-phased RFI and remediation activities were
conducted at the Site between 1995 and 2004, which included a human health risk assessment
and the development of Site-specific risk-based remedial action levels. Interim Measures (IM)
were conducted at some highly contaminated SWMUs between 2005 and 2007. In-situ

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landfarming, ex-situ landfarming, bioventing and excavation / off-Site disposal were selected as
corrective measures at different SWMUs of the Site.

Section 6 of the 2009 CAP also included a Site Management Plan (SMP), as required by R315-
101-7 of the Utah Admin. Code. In February 2010, an environmental covenant (EC) was
recorded in Duchesne County by RLI, the property owner, to ensure implementation of the
activity and use limitations for the Site.

In November 2020, the SMP was updated into a standalone document from the 2009 SMP
contained in the CAP. The updates and revisions to the SMP are necessary to reflect the current
activities, e.g., the facility inspection frequency from monthly in the past to semiannually and
groundwater monitoring frequency from semiannually to annually, as currently required by the
Post-Closure Permit. The updated SMP also incorporates the land activity and use limitations
specified late in the 2010 EC for the Site. The updated SMP contains the same requirements as
in the 2009 version of the SMP on maintaining the Site security, which are also required by the
permit.

However, the 2010 EC only referred to Section 6 of the 2009 CAP as the SMP companion to the
EC. The 2010 EC should also be updated in reference to the 2020 updated SMP. The EC also
needs to be updated to reflect the co-permittees of the permit.

In 2020, the DWMRC also approved an updated Sampling and Analysis Plan (SAP). Th updated
SAP was removed from an attachment of the permit through a Class 3 permit modification that
was approved in 2019. The SAP is now a stand-alone document that is referenced by the permit.
This allows the SAP to be updated with the most applicable and current information without
modifying the permit in the future. The updated SAP also includes a Quality Assurance Project
Plan (QAPP) as a part of the United States Environmental Protection Agency’s (USEPA)
mandatory quality system. The QAPP was developed in accordance with the USEPA
Requirements for Quality Assurance Project Plans, EPA/240/B-01/003, March 2001, to ensure
the type and quality of data needed for environmental decisions and to describe the methods for
collecting and assessing those data.

As a part of the above permit modification requested by the DWMRC, the permit and 2020 SAP
now require the full suite of volatile organic compound (VOC) analytes be reported to the
DWMRC to meet the fundamental objectives of detection monitoring and Site condition
assessment. In the past, many constituents of VOCs associated with the Site contamination were
present at the Site but were never reported to the DWMRC because of the limited reporting of
the analytes listed in the original permit. The analytical deficiency documented by the inspectors
based on split sampling results was corrected in 2020 SAP through a Class 3 permit modification
in 2019. The annual groundwater report was also changed in the permit from the Corrective
Action Status Report to the Annual Groundwater Monitoring and Site Management Report to
reflect the current activities.

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It is also necessary to note that the 2019 Class 3 permit modification to the 2014 permit added
RLI, the current property owner, as one of co-permittees of the permit, with Pennzoil - Quake
State Company, d.b.a. Shell Oil Products US (SOPUS). Based on the records, RLI has been a
recipient of the permit, annual reports, and correspondence regarding the former Pennzoil
refinery Site since its purchase of the property.

However, to date, RLI has been non-responsive to the DWMRC’s inquiries about the Site,
notifications of planned Site inspections, Site security, Site management requirements, spills, or
draft permit renewal. Recently, the Director of the DWMRC sent a letter dated July 9, 2024, via
certified mails, to all members of the Roosevelt Land Investment, LLC, in addition to Mr. John
Wells who is identified in the permit as a contact person, in order to seek their input on the draft
permit renewal. The members of RLI continue to remain non-responsive.

III. SITE GEOLOGY AND UPPERMOST AQUIFER

The former Pennzoil refinery is located in the northern portion of the Uinta Basin section of the
Colorado Plateau. Elevations in the northern Uinta Basin range from approximately 4,650 feet at
the confluence of the Green and White Rivers, to more than 13,000 feet in the Uinta Mountains.
Ground elevations of processing structures at the refinery lie at an elevation of approximately
5060 feet, with a maximum relief of approximately 25 feet between the southwest (upstream)
and northeast (downstream) corners of the property.

The geomorphology of the Uinta Basin is dominated by eroded sedimentary rocks, primarily of
Tertiary age, which are folded along an east-trending syncline. Part of the basin consists of
strongly dissected badlands, represented by the area east of Roosevelt, and part consists of local
plateaus, represented by the area west of Roosevelt, where the general land surface is higher.
The several levels of the plateaus slope gently southeastward and are pediment surfaces mantled
with coarse-grained unconsolidated and semi-consolidated deposits.

The existing monitoring well network is established in the uppermost, perched groundwater zone
that varies by location beneath the Site, from unconfined in unconsolidated sediments to
confined in consolidated sediments. The unconfined zone consists primarily of interbedded clay,
silt, sand, and gravel typical of fluvial erosion and deposition in an arid environment.

Sediment type changes fairly rapidly in both the vertical and horizontal directions. The materials
in the uppermost aquifer are primarily gravels (cobbles) with a sand and silt matrix in the area of
the upgradient wells (MW-1 and MW-7), and in the area north of the intermittent stream
channel. Around the wastewater treatment ponds the aquifer materials are primarily silty, very
fine to fine grained sands with minor amounts of clay. Sandy silts with clay are also present in
the area of the surface impoundments and assumed to be near the base of the uppermost aquifer.

The depth to groundwater surface in the uppermost zone ranges from approximately 1 to 10 feet
below ground surface. The groundwater in the uppermost aquifer is largely present under

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unconfined conditions. The potentiometric surface map of groundwater elevations in June 2022
is shown in Figure 4. The direction of groundwater flow in the upmost aquifer is generally
northeast. The hydraulic conductivity is in the Site range of 0.2 to 16.2 feet/day, the porosity is
from 0.25 to 0.35, the hydraulic gradient ranges from 0.007 to 0.038 foot per foot (ft/ft) during
the time of the RFI, and the groundwater velocity has been calculated in the range from 0.007 to
0.59 feet/day.

Based on groundwater elevation data collected during the 2023 monitoring event, the
predominant direction of the perched groundwater flow beneath the former refinery is to the
northeast. The hydraulic gradient beneath the WDC is approximately 0.0054 ft/ft to the
northeast between wells MW-7 and MW-11. The hydraulic gradient beneath the SWMU P-5
area is approximately 0.0074 ft/ft generally to the northeast between wells MW-24 and MW-109.
These gradients are similar to those derived in June 2022 and previous years.

IV. GROUNDWATER MONITORING PROGRAM

Details and standard practices regarding the groundwater monitoring program data quality
assurance and quality control are outlined in the SAP.

Below is a summary of the requirements found in the SAP document: Wells to be monitored
during post-closure care of the WDC include MW-7, MW-11, MW-12, MW-19, MW-20, and
MW-21, located upgradient and downgradient of the WDC (Figure 3). The WDC wells are
gauged and sampled in the following order from upgradient to downgradient locations, unless
based on field observation or based on the results of prior sampling events.

The Site-Wide monitoring wells, located on the eastern half of the property near SWMU P-5, the
Hydrocarbon Seepage, including MW-24, MW-105, MW-108, MW-109, and MW-115, are
monitored in accordance with the 2009 CAP and 2020 SMP. The Site-Wide monitoring wells
are located along the downgradient of the perimeter of the former refinery boundary except for
one well, MW-24. The primary purpose of Site-Wide monitoring is to assess the migration of
groundwater contamination off the property boundary and the groundwater contamination
source. Based on the current Site conditions, LNAPL is still present in a few monitoring wells.
In accordance with the updated 2020 SMP and to accurately assess the groundwater
potentiometric surface, the following additional wells in the vicinity of the WDC and SWMU P-
5 areas will be gauged for LNAPL thickness, if present, and depth to perched groundwater: MW-
15, MW-17, MW-102, MW-106, MW-107, MW-112, MW-120 and MW-127.
Additional monitoring wells and piezometers, which are neither a WDC nor a Site-wide well,
observed to have contained LNAPL at some point in the historical record, will be gauged during
post-closure care including MW-1, MW116A, MW-117, MW-118, MW-119, MW-121, MW-
122, MW-126, P-1, TP-40, TP-41, and TP-42.

Prior to purging and sampling, fluid level measurements will be collected from each designated

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monitoring well using a decontaminated electronic oil-water interface probe and documented on
field log forms. Depth to perched water and depth to LNAPL, if present, below the reference
point at the top of each casing will be measured to the nearest 0.01 foot and recorded on the
sampling log along with general well characteristics including well diameter, plug and lock
presence, type of well pad and condition. The total depth of each well will also be measured and
recorded to detect well obstructions or possible silting of the well screen.

The volume of water purged will equal three times the computed casing volume where possible.
The casing volume is calculated using the total standing depth of water in the well and the well
diameter. Wells which are dewatered prior to three well volumes being removed, will be
allowed to recharge prior to sampling. No additional purging will be conducted after the wells
are initially dewatered.

During purging field parameters including pH, specific conductivity, and temperature readings
will be obtained approximately every 10 minutes using a flow-through cell and water quality
meter. Parameters will be recorded on field sampling forms and/or the project field book. All
equipment used for field analyses will be calibrated prior to use according to the manufacturer’s
instructions and will be decontaminated prior to use at each well using the procedures described
in Section 2.6. The pH values will be measured to the nearest 0.01 unit, conductivity to at least
two significant digits, and temperature to the nearest 0.1 degrees Celsius (°C).

Samples for analysis of volatile organic compounds will be collected directly from the discharge
tubing at reduced flow rates (<100 milliliter per minute, mL/min). Vials for volatile organic
analyses will be filled to overflowing with a convex meniscus forming at the mouth of the vial.
The lids with Teflon-lined septa will be attached, and the vial will be inverted and gently tapped
to check for air bubbles (zero headspace). If bubbles exist, the sample and bottle will be
discarded and another new sample container with preservative to be collected a sample using the
above procedures until zero headspace is assured.

V. WDC MONITORING AND SITE CONTAMINATION STATUS

Based on historical groundwater detection monitoring data, it appears that there is no
evidence of a release from the WDC.

Based on the 2023 Site-Wide monitoring data from the current six wells required by the
permit, also as shown in the Figure 5 of this O&M report, it appears that the extent of the
groundwater contamination is primarily within the property boundary, except for 1,2
dichloroethane detected in the following perimeter monitoring wells MW-108 (3.79
micrograms per liter (µg/L) and MW-109 (6.25 µg/L) in 2023. LNAPLs were observed in
2023 in wells MW-117, MW-121, MW-126, TP-40, and TP-41, similar to the previous year.

During the 2023 monitoring event, in addition to sampling the six Site-Wide monitoring wells,
Pennzoil and AECOM also conducted one-time sampling at all other wells that are not currently

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sampled under the permit. The purpose of the one-time groundwater sampling event was to
assess the current groundwater conditions and the Site-Wide monitoring network and to abandon
the wells that are no longer needed for the Site in the future.

The one-time sampling results that are presented in the revised 2023 Roosevelt Site Assessment
Report (DSHW-2024-006540) indicate that benzene was detected at the concentration of 165 μg/L in MW-113, a perimeter well concerning off-Site migration exceeding the maximum
contaminant level (MCL) of 5 μg/L. Within SWMU-P5, the benzene was detected at the
concentrations of 3770 μg/L in MW-22 and 1670 μg/L in MW-25. Pennzoil sampled these wells
again in June 2024 to determine if the current Site-Wide groundwater monitoring network needs
to be updated.

Based on the results of the 2023 one-time groundwater sampling data Pennzoil and AECOM
proposed to abandon some groundwater wells and piezometers in the May 2024 revised
Roosevelt Site Assessment Report. The DWMRC approved the proposed well abandonment in
July 2024. The implementation of well abandonment is pending.

VI. O&M INSPECTION

VI.1. Office Preparation

The O&M Inspection is designed to determine whether Pennzoil is in compliance with
applicable requirements of the permit. Monitoring groundwater in the uppermost aquifer
assists in determining whether a release or potential release of hazardous waste constituents may
have occurred from the WDC and also in assessing the groundwater quality at other locations of
the former refinery. Based on the sampling results, if needed, corrective measures to protect
human health and the environment may be considered, according to Utah Admin. Rule R315-101
and the permit.

These requirements include inspections for proper O&M of the facility, proper maintenance
of groundwater monitoring wells and consistency of groundwater monitoring program. In
general, the O&M inspection should identify issues or concerns that should be assessed for
future groundwater monitoring events in accordance with the permit.

In preparation for the field inspection, DWMRC staff conducted a review of the Pennzoil's
SAP including the QAPP, referenced in the permit. The inspectors also conducted reviews
of the selected previous annual groundwater monitoring and Site management reports.

As a part of the office preparation and follow up review, the inspectors also reviewed the 2023
Annual Groundwater Monitoring and Site Management Report (DSHW-2023-209831).

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VI.2. Field Inspection and Observation

VI.2.1. Observation of Field Crew

Quinn Walker and Nathan Nicolodemos of AECOM performed the June 2023 groundwater
monitoring and sampling event. Mr. Walker has conducted the field sampling and
inspections several times at the Pennzoil Site. At the time of inspection, it appears that both
Mr. Walker and Mr. Nicolodemos have experience working on groundwater sampling and
investigation (Photo 1).

Based on the field observations of sampling activities, the inspectors concluded that the field
crew followed the overall groundwater monitoring and sampling procedures as specified in
the SAP.

In addition, the AECOM personnel were required to conduct an inspection of the WDC and
the Site in accordance with the current permit. The inspectors did not observe the
AECOM’s Site inspection. The results of the inspection will be included in the 2024
Annual Groundwater Monitoring and Site Management Report.

VI.2.2. Site Inspection Narratives

The following serves to document the findings and observations of the inspectors at the time, as
noted above, when inspection activities were performed of the groundwater sampling activities at
the Site. The inspectors also performed inspection and walk-through of the Site. Photos of
groundwater monitoring activities and the inspections are included in Attachment 3 of the 2024
O&M Report. Photos 1-2 show the samplers collecting groundwater samples.

At the time of inspection, the inspectors again observed oil piping that was stored likely by
RLI/the tenant, but not by Pennzoil, on the RLI property (Photos 3-4). It is unknow about
the quantity of residual oil left in the piping and the amount of oil that would drain out the
piping over time.

It appeared that the oil impact to the soil was minimal in comparison with what was
observed last year from the different piles of oil piping stored on the property.

During the 2023 O&M inspection, the inspector observed oil spills drained out of from the
stored piping impacted the soil on the ground over the time. On July 20, 2023, the AECOM
project manager provided the DWMRC with a written notice of the spill of waxy crude oil.
The notice (DSHW-2023-206633) indicated the oil and stained soil have been cleaned up
and disposed of at LaPoint Recycle and Storage, an approved oil disposal facility, based on
a statement made by Brad Wells, a property owner representative, to the AECOM project
manager. The last year’s piping was later sold to a metal recycler.

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AECOM also collected confirmation soil samples after the soil removal from the areas
where the piping was stored. The sampling results were included in the revised Roosevelt
Site Assessment Report (DSHW-2024-006540). For the spill observed last year, the
DWMRC requested the co-permittees Pennzoil and RLI address the oil spill in a letter dated
August 4, 2023.

At the time of inspection, the inspectors also met an AECOM contractor for the proposed
fencing around SWMU-P5.

VI.3. Identification of Deficiencies and Concerns

Based on the inspection conducted during a portion of the sampling event, no deficiencies were
identified regarding the annual groundwater monitoring event in accordance with the permit.

The inspectors noted that the oil piping was again stored on the ground and discussed the
concerns of potential spills from the piping with AECOM samplers.

________________________ _____________________
Hao Zhu Date
Environmental Engineer

8/13/2024

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Attachment 1 – Figures

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Attachment 2 - Tables

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Table 1: Post-Closure Analytical Requirements for Groundwater Samples

Parameter Container(s) Preservative1 Method Method Detection
Limits (µg/L)
Volatile Organic Compounds
Benzene
Carbon disulfide
Chlorobenzene
Chloroform
1,2-Dibromoethane
1,2-Dichloroethane
1,4-Dioxane
Ethylbenzene
Methyl ethyl ketone
Methylene chloride
Styrene
Toluene
Xylenes2
Three 40-mL
glass vials with
Teflon-lined
septa in caps
per sample
Additionally,
Quality Control
samples have
additional
sample
container
volumes as
specified above.
HCl to pH<2 SW 8260D
0.20
0.22
0.18
0.23
0.21
0.20
72
0.19
2.6
1.0
0.28
0.17
0.58
Oil & Grease Two 1 -Liter
amber glass
HCL volume
will be
determined
prior to
sampling
EPA 1664A 1,400

Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Lead
Magnesium
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Two 500 mL
plastic
HNO3 to pH<2 SW 6010B or
6010C, except
SW 7470A for
Hg

5.0
8.6
5.0
2.0
0.50
500
3.0
5.0
5.0
5.0
250
0.10
3.0
500
5.0
3.0
400
5.0
10
25
Sulfide One 250 mL
plastic
Zinc Acetate/
Sodium
Hydroxide
EPA 376.2 or
SM 4500S2 F-
2011
500
Cyanide One 250 mL
plastic
50% NaOH to
pH>12
SW 9012B 7.0

One 1-Liter

No chemical

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Parameter Container(s) Preservative1 Method Method Detection
Limits (µg/L)
General

Alkalinity
Bicarbonate
Carbonate
Chloride
Fluoride
Nitrate + Nitrite
pH
Specific Conductance
Sulfate
Total Dissolved Solids
Plastic for each
sample analyte
Preservative
H2SO4 –
(Nitrate +
Nitrite)
EPA 310.1 or
SM2320B-2011
EPA 310.1 or
SM2320B-2011
EPA 310.1 or
SM2320B-2011
EPA 9056A
EPA 9056A
EPA 353.2
EPA 9040C
EPA 9050AorSM
2510B-2011
EPA 9056A
EPA 160.1 or
SM 2540C-2011

5,000
5,000
5,000
200
10
80
N/A
10.0 (umhos/cm)
30
7,000

1 Preservative in addition to cooling to 4°-6 °C.
2 Ortho-, meta, and para- isomers, as well as total xylenes

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Attachment 3 - Photos

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Attachment 3 - Photos

2024 O&M Report
Pennzoil Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD073093874
Page - 23 -

Photo 1 Pennzoil Groundwater Sampling Activity, on June 26, 2024

2024 O&M Report
Pennzoil Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD073093874
Page - 24 -

Photo 2 – AECOM Groundwater Sampler Conducting Sampling, June 26, 2024

2024 O&M Report
Pennzoil Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD073093874
Page - 25 -

Photo 3 Oil Piping Stored at the Site, June 25, 2024

2024 O&M Report
Pennzoil Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD073093874
Page - 26 -

Photo 4 – Oil Piping Stored at the Site, June 25, 2024