HAVERTOWN PCP SITE 2008 · 4.4 Plant Operational and Flow Data 11 4.5 Plant's Operationai Changes 11 4.6 Chemical Usage, Utilities and Sludge Production Data 11 4.7 Free Product Recovery

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HAVERTOWN PCP SITE

2008

TECHNICAL ASSESSMENTAND

OPERATIONS & MAINTENANCEREPORT

REMEDIAL ACTION PHASE

Prepared for:

u.s. ENVIRONMENTAL PROTECTION AGENCYREGION III

UNDER

WORK ASSIGNMENT NO. 001-RALR-0354CONTRACT #EP-S3-07-04

JUNE 2009

Prepared by:

Tetra TechNewark, Delaware

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/

HAVERTOWN PCP SITE

2008

TECHNICAL ASSESSMENT AND

OPERATIONS & MAINTENANCE REPORT

REMEDIAL ACTION PHASE

Prepared for:

u.s. ENVIRONMENTAL PROTECTION AGENCY REGION III

UNDER

WORK ASSIGNMENT NO. 001-RALR-0354 CONTRACT #EP-S3-07-04

JUNE 2009

Prepared by:

Tetra Tech Newark, Delaware

Havertown PCP SiteRemedial Action Phase

TABLE OF CONTENTS

2008 Technical Assessment andOperations & Maintenance Report

1.0 INTRODUCTION 11.1 Site Background 11.2 Existing Groundwater Treatment Facility 2

2.0 OPERATIONS & PERFORMANCE SUMMARY 3

3.0 OPERATIONS AND MAINTENANCE ACTIVITIES 43.1 Routine Inspections and Maintenance .4

3.1.1 Daily Inspections .43.1.2 Weekly Inspections .43.1.3 Preventative Maintenance and Unscheduled Maintenance 4

3.2 Monitoring Well Network Description 53.3 Water Level Measurement 53.4 Sampling of Treatment System and Groundwater , 53.5 Major Plant Cleanup Activities (Non-Routine Activities) 63.6 Difficulties and Plant Improvements 73.7 Site Maintenance 83.8 Other Activities 8

4.0 SYSTEM PERFORMANCE 84.1 Groundwater Level and Contaminant Containment.. 84.2 Plant Influent, Effluent and Process Contaminant Data 94.3 Groundwater Contaminants and Containment.. 104.4 Plant Operational and Flow Data 114.5 Plant's Operationai Changes 114.6 Chemical Usage, Utilities and Sludge Production Data 114.7 Free Product Recovery 124.8 Other Unit Processes Performance and Related Issues 12

4.8.1 Oil-Water Separator 124.8.2 Recovery Weli I Collection Trench System 124.8.3 Wastewater Pump Issues 124.8.4 Air Diaphragm Pumps 124.8.5 UV/OX Lamps -Wiper Blades, Other Issues 13

5.0 TECHNICAL ASSESSMENT 135.1 QUESTION A: Is the remedy functioning as intended by the decision documents? 135.3 QUESTION C: Has any other information come to light that could call into question the

protectiveness of the remedy? 13

6.0 RECOMMENDATJONS 14

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Havertown PCP Site Remedial Action Phase

2008 Technical Assessment and Operations & Maintenance Report

TABLE OF CONTENTS

1.0 INTRODUCTION .............................................................................................................................. 1 1.1 Site Background .................................................................................................................. 1 1.2 Existing Groundwater Treatment Facility ............................................................................ 2

2.0 OPERATIONS & PERFORMANCE SUMMARY ............................................................................. 3

3.0 OPERATIONS AND MAINTENANCE ACTIVITIES ........................................................................ 4 3.1 Routine Inspections and Maintenance ............................................................................... .4

3.1.1 Daily Inspections .................................................................................................. .4 3.1.2 Weekly Inspections .............................................................................................. .4 3.1.3 Preventative Maintenance and Unscheduled Maintenance ................................. .4

3.2 Monitoring Well Network Description .................................................................................. 5 3.3 Water Level Measurement .................................................................................................. 5 3.4 Sampling of Treatment System and Groundwater .............................................................. 5 3.5 Major Plant Cleanup Activities (Non-Routine Activities) ..................................................... 6 3.6 Difficulties and Plant Improvements .................................................................................... 7 3.7 Site Maintenance ................................................................................................................. 8 3.8 Other Activities .................................................................................................................... 8

4.0 SYSTEM PERFORMANCE ............................................................................................................. 8 4.1 Groundwater Level and Contaminant Containment.. .......................................................... 8 4.2 Plant Influent, Effluent and Process Contaminant Data ...................................................... 9 4.3 Groundwater Contaminants and Containment.. ................................................................ 1 0 4.4 Plant Operational and Flow Data ...................................................................................... 11 4.5 Plant's Operational Changes ............................................................................................. 11 4.6 Chemical Usage, Utilities and Sludge Production Data .................................................... 11 4.7 Free Product Recovery ...................................................................................................... 12 4.8 Other Unit Processes Performance and Related Issues .................................................. 12

4.8.1 Oil-Water Separator ............................................................................................ 12 4.8.2 Recovery Weill Collection Trench System ......................................................... 12 4.8.3 Wastewater Pump Issues .................................................................................... 12 4.8.4 Air Diaphragm Pumps ......................................................................................... 12 4.8.5 UV/OX Lamps -Wiper Blades, Other Issues ....................................................... 13

5.0 TECHNICAL ASSESSMENT ......................................................................................................... 13 5.1 QUESTION A: Is the remedy functioning as intended by the decision documents? ...... 13 5.3 QUESTION C: Has any other information come to light that could call into question the

protectiveness of the remedy? .......................................................................................... 13

6.0 RECOMMENDATIONS .................................................................................................................. 14

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TABLES


Table 1Table 2Table 3Table 4Table 5Table 6Table 7Table 8Table 9aTable 9bTable 9cTable 10Table 11Table 12Table 13Table 14Table 15Table 16Table 17Table 18Table 19Table 20Table 21Table 22Table 23Table 24

FIGURES

Figure 1Figure 2Figure 3Figure 4Figure 5Figure 6Figure 7Figure 8Figure 9

O&M Routine ActivitiesMonitoring Wells Construction DetailsMonitoring Wells Water Level DataNon-routine O&M ActivitiesDifficulties EncounteredMajor Contaminants in Plant InfluentMajor Contaminants in Recovery Wells and CTRPlant Effluent DataUnit Process Performance Data - UV/OX - Organics RemovalUnit Process Performance Data - Pre-Treatment System - Metals RemovalPlant-wide Process Performance Data - Oil & Grease, Total Phenol and AnionsHistorical Contaminant Concentrations in Monitoring WellsTreatment Plant Online Details and Flow DataDetails of Plant Shutdown (off-line)RW Wells and CTR Flow DataChemical Usage and Feed Rate - Ferric SulfateChemical Usage and Feed Rate - Sodium HydroxideChemical Usage and Feed Rate - Sodium HypochloriteChemical Usage and Feed Rate - Sulfuric AcidChemical Usage and Feed Rate - PolymerChemical Usage and Feed Rate - Hydrogen PeroxideElectric Usage DataGas Consumption DataTreatment Plant Sludge DataFree Product Recovery DataUV/OX Lamps Usage Data

Site Location MapMonitoring Wells Locations (On-Site)Groundwater Level Contours (Shallow Wells)Groundwater Level Contours (Deep Wells)Influent PCP and Dioxin ConcentrationsRecovery Wells and CTR - PCP and Dioxin ConcentrationsTreatment Plant Flow DataRW Wells and CTR Flow DataTreatment Plant Electric Usage

ATTACHMENTS

Attachment AAttachment BAttachment CAttachment DAttachment EAttachment FAttachment G

Detailed System Description with Process Flow DiagramsSelected Tables from Field Sampling PlanNPDES PermitDMR Forms (January 2008 - October 2008)

Major Contaminants in Monitoring Wells (1990 - 2008)Monitoring Well Sampling Analysis (March 2008 - September 2008)

Major Contaminants in Plant Influent Annual Average (2002 - 2008)

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TABLES

Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8 Table 9a Table 9b Table 9c Table 10 Table 11 Table 12 Table 13 Table 14 Table 15 Table 16 Table 17 Table 18 Table 19 Table 20 Table 21 Table 22 Table 23 Table 24

FIGURES

Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9

O&M Routine Activities Monitoring Wells Construction Details Monitoring Wells Water Level Data Non-routine O&M Activities Difficulties Encountered Major Contaminants in Plant Influent Major Contaminants in Recovery Wells and CTR Plant Effluent Data Unit Process Performance Data - UV/OX - Organics Removal Unit Process Performance Data - Pre-Treatment System - Metals Removal Plant-wide Process Performance Data - Oil & Grease, Total Phenol and Anions Historical Contaminant Concentrations in Monitoring Wells Treatment Plant Online Details and Flow Data Details of Plant Shutdown ( off-line) RW Wells and CTR Flow Data Chemical Usage and Feed Rate - Ferric Sulfate Chemical Usage and Feed Rate - Sodium Hydroxide Chemical Usage and Feed Rate - Sodium Hypochlorite Chemical Usage and Feed Rate - Sulfuric Acid Chemical Usage and Feed Rate - Polymer Chemical Usage and Feed Rate - Hydrogen Peroxide Electric Usage Data Gas Consumption Data Treatment Plant Sludge Data Free Product Recovery Data UV/OX Lamps Usage Data

Site Location Map Monitoring Wells Locations (On-Site) Groundwater Level Contours (Shallow Wells) Groundwater Level Contours (Deep Wells) Influent PCP and Dioxin Concentrations Recovery Wells and CTR - PCP and Dioxin Concentrations Treatment Plant Flow Data RW Wells and CTR Flow Data Treatment Plant Electric Usage

ATTACHMENTS

Attachment A Attachment B Attachment C Attachment D Attachment E Attachment F Attachment G

Detailed System Description with Process Flow Diagrams Selected Tables from Field Sampling Plan NPDES Permit DMR Forms (January 2008 - October 2008)

Major Contaminants in Monitoring Wells (1990 - 2008) Monitoring Well Sampling Analysis (March 2008 - September 2008)

Major Contaminants in Plant Influent Annual Average (2002 - 2008)

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REFERENCES


1. CRL, 1996. USEPNOffice of Analytical Services and Quality Control. Data Validation Reports (seeAppendix D for cross-reference and specific laboratory report dates).

2. URS Construction Services. Preliminary Draft Operation and Maintenance Manual. June 2001.3. Tetra Tech, Inc. Sampling and Analysis Plan, March 2003 with June 2005 revised tables4. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

January 2008.5. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

February 2008.6. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

March 2008.7. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report. April

2008.8. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report. May

2008.9. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

June 2008.10. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report. July

2008.11. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

August 2008.12. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

September 2008.13. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

October 2008.14. Tetra Tech, Inc. Technical Assessment and Operation & Maintenance Report for Year 2002-2004,

June 2005.15. Tetra Tech, Inc. Technical Assessment and Operation & Maintenance Report for Year 2004-2005,

April 2006.16. Tetra Tech, Inc. Technical Assessment and Operation & Maintenance Report for Year 2006, March

2007.17. Tetra Tech, Inc. Technical Assessment and Operation & Maintenance Report for Year 2007, May

2008.

111

I!


REFERENCES


1. CRL, 1996. USEPNOffice of Analytical Services and Quality Control. Data Validation Reports (see Appendix D for cross-reference and specific laboratory report dates).

2. URS Construction Services. Preliminary Draft Operation and Maintenance Manual. June 2001. 3. Tetra Tech, Inc. Sampling and Analysis Plan, March 2003 with June 2005 revised tables 4. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

January 2008. 5. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

February 2008. 6. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

March 2008. 7. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report. April

2008. 8. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report. May

2008. 9. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

June 2008. 10. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report. July

2008. 11. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

August 2008. 12. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

September 2008. 13. Tetra Tech, Inc. Groundwater Extraction and Treatment System Discharge Monitoring Report.

October 2008. 14. Tetra Tech, Inc. Technical Assessment and Operation & Maintenance Report for Year 2002-2004,

June 2005. 15. Tetra Tech, Inc. Technical Assessment and Operation & Maintenance Report for Year 2004-2005,

April 2006. 16. Tetra Tech, Inc. Technical Assessment and Operation & Maintenance Report for Year 2006, March

2007. 17. Tetra Tech, Inc. Technical Assessment and Operation & Maintenance Report for Year 2007, May

2008.

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ABBREVIATIONS


UNITS

For groundwater: 1000 ppb = 1 part per million ('ppm'),1000 uglL = mg/LFor air: 1000 ppbv = 1 ppmv ("v" is concentration by volume)For dioxin: 1,000,000 pq/L (part per quadrillion)= 1ppb

For the purposes of providing continuity and ease ofcomparison, units of measurement in this report will bepresented in parts per billion·("ppb"), unless otherwisespecified. These units may differ from those used in theother reports concerning the Site (e.g., RifFS). Listed beloware the respective conversion unit equivalents.

AQARARsARCS

BDLCCCCERCLA

cfmCLPCOCCTRDASDMRDOEPAEQFCPFRPftgGAC

) GESgpmGWTPGWTSHDPEHHHOAHSOHVACLCPLTRAMCCMHMGmg/LMOCMSDSMWNANCNDNECNH4ng/LNONPDESNTNWPO&M

Aqueous PhaseApplicable, Relevant, or Appropriate RequirementsAlternative Remedial ContractingStrategyBelow detection limitCalgon Carbon CorporationComprehensive EnvironmentalResponse, Compensation, and liabilityActcubic feet per minuteContract Laboratory ProgramChain-of-CustodyCollection TrenchDelivery of Analytical ServicesDischarge Monitoring ReportDissolved oxygenEnvironmental Protection AgencyEqualization (tank)Field control panelFiberglass reinforced plasticfeetair (gaseous) phaseGranular Activated CarbonGroundwater & Environmental Services, Inc.gallons per minuteGroundwater Treatment PlantGroundwater Treatment SystemHigh density polyethyleneHi-hi (level alarm)Hand/Off/AutoHealth and Safety OfficerHeating, ventilation, and air conditioningLocal Control PanelLong Term Response ActionMotor Control CenterManholemillion gallonsmilligrams per liter = ppmMaterial of ConstructionMaterial Safety Data SheetMonitoring WellNot AvailableNormally closedNon-DetectNational Electrical CodeAmmoniananograms per liter = pptNormally openNational Pollutant Discharge Elimination SystemNot TestedNational Wood PreserversOperation and Maintenance

IV

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ABBREVIATIONS

AQ ARARs ARCS

BDL CCC CERCLA

cfm CLP COC CTR DAS DMR DO EPA EQ FCP FRP ft g GAC GES gpm GWTP GWTS HDPE HH HOA HSO HVAC LCP LTRA MCC MH MG mg/L MOC MSDS MW NA NC ND NEC NH4 ng/L NO NPDES NT NWP O&M

Aqueous Phase Applicable, Relevant, or Appropriate Requirements Alternative Remedial Contracting Strategy Below detection limit Calgon Carbon Corporation Comprehensive Environmental Response, Compensation, and Liability Act cubic feet per minute Contract Laboratory Program Chain-of-Custody Collection Trench Delivery of Analytical Services Discharge Monitoring Report Dissolved oxygen Environmental Protection Agency Equalization (tank) Field control panel Fiberglass reinforced plastic feet air (gaseous) phase Granular Activated Carbon

UNITS

For the purposes of providing continuity and ease of comparison, units of measurement in this report will be presented in parts per billion ("ppb"), unless otherwise speCified. These units may differ from those used in the other reports concerning the Site (e.g., RifFS). Listed below are the respective conversion unit equivalents.

For groundwater: 1000 ppb = 1 part per million ('ppm'), 1000 uglL = mg/L For air: 1000 ppbv = 1 ppmv ("v" is concentration by volume) For dioxin: 1,000,000 pq/L (part per quadrillion)= 1 ppb

Groundwater & Environmental Services, Inc. gallons per minute Groundwater Treatment Plant Groundwater Treatment System High density polyethylene Hi-hi (level alarm) Hand/Off/Auto Health and Safety Officer Heating, ventilation, and air conditioning Local Control Panel Long Term Response Action Motor Control Center Manhole million gallons milligrams per liter = ppm Material of Construction Material Safety Data Sheet Monitoring Well Not Available Normally closed Non-Detect National Electrical Code Ammonia nanograms per liter = ppt Normally open National Pollutant Discharge Elimination System Not Tested National Wood Preservers Operation and Maintenance

IV


2008 Technical Assessment andOperations &Maintenance Report

ORPOSHAOUOWOWSOXPADEPPAHPCPCGPCPPCRRPDUPEPIDP&IDpg/lPlCppbppbvPPEppmppqpptpsiPVCQNQCRACRASRDRHRODRWSOWSVOCTALTCETClTOSTSSug/lUPSUSACEUSEPAUVUV/OX1,1,1-TCA1,1-DCEVOC

Oxidation reduction potentialOccupational Safety and Health AdministrationOperable UnitObservation WellOil-water separatorOxidationPennsylvania Department of Environmental ProtectionPolynuclear Aromatic HydrocarbonsProcess ControllerPhiladelphia CheWing Gum CompanypentachlorophenolPenn Central RailroadPeroxide destruction unitPolyethylenePhotoionization DetectorPiping and Instrumentation Diagrampicograms per liter =ppqProgrammable logic controllerparts per billion by massparts per billion by volume (in air)Personal protective equipmentparts per million by massparts per quadrillion by massparts per trillion by masspounds per square inchPolyvinyl chloridequality assurance/quality controlRemedial Action ContractRoutine Analytical ServicesRemedial DesignRelative humidityRecord of DecisionRecovery WellStatement of WorkSemivolatile Organic CompoundTarget Analyte ListTrichloroetheneTarget Compound listTotal dissolved solidsTotal Suspended Solidsmicrograms per liter =ppbUninterruptible power supplyUnited States Army Corps of EngineersUnited States Environmental Protection Agencyultravioletultraviolet/oxidation1,1,1-Trichloroethane1,1-Dichloroethenevolatile organic compound

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ORP OSHA OU OW OWS OX PADEP PAH PC PCG PCP PCRR PDU PE PID P&ID pg/l PlC ppb ppbv PPE ppm ppq ppt psi PVC ONOC RAC RAS RD RH ROD RW SOW SVOC TAL TCE TCl TOS TSS ug/l UPS USACE USEPA UV UV/OX 1,1,1-TCA 1,1-DCE VOC

Oxidation reduction potential Occupational Safety and Health Administration Operable Unit Observation Well Oil-water separator Oxidation Pennsylvania Department of Environmental Protection Polynuclear Aromatic Hydrocarbons Process Controller Philadelphia Chewing Gum Company pentachlorophenol Penn Central Railroad Peroxide destruction unit Polyethylene Photoionization Detector Piping and I nstrumentation Diagram picograms per liter = ppq Programmable logic controller parts per billion by mass parts per billion by volume (in air) Personal protective equipment parts per million by mass parts per quadrillion by mass parts per trillion by mass pounds per square inch Polyvinyl chloride quality assurance/quality control Remedial Action Contract Routine Analytical Services Remedial Design Relative humidity Record of Decision Recovery Well Statement of Work Semivolatile Organic Compound Target Analyte List Trichloroethene Target Compound List Total dissolved solids Total Suspended Solids micrograms per liter = ppb Uninterruptible power supply United States Army Corps of Engineers United States Environmental Protection Agency ultraviolet ultraviolet/oxidation 1,1,1-Trichloroethane 1,1-Dichloroethene volatile organic compound

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1.0 INTRODUCTION


The United States Environmental Protection Agency (EPA), in accordance with provIsions of theRemedial Action Contract (RAG) Number EP-S3-07-04, authorized Tetra Tech to perform Operation andMaintenance Services (O&M) under Operable Unit 2 (OU2) Long Term Response Action (LTRA) at thegroundwater treatment facility at the Havertown PCP Site located in Haverford Township, Pennsylvania.This work assignment (No. 001-RALR-0354 is in accordance with the Statement of Work (SOW) issuedby the EPA to Tetra Tech dated June 28, 2007. The purpose of this LTRA is to operate and maintain thegroundwater treatment facility, optimize the facility's performance, perform all required monitoring(groundwater and surface water discharge) associated with this facility, and maintain the cap inaccordance with the objective of the Remedial Design (RD).

This report summarizes the O&M activities, the status of groundwater contaminant concentrations, andthe treatment system performance, and provides a summary of system operation from January 1, 2008 toDecember 31 , 2008.

1.1 Site Background

The Havertown PCP Superfund site is located in Havertown, Haverford Township, Delaware County, insoutheastern Pennsylvania (Figure 1). The site is located approximately 10 miles west of Philadelphiaand is surrounded by commercial establishments, industries, parks, schools, and residential homes.

The Havertown PCP Superfund site covers approximately 12 to 15 acres, but has no distinct boundaries.It is roughly delineated by Lawrence Road and Rittenhouse Circle to the south, the former Penn CentralRailroad (PCRR) tracks to the north, and the fence on the Continental Motors property to the west, and

'1 Naylors Run to the east.

Historically, the site consists of a number of distinct properties including a former wood treatment facilityowned by National Wood Preservers (NWP), a bubble gum manufacturing plant owned by thePhiladelphia Chewing Gum Company (PCG), and neighboring residential and commercial areas. Formerstructures on the NWP property (lies north of the intersection of Eagle Road and Lawrence Road)consisted of a sheet metal building with multiple aboveground chemical storage tanks. This two-acreNWP property has been capped and is enclosed within a chain-link fence. The PCG facility consists of asingle, large former gum production building located due east of NWP (northeast of the intersection ofEagle Road and Lawrence Road). The residential areas bordering Rittenhouse Circle and Naylors Runcomprise the remainder of the study area (Figure 2).

The major contaminants present at the site include volatile organic compounds (VOC), pentachlorophenol(PCP), polynuclear aromatic hydrocarbons (PAH) and dioxin.

USEPA issued the Record of Decision (ROD) for OU2 on September 30, 1991, and defined the remedy.The primary purpose of the ROD is to capture the entire contaminated shallow groundwater plume that ismigrating from the site under Eagle Road and to treat and discharge it into Naylors Run. Theextraction/recovery wells attempt to reduce the size of the oil plume floating on the water table.

)

Tetra Tech completed the conceptual design for OU2 (shallow groundwater) in 1994. The detailedRemedial Design (RD) for OU2 was completed during the period 1997-2000 by several contractors underU.S. Army Corps of Engineers (USACE). Treatment plant construction was completed in 2001. The plantwas placed in operation in July 2001. Groundwater Environmental Services, Inc. (GES) operated theplant under USACE until August 15, 2002. Since then Tetra Tech has been performing O&M activities atthis plant. A Technical Assessment and Operation & Maintenance Report for 2002-2004 was preparedand submitted in April 2005; a Technical Assessment and Operation & Maintenance Report for 20042005 was prepared and submitted in April 2006; a Technical Assessment and Operation & MaintenanceReport for 2006 was prepared and submitted in March 2007; and a Technical Assessment and Operation& Maintenance Report for 2007 was prepared and submitted in May 2008.

1


1.0 INTRODUCTION


The United States Environmental Protection Agency (EPA), in accordance with provIsions of the Remedial Action Contract (RAG) Number EP-S3-07-04, authorized Tetra Tech to perform Operation and Maintenance Services (O&M) under Operable Unit 2 (OU2) Long Term Response Action (L TRA) at the groundwater treatment facility at the Havertown PCP Site located in Haverford Township, Pennsylvania. This work assignment (No. 001-RALR-0354 is in accordance with the Statement of Work (SOW) issued by the EPA to Tetra Tech dated June 28, 2007. The purpose of this L TRA is to operate and maintain the groundwater treatment facility, optimize the facility's performance, perform all required monitoring (groundwater and surface water discharge) associated with this facility, and maintain the cap in accordance with the objective of the Remedial Design (RD).

This report summarizes the O&M activities, the status of groundwater contaminant concentrations, and the treatment system performance, and provides a summary of system operation from January 1, 2008 to December 31 , 2008.

1.1 Site Background

The Havertown PCP Superfund site is located in Havertown, Haverford Township, Delaware County, in southeastern Pennsylvania (Figure 1). The site is located approximately 10 miles west of Philadelphia and is surrounded by commercial establishments, industries, parks, schools, and residential homes.

The Havertown PCP Superfund site covers approximately 12 to 15 acres, but has no distinct boundaries. It is roughly delineated by Lawrence Road and Rittenhouse Circle to the south, the former Penn Central Railroad (PCRR) tracks to the north, and the fence on the Continental Motors property to the west, and

'1 Naylors Run to the east.

)

Historically, the site consists of a number of distinct properties including a former wood treatment facility owned by National Wood Preservers (NWP), a bubble gum manufacturing plant owned by the Philadelphia Chewing Gum Company (PCG), and neighboring residential and commercial areas. Former structures on the NWP property (lies north of the intersection of Eagle Road and Lawrence Road) consisted of a sheet metal building with multiple aboveground chemical storage tanks. This two-acre NWP property has been capped and is enclosed within a chain-link fence. The PCG facility consists of a single, large former gum production building located due east of NWP (northeast of the intersection of Eagle Road and Lawrence Road). The residential areas bordering Rittenhouse Circle and Naylors Run comprise the remainder of the study area (Figure 2).

The major contaminants present at the site include volatile organic compounds (VOC), pentachlorophenol (PCP), polynuclear aromatic hydrocarbons (PAH) and dioxin.

USEPA issued the Record of Decision (ROD) for OU2 on September 30, 1991, and defined the remedy. The primary purpose of the ROD is to capture the entire contaminated shallow groundwater plume that is migrating from the site under Eagle Road and to treat and discharge it into Naylors Run. The extraction/recovery wells attempt to reduce the size of the oil plume floating on the water table.

Tetra Tech completed the conceptual design for OU2 (shallow groundwater) in 1994. The detailed Remedial Design (RD) for OU2 was completed during the period 1997-2000 by several contractors under U.S. Army Corps of Engineers (USACE). Treatment plant construction was completed in 2001. The plant was placed in operation in July 2001. Groundwater Environmental Services, Inc. (GES) operated the plant under USACE until August 15, 2002. Since then Tetra Tech has been performing O&M activities at this plant. A Technical Assessment and Operation & Maintenance Report for 2002-2004 was prepared and submitted in April 2005; a Technical Assessment and Operation & Maintenance Report for 2004-2005 was prepared and submitted in April 2006; a Technical Assessment and Operation & Maintenance Report for 2006 was prepared and submitted in March 2007; and a Technical Assessment and Operation & Maintenance Report for 2007 was prepared and submitted in May 2008.

1


1.2 Existing Groundwater Treatment Facility


The groundwater extraction and treatment system consists of six recovery wells, one collection trench,and an on-site treatment system. Four of the six recovery wells (RW-1, RW-2, RW-3, and RW-4) havebeen offline since RW-5 and RW-6 have been online (since February 2006).· The treatment systemconsists of two major parts-a pretreatment system (for breaking the oil-water emulsion, removal ofmetals, and removal of suspended solids) and an organics removal/treatment system. The pretreatmentsystem consists of an emulsion tank, an oxidation tank, a secondary oxidation tank, an inclined plateclarifier and a gravity sand filter. The organic treatment system includes UV/OX lamps followed by aperoxide destruction unit (PDU) and two granular activated carbon (GAG) units. A detailed systemdescription, process flow diagram, and recovery well and pump details are provided under Attachment A.

Groundwater from the recovery wells and trench is pumped into an inclined plate oil-water separator(OWS) where oil is skimmed; the skimmed oil flows into a free product tank. Any settled material in theOWS is pumped to the sludge thickener, and the water from the OWS flows by gravity into twoequalization (EO) tanks.

From the EO tanks the groundwater is pumped into the oil emulsion tank, where sulfuric acid is added tolower the pH (-3.5) to break the oil-water emulsion. In January 2008, sulfuric acid feed was stopped tothe oil emulsion tank. The water then flows by gravity into the oxidation tank where caustic is added toraise the pH (-10.0), and sodium hypochiorite is added to oxidize and precipitate metals. This is followedby a secondary oxidation and pH adjustment step (pH is maintained to 9.5) to convert metais to insolubiemetal hydroxides. The water then flows into a rapid mix-inclined plate clarifier system where polymer isadded to form floc, and suspended soiids including insoluble metal hydroxides are removed. The waterexiting the clarifier is then filtered by a gravity sand filter, which removes suspended solids that have beencarried over in the clarifier effiuent.

Following pretreatment, groundwater flows into a surge tank from where it is pumped through theorganics removal system. Sulfuric acid is then injected inline to adjust the pH to normal (-7.0), andhydrogen peroxide is injected in preparation for ultraviolet oxidation (UV/OX). The organics removalsystem consists of three 30 IWI/ UV/OX lamps followed by the peroxide destruction unit (PDU), thengranular activated carbon (GAG) adsorption. The UV/OX system uSes ultraviolet light in conjunction withthe hydrogen peroxide catalyst to destroy organic contaminants. Starting in November 2003, this plantbegan operating effectively with just one 30 IWI/ lamp. The PDU system consisted of two units-the leadunit is a carbon unit, which removes any residual peroxide that exits the UV/OX system; and the lag unit,which was a bio-clay filter. In May 2003, this filter was taken out of service (not necessary and causingoperational probiems). The water is then filtered through a cartridge filter to remove any solids stillentrained in the effluent from the PDU. The GAG is a dual-vessel lead/iag unit for final polishing of anyorganic contaminants that have not been oxidized by the UV/OX system. Finally, treated water fiows intodual effluent tanks from where it is pumped out and discharged into Naylors Run Greek under a NPDESPermit. The effluent water is also used for filter backwash purposes.

The sludge handling system consists of a sludge thickener and a sludge dewatering system. Sludge iscollected in the thickener from the clarifier and filter backwash line; the thickened sludge is thendewatered in a plate and frame filter press. The dewatered sludge/filter cake is stored in a 10 cu. yd. rolloff container. Once every 2-3 months, this filter cake is disposed of as an F032-listed waste, which is ahazardous waste, to an approved incineration facility. The filtrate water is discharged into a building sumpand then pumped back to the equalization tank.

Through the middle to latter part of 2008, design and procurement of equipment for major modifications tothe pretreatment system were undertaken. Pre-construction began in October 2008 with demolition andconstruction beginning after plant shutdown on November 10, 2008. The plant remained shut down fromNovember 10, 2008, through mid-February 2009. The major modifications to the pretreatment system aredetailed in Section 3.6 of this report.

2


1.2 Existing Groundwater Treatment Facility


The groundwater extraction and treatment system consists of six recovery wells. one collection trench, and an on-site treatment system. Four of the six recovery wells (RW-1, RW-2, RW-3, and RW-4) have been offline since RW-5 and RW-6 have been online (since February 2006).· The treatment system consists of two major parts-a pretreatment system (for breaking the oil-water emulsion, removal of metals, and removal of suspended solids) and an organics removal/treatment system. The pretreatment system consists of an emulsion tank, an oxidation tank, a secondary oxidation tank, an inclined plate clarifier and a gravity sand filter. The organic treatment system includes UV/OX lamps followed by a peroxide destruction unit (PDU) and two granular activated carbon (GAG) units. A detailed system description, process flow diagram, and recovery well and pump details are provided under Attachment A.

Groundwater from the recovery wells and trench is pumped into an inclined plate oil-water separator (OWS) where oil is skimmed; the skimmed oil flows into a free product tank. Any settled material in the OWS is pumped to the sludge thickener, and the water from the OWS flows by gravity into two equalization (EO) tanks.

From the EO tanks the groundwater is pumped into the oil emulsion tank, where sulfuric acid is added to lower the pH (-3.5) to break the oil-water emulsion. In January 2008, sulfuric acid feed was stopped to the oil emulsion tank. The water then flows by gravity into the oxidation tank where caustic is added to raise the pH (-10.0), and sodium hypochlorite is added to oxidize and precipitate metals. This is followed by a secondary oxidation and pH adjustment step (pH is maintained to 9.5) to convert metals to insoluble metal hydroxides. The water then flows into a rapid mix-inclined plate clarifier system where polymer is added to form floc, and suspended solids including insoluble metal hydroxides are removed. The water exiting the clarifier is then filtered by a gravity sand filter, which removes suspended solids that have been carried over in the clarifier effluent.

Following pretreatment, groundwater flows into a surge tank from where it is pumped through the organics removal system. Sulfuric acid is then injected inline to adjust the pH to normal (-7.0), and hydrogen peroxide is injected in preparation for ultraviolet oxidation (UV/OX). The organics removal system consists of three 30 IWI/ UV/OX lamps followed by the peroxide destruction unit (PDU), then granular activated carbon (GAG) adsorption. The UV/OX system uses ultraviolet light in conjunction with the hydrogen peroxide catalyst to destroy organic contaminants. Starting in November 2003, this plant began operating effectively with just one 30 IWI/ lamp. The PDU system consisted of two units-the lead unit is a carbon unit, which removes any residual peroxide that exits the UV/OX system; and the lag unit, which was a bio-clay filter. In May 2003, this filter was taken out of service (not necessary and causing operational problems). The water is then filtered through a cartridge filter to remove any solids still entrained in the effluent from the PDU. The GAG is a dual-vessel lead/lag unit for final polishing of any organic contaminants that have not been oxidized by the UV/OX system. Finally, treated water flows into dual effluent tanks from where it is pumped out and discharged into Naylors Run Greek under a NPDES Permit. The effluent water is also used for filter backwash purposes.

The sludge handling system consists of a sludge thickener and a sludge dewatering system. Sludge is collected in the thickener from the clarifier and filter backwash line; the thickened sludge is then dewatered in a plate and frame filter press. The dewatered sludge/filter cake is stored in a 10 cu. yd. rolloff container. Once every 2-3 months, this filter cake is disposed of as an F032-listed waste, which is a hazardous waste, to an approved incineration facility. The filtrate water is discharged into a building sump and then pumped back to the equalization tank.

Through the middle to latter part of 2008, design and procurement of equipment for major modifications to the pretreatment system were undertaken. Pre-construction began in October 2008 with demolition and construction beginning after plant shutdown on November 10, 2008. The plant remained shut down from November 10, 2008, through mid-February 2009. The major modifications to the pretreatment system are detailed in Section 3.6 of this report.

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2.0 OPERATIONS AND PERFORMANCE SUMMARY


During this reporting period (January 2008 - December 2008), necessary O&M activities were carried outto properly operate and maintain the groundwater pump and treat system at the Havertown PCP site inaccordance with the O&M Plan and USEPA's instructions. Operations and performance activitiesinciuded operation of the plant by a full-time operator; routine and non_routine activities, such asperformance sampling of treatment system including quarteriy, semi-annual and annual sampling ofmonitoring wells; collection of water level measurements; and report preparation. In general, the plantwas operated and maintained successfully. Figure 2 shows the site and wells location.

A summary of the groundwater contaminants and treatment system performance is as follows:

• The plant operation continued with just one 30 'rWV UV/OX lamp.

• Total volume of groundwater treated from January 1, 2008, through November 10, 2008,was approximately 8.75 million gallons (MG) for an average fiow of 23.8 gpm. During thisreporting period, the treatment system was online for more than 81 % of the time (seeTable 11).

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• During this reporting period, PCP concentration in the plant influent varied from 1,400 ug/Lto 4,500 ug/L for an average of 2,490 ug/L compared to 2,948 ug/L in 2007, 3,975 ug/L in2006, 3,382 ug/L in 2005, 3,600 ug/L in 2004, 3,730 ug/L in 2003, and 4,680 ug/L in 2002.Dioxin concentration in plant influent varied from 41 pg/L to about 409 pg/L for an averageof280 pg/L, compared to 38 pg/L in 2007, 13 pg/L in 2006, 135 pg/L in 2005, 282 pg/L in2004, 510 pg/L in 2003, and 2,064 pg/L in 2002. (See Table 6 and Attachment G).

• During this reporting period, groundwater PCP concentrations in most of the source areawells remained either the same or decreased a little bit. However, PCP concentrations inthree wells increased somewhat (from 6,800 ug/L to 15,000 ug/L at CW-21; from 5 ug/L to7,000 ug/L at CW-29D; and from 200 ug/L to 1,400 ug/L at CW-16S). At CW-29D, the PCPconcentration in 2006 was 6,500 ug/L. The other two wells are shallow, and the increasedconcentration could be the result of desorbing of PCP from the soil.

• The operation of RW-5 continues to impact/reduce PCP concentrations in deepgroundwater. Monitoring wells CW-4 S/IIO, CW-5 S/I/D and CW-18D around PCG buildingshow a significant PCP reduction. Some of these wells are now non-detect (NO).

• There was also a significant PCP concentration reduction in downgradient wells. From2007 to 2008, the concentration of PCP in well CW-13D decreased from 120 ug/L to ND,while in CW-10D the PCP concentration decreased from 390 ug/L to 1.6 ug/L.

• The operation of RW-6 continued to impact deep groundwater; however, PCP data variedin some downgradient wells.

• During this reporting period, about 230 pounds of site-related organic contaminants wereremoved from the groundwater for a totai of 2,530 pounds since operation of the plant.

• During this reporting period, approximately 41,360 pounds of sludge generated at this plantwere processed and disposed as hazardous waste for a total of 586,395 pounds sinceoperation of the plant. This included some waste generated under Operable Unit 3 (OU3)Remedial Investigation (RI).

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2.0 OPERATIONS AND PERFORMANCE SUMMARY

During this reporting period (January 2008 - December 2008), necessary O&M activities were carried out to properly operate and maintain the groundwater pump and treat system at the Havertown PCP site in accordance with the O&M Plan and USEPA's instructions. Operations and performance activities included operation of the plant by a full-time operator; routine and non-routine activities, such as performance sampling of treatment system including quarterly, semi-annual and annual sampling of monitoring wells; collection of water level measurements; and report preparation. In general, the plant was operated and maintained successfully. Figure 2 shows the site and wells location.

A summary of the groundwater contaminants and treatment system performance is as follows:

• The plant operation continued with just one 30 'rWV UV/OX lamp.

• Total volume of groundwater treated from January 1, 2008, through November 10, 2008, was approximately 8.75 million gallons (MG) for an average flow of 23.8 gpm. During this reporting period, the treatment system was online for more than 81 % of the time (see Table 11).

• During this reporting period, PCP concentration in the plant influent varied from 1,400 ug/L to 4,500 ug/L for an average of 2,490 ug/L compared to 2,948 ug/L in 2007, 3,975 ug/L in 2006, 3,382 ug/L in 2005, 3,600 ug/L in 2004, 3,730 ug/L in 2003, and 4,680 ug/L in 2002. Dioxin concentration in plant influent varied from 41 pg/L to about 409 pg/L for an average of280 pg/L, compared to 38 pg/L in 2007, 13 pg/L in 2006, 135 pg/L in 2005, 282 pg/L in 2004, 510 pg/L in 2003, and 2,064 pg/L in 2002. (See Table 6 and Attachment G).

• During this reporting period, groundwater PCP concentrations in most of the source area wells remained either the same or decreased a little bit. However, PCP concentrations in three wells increased somewhat (from 6,800 ug/L to 15,000 ug/L at eW-21; from 5 ug/L to 7,000 ug/L at eW-29D; and from 200 ug/L to 1,400 ug/L at eW-16S). At eW-29D, the PCP concentration in 2006 was 6,500 ug/L. The other two wells are shallow, and the increased concentration could be the result of desorbing of PCP from the soil.

• The operation of RW-5 continues to impact/reduce PCP concentrations in deep groundwater. Monitoring wells eW-4 S/I/o, eW-5 S/I/D and eW-18D around peG building show a significant PCP reduction. Some of these wells are now non-detect (NO).

• There was also a significant PCP concentration reduction in downgradient wells. From 2007 to 2008, the concentration of PCP in well eW-13D decreased from 120 ug/L to ND, while in eW-10D the PCP concentration decreased from 390 ug/L to 1.6 ug/L.

• The operation of RW-6 continued to impact deep groundwater; however, PCP data varied in some downgradient wells.

• During this reporting period, about 230 pounds of site-related organic contaminants were removed from the groundwater for a total of 2,530 pounds since operation of the plant.

• During this reporting period, approximately 41,360 pounds of sludge generated at this plant were processed and disposed as hazardous waste for a total of 586,395 pounds since operation of the plant. This included some waste generated under Operable Unit 3 (OU3) Remedial Investigation (RI).

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• The plant continued to be effective in treating and disposing of contaminated groundwaterand sludge generated at this plant.

3.0 OPERATIONS AND MAINTENANCE ACTIVITIES

3.1 Routine Inspections and Maintenance

Tetra Tech's staff/operators continued to perform all O&M activities. A summary of routine O&M activitiesare provided in Table 1. A copy of daily O&M activities is kept on site for reference.

3.1.1 Daily Inspections

Field personnel performed maintenance tasks and daily (daiiy means each day that an operator was onsite) inspections during the five-day per week regularly scheduled O&M visits. Upon arrival, the PlantOperator inspected the area surrounding the treatment system compound for security, unusualconditions, and any other unusual signs. The following were the key inspections:

1. Inspection of the oil-water separator pump and electrical hookups;2. Inspection of the UV/Oxidation system, including scaling, piping and seals;3. Inspection of the flow equalization tank, primary and secondary effluent tanks, sludge

holding/conditioning tank;4. Inspection of an inclined plate separator;5. Inspection of continuous backwash sand filter;6. Inspection of liquid phase carbon adsorption system and PDU;7. Inspection of filter press;8. Inspection of all the pumps and hydraulic systems for the various unit processes;9. Inspection of air compressor system; and10. Site security.

3.1.2 Weekly Inspections

The Plant Operator performed weekly site and facility inspections. The weekly inspections included thefollowing:

1. Groundwater monitoring well and piezometer integrity, such as locks, seals, caps,identification markings and grouting;

2. Groundwater extraction wells, collection trench manhole, and recovery wells;3. Evidence of subsidence and settling at the facility, the associated cap, and the extraction

wells; and4. Scaling, plugging or fouling by bacterial growth on tanks, pumps, and instruments.

3.1.3 Preventative Maintenance and Unscheduled Maintenance

The Plant Operator performed any preventative maintenance necessary and responded to anyemergency telemetry notifications. Necessary maintenance was performed to maintain a fully operationalsystem. Efforts were made to ensure that the system shutdown time was minimal.

Preventive and unscheduled maintenance activities included, but were not limited to, the following:

1. Cieaning strainers;2. Pumping out rain water from valve boxes and manholes (after a major rain event);3. Replacing pump seals;4. Calibrating pH and ORP probes;5. Replacing chemicals as needed;6. Cleaning the UV/Oxidation system to prevent quartz tube fouling;

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• The plant continued to be effective in treating and disposing of contaminated groundwater and sludge generated at this plant.

3.0 OPERATIONS AND MAINTENANCE ACTIVITIES

3.1 Routine Inspections and Maintenance

Tetra Tech's staff/operators continued to perform all O&M activities. A summary of routine O&M activities are provided in Table 1. A copy of daily O&M activities is kept on site for reference.

3.1.1 Daily Inspections

Field personnel performed maintenance tasks and daily (daily means each day that an operator was on site) inspections during the five-day per week regularly scheduled O&M visits. Upon arrival, the Plant Operator inspected the area surrounding the treatment system compound for security, unusual conditions, and any other unusual signs. The following were the key inspections:

1. Inspection of the oil-water separator pump and electrical hookups; 2. Inspection of the UV/Oxidation system, including scaling, piping and seals; 3. Inspection of the flow equalization tank, primary and secondary effluent tanks, sludge

holding/conditioning tank; 4. Inspection of an inclined plate separator; 5. Inspection of continuous backwash sand filter; 6. Inspection of liquid phase carbon adsorption system and PDU; 7. Inspection of filter press; 8. Inspection of all the pumps and hydraulic systems for the various unit processes; 9. Inspection of air compressor system; and 10. Site security.

3.1.2 Weekly Inspections

The Plant Operator performed weekly site and facility inspections. The weekly inspections included the following:

1. Groundwater monitoring well and piezometer integrity, such as locks, seals, caps, identification markings and grouting;

2. Groundwater extraction wells, collection trench manhole, and recovery wells; 3. Evidence of subsidence and settling at the facility, the associated cap, and the extraction

wells; and 4. Scaling, plugging or fouling by bacterial growth on tanks, pumps, and instruments.

3.1.3 Preventative Maintenance and Unscheduled Maintenance

The Plant Operator performed any preventative maintenance necessary and responded to any emergency telemetry notifications. Necessary maintenance was performed to maintain a fully operational system. Efforts were made to ensure that the system shutdown time was minimal.

Preventive and unscheduled maintenance activities included, but were not limited to, the following:

1. 2. 3. 4. 5. 6.

Cleaning strainers; Pumping out rain water from valve boxes and manholes (after a major rain event); Replacing pump seals; Calibrating pH and ORP probes; Replacing chemicals as needed; Cleaning the UV/Oxidation system to prevent quartz tube fouling;

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7. Manual bale-out and disposing free product from monitoring well R-2;8. Cleaning various tanks and vessels;9. Cleaning oil-water separator; and10. Disposing the dewatered sludge.

3.2 Monitoring Well Network Description

Presently, there are 66 monitoring wells included in the O&M groundwater monitoring program. Thesewells can be classified as shallow wells above the bedrock (about 5' to 30' below grade) and deep wellsin the bedrock (up to 120' deep). In addition, there are 4 shallow recovery wells (RW-1 thru 4), two deeprecovery wells (RW-5 and 6) and a collector trench (CTR). RW-5 was placed online on February 20,2006 and RW-6 was placed online on April 17, 2006. Since the operation of RW-5, the four shallowrecovery wells (RW-1 thru 4) were placed offline due to the low water table. The well data can be foundin Table 2. These wells are shown on Figure 2.

3.3 Water level Measurement

Periodic water level measurements were taken at the existing monitoring wells to establish groundwaterdrawdown across the Havertown PCP Superfund site as related to the treatment plant operation. Thewater level measurements were taken on a quarterly basis. Static groundwater elevations were alsotaken whenever the extraction system (recovery wells and collector trench pumps) was shut downbecause of major maintenance. These data are provided in Table 3. Figure 3 shows a shallowzone/overburden potentiometric surface map, and Figure 4 shows a deep zone/bedrock potentiometricsurface map.

3.4 Sampling of Treatment System and Groundwater

The purpose of sampling is to monitor the treatment system performance and migration of the PCPplume. The sampling is performed as per the Field Sampling Plan (FSP) dated March 2003. In June2005, this sampling program was revised based on the revised NPDES permit (see below).

Initially, plant effluent was sampled on a bi-monthly basis (and plant infiuent once a month) to verifycompliance with the National Pollutant Discharge Elimination System (NPDES) permit, included inAttachment C. In December 2004, EPA requested the PADEP reduce the frequency of effluent samplingto once a month, as well as raise the manganese and iron discharge limits. PADEP approved this changein May 2005. Since then plant influent and effluent have been sampled on a monthly basis. Revised FSPtables (June 2005) are included under Attachment B. In addition, treatment process samples arecollected on a quarterly basis as part of performance sampling.

Groundwater samples are collected on a quarterly, semi-annual, and annual basis as follows:

• Quarterly sampling of eight locations to determine the recovery system water quality andextraction system's effectiveness.

• Semi-annual sampling of sixteen locations to monitor the edge of the shallow contaminantcapture zone.

• Annual sampling of all monitoring wells to update the historical database. This included allsite-related monitoring wells and recovery wells and collection trench.

Piant influent samples are analyzed for Target Compound List (TCl) Volatile Organic Compounds. (VOCs), TCl Semivolatile Organic Compounds (SVOCs), six metals, general minerals (once a year only),dioxins/furans, and oil and grease.

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7. Manual bale-out and disposing free product from monitoring well R-2; 8. Cleaning various tanks and vessels; 9. Cleaning oil-water separator; and 10. Disposing the dewatered sludge.

3.2 Monitoring Well Network Description

Presently, there are 66 monitoring wells included in the O&M groundwater monitoring program. These wells can be classified as shallow wells above the bedrock (about 5' to 30' below grade) and deep wells in the bedrock (up to 120' deep). In addition, there are 4 shallow recovery wells (RW-1 thru 4), two deep recovery wells (RW-5 and 6) and a collector trench (CTR). RW-5 was placed online on February 20, 2006 and RW-6 was placed online on April 17, 2006. Since the operation of RW-5, the four shallow recovery wells (RW-1 thru 4) were placed offline due to the low water table. The well data can be found in Table 2. These wells are shown on Figure 2.

3.3 Water Level Measurement

Periodic water level measurements were taken at the existing monitoring wells to establish groundwater drawdown across the Havertown PCP Superfund site as related to the treatment plant operation. The water level measurements were taken on a quarterly basis. Static groundwater elevations were also taken whenever the extraction system (recovery wells and collector trench pumps) was shut down because of major maintenance. These data are provided in Table 3. Figure 3 shows a shallow zone/overburden potentiometric surface map, and Figure 4 shows a deep zone/bedrock potentiometric surface map.

3.4 Sampling of Treatment System and Groundwater

The purpose of sampling is to monitor the treatment system performance and migration of the PCP plume. The sampling is performed as per the Field Sampling Plan (FSP) dated March 2003. In June 2005, this sampling program was revised based on the revised NPDES permit (see below).

Initially, plant effluent was sampled on a bi-monthly basis (and plant influent once a month) to verify compliance with the National Pollutant Discharge Elimination System (NPDES) permit, included in Attachment C. In December 2004, EPA requested the PADEP reduce the frequency of effluent sampling to once a month, as well as raise the manganese and iron discharge limits. PADEP approved this change in May 2005. Since then plant influent and effluent have been sampled on a monthly basis. Revised FSP tables (June 2005) are included under Attachment B. In addition, treatment process samples are collected on a quarterly basis as part of performance sampling.

Groundwater samples are collected on a quarterly, semi-annual, and annual baSis as follows:

• Quarterly sampling of eight locations to determine the recovery system water quality and extraction system's effectiveness.

• Semi-annual sampling of sixteen locations to monitor the edge of the shallow contaminant capture zone.

• Annual sampling of all monitoring wells to update the historical database. This included all site-related monitoring wells and recovery wells and collection trench.

Plant influent samples are analyzed for Target Compound List (TCl) Volatile Organic Compounds . (VOCs), TCl Semivolatile Organic Compounds (SVOCs), six metals, general minerals (once a year only),

/ dioxins/furans, and oil and grease.

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Plant effluent samples are analyzed for TCl VOCs, TCl SVOCs, six metals, general minerals (once ayear only), dioxins/furans, oil and grease, and total phenols.

Monthly system samples collected at the RayOx influent and effluent are analyzed for TCl VOCs andTClSVOCs.

Quarterly unit process samples related to system performance are collected as follows:

• Oil-water separator effluent is analyzed for oil and grease;• Clarifier effluent and sand filter effluent are analyzed for total metals;• Rayox effluent is analyzed for dioxins; and• Sludge filter cake is analyzed for % moisture.

Monitoring well samples are analyzed for VOC, SVOCs, total metals, dissolved metals, and dioxin. Duringmonitoring well sampling, other parameters were also collected; for example, pH, temperature, dissolvedoxygen, conductivity and oxidation/reduction potential.

All samples are sent to USEPA laboratories (procured under the Routine Analytical Services [RAS]program for VOCs, SVOCs, and metals analysis; and the Delivery of Analytical Services [DAS] programfor total phenols, minerals [nitrite, nitrate, chloride, fluoride, and sulfate], dioxin, oil and grease, moisturecontent, TSS, reactivity, and corrosivity).

3.5 Major Plant Cleanup Activities (Non-Routine ActiVities)

In order for the plant to continue running efficiently, several non-routine and major cleanup activities wereperformed as listed in Table 4. Some of the major activities were:

• In February 2008, Weltone was mixed and pumped into the collection trench and RW-6forcemain to clean iron buildup.

• In April 2008, oxidation tanks were completely drained and inspected for sludge buildup.The cross-pipe between tanks #2 and #3 was plugging. The cross-pipes between #1 and#2 and #2 and #3 were cleaned, and the mixer in tank #2 was cleaned of sludge buildup.

• In July 2008, the oxidation tanks and clarifier were drained in order to investigate crosspipes. Cross-pipes between oxidation tanks 1 and 2, and 2 and 3 were clear. Sludge hadbuilt up in the bottom of oxidation tank #3 around discharge. The sludge was cleared andthe cross-pipe between oxidation tank #3 and clarifier was brushed and cleared. The flocchamber and lamella plates in the clarifier were hosed out.

• In September 2008, the oil-water separator was cleaned.

• In late October 2008, an attempt was made to wash the solids out of the sand filter.ApprOXimately 150 Ibs of clean sand was added, and the remainder of washed sand(-850 Ibs) was placed back into the unit. The old dirty sand (-500 Ibs) was placed into thesludge container. Recycled water was run through the filter to further wash sand.

• In November 2008 the plant was systematically shut down in preparation for thepretreatment system upgrade. All non-carbon vessels were drained, and the 'sludge wasremoved and transferred to the sludge holding tank,

• In December 2008, the spent carbon was vacuumed from GAC PV-2 and transferred to six1-cubic yard boxes for incineration. New carbon was replaced in this unit in 2009 beforeplant restart.

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Plant effluent samples are analyzed for TCl VOCs, TCl SVOCs, six metals, general minerals (once a year only), dioxins/furans, oil and grease, and total phenols.

Monthly system samples collected at the RayOx influent and effluent are analyzed for TCl VOCs and TClSVOCs.

Quarterly unit process samples related to system performance are collected as follows:

• Oil-water separator effluent is analyzed for oil and grease; • Clarifier effluent and sand filter effluent are analyzed for total metals; • Rayox effluent is analyzed for dioxins; and • Sludge filter cake is analyzed for % moisture.

Monitoring well samples are analyzed for VOC, SVOCs, total metals, dissolved metals, and dioxin. During monitoring well sampling, other parameters were also collected; for example, pH, temperature, dissolved oxygen, conductivity and oxidation/reduction potential.

All samples are sent to USEPA laboratories (procured under the Routine Analytical Services [RAS] program for VOCs, SVOCs, and metals analysis; and the Delivery of Analytical Services [DAS] program for total phenols, minerals [nitrite, nitrate, chloride, fluoride, and sulfate], dioxin, oil and grease, moisture content, TSS, reactivity, and corrosivity).

3.5 Major Plant Cleanup Activities (Non-Routine Activities)

In order for the plant to continue running efficiently, several non-routine and major cleanup activities were performed as listed in Table 4. Some of the major activities were:

• In February 2008, Weltone was mixed and pumped into the collection trench and RW-6 forcemain to clean iron buildup.

• In April 2008, oxidation tanks were completely drained and inspected for sludge buildup. The cross-pipe between tanks #2 and #3 was plugging. The cross-pipes between #1 and #2 and #2 and #3 were cleaned, and the mixer in tank #2 was cleaned of sludge buildup.

• In July 2008, the oxidation tanks and clarifier were drained in order to investigate crosspipes. Cross-pipes between oxidation tanks 1 and 2, and 2 and 3 were clear. Sludge had built up in the bottom of oxidation tank #3 around discharge. The sludge was cleared and the cross-pipe between oxidation tank #3 and clarifier was brushed and cleared. The floc chamber and lamella plates in the clarifier were hosed out.

• In September 2008, the oil-water separator was cleaned.

• In late October 2008, an attempt was made to wash the solids out of the sand filter. Approximately 150 Ibs of clean sand was added, and the remainder of washed sand (-850 Ibs) was placed back into the unit. The old dirty sand (-500 Ibs) was placed into the sludge container. Recycled water was run through the filter to further wash sand.

• In November 2008 the plant was systematically shut down in preparation for the pretreatment system upgrade. All non-carbon vessels were drained, and the 'sludge was removed and transferred to the sludge holding tank.

• In December 2008, the spent carbon was vacuumed from GAC PV-2 and transferred to six-1-cubic yard boxes for incineration. New carbon was replaced in this unit in 2009 before plant restart.

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3.6 Difficulties and Plant Improvements


During this reporting period, a few major difficuities were encountered as described in Table 5. Thesedifficuities were related to continual iron sludge build-up in the oxidation system and sand filter plugging.Following is a summary of the major plant improvements:

• In January 2008, the sulfuric acid feed to Oxidation Tank #1 was stopped to optimize theoxidation step and reduce usage of sulfuric acid and sodium hydroxide.

• In early February 2008, a new filter press feed pump was installed.

• In mid-February 2008, because of ongoing problems with the poly-mixer polymer system, anew smaller system was purchased and placed online. The new system required lessmaintenance and required less power.

The existing pretreatment system, designed to remove iron and manganese, was unable to handle anyflow greater that 35 gpm on a continuous basis. In the near future, several other sources of groundwaterflow are expected to be treated at this plant as part of the final remedy of this site. The expected plantflow will be in the range of 60-75 gpm. For this reason, Tetra Tech designed a modification of the existingpre-treatment system to treat a 75-gpm flow on a continuous basis. This modification required removaland disposal of several pieces of existing pre-treatment equipment, tanks, pumps, piping and electricalitems; the reuse of several pieces of equipment/tanks (as-is or relocated); addition of a building to theexisting building; installation of new equipment, related mechanical, electrical, instruments and structuralitems. To complete the plant modifications, the plant was shut down during the first week of November2008 for the remainder of 2008. Plant improvements related to the pretreatment modifications includedthe following:

• Removal and disposal of existing pre-treatment system:o A clarifier/flash mix/flocculator tank and related mixerso A gravity sand filter tank and accessorieso Two existing equalization feed pumpso Two existing Rayox feed pumps

• Modification of existing wastewater steel tank with new level transmitter. This tank is nowused as the equalization tank.

• Removal of two FRP equalization tanks and relocating them inside a new building. Thesetanks are now used as backwash wastewater tanks. Two existing level sensors are beingreused as-is, and an existing pressure/level transmitter has been relocated at the drain line.A new backwash waste drain valve was installed.

• Relocation of two oxidation tanks and related mixers. These tanks were relocated on thesame platform but at a different location. Three pH and an ORP probes were removed andrelocated. Removal and disposal of a third oxidation tank and related mixer. A new flashmix tank was installed as described below.

• Some chemical feed tubing (ferric sulfate and sulfuric feed) was removed.

• Relocation of a chemical feed tank (hydrogen peroxide) and related pump. This tank alongwith feed pump (skid) was moved where the existing equalization tanks are located.

\, ) • Relocation of two air diaphragm sludge pumps and related air piping.

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3.6 Difficulties and Plant Improvements


During this reporting period, a few major difficulties were encountered as described in Table 5. These difficulties were related to continual iron sludge build-up in the oxidation system and sand filter plugging. Following is a summary of the major plant improvements:

• In January 2008, the sulfuric acid feed to Oxidation Tank #1 was stopped to optimize the oxidation step and reduce usage of sulfuric acid and sodium hydroxide.

• In early February 2008, a new filter press feed pump was installed.

• In mid-February 2008, because of ongoing problems with the poly-mixer polymer system, a new smaller system was purchased and placed online. The new system required less maintenance and required less power.

The existing pretreatment system, designed to remove iron and manganese, was unable to handle any flow greater that 35 gpm on a continuous basis. In the near future, several other sources of groundwater flow are expected to be treated at this plant as part of the final remedy of this site. The expected plant flow will be in the range of 60-75 gpm. For this reason, Tetra Tech designed a modification of the existing pre-treatment system to treat a 75-gpm flow on a continuous baSis. This modification required removal and disposal of several pieces of existing pre-treatment equipment, tanks, pumps, piping and electrical items; the reuse of several pieces of equipmentltanks (as-is or relocated); addition of a building to the existing building; installation of new equipment, related mechanical, electrical, instruments and structural items. To complete the plant modifications, the plant was shut down during the first week of November 2008 for the remainder of 2008. Plant improvements related to the pretreatment modifications included the following:

• Removal and disposal of existing pre-treatment system: o A clarifier/flash mixlflocculator tank and related mixers o A gravity sand filter tank and accessories o Two existing equalization feed pumps o Two existing Rayox feed pumps

• Modification of existing wastewater steel tank with new level transmitter. This tank is now used as the equalization tank.

• Removal of two FRP equalization tanks and relocating them inside a new building. These tanks are now used as backwash wastewater tanks. Two existing level sensors are being reused as-is, and an existing pressure/level transmitter has been relocated at the drain line. A new backwash waste drain valve was installed.

• Relocation of two oxidation tanks and related mixers. These tanks were relocated on the same platform but at a different location. Three pH and an ORP probes were removed and relocated. Removal and disposal of a third oxidation tank and related mixer. A new flash mix tank was installed as described below.

• Some chemical feed tubing (ferric sulfate and sulfuric feed) was removed.

• Relocation of a chemical feed tank (hydrogen peroxide) and related pump. This tank along with feed pump (skid) was moved where the existing equalization tanks are located.

• Relocation of two air diaphragm sludge pumps and related air piping.

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• Relocation of an existing polymer feed system.


• Instaliation of a new incline plate ciarifier and two celi pressure sand filter and relatedpiping.

• Instaliation of new equalization pumps and reiated suction and discharge piping including astrainer. Reuse existing three-way valve and flow meter. Pumps discharge piping wili nowhave a bypass pipe and a recycle pipe back to equalization tank.

• Instaliation of new Rayox pumps and related suction and discharge piping inciuding astrainer. Reuse existing flow meter.

• Instaliation of a new sludge holding tank drain valve, level transmitter, and floating decantersystem to decant off ciear liquid from sludge holding tank.

• Instaliation of a new self-contained sump pump in new bUilding.

• Instaliation a new flow sensor and a flow control vaive on backwash waste line.

• Instaliation of new effluent bypass vaives for recycle to equalization tank for effluent waterpH below 6.0 or above 9.0.

3.7 Site Maintenance

Site maintenance has included grass cutting, snow removal, trash pickup, and minimal and orderlystorage of items outside the treatment building. Starting this year, the grass on the cap is mowed by theowner while remaining surrounding fenced areas of the project site has been mowed on a periodic basisby a subcontractor. Site maintenance also includes keeping weeds to a minimum along the fence line,and picking up trash that blows onto the site from the surrounding area. The large stone swale arearequires an annual cutting and application of herbicide to minimize the growth of weeds. Additional grasscutting and maintenance are required in the fenced and landscaped areas of the collection trench. In thewinter months, snow removal on the parking lot and access drive has been subcontracted as needed. Anautomotive business (Direct Paint & Collision) provides additional snow removal. They have beenretained for routine snow removal because their business needs the access drive (common to treatmentplant) cleared more frequently after hours.

3.8 Other Activities

No other activities were performed in 2008.

4.0 SYSTEM PERFORMANCE

The purpose of the groundwater extraction and treatment system is to capture all the contaminatedshaliow and deep groundwater that is migrating from the site under Eagle Road and to treat anddischarge it into Naylors Run in accordance with PADEP's discharge permit. In general, the extractionsystem was able to contain the contamination in the shaliow and deep zones effectively, while thegroundwater treatment plant treated the extracted groundwater effectively prior to discharging intoNaylors Run. Discharge limits were met most of the time.

4.1 Groundwater Level and Contaminant Containment

Water level data presented in Table 3 indicates a measurable drawdown in the vicinity of the RW welisand CTR. The RW-5 pumping system continued to impact surrounding deep welis CW-24, CW-26,CW-27, CW-29, and CW-16S/IID. It also impacted several downgradient welis RW-2, RW-3, RW-4, R-2,

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• Relocation of an existing polymer feed system.


• Installation of a new incline plate clarifier and two cell pressure sand filter and related piping.

• Installation of new equalization pumps and related suction and discharge piping including a strainer. Reuse existing three-way valve and flow meter. Pumps discharge piping will now have a bypass pipe and a recycle pipe back to equalization tank.

• Installation of new Rayox pumps and related suction and discharge piping including a strainer. Reuse existing flow meter.

• Installation of a new sludge holding tank drain valve, level transmitter, and floating decanter system to decant off clear liquid from sludge holding tank.

• Installation of a new self-contained sump pump in new building.

• Installation a new flow sensor and a flow control valve on backwash waste line.

• Installation of new effluent bypass valves for recycle to equalization tank for effluent water pH below 6.0 or above 9.0.

3.7 Site Maintenance

Site maintenance has included grass cutting, snow removal, trash pickup, and minimal and orderly storage of items outside the treatment building. Starting this year, the grass on the cap is mowed by the owner while remaining surrounding fenced areas of the project site has been mowed on a periodic basis by a subcontractor. Site maintenance also includes keeping weeds to a minimum along the fence line, and picking up trash that blows onto the site from the surrounding area. The large stone swale area requires an annual cutting and application of herbicide to minimize the growth of weeds. Additional grass cutting and maintenance are required in the fenced and landscaped areas of the collection trench. In the winter months, snow removal on the parking lot and access drive has been subcontracted as needed. An automotive business (Direct Paint & Collision) provides additional snow removal. They have been retained for routine snow removal because their business needs the access drive (common to treatment plant) cleared more frequently after hours.

3.8 Other Activities

No other activities were performed in 2008.

4.0 SYSTEM PERFORMANCE

The purpose of the groundwater extraction and treatment system is to capture all the contaminated shallow and deep groundwater that is migrating from the site under Eagle Road and to treat and discharge it into Naylors Run in accordance with PADEP's discharge permit. In general, the extraction system was able to contain the contamination in the shallow and deep zones effectively, while the groundwater treatment plant treated the extracted groundwater effectively prior to discharging into Naylors Run. Discharge limits were met most of the time.

4.1 Groundwater Level and Contaminant Containment

Water level data presented in Table 3 indicates a measurable drawdown in the vicinity of the RW wells and CTR. The RW-5 pumping system continued to impact surrounding deep wells CW-24, CW-26, CW-27, CW-29, and CW-16S/IID. It also impacted several downgradient wells RW-2, RW-3, RW-4, R-2,

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,)

HAV-02, CW-4S/IID and CW-17D. Pumping systems at CTR and RW-6 impacted nearby monitoringwells MW-1, MW-2, and CW-10S/D, and downgradient well HAV-07. These two pumping systems alsoimpacted upgradient wells MW-3, CW-5S/I/D, CW-6S/I/D, CW-18D, and CW-19D. Water level variation atvarious other wells suggests seasonal variation.

Based on the water level data, it is evident that RW-5 and RW-6 are impacting the deeper zone, and thuscontinued to provide partial remedy of the deeper zone (bedrock) and source area contamination.

4.2 Plant Influent, Effluent and Process Contaminant Data

Major contaminants in the plant influent for this reporting period are presented in Table 6. PCPconcentration in the plant influent varied from 1400 ug/L to 4,500 ug/L for an average of 2,490 ug/Lcompared to 2,948 ug/L in 2007, 3,975 ug/L in 2006,3,382 ug/L in 2005, 3,600 ug/L in 2004, 3,730 ug/Lin 2003, and 4,680 ug/L in 2002.

Dioxin concentration in plant influent varied from 41 pg/L to about 518 pg/L for an average of 280 pg/Lcompared to 38 pg/L in 2007, 13 pg/L in 2006, 135 pg/L in 2005, 282 pg/L in 2004, 510 pg/L in 2003, and2,064 pg/L in 2002.

This indicates a reduction (-16%) in PCP and a significant increase (-637%) in dioxin concentrations inthe plant influent since the last report. PCP and dioxin data for this reporting period are graphicallypresented on Figure 5. Attachment G graphically presents historical annual average data for ten keycontaminants for 2002 through 2008.

Since the start of RW-5 operation, iron concentrations in the plant influent have steadily increased. Thishas caused excessive sludge production and laborious maintenance of the pre-treatment system. Sincethe last report, iron concentration has increased -35%, and manganese concentration has decreased-6%. Furthermore, beginning in August 2006, arsenic concentrations have increased in the plant influent;however, since the last report arsenic concentrations have decreased -28%.

Table 7 presents major contaminants in the recovery wells and CTR for the reporting period. PCPconcentrations at source area recovery well RW-5 varied from 2,300 ug/L to 4,000 ug/L, however, wereabout 1,200 ug/L at RW-6 and 920 ug/L at CTR. These data are graphically presented on Figure 6.

Table 8 shows plant effluent data and required NPDES permit limits for several key contaminants. Forsome unknown reason, in February 2008, PCP, dioxin, iron, and manganese concentrations in the planteffluent exceeded the discharge limits. The sample was taken at the end of the month after the existingpolymer pumping system failed and a malfunctioning pretreatment system created fouling problems in theGAC carbon vessels. Prior to sampling, extra backwashing of the GAC units was performed; however,one laboratory result indicated carbon in the plant effluent. This was the only exceedance in 2008.

Monthly Discharge Monitoring Reports (DMR) have been prepared and submitted to PADEP, HavertownTownship and USEPA. These reports are included as part of this report by reference. A copy of the DMRforms is included under Attachment D. Since the plant was shut down in November 2008, there was nosampling or DMR report in November and December 2008.

Various treatment processes have been sampled on a quarterly basis. Table 9a provides the UV/OXsystem's performance to remove organic contaminants. Generally, UV/OX has been successful indestroying >99% of organic contaminants while generating chloroform as a by-product. Table 9b providesthe pre-treatment system's metal removal performance. Table 9c provides the plant's performance datafor the removal of oil and grease and total phenol. Table 9c also lists various anions analyzed on aquarterly basis.

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HAV-02, CW-4S/IID and CW-17D. Pumping systems at CTR and RW-6 impacted nearby monitoring wells MW-1, MW-2, and CW-10S/D, and downgradient well HAV-07. These two pumping systems also impacted upgradient wells MW-3, CW-5S/I/D, CW-6SII/D, CW-18D, and CW-19D. Water level variation at various other wells suggests seasonal variation.

Based on the water level data, it is evident that RW-5 and RW-6 are impacting the deeper zone, and thus continued to provide partial remedy of the deeper zone (bedrock) and source area contamination.

4.2 Plant Influent, Effluent and Process Contaminant Data

Major contaminants in the plant influent for this reporting period are presented in Table 6. PCP concentration in the plant influent varied from 1400 ug/L to 4,500 ug/L for an average of 2,490 ug/L compared to 2,948 ug/L in 2007, 3,975 ug/L in 2006,3,382 ug/L in 2005, 3,600 ug/L in 2004, 3,730 ug/L in 2003, and 4,680 ug/L in 2002.

Dioxin concentration in plant influent varied from 41 pg/L to about 518 pg/L for an average of 280 pg/L compared to 38 pg/L in 2007, 13 pg/L in 2006, 135 pg/L in 2005, 282 pg/L in 2004, 510 pg/L in 2003, and 2,064 pg/L in 2002.

This indicates a reduction (-16%) in PCP and a significant increase (-637%) in dioxin concentrations in the plant influent since the last report. PCP and dioxin data for this reporting period are graphically presented on Figure 5. Attachment G graphically presents historical annual average data for ten key contaminants for 2002 through 2008.

Since the start of RW-5 operation, iron concentrations in the plant influent have steadily increased. This has caused excessive sludge production and laborious maintenance of the pre-treatment system. Since the last report, iron concentration has increased -35%, and manganese concentration has decreased -6%. Furthermore, beginning in August 2006, arsenic concentrations have increased in the plant influent; however, since the last report arsenic concentrations have decreased -28%.

Table 7 presents major contaminants in the recovery wells and CTR for the reporting period. PCP concentrations at source area recovery well RW-5 varied from 2,300 ug/L to 4,000 ug/L, however, were about 1,200 ug/L at RW-6 and 920 ug/L at CTR. These data are graphically presented on Figure 6.

Table 8 shows plant effluent data and required NPDES permit limits for several key contaminants. For some unknown reason, in February 2008, PCP, dioxin, iron, and manganese concentrations in the plant effluent exceeded the discharge limits. The sample was taken at the end of the month after the existing polymer pumping system failed and a malfunctioning pretreatment system created fouling problems in the GAC carbon vessels. Prior to sampling, extra backwashing of the.GAC units was performed; however, one laboratory result indicated carbon in the plant effluent. This was the only exceedance in 2008.

Monthly Discharge Monitoring Reports (DMR) have been prepared and submitted to PADEP, Havertown Township and USEPA. These reports are included as part of this report by reference. A copy of the DMR forms is included under Attachment D. Since the plant was shut down in November 2008, there was no sampling or DMR report in November and December 2008.

Various treatment processes have been sampled on a quarterly basis. Table 9a provides the UV/OX system's performance to remove organic contaminants. Generally, UV/OX has been successful in destroying >99% of organic contaminants while generating chloroform as a by-product. Table 9b provides the pre-treatment system's metal removal performance. Table 9c provides the plant's performance data for the removal of oil and grease and total phenol. Table 9c also lists various anions analyzed on a quarterly basis.

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4.3 Groundwater Contaminants and Co'ntainment


According to the OU2 RI/FS, the source area encompasses monitoring wells CW-21, R-2, CW-04, CW-05,HAV-02, and HAV-04. Table 10 provides a comparison of the historical (2002-2007) and current (2008)PCP and dioxin data at all monitoring and recovery wells, Attachment E tabulates key contaminants at alimonitoring and recovery wells since 1990, Also included in Attachment E are graphs of the tabulateddata, while Attachment F provides sampling analysis details of all monitoring wells contaminants for thisperiod,

In general, PCP concentrations in the groundwater continued to decrease in several wells, From 2007 to2008, PCP concentrations in CW-4 S/I/D wells decreased from 2,600 ug/L to 740 ug/L, 3,600 ug/L to3,000 ug/L and 480 ug/L to 370 ug/L, respectively, Similarly PCP concentrations in CW-5 SIIID wellsdecreased from 12 ug/L to ND, 47 ug/L to 2,7 ug/L and 38 ug/L to 1,7 ug/L, respectively, Another well,CW-18D, located around PCG building was ND (was 75 ug/L in 2007),

Generally PCP concentrations in the shallow wells continue to decline, For example, in the last fouryears, PCP concentrations at HAV-04 varied from 26,000 ug/L to 6,600 ug/L to 11,000 ug/L; 23,000 ug/Lto 16,000 ug/L to 7,100 ug/L to 12,000 ug/L at R-2; and 23,000 ug/L to 11,000 ug/L to 5,700 ug/L to 7,800ug/L at HAV-02,

Operation of source area deep extraction well, RW-5, continued to impact and decrease PCPconcentrations in the source area and deep groundwater. From 2007 to 2008, PCP concentrationsdecreased in some deep wells in the vicinity of RW-5 (CW-28D from 8,900 ug/L to 5,800 ug/L, CW-24Dfrom 7,500 ug/L to 7,100 ug/L, and CW-30D from 4,200 ug/L to 4,000 ug/L), However, PCPconcentrations in two wells increased somewhat (CW-21 from 6,800 ug/L to 15,000 ug/L, and CW-16Sfrom 200 ug/L to 1,400 ug/L), Similarly PCP concentrations in well CW-29D were 6,500 ug/L in 2006, thendown to 5 ug/L in 2007 and back to 7,000 ug/L in 2008, This increase could be attributed to PCPdesorbing from the soil.

Another deep extraction well, RW-6, continued to impact deep groundwater around CTR area, PCP intwo downstream wells decreased (MW-1 from 13 ug/L to 10 ug/L and MW-2 from 43 ug/L to 38 ug/L),while in other nearby wells it increased somewhat (CW-21D from 1,900 ug/L to 2,600 ug/L and CW-21Sfrom 1,700 ug/L to 2,900 ug/L), There was a significant reduction in the PCP concentration in thedowngradient wells as well. Concentrations in well CW-13D decreased from 120 ug/L to ND, whileconcentrations at CW-10D decreased from 390 ug/L to 1,6 uglL, and remained ND at CW-11D and CW12D, This indicates that RW-6 continues to be effective in capturing and containing the deep groundwaterplume, preventing it from migrating further downgradient.

In October 2008, another deep well (CW-31D) was installed near RW-3 (part of OU3 RD activities), ThePCP concentration in this well is similar to the nearby deep wells, In 2009, this well will be converted intoanother source area deep recovery well as RW-7 (part of OU3 RA),

During this reporting period, the TCE concentration in cluster wells CW-1 S/I/D (upgradient of the site)increased, It is not a site-related contaminant; rather. it is from another nearby source,

The MTBE concentration in cluster wells CW-7 SID and CW-8 SID continued to decrease, This is also nota site-related contaminant, but is from another nearby source,

Since the operation of RW-5, iron and arsenic concentrations in the plant influent have continued toincrease or remain high (Table 6),

Overall, there has been contaminant reduction in both the shallow and deep zones since the operation ofthe treatment plant. No major contaminants have been detected in the shallow zone boundary wells(CW-3S, CW-9S, CW-12S, CW-22S, and R4) in past few years; historically, these wells have been clean,PCP concentrations in several monitoring wells around PCG building have decreased to ND, This

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4.3 Groundwater Contaminants and Co'ntainment


According to the OU2 RI/FS, the source area encompasses monitoring wells CW-21, R-2, CW-04, CW-05, HAV-02, and HAV-04. Table 10 provides a comparison of the historical (2002-2007) and current (2008) PCP and dioxin data at all monitoring and recovery wells, Attachment E tabulates key contaminants at all monitoring and recovery wells since 1990, Also included in Attachment E are graphs of the tabulated data, while Attachment F provides sampling analysis details of all monitoring wells contaminants for this period,

In general, PCP concentrations in the groundwater continued to decrease in several wells, From 2007 to 2008, PCP concentrations in CW-4 S/I/D wells decreased from 2,600 ug/L to 740 ug/L, 3,600 ug/L to 3,000 ug/L and 480 ug/L to 370 ug/L, respectively, Similarly PCP concentrations in CW-5 SIl/D wells decreased from 12 ug/L to ND, 47 ug/L to 2,7 ug/L and 38 ug/L to 1,7 ug/L, respectively, Another well, CW-18D, located around PCG building was ND (was 75 ug/L in 2007),

Generally PCP concentrations in the shallow wells continue to decline, For example, in the last four years, PCP concentrations at HAV-04 varied from 26,000 ug/L to 6,600 ug/L to 11,000 ug/L; 23,000 ug/L to 16,000 ug/L to 7,100 ug/L to 12,000 ug/L at R-2; and 23,000 ug/L to 11,000 ug/L to 5,700 ug/L to 7,800 ug/L at HAV-02,

Operation of source area deep extraction well, RW-5, continued to impact and decrease PCP concentrations in the source area and deep groundwater. From 2007 to 2008, PCP concentrations decreased in some deep wells in the vicinity of RW-5 (CW-28D from 8,900 ug/L to 5,800 ug/L, CW-24D from 7,500 ug/L to 7,100 ug/L, and CW-30D from 4,200 ug/L to 4,000 ug/L), However, PCP concentrations in two wells increased somewhat (CW-21 from 6,800 ug/L to 15,000 ug/L, and CW-16S from 200 ug/L to 1,400 ug/L), Similarly PCP concentrations in well CW-29D were 6,500 ug/L in 2006, then down to 5 ug/L in 2007 and back to 7,000 ug/L in 2008, This increase could be attributed to PCP desorbing from the soil.

Another deep extraction well, RW-6, continued to impact deep groundwater around CTR area, PCP in two downstream wells decreased (MW-1 from 13 ug/L to 10 ug/L and MW-2 from 43 ug/L to 38 ug/L), while in other nearby wells it increased somewhat (CW-21D from 1,900 ug/L to 2,600 ug/L and CW-21S from 1,700 ug/L to 2,900 ug/L), There was a significant reduction in the PCP concentration in the downgradient wells as well. Concentrations in well CW-13D decreased from 120 ug/L to ND, while concentrations at CW-10D decreased from 390 ug/L to 1,6 uglL, and remained ND at CW-11D and CW-12D, This indicates that RW-6 continues to be effective in capturing and containing the deep groundwater plume, preventing it from migrating further downgradient.

In October 2008, another deep well (CW-31D) was installed near RW-3 (part of OU3 RD activities), The PCP concentration in this well is similar to the nearby deep wells, In 2009, this well will be converted into another source area deep recovery well as RW-7 (part of OU3 RA),

During this reporting period, the TCE concentration in cluster wells CW-1 S/I/D (upgradient of the site) increased, It is not a site-related contaminant; rather it is from another nearby source,

The MTBE concentration in cluster wells CW-7 SID and CW-8 SID continued to decrease, This is also not a site-related contaminant, but is from another nearby source,

Since the operation of RW-5, iron and arsenic concentrations in the plant influent have continued to increase or remain high (Table 6),

Overall, there has been contaminant reduction in both the shallow and deep zones since the operation of the treatment plant. No major contaminants have been detected in the shallow zone boundary wells (CW-3S, CW-9S, CW-12S, CW-22S, and R4) in past few years; historically, these wells have been clean, PCP concentrations in several monitoring wells around PCG building have decreased to ND, This

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suggests that the extraction system has been effective in containing the shallow and deep zonecontaminants.

4.4 Plant Operational and Flow Data

During this reporting period, the plant was operational more than 81 % of the time. Table 11 provides plantON and OFF-line data. Table 12 details the shutdown events.

Tabie 11 also provides flow data. During this reporting period, the average plant effluent flow was24.9 gpm (about 4 gpm lower than 2007 flow). The plant flow was reduced because of constant pluggingproblems at the sand filter. Figure 7 shows plant flow data and the percentage of time the piant wasonline. During this reporting period, the plant treated and discharged about 9.2 million gallons of waterinto Naylors Run. The pretreatment flow has been generally 5 gpm higher than the inflow as the sandfilter reject water and GAC/PDU backwash are recycled around the pretreatment system. Rayox flow hasbeen generally higher than effluent flow as -2 gpm of water is allowed to discharge from PDU air releasevalve assembly back into the surge tank, thus controlling excessive back pressure in PDU.

The average flow at RW-5 was 15.7 gpm (flow was manually adjusted/reduced to keep collector trenchflow higher). RW-6 and the collector trench (CTR) pumped as much as possible for an average flow of 3.5gpm and 4.6 gpm, respectively. The flow at CTR was lower because of sludge buildup in the line andseasonal drought conditions. These data are presented in Table 13 and on Figure 8. There was adiscrepancy in the combined three individual wells' flow meters data and plant influent flow meter data(within 5%).

4.5 Plant's Operational Changes

Since there was little or no free product in the plant influent, the sulfuric acid feed rate was stopped toOxidation Tank #1 (Oil Emulsion Tank) at the beginning of January 2008. Average plant influent pH was6.0. The sulfuric acid is now only used for pH adjustment at the Rayox influent.

4.6 Chemical Usage, Utilities and Sludge Production Data

The pre-treatment system uses four chemicals-sulfuric acid, sodium hydroxide, sodium hypochlorite andpolymer. The use of ferric sulfate was discontinued in September 2006 and as stated earlier, sulfuric acidwas discontinued in January 2008. Sulfuric acid and hydrogen peroxide are also added prior to the Rayoxtreatment system. Tables 14 through 19 provide usage of these six chemicals. Since there is no flowmeter at the chemical feed pumps, the data is based on respective tank level readings and hours ofsystem operation. Each chemical dose (ppm) is then computed based on pre-treatment flow and/orRayox flow as applicable.

With the stoppage of sulfuric acid feed to Oxidation Tank #1, there was a significant decrease (-39%) insodium hydroxide usage for the period.

The following is a comparison of 2008 feed rate with 2002-04, 2004-05, 2006, and 2007 average feedrates.

2002-04 2004-05 2006 feed 2007 feed 2008 feedChemical feed rate feed rate rate (ppm) rate (ppm) rate (ppm)

(ppm) (ppm)30% ferric sulfate 611 283 40* * *50% sodium hvdroxide 632 615 566 693 42615% sodium hypochlorite 504 301 282 747 25193% sulfuric acid 97 101 106 159 153**

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suggests that the extraction system has been effective in containing the shallow and deep zone contaminants.

4.4 Plant Operational and Flow Data

During this reporting period, the plant was operational more than 81 % of the time. Table 11 provides plant ON and OFF-line data. Table 12 details the shutdown events.

Table 11 also provides flow data. During this reporting period, the average plant effluent flow was 24.9 gpm (about 4 gpm lower than 2007 flow). The plant flow was reduced because of constant plugging problems at the sand filter. Figure 7 shows plant flow data and the percentage of time the plant was online. During this reporting period, the plant treated and discharged about 9.2 million gallons of water into Naylors Run. The pretreatment flow has been generally 5 gpm higher than the inflow as the sand filter reject water and GAC/PDU backwash are recycled around the pretreatment system. Rayox flow has been generally higher than effluent flow as -2 gpm of water is allowed to discharge from PDU air release valve assembly back into the surge tank, thus controlling excessive back pressure in PDU.

The average flow at RW-5 was 15.7 gpm (flow was manually adjusted/reduced to keep collector trench flow higher). RW-6 and the collector trench (CTR) pumped as much as possible for an average flow of 3.5 gpm and 4.6 gpm, respectively. The flow at CTR was lower because of sludge buildup in the line and seasonal drought conditions. These data are presented in Table 13 and on Figure 8. There was a discrepancy in the combined three individual wells' flow meters data and plant influent flow meter data (within 5%).

4.5 Plant's Operational Changes

Since there was little or no free product in the plant influent, the sulfuric acid feed rate was stopped to Oxidation Tank #1 (Oil Emulsion Tank) at the beginning of January 2008. Average plant influent pH was 6.0. The sulfuric acid is now only used for pH adjustment at the Rayox influent.

4.6 Chemical Usage, Utilities and Sludge Production Data

The pre-treatment system uses four chemicals-sulfuric acid, sodium hydroxide, sodium hypochlorite and polymer. The use of ferric sulfate was discontinued in September 2006 and as stated earlier, sulfuric acid was discontinued in January 2008. Sulfuric acid and hydrogen peroxide are also added prior to the Rayox treatment system. Tables 14 through 19 provide usage of these six chemicals. Since there is no flow meter at the chemical feed pumps, the data is based on respective tank level readings and hours of system operation. Each chemical dose (ppm) is then computed based on pre-treatment flow and/or Rayox flow as applicable.

With the stoppage of sulfuric acid feed to Oxidation Tank #1, there was a significant decrease (-39%) in sodium hydroxide usage for the period.

The following is a comparison of 2008 feed rate with 2002-04, 2004-05, 2006, and 2007 average feed rates.

2002-04 2004-05 2006 feed 2007 feed 2008 feed Chemical feed rate feed rate rate (ppm) rate (ppm) rate (ppm)

(ppm~ (ppm) 30% ferric sulfate 611 283 40* * * 50% sodium hydroxide 632 615 566 693 426 15% sodium hypochlorite 504 301 282 747 251 93% sulfuric acid 97 101 106 159 153**

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2002-04 2004-05 2006 feed 2007 feed 2008 feedChemical feed rate feed rate rate (ppm) rate (ppm) rate (ppm)

(ppm) (ppm)Polymer 6 2.1 2.0 4.1 5.650% hvdroQen peroxide 335 306 303 359 347

* Ferric sulfate feed was stopped on 9/19/06.** Sulfuric acid feed to pretreatment was stopped on January 17, 2008.

Tables 20 and 21 provide electric and gas usage at this plant for the reporting period. The buildingelectric meter is separate from the collector trench pump meter. With just one Rayox lamp online, theelectric usage has been about 75 KWH for every hour the plant was online (similar to last year). This isshown on Figure 9.

Sludge is pressed on an as-needed basis and dumped into the 10-yd roll-off. The roll-off is transportedan average of every three months. Table 22 provides the amount of sludge generated at this plant. Duringthis reporting period, about 41,360 pounds of sludge was generated and disposed as F032 hazardouswaste. This sludge was transported and disposed at the Ross incineration facility in Grafton, Ohio. Themajority of the plant sludge was produced due to the precipitation of iron and manganese in thegroundwater. This table also shows the amount of sludge produced per 1000 gallons of pre-treatmentwater since the plant operation began. This indicates a substantial sludge production rate.

4.7 Free Product Recovery

During this reporting period, no free product was recovered at well R-2.

4.8 Other Unit Processes Performance and Related Issues

4.8.1 Oil-Water Separator

Since the oil weir was set at its lowest level (2003), this unit process has been functioning properly.

4.8.2 Recovery Weill Collection Trench System

As stated previously, operation of four older recovery wells (RW-1 thru 4) was discontinued, and two newrecovery wells (RW-5 and RW-6) were added.

The collector trench sump also required some extra effort in order to keep it cleaned. This is explainedunder Section 3.5.

Three manholes and three valve pits along the recovery system transmission lines were not constructedwatertight; groundwater infiltrates the structures, and surface water seeps in through the manhole covers.The manholes and valve pits have been regularly pumped with a portable gas powered pump.

4.8.3 Wastewater Pump Issues

An old diaphragm pump is being used as a wastewater transfer pump (pumping into OWS influent) andas a free product transfer pump. For wastewater, a regular centrifugal pump needed to be added.

4.8.4 Air Diaphragm Pumps

The air diaphragm pumps continued to be a regular maintenance issue, primarily leaky mufflers andsplitting diaphragms, which allowed sludge to leak through the center-block assemblies.

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2002-04 2004-05 2006 feed 2007 feed 2008 feed Chemical feed rate feed rate rate (ppm) rate (ppm) rate (ppm)

(ppm) (ppm) Polymer 6 2.1 2.0 4.1 5.6 50% hydrogen peroxide 335 306 303 359 347

* Ferric sulfate feed was stopped on 9/19/06. ** Sulfuric acid feed to pretreatment was stopped on January 17, 2008.

Tables 20 and 21 provide electric and gas usage at this plant for the reporting period. The building electric meter is separate from the collector trench pump meter. With just one Rayox lamp online, the electric usage has been about 75 KWH for every hour the plant was online (similar to last year). This is shown on Figure 9.

Sludge is pressed on an as-needed basis and dumped into the 10-yd roll-off. The roll-off is transported an average of every three months. Table 22 provides the amount of sludge generated at this plant. During this reporting period, about 41,360 pounds of sludge was generated and disposed as F032 hazardous waste. This sludge was transported and disposed at the Ross incineration facility in Grafton, Ohio. The majority of the plant sludge was produced due to the precipitation of iron and manganese in the groundwater. This table also shows the amount of sludge produced per 1000 gallons of pre-treatment water since the plant operation began. This indicates a substantial sludge production rate.

4.7 Free Product Recovery

During this reporting period, no free product was recovered at well R-2.

4.8 Other Unit Processes Performance and Related Issues

4.8.1 Oil-Water Separator

Since the oil weir was set at its lowest level (2003), this unit process has been functioning properly.

4.8.2 Recovery Weill Collection Trench System

As stated previously, operation of four older recovery wells (RW-1 thru 4) was discontinued, and two new recovery wells (RW-5 and RW-6) were added.

The collector trench sump also required some extra effort in order to keep it cleaned. This is explained under Section 3.5.

Three manholes and three valve pits along the recovery system transmission lines were not constructed watertignt; groundwater infiltrates the structures, and surface water seeps in through the manhole covers. The manholes and valve pits have been regularly pumped with a portable gas powered pump.

4.8.3 Wastewater Pump Issues

An old diaphragm pump is being used as a wastewater transfer pump (pumping into OWS influent) and as a free product transfer pump. For wastewater, a regular centrifugal pump needed to be added.

4.8.4 Air Diaphragm Pumps

The air diaphragm pumps continued to be a regular maintenance issue, primarily leaky mufflers and splitting diaphragms, which allowed sludge to leak through the center-block assemblies.

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4.8.5 UV/OX Lamps -Wiper Blades, Other Issues


There have been several plant shutdowns due to premature failure of UV/OX lamps. Normally, theselamps should last about 3,000 hours. Table 24 lists lamp usage for this reporting period.

5.0 TECHNICAL ASSESSMENT

5.1 QUESTION A: Is the remedy functioning as intended by the decision documents?

The OU2 remedy, an interim remedy for this site, is functioning as intended. The OU2 remedy is tocapture the entire contaminated shallow groundwater plume that is migrating from the site under EagleRoad and to treat and discharge it into Naylors Run. The purpose of the extraction/recovery wells was toreduce the size of the oil plume floating on the water table. The extraction system has been effective inimpacting nearby shallow and deep monitoring wells. No major contaminant has been detected in theshallow zone boundary wells in the past two years. With the exception of an unexpectediuncontrolledvioiation, plant effluent has been meeting the permit limits. The floating product depth continues todecrease at various wells.

The O&M procedures implemented at the Havertown site have been effective in maintaining the responseaction. A full-time (40 hours/week) qualified operator is on site to provide O&M activities. A programmablelogic controller system (PLC) monitors and a computer stores pertinent operational data for tracking andtroubleshooting. A technical staff reviews and evaluates the data and makes any necessary adjustment inoperation. Periodic water level measurements are taken to determine if extraction system is workingproperly.

\ Regular plant effluent monitoring has been performed to verify compliance with the National Pollutant) Discharge Elimination System (NPDES) permit. Several monitoring wells have been sampled on a

quarterly basis to determine the extraction system water quality and its effectiveness. Shallow and deepzone boundary wells have been sampled on a semi-annual basis to monitor the edge of the shallowcontaminant capture zone. All monitoring wells have been sampled on an annual basis to update thehistorical database.

Based on the current data, there has been a slight contaminant reduction in the shallow and deep zonesince the operation of treatment plant. Furthermore, data suggests that RW-6 has been able to stopmigration of the contaminated groundwater in the deep zone past the collector trench.

5.2 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial actionobjectives (RAOs) used at the time of the remedy selection still valid?

The exposure assumptions, toxicity data, and remedial action objectives for OU2 are still valid.

5.3 QUESTION C: Has any other information come to light that could call into question theprotectiveness of the remedy?

There is no other information that calls into question the effectiveness of the remedy for OU2, thegroundwater extraction and treatment facility. The information examined during the drafting of this AnnualReport demonstrates that the remedy for the shallow groundwater has been protective of human healthand the environment. The protectiveness of the entire site cannot be determined at this time because theOU3 remedy for the deep groundwater has not yet been implemented.

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4.8.5 UV/OX Lamps -Wiper Blades, Other Issues


There have been several plant shutdowns due to premature failure of UV/OX lamps. Normally, these lamps should last about 3,000 hours. Table 24 lists lamp usage for this reporting period.

5.0 TECHNICAL ASSESSMENT

5.1 QUESTION A: Is the remedy functioning as intended by the decision documents?

The OU2 remedy, an interim remedy for this site, is functioning as intended. The OU2 remedy is to capture the entire contaminated shallow groundwater plume that is migrating from the site under Eagle Road and to treat and discharge it into Naylors Run. The purpose of the extraction/recovery wells was to reduce the size of the oil plume floating on the water table. The extraction system has been effective in impacting nearby shallow and deep monitoring wells. No major contaminant has been detected in the shallow zone boundary wells in the past two years. With the exception of an unexpectedluncontrolled violation, plant effluent has been meeting the permit limits. The floating product depth continues to decrease at various wells.

The O&M procedures implemented at the Havertown site have been effective in maintaining the response action. A full-time (40 hours/week) qualified operator is on site to provide O&M activities. A programmable logic controller system (PLC) monitors and a computer stores pertinent operational data for tracking and troubleshooting. A technical staff reviews and evaluates the data and makes any necessary adjustment in operation. Periodic water level measurements are taken to determine if extraction system is working properly.

\ Regular plant effluent monitoring has been performed to verify compliance with the National Pollutant ) Discharge Elimination System (NPDES) permit. Several monitoring wells have been sampled on a

quarterly basis to determine the extraction system water quality and its effectiveness. Shallow and deep zone boundary wells have been sampled on a semi-annual basis to monitor the edge of the shallow contaminant capture zone. All monitoring wells have been sampled on an annual basis to update the historical database.

Based on the current data, there has been a slight contaminant reduction in the shallow and deep zone since the operation of treatment plant. Furthermore, data suggests that RW-6 has been able to stop migration of the contaminated groundwater in the deep zone past the collector trench.

5.2 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?

The exposure assumptions, toxicity data, and remedial action objectives for OU2 are still valid.

5.3 QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?

There is no other information that calls into question the effectiveness of the remedy for OU2, the groundwater extraction and treatment facility. The information examined during the drafting of this Annual Report demonstrates that the remedy for the shallow groundwater has been protective of human health and the environment. The protectiveness of the entire site cannot be determined at this time because the OU3 remedy for the deep groundwater has not yet been implemented.

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6.0 RECOMMENDATIONS


Following is a list of outstanding recommendations, their status and new recommendations.

A. Conversion of spare bio-clay filter into a backup PDU unit - Need to evaluate once pre-treatmentmodifications are complete.

B. Modification to Rayox piping so that the system can be operated without water fiowing through allthree lamps - Need to evaiuate once pre-treatment modifications are complete.

C. Based on historical monitoring welis data (and addition of new OU3 wells), evaluate and modifycurrent monitoring wells sampiing pian

D. Continue to investigate PDU and GAC gas issues and add air release system at GAC

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6.0 RECOMMENDATIONS


Following is a list of outstanding recommendations, their status and new recommendations.

A. Conversion of spare bio-clay filter into a backup PDU unit - Need to evaluate once pre-treatment modifications are complete.

B. Modification to Rayox piping so that the system can be operated without water flowing through all three lamps - Need to evaluate once pre-treatment modifications are complete.

C. Based on historical monitoring wells data (and addition of new OU3 wells), evaluate and modify current monitoring wells sampling plan

D. Continue to investigate PDU and GAC gas issues and add air release system at GAC

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ATTACHMENT A

DETAILED SYSTEM DESCRIPTION

)

Process flow diagrams are enclosed under this attachment for reference.

Recovery Well/Collection Trench System

The present recovery system consists of two deep groundwater recovery wells (RW-5 and RW-6) and ashallow groundwater collector trench (CTR). RW-5 is located between the existing Swiss Farms DairyMarket and former Young's Produce Market parking lot. The CTR is located southeast of PCG on theperiphery of the PCG parking lot. RW-6 is located just downgradient of the CTR behind the former PCG.

Operation of four shallow recovery wells (RW-1, RW-2, RW-4 located just north of Eagle Road southeastof the CAP, and RW-3 located south of Eagle Road on the former PCG property) was discontinued in2006.

Figure 2 shows the location of all recovery wells, collection trench and monitoring wells.

Oil-Water Separator

The oil-water separator (OWS) contains no mechanical parts. Oil is separated from the water bycoalescing on the oleophilic plates (half pack assembly) within the unit. Separated oil is skimmed off theprocess water and fiows by gravity to the free product storage tank. A secondary oil outlet in the finalchamber allows manual discharging of oil and floating solids to the free product tank. Process water isgravity fed to equalization tank #1. Solids that precipitate in the OWS are pumped on a timed basis to thesludge thickener tank via an air-actuated diaphragm pump located under the OWS. Sludge outlets, freeproduct outlets, and the process water inlet each have butterfly valves to control flow. The process wateroutlet does not have a control valve.

Free Product Tank

In 2005, a new double-wall tank was added just outside the OWS room. This tank receives floatingproduct by gravity from the OWS in a manual mode. At least once a week, the plant operator checks theOWS for the floating oil and allows it to flow into the free product tank (by opening a valve). The tank hasa high level alarm for notification. A local level gauge indicates the water level in the tank. This tank alsohas a level transmitter sending a continuous signal to the PLC for trending. An eXisting air-actuateddiaphragm pump is used (in manual mode) to pump the water back into the OWS while observing thewater quality through the sight glass. Once this tank has sufficient free product, it will be pumped out indrums and trucked to an approved disposal facility.

Equalization System

The equalization system consists of two 2,800-gallon FRP tanks and two centrifugal pumps. Equalizationtank #1 receives influent groundwater from OWS. This tank has level switches and alarms, which areused to operate the equalization pump and/or the stand-by equalization pump. Equalization tank #2 canreceive GAC backwash and building sump discharge via a bypass line only when the wastewater tank isnot in operation. The flow rate from the pump(s) is registered by the flow meter installed downstream ofthe pump(s) discharge. A manual globe valve can be used to adjust the pump discharge rate. A threeway valve controlled by the PLC, based on tank level, allows recycling of some water back into thesetanks under low flow conditions in order to keep the equalization pump continuously operating. Bothpumps have local HOA switches that can be used to override the PLC. At present the equalization tanklevel, totalized pre-treatment flow, equalization pump flow rate, and pump discharge pressure arerecorded on the daily log sheet. The system is monitored for any flow changes over time that may signala blockage in the basket strainers. As part of pre-treatment system modification being made in 2008-

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ATTACHMENT A


DETAILED SYSTEM DESCRIPTION

Process flow diagrams are enclosed under this attachment for reference.

Recovery Well/Collection Trench System

The present recovery system consists of two deep groundwater recovery wells (RW-5 and RW-6) and a shallow groundwater collector trench (CTR). RW-5 is located between the existing Swiss Farms Dairy Market and former Young's Produce Market parking lot. The CTR is located southeast of PCG on the periphery of the PCG parking lot. RW-6 is located just downgradient of the CTR behind the former PCG.

Operation of four shallow recovery wells (RW-1, RW-2, RW-4 located just north of Eagle Road southeast of the CAP, and RW-3 located south of Eagle Road on the former PCG property) was discontinued in 2006.

Figure 2 shows the location of all recovery wells, collection trench and monitoring wells.

Oil-Water Separator

The oil-water separator (OWS) contains no mechanical parts. Oil is separated from the water by coalescing on the oleophilic plates (half pack assembly) within the unit. Separated oil is skimmed off the process water and flows by gravity to the free product storage tank. A secondary oil outlet in the final chamber allows manual discharging of oil and floating solids to the free product tank. Process water is gravity fed to equalization tank #1. Solids that precipitate in the OWS are pumped on a timed basis to the sludge thickener tank via an air-actuated diaphragm pump located under the OWS. Sludge outlets, free product outlets, and the process water inlet each have butterfly valves to control flow. The process water outlet does not have a control valve.

Free Product Tank

In 2005, a new double-wall tank was added just outside the OWS room. This tank receives floating product by gravity from the OWS in a manual mode. At least once a week, the plant operator checks the OWS for the floating oil and allows it to flow into the free product tank (by opening a valve). The tank has a high level alarm for notification. A local level gauge indicates the water level in the tank. This tank also has a level transmitter sending a continuous signal to the PLC for trending. An existing air-actuated diaphragm pump is used (in manual mode) to pump the water back into the OWS while observing the water quality through the sight glass. Once this tank has sufficient free product, it will be pumped out in drums and trucked to an approved disposal facility.

Equalization System

The equalization system consists of two 2,800-gallon FRP tanks and two centrifugal pumps. Equalization tank #1 receives influent groundwater from OWS. This tank has level switches and alarms, which are used to operate the equalization pump and/or the stand-by equalization pump. Equalization tank #2 can receive GAC backwash and building sump discharge via a bypass line only when the wastewater tank is not in operation. The flow rate from the pump(s) is registered by the flow meter installed downstream of the pump(s) discharge. A manual globe valve can be used to adjust the pump discharge rate. A threeway valve controlled by the PLC, based on tank level, allows recycling of some water back into these tanks under low flow conditions in order to keep the equalization pump continuously operating. Both pumps have local HOA switches that can be used to override the PLC. At present the equalization tank

\ level, totalized pre-treatment flow, equalization pump flow rate, and pump discharge pressure are . j recorded on the daily log sheet. The system is monitored for any flow changes over time that may signal

a blockage in the basket strainers. As part of pre-treatment system modification being made in 2008-

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09, these tanks will be relocated inside a new building addition and used as wastewater holdingtank (to store pressure filter backwash wastewater). New/larger EO pumps will be installed.

Oil Emulsion. Oxidation. and Extended Oxidation Tanks

The oxidation tank system flows in series and consists of an 800-gallon oil emuision tank (T-205). an 800gallon oxidation tank (T-305), and an 800-gallon extended oxidation tank (T-405). There is a pH probe ineach tank and an oxidation-reduction potential (ORP) probe in tank T-305. Ferric sulfate is fed to tank T205 and is tied with the equalization pump operation (feed terminated on September 19. 2006); sulfuricacid is fed to tank T-205 for pH adjustment (feed terminated on January 17, 2008); sodium hypochlorite isfed to tank T-305 based on ORP; and sodium hydroxide is fed to tanks T-305 and T-405 for pHadjustment. The flow is fed from the equalization pumps into tank T-205. Tank T-405 receives recycleflow from the clarifier seed pump on a timed basis. Each tank has a high speed mixer, which operateswhen the pre-treatment system is activated. Each motor also has a separate HOA switch located at eachtank. At present the pH and ORP values are recorded on the daiiy log sheet. Levels in the tanks arechecked for any changes over time that may signal a blockage. As part of pre-treatment systemmodification being made in 2008-09, the first two tanks will be used as-is, while a new floc tankwill replace old tank T-405. Chemical feed points will also be modified and pH/ORP probes will berelocated.

Clarifier

The inclined plate clarifier has integral flash and floc tanks. Polymer is introduced to the process waterjust prior to entering the flash tank. Mixers mounted in the flash and floc tanks are operated at the sametime as those in the emulsion, oxidation, and extended oxidation tanks. The sludge rake mounted in thebottom of the plate section of the clarifier is operated separately from the other motors. The clarifiersludge pump and the clarifier seed pump remove collected sludge at the bottom of the clarifier. The seedpump discharges into the extended oxidation tank. The clarifier sludge pump discharges to the sludgethickener tank. The effluent flows to the sand filter. The clarifier flocculation chamber is monitored on aregular basis for performance of the polymer and water quality at its discharge. Sludge settling testing isconducted to maintain efficient polymer addition. As part of pre-treatment system modification beingmade in 2008-09, this clarifier will be replaced with a new clarifier to handle higher flow.

Sand Filter

The sand filter follows the clarifier in the pre-treatment train. The sand filter is an up-flow type filter withcontinuous backwash. The continuous backwash rate is controlled at a local control panel equipped withflow indicators, flow regulators and pressure indicators. Solenoid valves installed in the air panel arecontrolled by the PLC. Effluent from the sand filter flows to the surge tank. In the air scour chamber dirtywater is rejected over a weir, which discharges to the floor sump. Daily O&M activities are visualinspection of the water quality, sand air lift and air scour operation, head loss tube, and reject quality.The air flow rate is recorded on the daily log sheet. As part of pre-treatment system modificationbeing made in 2008-09, this sand filter will be removed. A new duplex pressure filter system withautomatic backwash feature will be installed on the discharge of the Rayox pumps.

Surge Tank and UV/OX Feed Pumps

The surge tank and UV/OX feed pumps are designed to regulate flow through the UV/OX system. Theflow rate is adjusted automatically by the PLC based on surge tank level as indicated by the leveltransmitter. HOA switches are available at each of the two UV/OX pumps to override the PLC. TheUV/OX feed pump system has been performing as designed. The surge tank set point is 50 inches. Atpresent the UV/OX pump totalized flow, flow rate, pump discharge pressure, and surge tank level arerecorded on the daily log sheet. During this reporting period, one of the cartridge filters was relocated onthe Rayox pump discharge line. As part of pre-treatment system modification being made in 200809, new/larger Rayox pumps will be installed.

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09, these tanks will be relocated inside a new building addition and used as wastewater holding tank (to store pressure filter backwash wastewater). New/larger EQ pumps will be installed.

Oil Emulsion. Oxidation. and Extended Oxidation Tanks

The oxidation tank system flows in series and consists of an 800-gallon oil emulsion tank (T-205), an 800-gallon oxidation tank (T-305), and an 800-gallon extended oxidation tank (T-405). There is a pH probe in each tank and an oxidation-reduction potential (ORP) probe in tank T-305. Ferric sulfate is fed to tank T-205 and is tied with the equalization pump operation (feed terminated on September 19, 2006); sulfuric acid is fed to tank T-205 for pH adjustment (feed terminated on January 17, 2008); sodium hypochlorite is fed to tank T-305 based on ORP; and sodium hydroxide is fed to tanks T-305 and T-405 for pH adjustment. The flow is fed from the equalization pumps into tank T-205. Tank T -405 receives recycle flow from the clarifier seed pump on a timed basis. Each tank has a high speed mixer, which operates when the pre-treatment system is activated. Each motor also has a separate HOA switch located at each tank. At present the pH and ORP values are recorded on the daily log sheet. Levels in the tanks are checked for any changes over time that may signal a blockage. As part of pre-treatment system modification being made in 2008-09, the first two tanks will be used as-is, while a new floc tank will replace old tank T -405. Chemical feed points will also be modified and pH/ORP probes will be relocated.

Clarifier

The inclined plate clarifier has integral flash and floc tanks. Polymer is introduced to the process water just prior to entering the flash tank. Mixers mounted in the flash and floc tanks are operated at the same time as those in the emulsion, oxidation, and extended oxidation tanks. The sludge rake mounted in the bottom of the plate section of the clarifier is operated separately from the other motors. The clarifier sludge pump and the clarifier seed pump remove collected sludge at the bottom of the clarifier. The seed pump discharges into the extended oxidation tank. The clarifier sludge pump discharges to the sludge thickener tank. The effluent flows to the sand filter. The clarifier flocculation chamber is monitored on a regular basis for performance of the polymer and water quality at its discharge. Sludge settling testing is conducted to maintain efficient polymer addition. As part of pre-treatment system modification being made in 2008-09, this clarifier will be replaced with a new clarifier to handle higher flow.

Sand Filter

The sand filter follows the clarifier in the pre-treatment train. The sand filter is an up-flow type filter with continuous backwash. The continuous backwash rate is controlled at a local control panel equipped with flow indicators, flow regulators and pressure indicators. Solenoid valves installed in the air panel are controlled by the PLC. Effluent from the sand filter flows to the surge tank. In the air scour chamber dirty water is rejected over a weir, which discharges to the floor sump. Daily O&M activities are visual inspection of the water quality, sand air lift and air scour operation, head loss tube, and reject quality. The air flow rate is recorded on the daily log sheet. As part of pre-treatment system modification being made in 2008-09, this sand filter will be removed. A new duplex pressure filter system with automatic backwash feature will be installed on the discharge of the Rayox pumps.

Surge Tank and UV/OX Feed Pumps

The surge tank and UV/OX feed pumps are designed to regulate flow through the UV/OX system. The flow rate is adjusted automatically by the PLC based on surge tank level as indicated by the level transmitter. HOA switches are available at each of the two UV/OX pumps to override the PLC. The UV/OX feed pump system has been performing as designed. The surge tank set point is 50 inches. At present the UV/OX pump totalized flow, flow rate, pump discharge pressure, and surge tank level are recorded on the daily log sheet. During this reporting period, one of the cartridge filters was relocated on the Rayox pump discharge line. As part of pre-treatment system modification being made in 2008-09, new/larger Rayox pumps will be installed.

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UV/OX System


The UV/OX system consists of three UV/OX reactor units plumbed in series. Only one lamp is sufficient totreat the contaminants. These units are equipped with air-actuated cleaning devices to maintain thequartz tube that separates the process water from the UV lamps. The units are equipped with coolingblowers, heat sensors, and flow switches to ensure the units do not overheat. All sensors and alarms areincorporated into the PLC. A static mixer is installed prior to the UV/OX units. Sulfuric acid and hydrogenperoxide are injected into the process water at the static mixer. Chemical doses are controlled by thePLC and are based on pH readings and flow rate for sulfuric acid and hydrogen peroxide, respectively.At present the UV/OX pH and influent pressure are recorded on the daily log sheet.

PDU/Clay Filter and Cartridge Filter

The PDU contains no mechanical components. The PDU is an upflow filter designed to destruct thehydrogen peroxide used in the UV/OX process. The PDU is backwashed whenever there is excessivepressure buildup in the PDU. This backwash water is allowed to discharge into building floor sump.

The clay filter has been removed from service since May 2003.

As stated before, one of the cartridge filters was relocated just upstream of the Rayox system; now justone filter is used after the PDU/Clay filter. This filter is equipped with differential pressure gauges toindicate when the cartridges require replacement. At present the PDU influenVeffluent pressure, clay filtereffluent pressure, and cartridge filter differential pressure readings are recorded on the daily log sheet.The cartridge filter unit is recorded as well.

GAC Units

The purpose of the liquid-phase carbon adsorber system is to adsorb and remove the leftover organiccompounds (not removed by the UV/OX system) entrained in the groundwater. The GAC units containno mechanical components. The plant operator can re-align the valves to operate the two units in seriesor in parallel. The valves may also be aligned to facilitate backwashing of the carbon. See Performancesection for effluent quality issues. At present the GAC inlet pressure and GAC outlet pressures arerecorded on the daily log sheets. Also, GAC series are recorded (such as PV-1 to PV-2 or PV-2 to PV-1).These GAC units are backwashed on a periodic basis, and the backwash water is discharged intowastewater storage tank.

Effluent Tanks

Treated process water is stored temporarily in two 3,600-gallon LDPE tanks housed outside of thetreatment building. Closing the respective influent valve can isolate flow to the tank. Tank level ismonitored in Tertiary Effluent Tank #1. Each of the two effluent pumps is controlled by the PLC and hasa local HOA switch. Closing the respective effluent valve can isolate flow from the tank.

The effluent water will also serve as backwash water for the GAC units. A backwash pump is provided forthat purpose. The plant operator can position the valves on the GAC units to facilitate backwashing inseries or parallel or in a single GAC unit. At present effluent pump discharge pressure and effluent pH isrecorded on daily log sheet.

Wastewater Storage Tank

In 2005, this tank was created. This used to be a free product tank inside the OWS room. This tankreceives GAC and PDU backwash water and sump discharge. A high-high level alarm would shut downthe collection system. An existing air-actuated diaphragm pump (common to free product tank)automatically drained out this tank (based on its level, and equalization tank's level) into the OWS influent

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UV/OX System


The UV/OX system consists of three UV/OX reactor units plumbed in series. Only one lamp is sufficient to treat the contaminants. These units are equipped with air-actuated cleaning devices to maintain the quartz tube that separates the process water from the UV lamps. The units are equipped with cooling blowers, heat sensors, and flow switches to ensure the units do not overheat. All sensors and alarms are incorporated into the PLC. A static mixer is installed prior to the UV/OX units. Sulfuric acid and hydrogen peroxide are injected into the process water at the static mixer. Chemical doses are controlled by the PLC and are based on pH readings and flow rate for sulfuric acid and hydrogen peroxide, respectively. At present the UV/OX pH and influent pressure are recorded on the daily log sheet.

PDU/Clay Filter and Cartridge Filter

The PDU contains no mechanical components. The PDU is an upflow filter designed to destruct the hydrogen peroxide used in the UV/OX process. The PDU is backwashed whenever there is excessive pressure buildup in the PDU. This backwash water is allowed to discharge into building floor sump.

The clay filter has been removed from service since May 2003.

As stated before, one of the cartridge filters was relocated just upstream of the Rayox system; now just one filter is used after the PDU/Clay filter. This filter is equipped with differential pressure gauges to indicate when the cartridges require replacement. At present the PDU influenVeffluent pressure, clay filter effluent pressure, and cartridge filter differential pressure readings are recorded on the daily log sheet. The cartridge filter unit is recorded as well.

GAC Units

The purpose of the liquid-phase carbon ad sorber system is to adsorb and remove the leftover organic compounds (not removed by the UV/OX system) entrained in the groundwater. The GAC units contain no mechanical components. The plant operator can re-align the valves to operate the two units in series or in parallel. The valves may also be aligned to facilitate backwashing of the carbon. See Performance section for effluent quality issues. At present the GAC inlet pressure and GAC outlet pressures are recorded on the daily log sheets. Also, GAC series are recorded (such as PV-1 to PV-2 or PV-2 to PV-1). These GAC units are backwashed on a periodic basis, and the backwash water is discharged into wastewater storage tank.

Effluent Tanks

Treated process water is stored temporarily in two 3,600-gallon LDPE tanks housed outside of the treatment building. Closing the respective influent valve can isolate flow to the tank. Tank level is monitored in Tertiary Effluent Tank #1. Each of the two effluent pumps is controlled by the PLC and has a local HOA switch. Closing the respective effluent valve can isolate flow from the tank.

The effluent water will also serve as backwash water for the GAC units. A backwash pump is provided for that purpose. The plant operator can position the valves on the GAC units to facilitate backwashing in series or parallel or in a single GAC unit. At present effluent pump discharge pressure and effluent pH is recorded on daily log sheet.

Wastewater Storage Tank

In 2005, this tank was created. This used to be a free product tank inside the OWS room. This tank receives GAC and PDU backwash water and sump discharge. A high-high level alarm would shut down the collection system. An existing air-actuated diaphragm pump (common to free product tank) automatically drained out this tank (based on its level, and equalization tank's level) into the OWS influent

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line. This tank also has a levei transmitter, which sends a continuous signal to PLC for trending and pumpcontrol. As part of pre-treatment system modification being made in 2008~9, this tank will now beused as equalization tank.

Sludge Thickener

The sludge thickener receives sludge from both the OWS and the clarifier. To increase the solids contentof the sludge tank, a motorized sludge rake is installed at the bottom of the tank. This motor is controlledby the PLC and has a local HOA switch. Decant water from the thickening process is discharged to thebuilding sump.

Filter Press

Thickened sludge is removed from the sludge thickener tank by the filter press sludge pump anddischarged to the filter press. The filter press sludge pump is an air-actuated diaphragm pump controlledby the PLC. Once activated, the pump operates through three pressure settings to maximize solidscontent at the filter press. The sludge cake is dropped into a 10 c.y. roll-off box. To maximize the sludgecake stored in the roll-off, the plant operator rakes and levels the sludge in the roll-off.

Building Sump

The treatment building sump receives overflow from all the process tanks housed inside the building, aswell as reject flow from the sand filter, decant water from the sludge thickener tank, filter press water, andUV/OX bleed valve water. A submersible pump that is controlled by level switches empties the sump. Alocal HOA switch can be used to override the level switches. Discharge from the sump is pumped back tothe wastewater storage tank (or it can be sent to equalization tank #2 as well using bypass valve).

As part of pre-treatment system modification being made in 2008-09, a bUilding addition will beadded to house two tanks and a new sump.

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line. This tank also has a level transmitter, which sends a continuous signal to PLC for trending and pump control. As part of pre-treatment system modification being made in 2008~9, this tank will now be used as equalization tank.

Sludge Thickener

The sludge thickener receives sludge from both the OWS and the clarifier. To increase the solids content of the sludge tank, a motorized sludge rake is installed at the bottom of the tank. This motor is controlled by the PLC and has a local HOA switch. Decant water from the thickening process is discharged to the building sump.

Filter Press

Thickened sludge is removed from the sludge thickener tank by the filter press sludge pump and discharged to the filter press. The filter press sludge pump is an air-actuated diaphragm pump controlled by the PLC. Once activated, the pump operates through three pressure settings to maximize solids content at the filter press. The sludge cake is dropped into a 10 c.y. roll-off box. To maximize the sludge cake stored in the roll-off, the plant operator rakes and levels the sludge in the roll-off.

Building Sump

The treatment building sump receives overflow from all the process tanks housed inside the building, as well as reject flow from the sand filter, decant water from the sludge thickener tank, filter press water, and UV/OX bleed valve water. A submersible pump that is controlled by level switches empties the sump. A local HOA switch can be used to override the level switches. Discharge from the sump is pumped back to the wastewater storage tank (or it can be sent to equalization tank #2 as well using bypass valve).

As part of pre-treatment system modification being made in 2008-09, a building addition will be added to house two tanks and a new sump.

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TABLES


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TABLES


Table 1Operations and Maintenance Routine Activities

January 2008 Continued operating the plant. Provided a full-time operator on 40 hrslweek basis.

Continued normal O&M activities (sludge dewatering, cleanup of strainers, water level measurements, etc).

Plant operation continues with one Rayox iamp.

On 01104108, Quartz tube on RayOx Unit #2 broke, shutdown on leak detect. New tube and O-Rings installed.

On 01104108, replaced RayOx influent pH probe.

On 01107108, Bypass line from clarifier was still functioning, but could not close valve due to iron fouling.

On 01107108, Filter Press would not close, hydraulic fluid low. Main hydraulic piston is leaking at seal.

On 01107108, cleared PDU bleed off of carbon and continued flow to RayOx surge tank.

On 01108108, replaced sand filter bypass and closed off fiow to surge tank. All flow thru sand filter.

On 01109108, an additional weir was fabricated for the sand filter reject in order to reduce the flow. A longer air lancewas assembied for the sand filter.

On 01114108, the second RayOx pump (P-116) was reinstalied.

On 01115108, the January NPDES plant sampling was conducted.

On 01117108, sulfuric acid feed to Oxidation Tank #1 was stopped. This was done to optimize the oxidation stepand reduce usage of sodium hydroxide. Iron and manganese monitored.

On 01119108, plant shutdown due to power ioss.

On 01121108, changed out pressure gauges on RayOx discharge and cartridge filter discharge.

On 01124108, replaced OWS sludge pump with new unit.

On 01125108, found valve clogged in RayOx discharge, cleaned. Also, backwashed GACs.

On 01129108, on quick-panel, hydrogen peroxide flow factor reset from 2000 to 1500 to reduce peroxide feed rate.

February 2008 Continued operating the plant. Provided a full-time operator on 40 hrslweek basis.


Plant operation continues with one Rayox lamp.

On 02107108, removed filter press sludge feed pump.

On 02108108, installed new filter press sludge feed pump. Also backwashed GAC's.

On 02110108, system shutdown due to power loss.

On 02111108, after restarting, RayOx unit #2 bulb failed due to high kVA at 1924 hoursl69 starts. Replaced withnew lamp on 02112108.

On 02112108, attempted to replace poiymer mixer motor with SUbstitute. Motor did not fit, plant was shut down.

On 02114108, attempted to reinstall existing polymer mixer motor but there was internal damage. New systemordered.

Page 1 of6

January 2008

Table 1

I r,mt;;n",.rl operating the plant. Provided a full-time operator on 40 hrslweek basis.

Ir,mt;,n",.rl normal O&M activities (sludge dewatering. cleanup of strainers. water level measurements. etc).

operation continues with one Rayox lamp.

01104108, Quartz tube on RayOx Unit #2 broke, shutdown on leak detect. New tube and O-Rings installed.

01104108, replaced RayOx influent pH probe.

01107108, Bypass line from clarifier was still functioning, but could not close valve due to iron fouling.

01107108, Filter Press would not close, hydraulic fluid low. Main hydraulic piston is leaking at seal.

01107108, cleared PDU bleed off of carbon and continued flow to RayOx surge tank.

01108108, replaced sand filter bypass and closed off flow to surge tank. All flow thru sand filter.

On 01109108, an additional weir was fabricated for the sand filter reject in order to reduce the flow. A longer air lance was assembled for the sand filter.

On 01114108, the second RayOx pump (P-116) was reinstalled.

On 01115108, the January NPDES plant sampling was conducted.

On 01117108, sulfuric acid feed to Oxidation Tank #1 was stopped. This was done to optimize the oxidation step and reduce usage of sodium hydroxide. Iron and manganese monitored.

On 01119108, plant shutdown due to power loss.

On 01121108, changed out pressure gauges on RayOx discharge and cartridge filter discharge.

On 01124108, replaced OWS sludge pump with new unit.

01125108, found valve clogged in RayOx discharge, cleaned. Also, backwashed GACs.

01129108, on quick-panel, hydrogen peroxide flow factor reset from 2000 to 1500 to reduce peroxide feed rate.

February 2008 Ir"nt;n""rl operating the plant. Provided a full-time operator on 40 hrslweek basis.

I r"nt;m ",rl normal O&M activities (sludge dewatering, cleanup of strainers, water level measurements, etc).


02107108, removed filter press sludge feed pump.

02108108, installed new filter press sludge feed pump. Also backwashed GAC's.

02110108, system shutdown due to power loss.

02111108, after restarting, RayOx unit #2 bulb failed due to high kVA at 1924 hoursl69 starts. Replaced with lamp on 02112108.

02112108, attempted to replace polymer mixer motor with substitute. Motor did not fit, plant was shut down.

02114108, attempted to reinstall existing polymer mixer motor but there was internal damage. New system lorder·ed.

Page 1 of6


February 2008 On 02/18/08, processed water out of pretreatment system in order to have room to recycle water during start-up willnew polymer system. Removed existing poiymer system.

On 02/21/08, installed new polymer system and started placing plant back in operation. Upon RayOx restart thesystem went to Emergency Stop for unknown reason. Unable to reset. Snow and ice prevented programmer fromreaching site before weekend. Had to wait until Monday.

On 02/25/08, programmer onsite, found RayOx wiper proximity switches were defective in Unit #1 and #3. Thoseswitches were disarmed since RayOx has been running Unit #2 only. System back online.

On 02/26/08, continue to make adjustments to new polymer settings. Leak developed in flange at PDU inlet. Metaltape was placed on leak until it could be serviced.

On 02/28/08, February NPDES sampling conducted.

March 2008 Continued operating the plant. Provided a full-time operator on 40 hrslweek basis.



On 03/03/08, backwashed PDU and both GACs.

On 03/04/08, resampled plant effluent for SVOCs only due to hits in PCP from 02128/08 sample.

On 03/04/08, filter press low on hydraulic fluid. Refilled.

On 03/08/08, system shutdown due to power loss (high winds in area).

On 03/10108, due to power loss, Main Control Panel and RayOx Control Panels powered down and reset.

On 03/10108, system shutdown due to power loss at collection trench overnight.

On 03/17/08, the system shutdown due to RayOx low flow. The sand filter was backing up and flow to RayOx surgetank was diverting back to EO tanks via floor sump.

On 03/18/08, sand filter backing up again causing clarifier to overflow. Air lanced sand filter.

On 03/21/08, programmer installed new PLC processor and plant was placed back online. Data issues with trendingprogram were solved.

On 03/24/08, chemical tanks sodium hydroxide, and sulfuric acid were filled.

On 03/25/08, chemical tanks hydrogen peroXide and sodium hypochlorite were filled.

On 03/27/08, March NPDES annual plant sampling conducted.

On 03/28/08, slight leak at polymer system suction. Tightened fitting.

April 2008 Continued operating the plant. Provided a full-time operator on 40 hrslweek basis.



On 04/01/08, replaced WWT site tube.

On 04/04/08, replaced light bulbs in OWS room.

Page 2 of6

,j

r

Table 1

02/21/08, installed new polymer system and started placing plant back in operation. Upon RayOx restart the Isvstem went to Emergency Stop for unknown reason. Unable to reset. Snow and ice prevented programmer from reaching site before weekend. Had to wait until Monday.

On 02/25/08, programmer onsite, found RayOx wiper proximity switches were defective in Unit #1 and #3. Those switches were disarmed since RayOx has been running Unit #2 only. System back online.

On 02/26/08, continue to make adjustments to new polymer settings. Leak developed in flange at PDU inlet. Metal tape was placed on leak until it could be serviced.

On 02/28/08, February NPDES sampling conducted.

March 2008 Continued operating the plant. Provided a full-time operator on 40 hrslweek basis.

April 2008



On 03/03/08, backwashed PDU and both GACs.

03/04/08, resampled plant effluent for SVOCs only due to hits in PCP from 02128/08 sample.

On 03/04/08, filter press Iowan hydraulic fluid. Refilled.

On 03/08/08, system shutdown due to power loss (high winds in area).

On 03/10/08, due to power loss, Main Control Panel and RayOx Control Panels powered down and reset.

03/10/08, system shutdown due to power loss at collection trench overnight.

03/17/08, the system shutdown due to RayOx low flow. The sand filter was backing up and flow to RayOx was diverting back to EQ tanks via floor sump.

03/18/08, sand filter backing up again causing clarifier to overflow. Air lanced sand filter.

03/21/08, programmer installed new PLC processor and plant was placed back online. Data issues with trending I progr'am were solved.

03/24/08, chemical tanks sodium hydroxide, and sulfuric acid were filled.

03/25/08, chemical tanks hydrogen peroxide and sodium hypochlorite were filled.

03/27/08, March NPDES annual plant sampling conducted.

03/28/08, slight leak at polymer system suction. Tightened fitting.

Continued operating the plant. Provided a full-time operator on 40 hrs/week basis.



On 04/01/08, replaced WWT site tube. , )

r On 04/04/08, replaced light bulbs in OWS room.

Page 2 of6


\J

April 2008

May 2008

June 2008

On 04/07/08, leveled sludge in roll-off.

On 04/14/08, annual maintenance performed on air compressor and air dryers by Atlas Copco.

On 04/15/08, oxidation tank #1 was overflowing. Reduced pretreatment flow rate and set up for cleaning crosspipes due to sludge build-up.

On 04/15/08, pre-treatment system shutdown in evening due to oxidation tank #3 pH probe reading Low-Low.Problem was determined to be from loose connection at BNC connector.

On 04/16/08, April NPDES monthly plant sampling conducted.

On 04/17/08, sludge roll-off was removed with 12,760 Ibs. of filter sludge cake. The roll-off was removed by FCI andtransported to Ross Environmental in Grafton, OH for incineration.

On 04/19/08, the plant shutdown due to an apparent power loss in the evening. Restarted on Monday, 04/21/08.

On 04/25/08, repatched pipe on PDU fill line.

On 04/29/08, plant shutdown due to power loss. After restart power was lost again. Okay after second restart.

On 04/30/08, at influent sampling valve ahead of OWS, repiaced pipe coupling due to corrosion.

Continued operating the plant. Provided a full-time operator on 40 hrslweek basis.



On 05/09/08, plant shutdown due to power loss. Heavy storms in the area.

On 05/12/08, the PDU was backflushed due to increasing pressure in the system. High pressure in system wasdetermined to be in GAC PV-2 unit. This unit scheduled to be backwashed after plant sampling.

On 05/15/08, chemicals were deiivered.

On 05/15/08, a ieaking valve on PDU discharge was replaced.

On 05/19/08, May NPDES Plant Sampling conducted.

On 05/20108, both GAC units were backwashed 3,500 gallons each. Reduced pressure by 20 psi.

On 05/21/08, the clarifier was overflowing due to sand filter plugging.

On 05/23/08, the polymer system was not working again. The system had to remain down until 5128108.

On 05/28/08, system remained down.

On 05/29/08, polymer soienoid valve bypassed and system being run in manual mode. Low flow issues developedin RayOx pumps.

On 05/30/08, new polymer parts arrived and installed. Polymer system back online, but RayOx pumping at lowerflowrate (15-20 gpm).

Continued operating the plant. Provided a full-time operator on 40 hrslweek basis.



Page 3 of6

May 2008

\J June 2008

Table 1

On 04/14/08, annual maintenance performed on air compressor and air dryers by Atlas Copco.

On 04/15/08, oxidation tank #1 was overflowing. Reduced pretreatment flow rate and set up for cleaning pipes due to sludge build-up.

On 04/15/08, pre-treatment system shutdown in evening due to oxidation tank #3 pH probe reading Low-Low. Problem was determined to be from loose connection at BNC connector.

On 04/16/08, April NPDES monthly plant sampling conducted.

On 04/17/08, sludge roll-off was removed with 12,760 Ibs. of filter sludge cake. The roll-off was removed by FCI and ItrclnslPorted to Ross Environmental in Grafton, OH for incineration.

On 04/19/08, the plant shutdown due to an apparent power loss in the evening. Restarted on Monday, 04/21/08.

On 04/25/08, repatched pipe on PDU fill line.

On 04/29/08, plant shutdown due to power loss. After restart power was lost again. Okay after second restart.

On 04/30/08, at influent sampling valve ahead of OWS, replaced pipe coupling due to corrosion.

I C()ntinu"d operating the plant. Provided a full-time operator on 40 hrslweek basis.



05/09/08, plant shutdown due to power loss. Heavy storms in the area.

05/12/08, the PDU was backflushed due to increasing pressure in the system. High pressure in system was Id"termilled to be in GAC PV-2 unit. This unit scheduled to be backwashed after plant sampling.

On 05/15/08, chemicals were delivered.

05/15/08, a leaking valve on PDU discharge was replaced.

05/19/08, May NPDES Plant Sampling conducted.

05/20108, both GAC units were backwashed 3,500 gallons each. Reduced pressure by 20 psi.

05/21/08, the clarifier was overflowing due to sand filter plugging.

05/23/08, the polymer system was not working again. The system had to remain down until 5128108.

05/28/08, system remained down.

05/29/08, polymer solenoid valve bypassed and system being run in manual mode. Low flow issues developed RayOx pumps.

05/30/08, new polymer parts arrived and installed. Polymer system back online, but RayOx pumping at lower Illo~lfate (15-20 gpm).

I C(lntilnlJ"d operating the plant. Provided a full-time operator on 40 hrslweek basis.

I CClntilnlJf,d normal O&M activities (sludge dewatering, cleanup of strainers, water level measurements, etc).


Page 3 016


June 2008

July 2008

On 06/01/08, system shutdown due to RayOx Lamp #2 supply wire burning off at terminal.

On 06/02108, flow thru RayOx pumps running between 10-15 gpm. Troubieshooting pumps by disassemblingsuction and discharge piping for biockages. None found so attempted to look at pump impeller. Found impellerclogged with iron solids.

On 06/03/08, cleaned pump impeller by flushing with 10% acid solution. Pump flow returned to normal.

On 06/10/08, June NPDES Quarterly plant sampling was conducted.

On 06/10/08, effluent pH probe was cleaned and calibrated. The three oxidation and ORP probes were cleaned andthe polymer system was draped with plastic sheeting to prevent future splashing.

On 06/17/08, the RayOx system shutdown on low flow due to sand filter plugging. Sand filter was air lanced andsystem restarted. After restart it was discovered that peroxide pump was not working (no display). Equipmentvendor was called.

On 06/18/08, the peroxide pump was disassembled and found to have a cracked diaphragm. This allowed peroxideto get inside the pump and damaging the electronics. A new pump and diaphragm was ordered.

On 06/19/08, the new pump arrived in morning but diaphragm was missing. Reordered diaphragm.

On 06/20/08, new diaphragm arrived, pump reassembled and system restarted.

On 06/24 and 06/25/08, two hydraulic technicians onsile to inspect filter press and present quote for servicing.




On 07/02 and 07/03108, chemicals were delivered.

On 07/07108, RayOx Unit #2 top gasket leaked which shutdown system. Replaced both O-rings.

On 07/08/08, Oxidation tanks were overflowing. Reduced flow rate to 28 gpm. Shutdown scheduled for next day.

On 07/09/08, Atlas Copco onsite for quarterly service on air compressor. System placed back online after service.

On 07/11108, system shutdown due to low pH reading on effluent. Readings had been fluctuating at an abnormallevel so probe was investigated. Probe was cleaned and calibrated. pH level returned to normal (-7.0 pH). Systemplaced back online.

On 07/18/08, both GACs were backwashed with 3,000 gallons each of potable water due to pressure build-up andhigh Manganese levels taken with HACH field sampler.

On 07/21/08, the monthly NPDES sampiing was conducted.

On 07/23/08, power was Interrupted in the morning due to strong lightning storms in area. System was restarted.

)

August 2008 Continued operating the plant. Provided a full-time operator on 40 hrs/week basis.



On 08/07/08, the monthly NPDES sampling was conducted.

Page40f6

1

June 2008

July 2008

August 2008

Table 1

On 06/01/08, system shutdown due to RayOx Lamp #2 supply wire burning off at terminal.

On 06/02108, flow thru RayOx pumps running between 10-15 gpm. Troubleshooting pumps by disassembling suction and discharge piping for blockages. None found so attempted to look at pump impeller. Found impeller clogged with iron solids.

On 06/03/08, cleaned pump impeller by flushing with 10% acid solution. Pump flow returned to normal.

On 06/10/08, June NPDES Quarterly plant sampling was conducted.

On 06/10/08, effluent pH probe was cleaned and calibrated. The three oxidation and ORP probes were cleaned and polymer system was draped with plastic sheeting to prevent future splashing.

On 06/17/08, the RayOx system shutdown on low flow due to sand filter plugging. Sand filter was air lanced and system restarted. After restart it was discovered that peroxide pump was not working (no display). Equipment

Ivendl)rwas called.

On 06/18/08, the peroxide pump was disassembled and found to have a cracked diaphragm. This allowed peroxide get inside the pump and damaging the electronics. A new pump and diaphragm was ordered.

06/19/08, the new pump arrived in morning but diaphragm was missing. Reordered diaphragm.

06/20/08, new diaphragm arrived, pump reassembled and system restarted.

06/24 and 06/25/08, two hydraulic technicians onsile to inspect filter press and present quote for servicing.


I LemIlnu,," normal O&M activities (sludge dewatering, cleanup of strainers, water level measurements, etc).


07/02 and 07/03108, chemicals were delivered.

07/07108, RayOx Unit #2 top gasket leaked which shutdown system. Replaced both a-rings.

07/08/08, Oxidation tanks were overflowing. Reduced flow rate to 28 gpm. Shutdown scheduled for next day.

07/09/08, Atlas Copco onsite for quarterly service on air compressor. System placed back online after service.

07/11108, system shutdown due to low pH reading on effluent. Readings had been fluctuating at an abnormal I so probe was investigated. Probe was cleaned and calibrated. pH level returned to normal (-7.0 pH). System

back online.

07/18/08, both GACs were backwashed with 3,000 gallons each of potable water due to pressure build-up and Manganese levels taken with HACH field sampler.

07/21/08, the monthly NPDES sampling was conducted.

07/23/08, power was interrupted in the morning due to strong lightning storms in area. System was restarted.

IC(mtilnue,d operating the plant. Provided a full-time operator on 40 hrs/week basis.


1 Plant operation continues with one Rayox lamp.

08/07/08, the monthly NPDES sampling was conducted.

Page40f6

)

\ /


August 2008 On 08/14/08, upon restart, RayOx Unit #2 bottom lamp wire connector burnt off. Connector replaced and restarted.

On 08/19/08, sludge roll-off was removed with approximately 13,150 Ibs. of filter sludge cake. The roll-off wasremoved by FCI and transported to Ross Environmental in Grafton, OH for incineration.

September 2008 Continued operating the plant. Provided a full-time operator on 40 hrslweek basis.

Continued normal O&M activities (sludge dewatering, cleanup of strainers, water level measurements, etc),


On 09102/08, a leak in hypochlorite suction was discovered and repaired.

On 09/03/08, RW-5 was shutdown in the morning for a modified pump test at CW-17 for an OU3 task, In earlyafternoon the plant shutdown due to RayOx #2 leak. The RayOx was leaking at the top a-Ring. After the CW-17testing was completed the a-Ring was replaced and the piant placed back online with RW-5 back online also.

On 09/09/08, the quarterly NPDES sampling was conducted.

On 09/11/08, the hypochlorite return line to the storage tank was found ciogged causing a flow stoppage thru pump.This was cleared and pump placed back online.

On 09/16/08, fuse was blown on polymer system. Fuse replaced.

On 09/19/08, plant shut down due to air compressor maifunctioning. Service tech was contacted and found thatcooling fan had failed due to bad bearing. A new fan was ordered and replaced on 9/25/08. Minor preventivemaintenance of air compressor was also performed. Plant was back online on 9/26/08.

On 09/19/08, Quartz tube was replaced in RayOx unit #2.

On 09/23/08, the sand filter influent piping was dismantled and cleaned.

October 2008 Continued operating the piant. Provided a full-time operator on 40 hrslweek basis.



On 10108/08, shutdown system and removed RayOx pump in order to clean impeller due to flow rate reduction.After cleaning placed system back online.

On 10109108, RayOx pump leaking from weep hole. Investigated on 10/15/08,

On 10109/08, monthly NPDES sampling conducted for October.

On 10/10108, removed ball valve on clarifier to surge tank bypass because it was stuck open.

On 10/15/08, disassembled RayOx pump. New seal kit ordered for replacement of mechanical seal.

On 10/16108, RayOx pump rebuilt with new impeller and mechanical seal. System placed back online. Later inafternoon clarifier was overllowing. System shutdown.

On 10/17/08, air lanced sand filter and placed system back online.

On 10/17/08, RW-6 level had drawn down to pump inlet. Pump shutoff setpoint not working on computer.Shutdown RW-6 until programmer was available to fix pump onloff setpoint.

Page 5 of6

)

Table 1

August 2008 On 08/14/08, upon restart, RayOx Unit #2 bottom lamp wire connector burnt off. Connector replaced and restarted.

September 2008

October 2008

On 08/19/08, sludge roll-off was removed with approximately 13,150 Ibs. of filter sludge cake. The roll-off was removed by FCI and transported to Ross Environmental in Grafton, OH for incineration.

operating the plant. Provided a full-time operator on 40 hrslweek basis.



09102/08, a leak in hypochlorite suction was discovered and repaired.

09/03/08, RW-5 was shutdown in the morning for a modified pump test at CW-17 for an OU3 task. In early laflerr,ocln the plant shutdown due to RayOx #2 leak. The RayOx was leaking at the top O-Ring. After the CW-17

was completed the O-Ring was replaced and the plant placed back online with RW-5 back online also.

09/09/08, the quarterly NPDES sampling was conducted.

09/11/08, the hypochlorite return line to the storage tank was found clogged causing a flow stoppage thru pump. This was cleared and pump placed back online.

09/16/08, fuse was blown on polymer system. Fuse replaced.

09/19/08, plant shut down due to air compressor malfunctioning. Service tech was contacted and found that I~nnlicln fan had failed due to bad bearing. A new fan was ordered and replaced on 9125108. Minor preventive lmoainllenanc:e of air compressor was also performed. Plant was back online on 9/26/08.

09/19/08, Quartz tube was replaced in RayOx unit #2.

09/23/08, the sand filter influent piping was dismantled and cleaned.

operating the plant. Provided a full-time operator on 40 hrslweek basis.

normal O&M activities (sludge dewatering, cleanup of strainers, water level measurements, etc).


On 10108/08, shutdown system and removed RayOx pump in order to clean impeller due to flow rate reduelion. cleaning placed system back online.

10109108, RayOx pump leaking from weep hole. Investigated on 10/15/08.

10109/08, monthly NPDES sampling conducted for October.

On 10/10108, removed ball valve on clarifier to surge tank bypass because it was stuck open.

10/15/08, disassembled RayOx pump. New seal kit ordered for replacement of mechanical seal.

10/16108, RayOx pump rebuilt with new impeller and mechanical seal. System placed back online. Later in afternoon clarifier was overfrowing. System shutdown.

On 10/17/08, air lanced sand filter and placed system back online.

On 10/17/08, RW-6 level had drawn down to pump inlet. Pump shutoff setpoint not working on computer. Shutdown RW-6 until programmer was available to fix pump onloff setpoint.

Page 5 of6


October 2008 On 10/20108, due to sand filter plugging switched to bypass from clarifier to surge tank.

On 10/23/08, returned sand filter online.

On 10/26/08, plant shutdown due to power loss on weekend.

On 10/28/08, pulled CTR pump and cleaned. When pump was installed there was no flow.

On 10/29/08, piant shutdown due to storms. Upon restart, oxidation tank #2 pH transmitter not functionin9. Hadeiectrician onsite switch Tank #3 transmitter (not in use) with failed #2 transmitter. Motherboard issue. Effluent pHwas reading low so probe was cleaned. Upon disassembly wires were puiled out of probe. Effluent pH wiil betracked manuaily until plant modifications to start. CTR pump pUiled again. Pump drive coupling was stripped. CTRremained shutdown.

On 10/30108, replaced CTR pump with standby Grundfos pump used for CW-25 pump test. Electrician rewired forthis pump. Pump piaced online and CTR produced 7.0 gpm. TDH still too much for pump.

On 10/30108, effluent pH probe malfunctioning. Programmer jumpered effluent pH probe so that system would run.pH monitored manuaily.

On 10/31/08, defective CTR flow paddlewheel removed to check for blockage. Plug was instailed.

On 10/31/08, sludge roil-off was removed with approximately 13,150 Ibs. of filter sludge cake and -500 Ibs of sandfiiter dirty sand. The roil-off was removed by FCI and transported to Ross Environmental in Grafton, OH forincineration.

November 2008 Continued operating the plant. Provided a fuil-time operator on 40 hrslweek basis.



On 11103/08, Polymer pump not feeding. TUbing was disassembled and a smail blockage was found. Systemplaced back online.

On 11/13/08 plant was completely shut down for demolition and start pretreatment system modifications.

Due to cleanup activities starting on November 3rd and plant shutiing down on November 10th, there was noNPDES sampling conducted for the month of November.

December 2008 No O&M activities due to plant upgrade. No NPDES sampling conducted for the month of December.

Page 6 of6

Table 1

On 10/23/08, returned sand filter online.

10/26/08, plant shutdown due to power loss on weekend.

10/28/08, pulled CTR pump and cleaned. When pump was installed there was no flow.

10/29/08, plan! shutdown due to storms. Upon restart, oxidation tank #2 pH transmitter not functioning. Had I~::~tl~~~~~r~onsite switch Tank #3 transmitter (not in use) with failed #2 transmitter. Motherboard issue. Effluent pH I, low so probe was cleaned. Upon disassembly wires were pulled out of probe. Effluent pH will be Itra.cke,d manually until plant modifications to start. CTR pump pulled again. Pump drive coupling was stripped. CTR I rAmeinAri shutdown.

10/30108, replaced CTR pump with standby Grundfos pump used for CW-25 pump test. Electrician rewired for pump. Pump placed online and CTR produced 7.0 gpm. TDH still too much for pump.

10/30108, effluent pH probe malfunctioning. Programmer jumpered effluent pH probe so that system would run. pH monitored manually.

10/31/08, defective CTR flow paddlewheel removed to check for blockage. Plug was installed.

10/31/08, sludge roll-off was removed with approximately 13,150 Ibs. of filter sludge cake and -500 Ibs of sand dirty sand. The roll-off was removed by FCI and transported to Ross Environmental in Grafton, OH for

November 2008 I Ccmtilnue,d operating the plant. Provided a full-time operator on 40 hrslweek basis.

I Ccmtilnue,d normal O&M activities (sludge dewatering, cleanup of strainers, water level measurements, etc).


On 11103/08, Polymer pump not feeding. Tubing was disassembled and a small blockage was found. System back online.

On 11/13/08 plant was completely shut down for demolition and start pretreatment system modifications.

Due to cleanup activities starting on November 3rd and plant shutting down on November 10th, there was no NPDES sampling conducted for the month of November.

December 2008 No O&M activities due to plant upgrade. No NPDES sampling conducted for the month of December.

Page 6 of6

\ , ,

Table 2Monitoring Wells Construction Details

Well-IO Commentsfl. top bot.

1',,; ," C'"w',".'1'0': ,:\,,' 1, -" "; '31"2"7"""0'" '5'7'6"0"\ "" ";'" ," ,,' ",," "", ",' "" "" ",-oF" ," ,,' ,,,, "0" , " ' , ,,,' ,,'I",' , ,,12"{ , ,,52,~0' -' 57.60 Conlilient"l Auld Partsgf(Lawrence Road,): -', , " : - "',

2 CW-11 2" 312.27 34.10 24.10 - 34.10 Continental Auto Parts off Lawrence Road Located on cap

~3 Ic~:i§',,,,1 ;~:':M2.i7;r~O iGo: ;t~6; 8~hii~~Al~1;i\~to;~~~~otitav;,:~~c~~~~d;, '.," ~; ",',

4 CW-20 2" 316.51 ~,,~,.:~~, 57.20 - 65.20 GWTP Property, NE corner of ca Located~

:f{ r.w_?! _1" I'~~, 3;;s',~~4f20131:20\:~'1,~Il;' , ~':',

6 CW-2S 2" 316.38 26.20 16.20 - 26.20 GWTP Property, NE corner of cap Located on cap

2;7.', cv.;:3b.,', '2';: :i6~:s'f ~5'85' 3565:' 4505 p,cG~~rkl~gIOFNWD~ildj~gcbr~g;;,i\; f;,!; 'f I' .. ;',8 CW·31

.'~. ,; t'W-3S'2" 303.66 19.10 14.10 - 19.10 PCG parking lot, NW building corner

,\2'" 363~~~'15~~0' 15.60 ~2df,~~k;'~al;;i:;N'VVb~ildi~(,'~~i~['?;;'.;': {; ;

.' .

NE buildinQ:~46.75 ~50 PCG parkin

26.90',,33.90 IPC

16 CW·60 2" 299.97

,n, {;;1,lz';1 ~9~'~~

10 CW-40 2" 304.29 49.25 39.25 - 49.25 PCG property SW building corner

11 ~E44i Sgci 2430 -'3430 ~'8~~id~~it;/~Wfj~j!di~gdat~e;;~",' Y~, .'12 CW-4S 2" 304.53 23.02 8.02 - 23.02 PCG property SW buildinQ corner

,j ~2';;'~f~3 '4,530 35.30: 45.jO·I~'~G;~~'t~E)

~...I;~~' CCWW;67S0"" 2" 299.60 ;;;2;~~i;,~50:: ~4~~ PCGp~ner

1-1-=19-4";=-"-'::'_"-\'''-''{I-~--'- 302.90 ll9.60 llO.OO- 50-.00, c;uO~krri6nts'~bs~ii~ii'Prgb;

20 CW-7S 4" 301.74 29.40 2?00 ~ 30:~0, PEco~prop~

121. cw:so'··, ,'~"298.:2653.50. 33.50 "'53.50 Endo~IT,~;,·,:,~~~j~S·.S:.)S'::S··,~sj22 CW-8S 4" 299.11 30.00 20.00 - 30.00 End of Ralston AYe.

24 CW-9S 2" 293.79 35.60 25.60 - 35.60 Rittenhouse Circle (near #453) Installed September 2003


28 CW·11S 2" 276.92 39.70 29.70 - 39.70 Rittenhouse Circle (near #400) Installed September 2003


'\, ) 32 CW-13S 4" 292.01 45.14 33.14 - 45.14 Lawrence Road (between #428 & #432) Installed September 2003

34 CW-14S 2" 320.43 40.55 25.55 - 40.55 Lawrence Road Park behind rowhomes Installed September 2003

Page 1 of 3

)

'\ )

Well-tO

Table 2 Monitoring Wells Construction Details

Comments

2003

Page 1 of 3


I

Well-IDft. top bot.

Comments

38 CW-16S 6" 314.0 55.00 38.0 - 55.0 FormerYouno's Produce Installed March 2005

36"~ cw.ljfr~:{;;2:' 3086 78:00 '62:0' 77.0"'; " . c·. I A

40 CW-18D 2" 302.2 68.00 58.0 - 68.0 SE corner PCG near CW-5S Installed Auaust 2004

41 CW:1stl ··2~: 299.1 ;61:60s~.d~7a:O rearPCGparkinal;;'~~~{CW-6D -1i\1 ':" iii42 CW-20D ~~(1~:2, _6.~.0~;~~.~ ,:~;~. L~:::~;n?e~~a~:i\~~~~e~,~5~~~~~,4~t. ~;o20~0~4~~1

I43 dvtl~o~: ~310.135.UO~ 5.0 Lawrence RoaiJ,betWeeri'#553&#549f'; ~u({u"i2004j;.ci ;-

44 CW-21D 2".2288'.1

1'<.33 ,~~~~~ BB••,aa',cr~kk' eerr":(('#4~~4,.,11)!7R~ii~tt' ee't'n~:h"?'O.>uu....ss..ee.;..rc'~irr;cci:I'ee.)).rreeaa' rr.•c..... :,....'....•,•...••........:. Installed.6J>.riL2005I'45; t~~~1i::·;1:-2~~. ,~u.vv3b.0-4bo'}~;1;

46 CW·22D 2" 295.9 55.00 48.0 - 58.0 rear PCG R.O,W. Installed March 20051>'.-:" "'''1'.> ·2'··9:..7'·.. 0···. '2'8"'.'3"0": ,•. : ...•.",'. 'P",~.... R .•• , ~1·n···s·t"ac:l·l·e··'d·:···J:·a·c···n·;u:.'·a"');·····2··'0'·0'·5'······.·,,·..··.··147, cvv:~~Si;;·H2".·,An:?AQ ,__" __ '"'' i::"'c,:",1 "".

48 CW-23D 2" 314.3 50.00 ,,3~.O ;,.~?'U c' FormerYouna'spr~ Installed March 2005 .

49; CW-246:'.:;:i;l:s:, 315.b50.00 '35.0 -50.0~sr'r~ "'. ~Mar, 200b~

I:~ ~~~i6D I:::::;~:: :~::~~ 35.0 -,::.0 Swiss ::;~ ~:~: RW-4 ':'i;::;'.' Installed&~~~52 CW-28D 6" 310,1 45.00 35.0 - 45.0 Swiss Farm front Installed April 2005

153 C'W:290 :1. 6~j·~10tl4~i66~.0'4b:0 l;ao area rear ~~~ I). irs:!54 CW-30D 6" 311.4 45.00 35.0 - 45.0 Cao area rear of Swiss Farm Installed April 2005

~'55 cw-i1D"j: I~'; 3(r?3~I2d.ool;90:(j~:i2o:o h 'PCG .,:·;·i': Igtt~~~a;561g6~:i'~008!,i./

56 HAV-02 2" 305.70 28.30 18.30 - 28,30 PCG property, outside office entrance Product sheen

57 ti)..Y:04; I~;' 292:62 6.'771~i1i1 CR 77: conne,i(#453Ritt~;;~~'J§e:6iid~)~~~r'i:.~ .... :

58 HAV-OS 2" 292.56 10.05 6.50 - 11.50 Conneli (#453 Rittenhouse Circle) rear Product sheen

60 NW-1-81 4" 306.56

61 N.x;~6~8{::4:' 308:19

26.00

24.00

14.50 - 26.00 Along Eagle Road near GWTP

i4:3b:d;i~o C6~tl;;;nt~1 A~~()p;rt~~iit~~~:;;~~ ~~ad . I,;,.:i( .62 R-2'

63. 0

4" 311.36 29.00

3'14.763383

. 9.~O .: 29:0~';ISWiSSFarm Market near RW-220.33-33:83 . 'Jce:,z

Product: • I ,t.:.'· .•:c

64 MW-10,'"".',_"

'sir IMW~2·::'

2" 283.96 21.65

.j :284.2~ '-id6'4.50 - 24.50 Collection Trench

.' ;.50-11.?O B~f~~d~4f'~iit~nho~seci(cl~)re"r:.::: ii"':'

66 MW-3 2" 301.37 63.00 53.0 - 63.0 PCG behind rear oarkina lot

Page 2 of 3

Converted EW-2 May 2005


Well·ID

56

58

Page 2 of 3


PZ-4 1" 285"60 11.94 nla Collection Trench

Recovery Well(Offline 8/31/05Recovery"W

Piezometer

Piezometer

)

Notes:

* O&M activities include baling of free product in R-2 when product thickness is >1 foot.

ns = not surveyed

Page 3 of 3

)


Well-ID

Notes:

* O&M activities include baling of free product in R-2 when product thickness is >1 faa!.

ns = not surveyed

Page 3 of 3

Comments

'"," ,./ " . ./

Table 3Monitoring Wells Water Level Data

"". v-..... ""

vvv-;.)u"".,\0""::" ..,,,.''''''

297.14 ~=P2Jg"~o~,C::4J~~=~297.11

282.70 279.90 263.50 281.37

290.52 289.01 288.92

P'VN.itQQJ:l"''''''"

290.39 290.40 286.50 289.91 288.83 ,,~~, """ ~~

289.79 I 290.39 I 286.47 I 289.34 I 288.88

2n.55

290.12

290.68 I 290.53 I 286.63 I 290.08 I 289.03

281.29 281.29 280.01 281.29 280.86

288.16 287.79

=.W ~ro ~.OO ~n =.27

=.~ ~~ ~~ =.~ ~OO

274.11 272.64 273.27 273.53 0._,

283.98

291.19

289.35 290.30 290.84 286.41 289.83 288.91

274.85

287.71 289.21 288.56 286.14 288.46 287.44 I\;'~~(I~,':,-~:::' I287.84 288.35 287.81 285.48 288.10

,U"'t.U I LU..J."'tU

ia'1"1''j}E~':;:~

l.UL,..•..,..,..,--.,';(1'\;,,""1:'\.

I: .~~::~ ··1 ·E~:~~ I ~::~:~:J,::==11=

nd = No Data

CW-3S

CW-5D

CW-41

CW'4S "'d'

CW-3D

1~7~V;;;;;~':'~:'T ;'Ui:H: j~~"~:t· '''I "";"'::~''':: :::::'1 "":""j''':;;:~::;'~~''; 'T;,',';' ""''';'';'';:,~:~:~i::iWj;,;,''''';

Table 3 Monitoring Wells Water Level Data

Table 4Non~Routine Operations and Maintenance Activities

-'") January 2008 On 01109108, the backfiow preventers for the potable water and fire service were tested for

their annual inspection by Wayman Fire Protection. Fire extinguishers were mountedproperly inside the building. Three additional mounts were needed.

On 01109108, groundwater samples were collected at RW-5 and CW-24 as part of OU3activities. The samples were picked up by Lehigh Nanotech in order to conduct a benchscale treatability study using nano-iron technology.

On 01114108 thru 01116108, trees, vines, and brush were cut from the fence lines alongEagle Road and Swiss Farms.

February 2008 On 02101108, parking lot had ice from previous night's freezing rain. Salt was spread.

On 02113108, parking iot had ice. Salt was spread.

On 02115108, Applied Control Engineering began working on upgrading existing computerfor a more powerful, faster unit.

On 02118108, mixed Weltone and pumped into the Collection Trench/RW-6 forcemain tohelp with iron buiid-up.

On 02119108 - 02120108, site wide monitoring well levels taken whiie system OFF.

March 2008 On 03/07108, site wide monitoring well levels taken while system ON.

On 03110108 - 03121108, March 2008 Annuai site well sampling conducted. A totai of 72wells sampled for volatiles, semi-volatiies, total and dissolved metals, along with QAlQCsamples. 25 of those wells sampled for DioxinslFurans.

On 03112108, health and safety site inspection was conducted by TtNUS-Newark SafetyOfficer. Report in progress.

On 03114108, a spill pallet was purchased from Grainger and installed under two 15-gallondrums of 23% HCr stored on site. The HCI is diluted for cieaning iron bUild-up and acidwashing sand filter.

April 2008

May 2008

On 04101108, installed new lock-out/tag-out station near office.

On 04102108, replaced well caps and flush mounts on various site monitoring wells. Addedsecurity plugs on RW-1 thru 5. RW-5 hatch still has not been raised in grass area of"Chariees Burgers".

On 04116108, after NPDES sampling, oxidation tanks were compieteiy drained andinspected for sludge build-up. The cross-pipe between tank #2 & #3 was plugging. Thecross-pipes between #1&2 and #2&3 were cleaned, and the mixer in tank #2 was cleanedof sludge bUiid-up. System was restarted in early afternoon.

On 05106108, water suppiy line to toilet was leaking. Plumber called to give estimate.

On 05115108, grass around building and in area of collection trench was cut by operator.The hoses running to CW-29 were coiled and stored, the oil socks and used oil soak wascleaned up around product tank

On 05119108, the hot water heater was found to be leaking. Heater shutoff due to non use.

Page 1 of 4

January 2008

February 2008

March 2008

April 2008

May 2008

Table 4 Non~Routine Operations and Maintenance Activities

01109108, the backfiow preventers for the potable water and fire service were tested for annual inspection by Wayman Fire Protection. Fire extinguishers were mounted

I moo,,,lv inside the building. Three additional mounts were needed.

01109108, groundwater samples were collected at RW-S and CW-24 as part of OU3 The samples were picked up by Lehigh Nanotech in order to conduct a bench

treatability study using nano-iron technology.

01114108 thru 01116108, trees, vines, and brush were cut from the fence lines along Road and Swiss Farms.

02101108, parking lot had ice from previous night's freezing rain. Salt was spread.

02113108, parking lot had ice. Salt was spread.

0211S108, Applied Control Engineering began working on upgrading existing computer a more powerful, faster unit.

02118108, mixed Weltone and pumped into the Collection TrenchlRW-6 forcemain to with iron build-up.

02119108 - 02120108, site wide monitoring well levels taken while system OFF.

03107108, site wide monitoring well levels taken while system ON.

On 03110108 - 03121108, March 2008 Annual site well sampling conducted. A total of 72 I sampled for volatiles, semi-volatiles, total and dissolved metals, along with QAJQC

samples. 2S of those wells sampled for DioxinslFurans.

On 03112108, health and safety site inspection was conducted by TtNUS-Newark Safety Officer. Report in progress.

On 03114108, a spill pallet was purchased from Grainger and installed under two 1S-gallon drums of 23% HCI stored on site. The HCI is diluted for cleaning iron build-up and acid

Iw"shino sand filter.

On 04101108, installed new lock-outltag-out station near office.

On 04102108, replaced well caps and flush mounts on various site monitoring wells. Added Ise,ouriltvplugs on RW-1 thru S. RW-S hatch still has not been raised in grass area of 1"r.h~,·IA'!. Burgers".

On 04116108, after NPDES sampling, oxidation tanks were completely drained and inspected for sludge build-up. The cross-pipe between tank #2 & #3 was plugging. The

Icn,ss-piil,es between #1&2 and #2&3 were cleaned, and the mixer in tank #2 was cleaned sludge build-up. System was restarted in early afternoon.

On 05106108, water supply line to toilet was leaking. Plumber called to give estimate.

On OS115108, grass around building and in area of collection trench was cut by operator. hoses running to CW-29 were coiled and stored, the oil socks and used oil soak was

cleaned up around product tank

On OS119108, the hot water heater was found to be leaking. Heater shutoff due to non use.

Page 1 of 4

May 2008

June 2008

July 2008

Table 4Non-Routine Operations and Maintenance Activities

On OS/28/08, site wide monitoring well levels taken while system OFF.

On 06/16/08-06/17/08, performed quarterly well sampling at CW-21 S, CW-21 D, CW-22S,CW-22D, HAV-07, MW-1, MW-2, and HAV-05.

On 06/19, 06/27, and 06/30/08, grass around the piant building was cut.

On 06/24/08, Mardinly Enterprises was onsite to investigate the leaking Hydraulic fluidfrom the filter press in order to prepare a quotation of services. On 06/26/08, Hydraulicindustriai Supplies Co. was onsite to do the same.

On 07/09/08, draining oxidation tanks and clarifier in order to investigate cross-pipes.Cross-pipes between oxidation tanks 1 & 2 and 2 & 3 were clear. Sludge was built up inthe bottom of ox tank #3 around discharge. Sludge was cieared and cross-pipe betweenox tank #3 and clarifier was brushed and cleared. Floc chamber and lamella plates inclarifier were hosed out.

On 07/11, grass was cut around plant building, rear storage yard and in trench area.

On 07/14/08, Waste Recovery Solutions was onsile to take soil samples from underparking lot asphalt in vicinity of new addition footers. Four locations were sampled to -4feet deep for VOC/SVOC/Pesticides&PCBs. Each location was hand augured to avoidU/G utilities.

\)

August 2008 Grass cutting by operator is ongoing.

On 08/13 and 08/14/08, the plant was shutdown for 3 hours each day during whichcontractors were onsite for pre-bid meetings for the pre-treatment modifications.

September 2008 On 09/03/08, RW-5 was shutdown in the morning for a modified pump test at CW-17 foran OU3 task.

On 09/18/08, plant was shutdown for maintenance. Cleaned Oil-Water Seperator,replaced gasket on OWS suction pump flanged gasket, and cleaned the sand filterbutterfly valves.

On 09/22/08, site wide monitoring well levels taken while system OFF.

On 09/22/08, grass was cut by operator.

On 09/29/08 - 09/30/08, semi-annual well sampling conducted. The following wells weresampled for SVOC only: CW-10D, CW-13D, CW-17D, CW-20S, CW-20D, CW-21S, CW210, CW-22S, CW-23D, CW-24D, CW-26D, CW-27D, HAV-07, MW-1, MW-2, NW-06,and RW-5.

October 2008 On 10/01, 10/02, and 10/09/08, semi-annual well sampling continued.

On 10/10/08, grass was cut by operator.

On 10/15/08, electrician completed installation of new MCC section. Over remainingweeks of October electrician identified various electrical conduits.

Page20f4

June 2008

July 2008

August 2008

Table 4 Non-Routine Operations and Maintenance Activities

06/16/08-06/17/08, performed quarterly well sampling at CW-21 S, CW-21 D, CW-22S, I'-"'V-"-"-U, HAV-07, MW-1, MW-2, and HAV-OS.

06/19, 06/27, and 06/30108, grass around the plant building was cut.

06/24/08, Mardinly Enterprises was onsite to investigate the leaking Hydraulic fluid the filter press in order to prepare a quotation of services. On 06/26/08, Hydraulic

IIIHlUS1,"a,1 Supplies Co. was onsite to do the same.

07/09/08, draining oxidation tanks and clarifier in order to investigate cross-pipes. I(.;ros"-pllpes between oxidation tanks 1 & 2 and 2 & 3 were clear. Sludge was built up in

bottom of ox tank #3 around discharge. Sludge was cleared and cross-pipe between tank #3 and clarifier was brushed and cleared. Floc chamber and lamella plates in

IcI,,,ifi,.rwere hosed out.

07/11, grass was cut around plant building, rear storage yard and in trench area.

07/14/08, Waste Recovery Solutions was onsite to take soil samples from under r nn,"',," lot asphalt in vicinity of new addition footers. Four locations were sampled to -4

deep for VOC/SVQC/Pesticides&PCBs. Each location was hand augured to avoid U/G utilities.

cutting by operator is ongoing.

On 08/13 and 08/14/08, the plant was shutdown for 3 hours each day during which contractors were onsite for pre-bid meetings for the pre-treatment modifications.

September 2008 On 09/03/08, RW-S was shutdown in the morning for a modified pump test at CW-17 for an OU3 task.

October 2008

On 09/18/08, plant was shutdown for maintenance. Cleaned Oil-Water Seperator, replaced gasket on OWS suction pump flanged gasket, and cleaned the sand filter butterfly valves.

09/22/08, site wide monitoring well levels taken while system OFF.

09/22/08, grass was cut by operator.

On 09/29/08 - 09/30108, semi-annual well sampling conducted. The following wells were IsarnDI"d for SVOC only: CW-10D, CW-13D, CW-17D, CW-20S, CW-20D, CW-21S,

, CW-22S, CW-23D, CW-24D, CW-26D, CW-27D, HAV-07, MW-1, MW-2, NW-06, RW-5.

10101,10102, and 10109/08, semi-annual well sampling continued.

10/10108, grass was cut by operator.

10/15108, electrician completed installation of new MeC section. Over remaining of October electrician identified various electrical conduits.

Page20f4

\ )


\ October 2008 On 10/21/08, began removing dirty sand from sand fiiter, Art from ACE worked on RW-6program setpoint. Got programming to work so that pump shuts off at 5' above inlet andcomes on after 15 minutes, Observed that pump drew down to inlet rapidly, Well screenmay be plugging with iron, Will add this to cleaning of collection trench sump andforcemain work.

On 10/22/08, washed solids out of sand and separated, Added 150 Ibs clean sand andremainder of washed sand (-850 Ibs) back into unit. aid dirty sand (-500 Ibs) was placedinto sludge container, Recycled water in filter to further wash sand,

Beginning on 10/24/08, various clean-up efforts were begun inside plant in preparation ofplant modifications, All loose equipment and shelving was moved into the steel containerand on top of the office roof,

November 2008 On 11/04/08, the cargo shed was organized so that loose items could be moved into itfrom plant. Area above office was cleaned and shelves organized,

On 11/06/08, Wastewater tank was opened and cleaned of -4" of sludge

On 11/10/08, the pre-treatment system was shutdown and cleaning of tanks begun. Thisincluded EO tanks, oxidation tanks, clarifier, and sand filter. Dirty water with sludge solidswas pumped to the sludge holding tank so that the solids could be pressed. Rayox andGAC system continued to treat water.

On 11/10/08, Oil-Water Separator was drained and cleaned. Equalization tanks openedand inspected. ApproXimately 2' of mud and sand is In Tank #2. Less in Tank #1.

)

)

December 2008

On 11/11/08, sand filter dumped and piping dismantled between clarifier and sand filter.

On 11/12/08, Oxidation tanks were cleaned of slUdge.

On 11/13/08, Waste Recovery Solutions onsite to vacuum slUdge from equalization tanks,wastewater waste tank, clarifier, and floor sump. Sludge was transferred to sludge holdingtank for filter pressing.

On 11/13/08 and 11/14/08, pipe dismantling and finai cleaning of clarifier.

On 11/14/08, contractor began dismantling oxidation tank mezzanine.

During week of 11/17/08, contractor removed all structures and tanks related to thepretreatment system.

On 11/19/08, the concrete footers were poured for the new building addition.

On 11/21 and 11/22/08, equipment pads inside the building were constructed.

On 11/25/08, clarifier and pressure filters were delivered to the site.

On 11/27/08 peroxide tank and pump skid was moved back into building and positioned innew location.

On 12102/08, pressure filters and clarifier were moved into building and positioned on newpads. Steel oxidation tank mezzanine returned inside also. Frac tank was delivered inorder to pump remaining water in wastewater tank and for unloading GAC unit PV-2.

On 12/03/08, Waste Recovery Solutions was onsite to vacuum carbon from GAC PV-2,Six, 1-yd cardboard boxes were filied with spent carbon, Dismantled waste PVC pipeswere cut up and filled one additional box,

Page 3 of 4

)

)


began removing dirty sand from sand I I pnogr·am setpoin!. Got programming to work so that pump shuts off at 5' above inlet and

on after 15 minutes. Observed that pump drew down to inlet rapidly. Well screen be plugging with iron. Will add this to cleaning of collection trench sump and

Iforcenlain work.

10/22/08, washed solids out of sand and separated. Added 150 Ibs clean sand and Ireillaiind,,, of washed sand (-850 Ibs) back into uni!. Old dirty sand (-500 Ibs) was placed

sludge container. Recycled water in filter to further wash sand.

I B"airmirlO on 1 0/24/08, various clean-up efforts were begun inside plant in preparation of modifications. All loose equipment and shelving was moved into the steel container

and on top of the office roof.

November 2008 On 11/04/08, the cargo shed was organized so that loose items could be moved into it from plant. Area above office was cleaned and shelves organized.

December 2008

On 11/06/08, Wastewater tank was opened and cleaned of -4" of sludge

On 11/10/08, the pre-treatment system was shutdown and cleaning of tanks begun. This included EQ tanks, oxidation tanks, clarifier, and sand filter. Dirty water with sludge solids

pumped to the sludge holding tank so that the solids could be pressed. Rayox and GAC system continued to treat water.

On 11/10/08, Oil-Water Separator was drained and cleaned. Equalization tanks opened and inspected. Approximately 2' of mud and sand is in Tank #2. Less in Tank #1.

On 11/11/08, sand filter dumped and piping dismantled between clarifier and sand filter.

On 11/12/08, Oxidation tanks were cleaned of sludge.

On 11/13/08, Waste Recovery Solutions onsite to vacuum sludge from equalization tanks, Iw"st"w.,terwaste tank, clarifier, and floor sump. Sludge was transferred to sludge holding

for filter pressing.

On 11/13/08 and 11/14/08, pipe dismantling and final cleaning of clarifier.

On 11/14/08, contractor began dismantling oxidation tank mezzanine.

During week of 11/17/08, contractor removed all structures and tanks related to the pretreatment system.

11/19/08, the concrete footers were poured for the new building addition.

11/21 and 11/22/08, equipment pads inside the building were constructed.

11/25/08, clarifier and pressure filters were delivered to the site.

11/27/08 peroxide tank and pump skid was moved back into building and positioned in location.

12102/08, pressure filters and clarifier were moved into building and positioned on new Steel oxidation tank mezzanine returned inside also. Frac tank was delivered in

to pump remaining water in wastewater tank and for unloading GAC unit PV-2.

12/03/08, Waste Recovery Solutions was onsite to vacuum carbon from GAC PV-2. , 1-yd cardboard boxes were filled with spent carbon. Dismantled waste PVC pipes

cut up and filled one additional box.

Page 3 of 4


December 2008 On 12/03/08, Oxidation tanks #1,2, and new #3 were placed onto mezzanine. Catwalkwas reinstailed.

On 12/04/08, spent carbon and waste pipe was picked up by FCI (sub to Waste Recovery)and transported to Ross Environmental at Grafton, Ohio facility as F032 waste forincineration.

On 12/04/08, PECO onsite to look at moving of gas meter.

Contractor began repiacing existing ASS airline with galvanized steel pipe.

On 12/10/08 grounding grid wire was reconnected.

On 12/12/08, new building foundation wails started.

On 12/15/08, inside piping worked commenced. Groundwater was pumped out ofManholes MH-1, 2, & 3 and Valve Vault VP-2 in order to es-built piping.

From 12/15 thru 12/26108, contractor continued instailing new equalization pumps, Rayox'pumps, clarifier sludge pumps and associated piping.

Page 4 of4

\

)

)


12/04/08, spent carbon and waste pipe was picked up by FCI (sub to Waste Recovery) transported to Ross Environmental at Grafton, Ohio facility as F032 waste for

12/04/08, PECO onsite to look at moving of gas meter.

Contractor began replacing existing ASS airline with galvanized steel pipe.

12/10108 grounding grid wire was reconnected.

On 12/12/08, new building foundation walls started.

On 12/15/08, inside piping worked commenced. Groundwater was pumped out of Manholes MH-1, 2, & 3 and Valve Vault VP-2 in order to as-built piping.

From 12/15 thru 12/26108, contractor continued installing new equalization pumps, Rayox' pumps, clarifier sludge pumps and associated piping.

Page 4 of4

\

)

)

Table 5Difficulties Encountered / Corrective Action

)

January 2008

February 2008

March 2008

On 01/04/08, upon RayOx system restart, Unit #2 exhaust fan failed.- Action: On 01/05/08, replaced RayOx Unit #2 fan by using fan from Unit #1.

In 12/18/07 NPDES plant sample, Manganese exceeded MCl of 600 ug/l, Aluminumexceeded MCl of 720 ug/l, and Cobalt almost exceeded MCl of 106 ug/l .

- Action: RayOx influent pH probe replaced on 01/04/08.- Further Action: Plant effluent resampled on 01/09/08 at local lab for Total Metals.+ Result: The data received on 01/10/08 had aluminum and cobalt at non-detect, however,

manganese exceeded MCl with value of 680 uglL. The 01/15/08 NPDES sample formanganese was below the MCL.

On 01/18/08, sand filter investigated for continual plugging.- Action: Sand filter bypassed, half the sand was removed in the bottom and the bottom andinlet were air lanced. Sand returned and placed back online.

On 02/14/08, attempted to reinstall existing polymer mixer motor but there was internaldamage. Notified EPA for various options to replace the polymer system.

- Action: Due to the extra expense of a new motor and delays in shipping it was decided toreplace existing PolyMixer system with a more efficient and maintenance free unit. Thesystem was ordered with delivery by 02/21/08.

On 02/28/08, various compounds in the plant effluent exceeded the maximum allowableNPDES limits. PCP, MCl of 1.0 ug/l (11 ug/l SVSIM and 4.6 ug/l diluted); Dioxin, MCl of4.4 ppq (12.48 ppq); Iron, MCl of 1000 ug/l (1000 ug/l); and Manganese, MCl of 600 ug/l(626 ug/l).- Action: Plant effluent resampled on 03/04108 for SVOC.

On 03/04/08, plant effluent resampled for SVOC due to exceedances in 02/28/09 sample.+ Result: The Preliminary SVOC flex clause data was received on 03/10108. The effluent

PCP again exceeded the MCl of 1.0 ug/l (11 ug/l SVSIM and 5.0 ug/l diluted). On03/07/08, the VOC/SVOC data for the plant influent, RayOx Influent and RayOx Effluent wasreceived. The PCP was NO (non-detect) at the RayOx effluent.

- Action: PCP is being released either from PDU or GACs. Investigated a carbon release inthe effluent tank that may be "washing" out of GAC.

-- Additional action: On 03/14/08, extra SVOC samples were taken from RayOx effluent,PDU effluent, GAG PV-1 effluent, GAC PV-2 effluent, and plant effluent in order to pin-pointwhere problem is occurring.

--- Additional Action: On 03/14/08, Iron and Manganese were sampled at various locationsusing the inhouse Hach sampler kit: Sand Filter: Mn=0.04ppm; Fe=0.06ppm; PDU effluent:Mn=0.33ppm; Fe=0.10ppm; GAC PV-1 effluent: Mn=0.65ppm; Fe=0.06ppm (Mn exceedspermit of 0.6mg/l); GAC PV-2 effluent: Mn= 0.37ppm; Fe=0.09ppm; Plant effluent:Mn=0.66ppm; Fe=0.03ppm (Mn exceeds permit of 0.6mg/l).

On 03/18/08, the validated data report was received from ASQAB for Oil & Grease and TotalPhenol samples taken on 02/28/08. The narrative read as follows: A dark material wasobserved floating in the effluent sample. Since the post spike (PS) was in control it wasbelieved that activated charcoal in the effluent scavenged the phenol added prior todistillation thus lowering the % recovery of the matrix spike." Apparently, activated carbonmay have passed into the effluent tanks from the GAC. This may explain the exceedancesoccurring in February PCP, Dioxin, Iron, and Manganese.

Page 1 of 3

January 20.0.8

February 20.0.8

)

March 20.0.8

Table 5 Difficulties Encountered I Corrective Action

On 0.1/0.4/08, upon RayOx system restart, Unit #2 exhaust fan failed. - Action: On 0.1/0.5/0.8, replaced RayOx Unit #2 fan by using fan from Unit #1.

In 12/18/0.7 NPDES plant sample, Manganese exceeded MCl of 60.0. ug/l, Aluminum exceeded MCl of 720. ug/l, and Cobalt almost exceeded MCl of 10.6 ug/l .

- Action: RayOx influent pH probe replaced on 0.1/04/0.8. - Further Action: Plant effluent resampled on 0.1/0.9/0.8 at local lab for Total Metals. + Result: The data received on 0.1/10.108 had aluminum and cobalt at non-detect, however,

mann:.nF'~" exceeded MCl with value of 680. uglL. The 0.1/15/0.8 NPDES sample for manganese was below the MCL.

0.1/18/0.8, sand filter investigated for continual plugging. - Action: Sand filter bypassed, half the sand was removed in the bottom and the bottom and

were air lanced. Sand returned and placed back online.

0.2/14/0.8, attempted to reinstall existing polymer mixer motor but there was internal I dama,ge .. Notified EPA for various options to replace the polymer system.

- Action: Due to the extra expense of a new motor and delays in shipping it was decided to 1 r""I",·" existing PolyMixer system with a more efficient and maintenance free unit. The I~v~tplm was ordered with delivery by 0.2/21/0.8.

On 0.2/28/0.8, various compounds in the plant effluent exceeded the maximum allowable NPDES limits. PCP, MCl of 1.0. ug/l (11 ug/l SVSIM and 4.6 ug/l diluted); Dioxin, MCl of 4.4 ppq (12.48 ppq); Iron, MCl of 100.0. ug/l (100.0. ug/l); and Manganese, MCl of 60.0. ug/l (626 ug/l). - Action: Plant effluent resampled on 0.3/0.4108 for SVOC.

On 0.3/0.4/0.8, plant effluent resampled for SVOC due to exceedances in 0.2/28/0.9 sample. + Result: The Preliminary SVOC flex clause data was received on 0.3/10.108. The effluent

PCP again exceeded the MCl of 1.0. ug/l (11 ug/l SVSIM and 5.0. ug/l diluted). On 0.3/0.7/0.8, the VOC/SVOC data for the plant influent, RayOx Influent and RayOx Effluent was received. The PCP was NO (non-detect) at the RayOx effluent.

- Action: PCP is being released either frorn PDU or GACs. Investigated a carbon release in the effluent tank that may be "washing" out of GAC.

-- Additional action: On 0.3/14/0.8, extra SVOC samples were taken from RayOx effluen~ PDU effluent, GAG PV-1 effluent, GAC PV-2 effluent, and plant effluent in order to pin-point

Iwh"rp problem is occurring. --- Additional Action: On 0.3/14/0.8, Iron and Manganese were sampled at various locations

using the inhouse Hach sampler kit: Sand Filter: Mn=D.D4ppm; Fe=0.D6ppm; PDU effluent: Mn=D.33ppm; Fe=D.1Dppm; GAC PV-1 effluent: Mn=D.65ppm; Fe=D.D6ppm (Mn exceeds permit of D.6mg/l); GAC PV-2 effluent: Mn= D.37ppm; Fe=D.D9ppm; Plant effluent: Mn=D.66ppm; Fe=D.D3ppm (Mn exceeds permit of D.6mg/l).

On 0.3/18/0.8, the validated data report was received from ASQAB for Oil & Grease and Total Phenol samples taken on 0.2/28/0.8. The narrative read as follows: A dark material was observed floating in the effluent sample. Since the post spike (PS) was in control it was believed that activated charcoal in the effluent scavenged the phenol added prior to distillation thus lowering the % recovery of the matrix spike." Apparently, activated carbon may have passed into the effluent tanks from the GAC. This may explain the exceedances

in February PCP, Dioxin, Iron, and Manganese.

Page 1 of 3


March 2008

April 2008

May 2008

June 2008

July 2008

On 03/20/08, programmer was called to troubleshoot data problems in Graphworks trendingprogram. Data was sporadic and not continuous. Problem was found in PlC processor.When programmer tried to reboot processor it failed.

- Action: New processor was ordered immediately. A rebuilt processor was bought fromTecot and delivered via FedEx next day.

On 03/26/08, Dioxin validated data for February NPDES was received and there was anexceedance in the plant effluent. The result was 12.8 ppq. MCl is 4.4 ppq. This is probablydue to the carbon in effluent tank.

None

On OS/21/08, the clarifier was overflowing due to sand filter plugging. The water hadsplashed onto the polymer system causing a "short" in the polymer system power receptacleand a blown fuse in the control box. Electrician was called to fix the receptacle andtroubleshoot the fuse issue.

On OS/23/08, the polymer system was not working again. The fuse was blown again butreceptacle was still working. The fuse was replaced but the system would not power on. Theelectrician was called and diagnosed that the water supply solenoid valve had a "burnt" coil.The plant had to be shut down until another coil is purchased. The system had to remaindown until 5/28/08. \

)

On OS/28/08, parts arrived for polymer system. Coil was replaced but electrician found thatthe wiring had been damaged as well. A new wire had to be ordered. System still down.

On OS/29/08, polymer solenoid valve bypassed and system being run in manual mode. lowflow issues developed in RayOx pumps.

On 05/30/08, new polymer parts arrived and installed. Polymer system back online, butRayOx pumping at lower flowrate (15-20 gpm).

Michael Seeds landscaping has been contacted numerous times to cut the grass in EPAareas because of infrequent cutting and lack of schedule. Tetra Tech has been cutting thegrass to maintain a two week cutting interval. Seeds also has not provided a formal quotefor services. In meantime, Dougherty landscape has provided a quotation for landscapingservices.

On 07/10/08, the system had shutdown during evening of 07/09 due to overflowing ofoxidation system. The tanks were again drained as well as clarifier. The cross-pipebetween ox tank #3 and clarifier was removed and inspected and cleaned. Sludge -1' thickwas in bottom of flash mixer. This was cleared out and cross-pipe reinstalled and systemplaced back online.

On 07111108, after system had been online a couple hours the oxidation tanks began tooverflow again. There was no flow thru the clarifier.

Page 2 of3

March 2008

April 2008

May 2008

June 2008

July 2008

Table 5 Difficulties Encountered I Corrective Action

03/20/08, programmer was called to troubleshoot data problems in Graphworks trending program. Data was sporadic and not continuous. Problem was found in PlC processor. When programmer tried to reboot processor it failed.

- Action: New processor was ordered immediately. A rebuilt processor was bought from Tecot and delivered via Fed Ex next day.

On 03/26/08, Dioxin validated data for February NPDES was received and there was an exceedance in the plant effluent. The result was 12.8 ppq. MCl is 4.4 ppq. This is probably due to the carbon in effluent tank.

None

On 05/21/08, the clarifier was overflowing due to sand filter plugging. The water had splashed onto the polymer system causing a "short" in the polymer system power receptacle and a blown fuse in the control box. Electrician was called to fix the receptacle and troubleshoot the fuse issue.

On 05/23/08, the polymer system was not working again. The fuse was blown again but receptacle was still working. The fuse was replaced but the system would not power on. The electrician was called and diagnosed that the water supply solenoid valve had a "burnt" coil. The plant had to be shut down until another coil is purchased. The system had to remain down until 5128108. \

On 05/28/08, parts arrived for polymer system. Coil was replaced but electrician found that wiring had been damaged as well. A new wire had to be ordered. System still down.

05/29/08, polymer solenoid valve bypassed and system being run in manual mode. low issues developed in RayOx pumps.

On 05/30/08, new polymer parts arrived and installed. Polymer system back online, but RayOx pumping at lower flowrate (15-20 gpm).

I Michael Seeds landscaping has been contacted numerous times to cut the grass in EPA because of infrequent cutting and lack of schedule. Tetra Tech has been cutting the to maintain a two week cutting interval. Seeds also has not provided a formal quote

In meantime, Dougherty landscape has provided a quotation for landscaping

07/10/08, the system had shutdown during evening of 07/09 due to overflowing of 10)dd1ltiion system. The tanks were again drained as well as clarifier. The cross-pipe between ox tank #3 and clarifier was removed and inspected and cleaned. Sludge -1' thick

in bottom of fiash mixer. This was cleared out and cross-pipe reinstalled and system I pla,ced back online.

07111108, after system had been online a couple hours the oxidation tanks began to In"'~rfllnw again. There was no flow thru the clarifier.

Page 2 of3

)

\ /


July 2008 On 07/14/08, oxidation tank and clarifier water levels lowered again. The lamella plateswere investigated for blockage. In the flash mixer, again thick sludge was found and clearedout. This opened up flow into the clarifier. System placed back online.

On 07/15/08, oxidation tanks found overflowing when operator arrived. Water level waslowered in oxidation tank #3 again and "chunks" of hardened sludge found blocking the tankdischarge. All sludge was scraped off tank sidewalls and removed (-six 5 gallon buckets).System placed back online.

On 07/17/08, due to continuing flow through problems with the oxidation system, tanks #2 &#3 were completely drained and all sludge coating the walls and floor of the tanks wasscraped off and taken out by five gallon buckets. Approximately 5 buckets were removedfrom tank #2 and 25 buckets were removed from tank #3. The system was placed backonline and flow has returned to normal.

August 2008 None

September 2008 None

October 2008 None

)November 2008 None

December 2008 None

\)

Page 3 of3

\ July 2008

August 2008

September 2008

October 2008

) November 2008

December 2008

\)

Table 5 Difficulties Encountered 1 Corrective Action

On 07/14/08, oxidation tank and clarifier water levels lowered again. The lamella plates were investigated for blockage. In the flash mixer, again thick sludge was found and cleared out. This opened up flow into the clarifier. System placed back online.

On 07/15/08, oxidation tanks found overflowing when operator arrived. Water level was lowered in oxidation tank #3 again and "chunks" of hardened sludge found blocking the tank discharge. All sludge was scraped off tank sidewalls and removed (-six 5 gallon buckets). System placed back online.

On 07/17/08, due to continuing flow through problems with the oxidation system, tanks #2 & were completely drained and all sludge coating the walls and floor of the tanks was

scraped off and taken out by five gallon buckets. Approximately 5 buckets were removed tank #2 and 25 buckets were removed from tank #3. The system was placed back

lonllne and flow has returned to normal.

None

None

None

None

None

Page 3 of3

Jan 2008 16 90 14 230 1700 11 500

Mar 2008 24 157 17 260 1900 9.3 219

m~p1!ig"Q9,~~~~~!~[~!m~ii

Date

Table 6Major Contaminants in Plant Influent

Jan. 2008 to Dec. 2008

Benzene I BTEX -I Trlchloroethene -1- Naphthalene I· pentachlorOPhenol·l- Phenanth-..~1 Dioxlns/Furans 1 lron- 1 Manganesefua/L) fUJ:j/Ll fuq/Lj {uq/U {uQ/U fuqlLl TEO ( ppq) (uJ:j/Lj (uJ:jfLj

16 86 10 230 2600 11 312 13500 9340

I

I

Arsenic

~9.1

13

Jul2008 16 84 11 150 2000 10 180 13200 9320

Sep 2008 11 54 12 210 2100 7.8 359 13700 9690

;;";i'c2M~::~:~p'q~j:H!gITj~::i:" mm!imm~ :Hm~1,gJl::::N~1~i~i:!i_~

2002·2008 Low 1.8 3.9 0 0.15 1800 6970 0

NS NS NS NS NS NS NS NS

2008 Average I 16 I 89 1 12 I 238 I 2490 I 10 I 280 I 20170 I 10059 I 9.22007 Average 14 99 12 280 2948 10 38 14925 10680 13

2005 Average 11 61 14 98 3382 5.3 135 8668 10253 4.2

".""" -!:?Q_~:'A~~g~iiii):iii',

NS=notsampled0= ND (Not Detected)* Treatment plant was shutdown during November and December 2008 due to modifications and upgrades in the Pre-treatment system.

\'-............- "--"/

0= ND (Not Detected)

Table 6 Major Contaminants in Plant Influent

Jan. 2008 to Dec. 2008

* Treatment plant was shutdown during November and December 2008 due to modifications and upgrades in the Pre-treatment system.

"---_/

Table 7Major Contaminants in Recovery Wells and Collection Trench

Jan. 2008 to Dec. 2008RW·1 (Offline 3/27/06 • No Samples)RW·2 (Offline 12121/05· No Samples)RW..J (Offline 3/28/06 • No Samples)RW-4 (Offline 8/31/05· No Samples)

NSi:,jjm~:m,i:1l~oi),:'

12300

,-_./

Collection Trench

NS = not sampledo = ND (Not Detected)* Treatment plant was shutdown during November and December 2008 due to mo~ifications and upgrades in the Pre-treatment system.

RW·1 (Offline 3/27/06 • No Samples) RW·2 (Offline 12/21/05· No Samples) RW..J (Offline 3/28106 • No Samples) RW4 (Offline 8/31/05· No Samples)

NS = not sampled o = ND (Not Detected)

Table 7 Major Contaminants in Recovery Wells and Collection Trench

Jan. 2008 to Dec. 2008

* Treatment plant was shutdown during November and December 2008 due to mo~ifications and upgrades in the Pre-treatment system.

'- ./

ND =Not Detected* A revised NPDES permit, as approved by PACEP on 512105, allowed the following: reduction in the frequency of plant effluent sampling to once a month; change the effluent sampling method from composite to grab;increase the manganese limit from 50 ug/L to 300 uglL (average) an,d 100 ug/L to 60Q,ugfL (maximum); increase the Total Iron limit from 300 ugfL to 500 ug/L (average) and 600 ug/L to 1000 ug/L (maximum); andeliminate sampling requirements for Dissolved fron.** Treatment plant was shutdown dunng November and December 2008 due to mocflfications and upgrades in the Pre-treatment system.

Table 8Plant Effluent Data

Jan. 2008 tb Dec. 2008

Date I Benzene BTEX Trichloroethene Naphthalene Pentachlorophenol Phenanthrene Dioxins/Furans Iron

t

Manganese

t

Arsenic(ugIL) (ugIL) (ugIL) (ugIL) (ugIL) (ugIL) TEQ (ppq) (ugIL) (ugIL) (ugIL)

2008 T NO NO NO NO NO NO 2.76 NO 89 NO

NC NO NO NO I 0.34 I NO 0.66 89 159 --I- NO

NO NO NO

~0.97 NO «i 38 89

NC NO NO NO 204 "I NO

Sep 2008 I NO ~ NO I NO _L NO 0.4 ~ NO 0.14 ~ 30 ~ 137 ~ NO

'--.....~"

Date Benzene

(uglLI BTEX (uglL(

Trichloroethene (ugIL)

Naphthalene (ugIL)

Table 8 Plant Effluent Data

Jan.2008tbDec.2008

Pentachlorophenol (ugIL)

Phenanthrene (ugIL)

Dioxins/Furans TEQ (ppq)

Iron (ugIL)

Manganese (ugIL)

* A revised NPDES permit, as approved by PACEP on 512105, allowed the following: reduction in the frequency of plant effluent sampling to once a month; change the effluent sampling method from composite to grab; increase the manganese limit from 50 ug/L to 300 uglL (average) an,d 100 ug/L to 60Q.ugfL (maximum); increase the Total Iron limit from 300 ugfL to 500 ug/L (average) and 600 ug/L to 1000 ug/L (maximum): and eliminate sampling requirements for Dissolved fron. ** Treatment plant was shutdown during November and December 2008 due to modifications and upgrades in the Pre-treatment system.

Arsenic (ugIL)

~. ~.~"-----/

Table 9aUnit Process Performance Data

UV/OX • Organics RemovalJan. 2008 to Dec. 2008

3=~o~a~.~ INF EFF

Feb 2008 NO 140

Apr 2008 #2/1122 NO 99 300 93

Jun 2008 #2/2168 19 14 NO NO 110 73 200 180

#2/611 9.8 1.4 NO 73 47

Oct 2008 #2/1747 7.4 10 NO NO 40 59 ND

Dec 2008 * NS NS NS

NS

0.05

0.06

0.06

NSNSNS

NO

NSNSNSDec200S" I NS I NS I NS I NS I NS I NS I N$

Date Lam No.fHours INF

#2/1122 1400

NO ~ Not Detected

NS· Not SampledINF "'" Plant Influent

UV IN = RayOx InfluentUV OUT = RayOx EffluentEFF = Plant Effluent

ug/L =micrograms per liter or parts per billion (ppb)pq/L = picograms per liter or parts per quadrillion (ppq)* Treatment plant was shutdown during November and December 2008 due to modifications and upgrades in the Pre-treatment system.

ND ~ Not Detected NS· Not Sampled INF '" Plant Influent UV !N = RayOx Influent UV OUT = RayOx Effluent EFF = Plant Effluent ug/L = micrograms per liter or parts per billion (ppb) pq/L = picograms per liter or parts per quadrillion (ppq)

Benzene (ug/L)

Table 9a Unit Process Performance Data

UV/OX • Organics Removal Jan. 2008 to Dec. 2008

BTEX (ug/L)


Trichloroethene (uglL)

Chloroform (ug/L)

Table 9bUnit Process Performance Data

Pre-Treatment System - Metals RemovalJan. 2008 to Dec. 2008

Iron(ug/L)

CLE I SFE351 I 106

Dissolved Iron(ug/L)

CLE I SFE19 I 20

Dissolved Manganese(ug/L)

CLE I SFE55 I 13

NS - Not Sampled

ND - Not DetectedINF =Plant InfluentCLE =Clarifier Effluent

SFE =Sand Filter EffluentEFF =Plant Effluentug/L =micrograms per liter or parts per billion (ppb)

• Treatment plant was shutdown during November and December 2008 due to modifications and upgrades in the Pre-treatment system.

~ ~j

NS - Not Sampled

ND - Not Detected INF = Plant Influent CLE = Clarifier Effluent

SFE = Sand Filter Effluent EFF = Plant Effluent

Table 9b Unit Process Performance Data

Pre-Treatment System - Metals Removal Jan. 2008 to Dec. 2008

ug/L = micrograms per liter or parts per billion (ppb) • Treatment plant was shutdown during November and December 2008 due to modifications and upgrades in the Pre-treatment system.

,--/

Table 9cPlantwide Process Performance Data

Oil Grease, Total Phenols, AnionsJan. 2008 to Dec. 2008

"---_/

NPDESMDL nfa nfa nfa nfa nfa nfa nfa

NS - Not SampledND M Not DetectedlNF = Plant InfluentOWE =OillWater Seperator EffluentEFF = Plant Effluentug/L =micrograms per liter or parts per billion (ppb)mglL = milligrams per liter or parts per million (ppm)* Treatment plant was shutdown during November and December 2008 due to modifications and upgrades in the Pre-treatment system.

NS - Not Sampled

ND - Not Detected lNF = Plant Influent OWE = OillWater Seperator Effluent EFF = Plant Effluent ug/L = micrograms per liter or parts per billion (ppb) mg/L = milligrams per liter or parts per million (ppm)

Table 9c Plantwide Process Performance Data

Oil Grease, Total Phenols, Anions Jan. 2008 to Dec. 2008


WellLocation

'"'"'"_170CW-16DCW_190CW_20SCW-20DCW_219CW-21DCW-22SCW_22DCW-23DCW-24DCW_25DCW_25DCW-27DCW_28DCW_29DcW-JoDCW-J1D.ND- Not Deteoted

Table 10Historical Contaminant Concentration. In Monitoring Wells

."'"11.646

0.0060.6410.0120.0130.266

7200 0.026 5100INSTAL EOOCTO R2006

Table 10 Hlslorlcal Contaminant Concentration. In Monitoring Wells

~/ '--

Table 11Treatment Plant Online and Flow Data

MONTH

% OF I ONLINE

HOURS IHOURS IMONTH

INFLUENT PRE-TREATMENT

FLOW

UV/OX EFFLUENT

Notes:* Treatment plant was shutdown on November 10, 2008 through February 2009 due to modifications and upgrades in the Pre-treatment system.

MONTH

Notes:

'10 OF

HOURS HOURS MONTH ONLINE OFFLINE ONLINE

Table 11 Treatment Plant Online and Flow Data

ONLINE INFLUENT PRE-TREATMENT UV/OX

* Treatment plant was shutdown on November 10, 2008 through February 2009 due to modifications and upgrades in the Pre-treatment system.

EFFLUENT

Documents

HAVERTOWN PCP SITE 2008 · 4.4 Plant Operational and Flow Data 11 4.5 Plant's Operationai Changes 11 4.6 Chemical Usage, Utilities and Sludge Production Data 11 4.7 Free Product Recovery