removal action operations & maintenance plan - relief … · 2019-12-30 · removal action...

REMOVAL ACTIONOPERATIONS & MAINTENANCE PLAN

RELIEF AND GAS HOLDER REMEDIATION

UGI COLUMBIA GAS PLANT SITEColumbia, Pennsylvania

SOWS DocID

Preparedfor:

PENNSYLVANIA POWER AND LIGHT COMPANYTwo North Ninth Street

Allentown, Pennsylvania 18101-1179

Prepared by:

REMEDIATION TECHNOLOGIES, INC.9 Pond Lane - Suite 3-A

Concord, Massachusetts 01742-2851

RETEC Project # 3-1612-200

JUNE 1996

AR400595

Pennsylvania Department of Environmental Protection

One Ararat BoulevardHarrisburg, PA 17110-9333

January 10,1997

717-657-4592Southcentral Regional Office FAX 717-540-7492

Mr. Mark MoellerRemediation Technologies, Inc.Damomill Square9 Pond LaneConcord, MA 01742-2851

Re: UGI Columbia Gas Plant SiteOperation & Maintenance Plan andSampling & Analysis Plan

Dear Mr. Miller:

The Department of Environmental Protection has reviewed the Additional GroundwaterSampling letter dated January 8, 1997. The letter has been accepted as an addendum to the Operation& Maintenance Plan and the Sampling & Analysis Plan for the Relief and Gas Holder Remediation,dated July, 1996. These are now considered final and approved documents.

If you have any questions, please contact me at 717-657-4020.

Sincerely,

Anthony L. MartinelliProject OfficerEnvironmental Cleanup Program

cc: Steve Donahue, EPA, 3HW22Scott Miller, CSES (hand carried)

\barb\hsca\moeller.doc

An Equal Opportunity/Affirmative Action Employer http://www.dep.state.pa.us Printed on Recycled Paper \QAR400596

966T-TZ-03Q

' *

FAX TRANSMITTAL SHEET

CLEAN SITES ENVIRONMENTAL SERVICES, INC.UGI COLUMBIA GAS PLANT SITE

COLUMBIA, PENNSYLVANIA

Voice: (717)684-1619 Fax: (717)684-1629

TO: Steve Donohue EPATony Martinelli PADEP

FROM: Scott R. Miller

SUBJECT: Holder Remediation - Sampling Plan Addendum

DATE: December 31,1996

NUMBER OF PAGES (including this cover): 2

Attached is an addendum letter from ReTec that discusses sampling the monitoring well (BG-l) thatis adjacent to the relief holder. As previously discussed, groundwater samples will be collected fromthis well three times and will be analyzed by EPA method 8260.

We anticipate starting up the system with a new boiler in a few weeks and would like to have theproject plans approved by then.

Should you have any questions regarding this matter, or need additional information before you canissue an approval letter for the plans, please call me at (717) 684-1619.

Thank you,

Scott

If you do not receive the correct number of pages for this transmission, please call (717) 684-1619immediately.

AR400597

30 'd *9S i0:2T 966T-T£-D3d

« fondle*

Can"»< UADecembers, 1996

Mr. Douglas AmmonClean Sites Environmental Services, Inc.635 Slaters Lane, Suite 130Alexandria, VA 22314

SUBJECT: Additional Oroundwater Sampling at UGI Columbia Site

Dear Doug:

During the November 7th meeting with EPA and DEP, we agreed to sample the new monitoringweU(BG-l) that was installed jest outskle of fe Became the Sampling and AnalysisPlan does not specify the nature of (his work, this letter wfll serve as an addendum to mis Plan.

RETEC proposes to collect groundwater samples from this well three tunes during the coarse ofthis project; one time prior to initiating OBLOM?11* activities, one time shortly after the steady-stateoperation of the system, and one time several months into the operations. All samples will becollected in compliance with RETEC standard operating procedures and general groundwatersampling standards. Each sample will be analyzed for total volatile organic compounds by EPAmethod S260. The results will be included in the subsequent monthly report for issuance to DEPand EPA. Please call me if you have any questions or comments about this additional work.

Sincerely,

SEMED:

Environmental Engirt

MWM/kmb

cc: S. Miller (CSES)B. Wise (PP&L)A. Leuschner (RETEC)

KMsOiATlONTECHNOlOGIESINCORfORATEO

AR400598

Tannarv 8 10Q7 Damonmiil SquareJanuary s, ivy / 9 Pond loneConcord, MA 01742-2851

(5031 37!-! 422FAX (508J 369-9279

Mr. Anthony MartinelliPennsylvania Department of Environmental ProtectionSouthcentral RegionOne Ararat Blvd.Harrisburg, PA 17110

SUBJECT: Additional Groundwater Sampling at UGI Columbia Site

Dear Tony:

During the November 7 meeting with EPA Region HI and DEP, PP&L agreed to sample the newmonitoring well (BG-1) that was installed just outside of the relief holder. Because the Samplingand Analysis Plan does not specify the nature of this work, this letter will serve as an addendumto this Plan.

RETEC proposes to collect groundwater samples from this well three times during the course ofthis project; one time prior to initiating CROW™ activities, one time shortly after the steady-stateoperation of the system, and one time several months into the operations. All samples will becollected in compliance with RETEC standard operating procedures and general groundwatersampling standards. Each sample will be analyzed for total volatile organic compounds by EPAMethod 8260. The results will be reported to RETEC within 10 days of the laboratory's receiptof the samples. RETEC will immediately forward these results to DEP and EPA Region m.Please call me if you have any questions or comments about this additional work.

Sincerely,

REMEDIATION TECHNOLOGIES, INC.

'MarkW. MbeTler, P.E.Environmental Engineer

MWM/kmb

cc: D. Ammon (CSES)S. Miller (CSES)B. Wise (PP&L)S. Donohue (EPAHI)A. Leuschner (RETEC)J. Gerrish (RETEC)

1-2507-400\F:\LETSMEMO\MOELLER\1996\MARTIME.LTR.REMEDIATION TECHNOLOGIES INCORPORATED

OFFICES .WIONW/DtAR400599

DatejL

Operator:

Orn-ratinnal Status;

Dally Pit*Inltfltlnn In Indies:

Coal Tar Removed From Site

^..'.",';:. j . : - , •• , !•. ,y

T-ra.Ta Tank Levels

Health & Safety Meetines

Daily Operations LogUGI Columbia Gas Plant Site

Pennsylvania Power & Light CompanyColumbia, Pennsylvania

Propane Usage

Morning

Afternoon

Note* Meetines should occur once weekly.

Monitoring Well Water Elevations

Pore Volume Information

Sampling

Date of lfl«t iumpltng- NCXt Mfltplirtf '

Flowmeters/Orifice MetersIW1 -io.;m • ' ' > ' - , ; ; 2! i*# '•!i;S'''.'l '••$$$& • : ' . ' • ' . :'Vt3 ("?'/!'•

; Boikr Feed ''^ittw^'1 '?DK»2B

W3A + 3B^DK»'\.'

W 4 A + 4 B

Temperature ThermocouplesLliEfeMtML tl6-Po«tB61ig- -;!-: "TH3-IW4A TllS-Pre Bolicr

Monitoring Well Temperature Thermocouples•"-!-!-1-" ': ;;::|.|j:i;||tgiSMid;iiic'-.':l!i:;.fcBiJ^gdoa-!.YMRB^TOt*;.:1 •'• ,1 :---lua-Middll-JKS1B2JI RB4-B<*lan RB5-BoOan

Pressure Gauges110-BoflerFte ms-te***

Vm-Prtcoole*

Chemical Management: : DH ' . .,

Pre Acid,:. . : , $t3 .':":.'.'

Post AcidSP4

PreCuutiASP5

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Dissolved Fe Cone, (PreT«nkl

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ppfn) •PottTmkB

, ' SP7 ,

: ': v.Cbemlcri:WB»:Kdii:::::-!li:, H2SO4 ,,

Stroke Ltaatt 5tr«k«IUteN«OH, i'..'?' . .:• '•;: . ,•,•:•

Stroke La** Stroke R«e

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. ji i., ;..:::•.;:• .-:-.H2O2-; .:• .«':•*': :.StrtkeLaieib Stroke fUte

V»«nt •:

System Leak Detection (Check box if no leaks are found. If leak discovered, indicate book ft and Page ft in notes where repairs are discussed)

Notes: (Weekly anafysu) Pre Ttnk-1 and Pre-Boikr (re for TOO by method 9060A «nd Oil A Oreise by method 413.2. Post CA-1 and CA-2 are for VOCa by method 8260.

Printed: 01/73/77-01:34 PM. !

AR400600

REMOVAL ACTIONOPERATIONS & MAINTENANCE PLAN

RELIEF AND GAS HOLDER REMEDIATION

UGI COLUMBIA GAS PLANT SITEColumbia, Pennsylvania

Prepared for:

PENNSYLVANIA POWER AND LIGHT COMPANYTwo North Ninth Street

Alleniown, Pennsylvania 18101-1179

Prepared by:

REMEDIATION TECHNOLOGIES, INC.9 Pond Lane - Suite 3-A

Concord, Massachusetts 01742-2851

Prepared by:

Reviewed by:/r

RETEC Project # 3-1612-200

JUNE 1996

AR400601

TABLE OF CONTENTSNO. DESCRIPTION PAGE NO.

1.0 INTRODUCTION 1-1

2.0 HEALTH AND SAFETY 2-12.1 Personnel Restrictions 2-12.2 Emergency Equipment 2-12.3 Site Organization and Cleanliness 2-22.4 Site Security 2-2

3.0 RECORD KEEPING 3-13.1 Operator's Notebook 3-13.2 Operator's Logbook 3-1

4.0 CROW™ OPERATION AND MAINTENANCE PROCEDURES 4-14.1 Process Monitoring 4-1

4.1.1 Flowrate Monitoring 4-14.1.2 Pressure Monitoring 4-44.1.3 Temperature Monitoring 4-54.1.4 pH Monitoring 4-64.1.5 Total and Dissolved Iron Concentration Monitoring 4-64.1.6 Process Tank Level Monitoring 4-6

4.2 Data Acquisition 4-74.3 Chemical Management 4-8

4.3.1 Chemical Injection (chemical pump operation) 4-84.3.1.1 Acid Injection 4-84.3.1.2 Caustic Injection 4-84.3.1.3 Hydrogen Peroxide Injection 4-84.3.1.4 Flocculent Injection 4-8

4.3.2 Drum Handling 4-94.3.3 Drum Storage 4-94.3.4 Chemical Procurement 4-9

4.4 Strainer and Filter Maintenance 4-104.4.1 Strainer Cleaning 4-104.4.2 Bag Filter Operation 4-124.4.3 Bag Filter Replacement 4-124.4.4 Spent Bag Filter Disposal 4-134.4.5 Bag Filter Procurement 4-13

4.5 Carbon Drum Maintenance 4-134.5.1 Carbon Unit Operation 4-14

4.5.1.1 Liquid Phase Carbon Unit Operation 4-144.5.1.2 Vapor Phase Carbon Unit Operation 4-14

4.5.2 Liquid Phase GAC Unit Backwash and Disinfection Procedures . . 4-154.5.2.1 Disinfection 4-154.5.2.2 Neutralization 4-16

F:\PROJECTS\3-1612\DOCS\O&M2.PLN 1 June 6, 1996AR400602

TABLE OF CONTENTSNO. DESCRIPTION PAGE NO.

4.6 Boiler Operation 4-164.7 Tankfarm Sump Operation Procedures 4-174.8 CROW™ Shutdown 4-17

5.0 RELIEF HOLDER PUMPDOWN OPERATION 5-1

6.0 GAS HOLDER PUMPDOWN OPERATION 6-1

7.0 LEAK DETECTION 7-1

LIST OF FIGURESNO. DESCRIPTION PAGE NO.

1-1 Site Location Map 1-21-2 Current Site Layout 1-33-1 Flowmeter Daily Checklist 3-33-2 Visitors Log 3-43-3 System Leak Detection Daily Checklist 3-53-4 Chemical Management Daily Checklist 3-63-5 Well Flowrates Daily Checklist 3-73-6 Temperature Sensor Daily Checklist 3-83-7 Pressure Gauge Daily Checklist 3-93-8 Precipitation Log 3-103-9 Tank Levels Daily Checklist 3-114-1 CROW™ Process Piping & Instrumentation Diagram 4-24-2 Purchase Requisition 4-11

/ £-.£ a-> c*s*e*s-T.-^ os "i /""-' 4'"tx ,,1, o/» y^_ ' t f S •

7 « /* (: i ;.v a ,^ .

APPENDICES

APPENDIX A MSDS'sAPPENDK B SOP's 110 & 230APPENDIX C National Vapor Industries Operations Plan

F:\PROJECTS\3-1612\DOCS\O&M2.PLN 11 June 7, 1996AR400603

1.0 INTRODUCTION

This Operations and Maintenance (O&M) Plan has been prepared for the removal of MGP

residuals from the two holder pits in Columbia, Pennsylvania. The purpose of this O&M Plan

is to outline operator duties and responsibilities, specify process monitoring procedures, describe

required maintenance activities, and detail safety and security measures.

The former MGP Site in Columbia, Pennsylvania (Figures 1-1 and 1-2) was placed on the

National Priorities List in June 1994. The process of site remediation has been initiated under the

Superfund Accelerated Cleanup Model (SACM) as a non-time critical removal action. RETEC

prepared an Engineering Evaluation/Cost Analysis (EE/CA) for the relief and gas holders at the

site. The results of the EE/CA showed that the selected remedy for the relief holder should be

enhanced recovery using steam injection. The selected remedy for the gas holder should be

conventional pumping. The final step will be to remove residual liquids from both holders and

grout them closed. The PADEP issued a Statement of Decision on July 17, 1995, that concurred

with the selected remedies from the EE/CA. The Electric Power Research Institute (EPRI) and

Pennsylvania Power and Light Company (PP&L) have entered into a Tailored Collaboration to

remediate the relief and gas holders at the site.

The work to be performed at the site includes removing MGP residuals from two former

holders; a relief holder (60 feet diameter, 27 feet deep) and a gas holder (40 feet diameter, 17 feet

deep). The relief holder is filled with soil and debris and is saturated with tar and water. The gas

holder is also filled with soil and debris and is saturated with water and aqueous tar constituents.

The selected remedy for removing the MGP residuals from the relief holder is an enhanced

recovery process. The enhanced recovery process involves injecting steam into the holder,

pumping tar and water out of the holder, separating the tar from the water, disposing of the tar,

heating the water and recycling it back through the holder. Once all separable tar has been

removed from the holder, the remaining water will be pumped from the holder, treated in an on

site wastewater treatment system, and discharged to the Susquehanna River. The selected remedy

for the gas holder involves pumping the liquids out of the holder, treatment with the on site

wastewater treatment system and discharging to the river.

F:\PROJECTSV»-1612\DOCS\O&M2.PLN 1-1 June 6, 1996AR400604

RlTECSchuylkHTHin

V,^JH&isburg ;

CampHiir"^nNewXuiribplaM

/vif f Eliizabethtown /ll\\ ^V A'''

) 1993 DeLorme Mapping

Site Location Map FIGURE1-1

AR400605

Concrete SlabOver Holders

of MGP Operati

BoatStorage

AreaPropertyFence

GravelCover

Concrete Slab Over

Relief HolderDealership

Front Street

GravelArea

Boat Storage AreaGrass Area

Consolidated Rail Corporation

To Susquehanna River

PENNSYLVANIA POWER 4 LIGHT COMPANYUGI COLUMBIA SITE

3-1S11

AR400606

2.0 HEALTH AND SAFETY

The site engineer/systems operator (Operator) is ultimately responsible for maintaining site

conditions that are safe for on-site personnel. This section of the O&M Plan presents some

general guidelines that the Operator will follow to ensure safe conditions. The Site-Specific

Health and Safety Plan should be referenced for more detailed information.

2.1 Personnel Restrictions

The Operator will verify that every person entering the exclusion zone has read and signed

the Site-Specific Health and Safety Plan and familiarized themselves with all potential hazards

associated with the site. Also, individuals must have successfully completed an OSHA 40-hour

training course to be allowed into the exclusion zone. No person may enter the exclusion zone

without the Operator's knowledge and authorization.

2.2 Emergency Equipment

All operators will be instructed in the use of on-site emergency equipment. Emergency

equipment will consist of an eye wash station, first-aid kit, burn kit, emergency blanket,

telephone, and fire extinguisher. The telephone will be used for business and emergency

purposes. The operator will be responsible for ensuring that emergency equipment is in proper

working condition and available for use.

In addition to the emergency equipment, copies of the Site-Specific Health and Safety Plan,

Operations and Maintenance Plan, and Contingency Plan will be kept on-site. These documents

will not leave the site and will be reviewed by all operators.

Evacuation procedures are discussed in Section 5.4 of the Contingency Plan. Emergency

contacts are listed in Table 6-1 of the Contingency Plan.

F:\PROJECTS\3-1612\DOCS\0&M2.PLN 2-1 June 6, 1996AR400607

2.3 Site Organization and Cleanliness

Due to the deficiency of open space and the closeness of site features, improperly orprecariously placed materials may be unsafe to site personnel or may obstruct evacuation routes.

Operators are responsible for keeping materials in their proper locations and, in general,

maintaining site order and cleanliness. In addition, all walkways should be kept free from

obstructions, trash, and debris.

2.4 Site Security

The site will be kept secure by an existing security fence and wall that surround the site.

Whenever personnel are to be absent from the site for extended periods or overnight, the Operator

will secure the site by locking the gate with a padlock.

F:\PROJECTS\3-1612\DOCS\O&M2.PLN 2-2 June 6, 1996AR400608

3.0 RECORD KEEPING

Various types of information related to system performance will be recorded by the

Operator in either the Site Logbook or the Site Notebook. The information in the Notebook will

provide reference to system events and parameters. The Notebook is a less formal information

log that is to be used in common by each of the site operators. The Logbook will present field

gathered information and a record of when specific maintenance tasks were performed. The

Logbook will contain formal documentation of all parameters of the recovery system. These

books will remain on-site at all times and will be available for review.

3.1 Operator's Notebook

The operator will possess a Site Notebook to be used for all note taking concerning system

operations. The notes should include all pertinent information including:

• tank levels;• temperatures;• flowrates;• pressures;

pH's;• iron concentrations;• repairs performed;• maintenance activities;• site activities;• visitor information;• intervals the Operator is on-site;• modifications in system operation; and• additional consequential events.

3.2 Operator's Logbook

The Site Logbook will contain forms and checklists including:

Flowmeter Daily Checklist (Figure 3-1)

Visitor's Log (Figure 3-2)

System Leak Detection Daily Checklist (Figure 3-3)

Chemical Management Daily Checklist (Figure 3-4)


• Well Flowrates Daily Checklist (Figure 3-5)

• Temperature Sensor Daily Checklist (Figure 3-6)

• Pressure Gauge Daily Checklist (Figure 3-7)

• Tank Levels Daily Checklist (Figure 3-8)

• Precipitation Log (Figure 3-9)

These forms are included at the end of this section.

The Operator is responsible for completing all checklists within the time periods specified

in the Logbook and this manual. If checklist pages need to be removed from the Logbook, they

will be stored on-site in a designated location. Analytical data collected during the CROW™

process will be obtained in accordance with the Sampling and Analysis Plan. Sampling activities

will be recorded in the Operators Notebook. Sampling results will be filed by RETEC in the

Concord, Massachusetts office.


Figure 3-1UGI Columbia Gas Plant Site

FlowmeterDaily Checklist

Date Flowrate in GPMPW1FM1

| Oil Line 1FM2 (Total) 1

Post Tank 8 !

FM3 iBoiler Feed j

FM4 !PW2FM5

IW 1A + IB! OM1

' IW 2A + 2BOM2

IW 3A + 3B! OM3

FVV 4A + 4 BOM4

File= jgerrish- c:\projects\columbia\workplan/no Operator's Logbook Entry Sheet Primed- 11/06/95- 11::40 PM

AR400611


Visitors Log

Name Representing ! Date/Time In J Date/Time

File- jecmsh- c \projects>columbia/sitelist wk4 Operator's Logbook Entry Sheet Printed- 11 '06 9? - 1 ] 33 PM

AR400612


System Leak DetectionDaily Checklist

DATE Oil ', Heat ' Boiler CA Units & Discharge Production Injection Production Injection Tankfarm Tankfarm Bag Chemical__Lines ^xchanger^ 'Assoc.j'iBes Piping Wellheads Wellheads Puropline PjinjrJineJ^Tanjs Pipfflg jfjjjgg- Liges

File= jLierrish-c: projects\columbia'workplan'leakchek.\vk4 Operaior's Logbook Entr> Sheet Printed 11'06 ;95- I] 41 PM

AR400613


Chemical ManagementDaily Checklist

•; pH I! Dissolved Fe Cone, (ppm) Chemical Pump RatesDate Pre Acid Post Acid 'Pre Caustic Post Caustic 'Post Tank 8 Pre Tank 1 Post H2O2:Poa Tank 8 H2SO4 i NaOH H2O2

'•' SP3 '. $P4 ' _S£g__ J §E6 ! SP7 3_$P3 ! SP6 I _SP7 _ StrkJ-eiattL_Strk Rate :Strk.I^.^hJ_Strk_Rate_JSak,Ltngh_StrlLRaleI

File=jgemsh-c -projects columbia'workplan'chemmngi v.k-1 Operator's Logbook Emry Sheet Printed ]0'1Q'9> - 04 23 PM

AR400614

Figure 3-5

UGI Columbia Gas Plant SiteWell Flowrates

Daily Checklist

Date '; Flowrate in GPMPW2

Filc= jeerrish- c:\projecis\columbia\workplan/flo Operator's Logbook Entry Sheet Printed: 10/19/95 - 04:23 PM

AR400615


Temperature SensorDaily Checklist

Date j

;i

tj

i

i

'

PVVIi Til

1

i

i

i

( 1

Post PW1TI2

Post Heat Exch.TI3

.

ChiririerTI4

Tank2T15

Post BoilerTI6

-

Tcmpcrutur1VV1ATI7

IVVIBTIS

IW2AT19

IVV2BTI10

IVV3ATill

IVV3BTI12

1VV4ATI13

IVV4BTIM

l ; i lc= j^crrish- c:\pn>jccis\colunihi,i\workplan/tcmp.wk4 Operator's Logbook Kntry Sheet F'rintal: 11/06/95 - 11:39 I'MAR400616


Pressure GageDaily Checklist

DatePre Boiler

PI10Post Boiler

! PI9 irwiAPII

IW1BPI2

Pressure in psiIW2API3

IW2BPI4

\ IW3A: PIS

i IW3BPI6

IW4A! PI7

IW4BPIS

Filc= jgerrish-c:\projecls\columbia\workp]an,'prESSure.wk4 Operator's Logbook Emr> Sheet Printed 11/06'95- 11:36 PM

AR400617


Precipitation Log

Date Precipitation in Inches

- c' 'proiects,columbia'5itelisl wk Operator's Logbook Entry Sheet Primed- !1-'06'9^- 1] 37 PM

AR400618


Tank LevelsDaily Checklist

DATE Tank Tank ! Tank Tank Tank Tank1 ' .2 \ 3 6 ' 8 _9

l r i l c = jj!errisri- c-.projects Columbia workplanleakchek \vk4 Operator's Logbook Entr>-Shecl Primed l l ' O I 95- 1 2 0 9 A MAR400619

4.0 CROW™ OPERATION AND MAINTENANCE PROCEDURES

4.1 Process Monitoring

This section addresses monitoring that the Operator will conduct during daily data

acquisition procedures, during hourly system inspections, or when system modifications have been

made. Divisions of system monitoring include flowrates, pressures, temperatures, pH's, iron

concentrations, and tank levels. Figure 4-1 presents the Piping and Instrumentation Diagram for

reference purposes. The system will be actively monitored throughout each day but operated

continuously (24-hours per day).

4.1.1 Flowrate Monitoring

Flowrate monitoring is necessary to ensure that pumps are functioning properly and that

tank levels are within acceptable ranges. The Operator must manually check each flowmeter and

should do so at least twice daily, or whenever modifications are made in the system.

Flowrates should be monitored in the production line, the reinjection lines, the oil line, and

the discharge line. During CROW™, the production flowrate and the total injection flow will

require frequent attention to ensure that they are comparable. The flowrate in the oil line to Tank

2 will require attention when the Operator manually starts Pump 6 to pump oil from either Tank

1 or 6. The discharge flowrate will require operator attention during pumpdown activities or

whenever process water is being discharged.

The flowmeters for the treatment system are as follows:

Flowmeter #

1,5 IVz" line Production line flow meter, 10 gpm, IVi-inch diameter, turbinetype, 100-inch WC pressure drop. Pressure transmitter withintegrator, 4-20 mA output.

2 IVi" line Oil line flow meter with totalizer, 10 gpm, 1%-inch diameter,turbine type, 100-inch WC pressure drop. Pressure transmitter withintegrator, 4-20 mA output.


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PENNSYLVANIA POWER & LIGHT COMPANYCOLUMBIA SITE

3-1612

COO-f^ or iiied, (

CURSEM QArt:[ 9/29/95 ICAD FILE I 1612P002

CROW PROCESSPIPING & INSTRUMENTATION DIAGRAM

AR400621

" line Separator produced water flow meter, IV^-inch diameter, 2-15 gpm,

150°F Halliburton type turbine meter with magnetic pickup and

HFC-RTV frequency converter.

4 1" line Boiler feedwater line flow meter, 34 -inch diameter, 2-15 gpm,

150°F Halliburton type turbine meter with magnetic pickup and

HFC-RTV frequency converter.

Orifice meters are used to measure injection flow. Because steam will be injected into the

relief holder, a standard flowmeter could not be used. The orifice meter operates by measuring

a pressure differential across an orifice plate. The operator must then compare the differential

pressure reading with a manufacturer prepared flow versus pressure differential curve to find the

flowrate through the orifice meter.

The orifice meters for the treatment system are as follows:

Orifice Meters

1-4 Steam injection lines, 5,000 Ibs/hr, 3-inch diameter, 0-2 psi differential pressure

gauge.

A higher flowrate out of the production wells, as compared to the injection flowrate, will

produce an increase in the water level in Tanks 8 and 1, whereas a lower flowrate out of the

production wells, as compared to the injection flowrate, will produce a decrease in the water level

in Tanks 8 and 1. If flowrates are not accurately regulated and tank levels increase, level switches

in Tanks 1 and 8 will stop Pump PW-1 to prevent tank overflows. The Operator should attempt

to correct variations in flowrates before automatic shutoffs engage.

Discharge flowrates must be monitored to ensure that they do not exceed the

manufacturer's recommended maximum flowrate for the carbon adsorption units. The carbon

adsorption units require a minimum contact period with the water to appropriately extract

dissolved organics. Flowrates that exceed the recommended flowrate may lessen the effectiveness

of the units, thereby allowing organics to bypass the carbon units and be discharged. If sufficient

quantities of organics bypass the units, scheduled laboratory analysis of discharge water may

indicate constituent levels that exceed the established criteria. Additional GAC units will be

plumbed into the system, as necessary, to alleviate the excess demand associated with flow rates

or organic removal.

F:\PROJECTS\3-1612\DOCS\0&M2.PLN 4-3 June 6,AR400622

4.1.2 Pressure Monitoring

Pressure gauges have been located throughout the treatment system to provide the Operator

with supplementary information about system conditions and to alert the Operator to potential

problems. The Operator will manually check each pressure gauge at least twice daily, or

whenever modifications are made in the system.

The major areas of concern for pressure are the bag filters, carbon adsorption units, and

injection wellheads.

The pressure gauges for the treatment system are as follows:

Pressure Gauge #

1 Injection wellhead pressure, 0-100 psig








9 Boiler outlet pressure, 0-100 psig

10 Boiler inlet pressure, 0-100 psig

11 Filter 2 inlet pressure, 0-100 psig

12 Filter 2 outlet pressure, 0-100 psig

13 Filter 1 inlet pressure, 0-100 psig

Appropriate system pressures and pressures the Operator should expect to see on individual

pressure gauges will depend on various field conditions. Therefore, additional pressure

information will not be presented here.

In addition to system pressures, the Operator will be required to measure pressures within

the relief holder. Four pressure monitoring points will be installed within the relief holder

(RHP1, RHP2, RHP3 and RHP4). These pressures will be directly read off of differential

F:\PROrcCTS\3-1612\DOCS\0&M2.PLN 4-4 June 6, 1996AR400623

pressure gauges and will correlate to the static water level within the relief holder. Also, the

operator must measure hydraulic head in the piezometer located outside the holder.

A decrease in static water level in the relief holder piezometer, or an increase in the outside

piezometer during balanced injection and extraction conditions could indicate a leak in the system.

If the operator determines that no leaks are occurring within the process equipment and the relief

holder water level continues to decrease, then a leak may be occurring in the relief holder walls.

The operator should collect additional water level data from nearby shallow wells (MW-01S, MW-

01SR, MW-4). EPA should be notified under this scenario. EPA may request that the extraction

system be overdrawn in order to match holder levels with groundwater levels.

Under this scenario, the operator must bleed 1-5 gpm of process water to the CA units by

cracking Valve # 28. The Operator must then follow carbon unit operation procedures under

Section 4.5.1, as well as appropriate sampling procedures as described in the Sampling and

Analysis Plan.

4.1.3 Temperature Monitoring

Temperature monitoring is necessary to ensure that the boiler is functioning properly and

that coal tar removal is working efficiently. The Operator will manually check each temperature

sensor and should do so at least twice daily or whenever modifications are made to the system.

During CROW™, temperatures should be monitored in the boiler piping (TI6), Injection

wellheads (TI7, TI8, TI9, TI10, Till, TI12, TI13, and TT14), PW1 (Til), PW1 flow (TT2), Post-

Heat Exchanger Flow (TI3), and clarifier tank 6 (TI4).

The temperature sensors for the treatment system are as follows:

Temperature Sensor #

1 Production well downhole temperature, 0-250°F

2 Post heat exchanger temperature, 0-300°F

3 Tank 1 temperature, 0-300 °F

4 Tank 2 oil temperature, 0-300 °F

5 Boiler outlet temperature, 0-300 °F

6 Injection wellhead 1A temperature, 0-300°F

7 Injection wellhead IB temperature, 0-300°F



9 Injection wellhead 2B temperature, 0-300°F





In addition to process temperatures, the Operator will also be required to monitor relief

holder temperatures. Thermocouples will be installed in four locations within the relief holder

(RHT1, RHT2, RHT3 and RHT4). Each location will contain three thermocouples which will

monitor top, middle and bottom temperatures (A, B, and C).

The purpose of the temperature monitoring is to track the uniformity of temperatures

throughout the holder.

4.1.4 pHMonitoring c, t l J l a f f f t

pH monitoring will be performed automatically by the pH controllers located at the H2SO4

and NaOH injection points. The operator should manually monitor pH once per day to ensure

proper operation of the controllers. Initial target pH's should be as follows:

SP1, 2: As is

SP4: 5.5

SP5: 5.5

SP6: 7.2

SP7: Same as SP2

4.1.5 Total and Dissolved Iron Concentration Monitoring

Iron concentration monitoring will be performed automatically by the REDOX controller.

The REDOX controller will regulate the flow of hydrogen peroxide into the system in order to

fully oxidize all reduced metals. The Operator should manually sample and analyze process fluids

for total and dissolved iron concentrations to ensure proper operation of the REDOX controller.

Water from SP9 should contain no dissolved iron. Water from SP7 should contain less than 2

ppm of total iron.


4.1.6 Process Tank Level Monitoring

The level sensors for the treatment system are as follows:

Water Level Sensor #

LSL-1 Production well 1 low level shutdownLSH-1 Production well 1 high level shutdownLSH-T1 Tank 1 high level shutdownLSH-T2 Tank 2 high level shutdownLSH-T8 Tank 8 high level shutdownLSH-T3 Tank 3 discharge pump P8 activationLSL-T3 Tank 3 discharge pump P8 shutdownLSHH-T3 PW1, 2, 3, 10 and 12 shutdownLSH-P12 Sump high levelLSH-2 Production well 2 low level shutdownLSH-2 Production well 2 high level

4.2 Data Acquisition

One of the daily Operator activities includes data acquisition. Data acquisition will occur

twice daily and involves the Operator entering several categories of information from the process,

into either the Logbook or the Notebook. Because the system does not have computerized data

acquisition, the record books will contain all essential information and details pertaining to the

process. The Operator has the responsibility of entering all required and pertinent information

into the record books.

The system will be equipped with measuring devices and sensors that monitor the

performance of the system. All measurements will be registered on gauges or digital read-outs

that will be manually inspected and recorded. The types of information that will be collected and

recorded include:

• tank levels;

• temperatures;

• flowrates;

• pressures;

pH's;

• iron concentrations; and

• precipitation.


4.3 Chemical Management

4.3.1 Chemical Injection

4.3.1.1 Acid Injection

55-gallon drums of 93 % sulfuric acid will be used to lower the pH of the process water.

All of the acid drums will be delivered with lift gate service to the top of the tank farm entrance

ramp. The site Operator will be responsible for moving the drums (via drum dolly) to their

appropriate storage space within the tank farm. The Operator will tap one drum and set up the

metering pump - pH controller system. According to preliminary calculations, one acid drum

should last approximately one week.

4.3.1.2 Caustic Injection

55-gallon drums of 25% sodium hydroxide solution will be used to raise the pH of the

process water. All of the caustic drums will be delivered with lift gate service to the top of the

tank farm entrance ramp. The site Operator will be responsible for moving the drums to their

appropriate storage location within the tank farm. The metering pump will be set up in the same

manner as the acid pump. According to preliminary calculations, one caustic drum should last

several weeks.

4.3.1.3 Hydrogen Peroxide Injection

55-gallon drums of 50% hydrogen peroxide solution will be used to oxidize the process

water. All of the hydrogen peroxide drums will be delivered with lift gate service to the top of

the tank farm entrance ramp. The site operator will be responsible for moving the drums to their

appropriate storage location within the tank farm. The metering pump will be set up in the same

manner as the acid pump. According to preliminary calculations, one peroxide drum should last

several weeks.

4.3.1.4 Flocculent Injection

The flocculent that will be used for this project is Drew-Floe. Drew-Floe (polyacrylic

acid) is a viscous polymer that requires dilution prior to injection into the system. Drew-Floe will

be delivered to the site in 5-gallon buckets. The Operator will be responsible for following the


4.3.2 Drum Handling

The Operator must be aware that all drummed chemicals are in an extremely concentrated

state and extreme caution must be used whenever a drum is moved or tapped. Chemical resistant

clothing and faceshield will be provided and must be used during drum handling. Do not attempt

to move a drum that has already been tapped unless it is empty.

4.3.3 Drum Storage

Whenever a new chemical drum needs to be placed on-line, the used drum must be

completely emptied using the available hand operated drum pump. The new chemical drum

should have sufficient head space so that the residual chemicals can be pumped directly into it.

All required safety measures must be used when handling or working near the chemicals. All used

drums should be stored in the designated on-site storage area.

Full chemical drums should be stored in the designated storage area at all times. Only

empty drums should be removed from the drum storage area. Due to reactivity dangers, the drum

storage has been designed so that caustic and hydrogen peroxide are stored separately from

sulfuric acid. Also, activated carbon will be stored in the building to keep it separate from the

hydrogen peroxide.

4.3.4 Chemical Procurement

The Operator must remain aware of the available supply of chemicals. When the supply

of sulfuric acid (H2S04), sodium hydroxide (NaOH), hydrogen peroxide (1^ Q), or Drewfloc

2270 decreases to less than one week's supply, the Operator should make arrangements to have

additional chemicals delivered to the site. The Operator should become familiar with the chemical

usage rate and order enough chemicals to last approximately one month.

The chemical distributer is Textile Chemical Company (P. O. Box 13788, Reading, PA,

19612-3788, Phone (800) 422-8160) and Ashland Chemical's Drew Industrial Division (One Drew

Plaza, Boonton, New Jersey 07005, Phone (201) 263-7800). When ordering additional chemicals,

the Operator must be sure to request liftgate service. Also, proper procedures should be followed

including having a Purchase Requisition (Figure 4-2) approved and obtaining a Purchase Order

Number.


4.4 Strainer and Filter Maintenance

Due to the nature of this remediation, particulates and other types of foreign matter will

be a part of the process flow through the treatment system. Strainers and bag filters have been

designed into the treatment system to remove these particles from the process flow.

Strainers are located wherever large particulates need to be removed. Bag filters are

located wherever small particulates need to be removed. Typically, a strainer will be located

before a pump. A bag filter is typically located before equipment that may be affected by small

particles. This system has three bag filters; one is located on the boiler feed line and the other two

are located prior to the carbon adsorption units.

Bag filter 1, located between Pump 3 and the heater, will contain a 15,u (micrometer or

micron) filter to remove fine particles. The carbon adsorption units are very sensitive to

particulate loads and will, therefore, have bag filters of 5^ and 1/z size.

4.4.1 Strainer Cleaning

The system strainers need to be inspected daily for the first month of operation due to the

likelihood that larger particles will be generated during this startup period. After the first month

of operation, strainers should be inspected weekly unless more frequent inspection is necessary.

The strainers must be kept free of large amounts of debris because large particles collecting in the

strainers may reduce or obstruct flow.

To clean the strainers, the Operator should follow the following procedure:

1. Engage the strainer bypass line.

2. Open the strainer canister to expose the strainer basket.

3. Remove the strainer basket and properly dispose of any collected particles.

4. Replace the strainer basket in the strainer canister.


ITsOTDate: PURCHASE REQUISITION

(THIS IS NOT A PURCHASE ORDER)

MA-

To: Ship 10:

Date required:

Ship via:

F.O.B.:

Terms:

NO

1

2

3

4

5

6

B

9

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QUANTITY MODEL * MODEL

OTHER VENDORS CONTACTED THEIR PRICE

NUMBER'DESCRIPTION UNIT PRICE

SH/HD

T A X - at %

TOTALS

EXTENSION

NO ACCOUN' NO LINE :T£V,

1.

5.

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3. 4

7. 8.

11. 12

Requested by:

Wrinen by:

Dale:

Date:

Regional Mgr_

Corporate:

Date:_

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Purchase Requisition Form (example)FIGURE

4-2AR400630

5. Close the strainer canister and disengage the strainer bypass line.

Following strainer cleaning, the Operator should inspect the canister and its connections for any

leaks and make repairs if necessary.

4.4.2 Bag FUter Operation

The bag filter canisters have been designed to include pressure gauges. The normal

operating pressure of the bag filter canister will be dependent on many field related factors.

Typically, the bag filter's pressure will be quite low when a new, clean bag is in use. As the bag

clogs with particulates, the pressure will rise until flow begins to decrease. The Operator should

familiarize himself with the standard operating pressure of the bag filter and know at what

pressure the bag should be changed. As a rule, the Operator should install a new filter bag whentVi*» nr\t-mnl -f1r«i7 rt^r*TV*ocoe mrviv* tHan OflQZ,

hS-l. WUh?U.L W W.AW T'^fa U.1 i V w».»x* LSW W11**A*^»*^»» * »« ** *. W

the normal flow decreases more than 20%.

4.4.3 Bag FUter Replacement

The system bag filters need to be inspected at least twice daily for the first month of

operation because it is more likely that particles will be generated during this startup period.

To clean the bag filters, the Operator should follow the following procedure:

1. Engage the bag filter bypass line.

2. Slowly open the pressure relief valve on the top of the canister and then leave

open.

3. Using a bucket to catch the water, open the drain on the bottom of the canister.

4. Loosen the clamps holding the canister cover and remove the cover completely.

5. Slowly remove the old filter bag and dump any excess water in the bag into the

water bucket.

6. Properly dispose of the used filter bag.

1. Close the canister drain and the pressure relief valve.


8. Obtain a clean filter bag of the same micron rating as the old bag, making sure toremove the indicator tag from the bag so that it does not break free and becomelodged in the downstream piping.

9. Properly insert and seat the bag in the canister and replace the canister cover.

10. Tighten the cover clamps and disengage the bag filter bypass line.

11. Pump collected water into the system via the tankfarm sump.

Following bag filter cleaning, the Operator should inspect the canister and associated piping for

any leaks and make repairs if necessary.

4.4.4 Spent Bag Filter Disposal

Spent filter bags will be stored in covered 55-gallon drums. Before the spent filter bags

are disposed, they will have a TCLP analysis performed on a composite sample to determine

proper disposal.

4.4.5 Bag Filter Procurement

The Operator must remain aware of the available bag filter supply. When the supply

decreases to less than one week's supply of clean filter bags, the Operator should make

arrangements to have additional filter bags delivered to the site. The Operator should become

familiar with the filter bag usage rate and order enough bags to last approximately one month.

The bag filter distributor is Baron Filtration (Box 329, Claysville, PA 15323 - phone=

(412) 223-0299). When ordering additional filter bags, proper procedures should be followed

including having a Purchase Requisition (Figure 4-1) approved and obtaining a Purchase Order

Number.

4.5 Carbon Drum Maintenance

Envirotrol, Inc., will provide three 200 pound (55-gallon), and two 1800 pound liquid

phase granular activated carbon adsorption (GAC) units (Model LP-2000), and one 300 pound

vapor phase carbon unit. The liquid phase GAC units are used, as part of the treatment system,

to remove dissolved organics from discharge water. The vapor phase carbon unit is used to

remove organics from the boiler's excess gas line and any gas released from PW1 in the relief

F:\PROJECrSV3-1612\DOCS\O&M2.PLN 4-13 June 6, 1996AR400632

holder. The units have been sized according to designed flowrates and expected concentrations

of organics in the process water and will be installed in series. The LP-2000 units are designed

for medium-flow water treatment applications and contain 1800-2000 pounds of granular activated

carbon. The LP-2000 units will require daily inspection for back pressure levels and flowrates

and will need occasional backwashing to remove excess particulate buildup within the units. The

200 pound carbon units will be plumbed into the system to treat occasional low flows generated

by unbalanced system operations.

4.5.1 Carbon Unit Operation

This section presents the two types of carbon units to be used at the site and the operational

procedures associated with the units.

4.5.1.1 Liquid Phase Carbon Unit Operation

Specifications for the LP-2000 units include a maximum flowrate of 50 gpm and maximum

operating pressure of 15 psig per DOT 17C. The UGI Columbia Gas Plant Site design specifies

a 10-20 gpm discharge flowrate through the GAC units. The specified pressure drop across the

unit is < 2 psi with clean water and carbon, but this drop will increase over time as particulates

clog the units. Ultimately, the influent pressure level will increase over time. The 200 pound

carbon units include a maximum flowrate of 10 gpm and a maximum operating pressure of 15

psig.

As a part of the Operator's daily inspection routine, the pressure on the influent side of the

GAC units will be read from PI-14 and recorded in the Logbook. When the Operator finds that

the influent pressure must exceed 15 psig to keep up with discharge flow, backwash procedures

will be initiated.

4.5.1.2 Vapor Phase Carbon Unit Operation

During operations, it is possible that the injection of steam into the relief holder will cause

a build-up of gas pressure inside the production well. Also, gases may build up within the boiler.

The vapor phase carbon unit has been designed into the system to remove organics from both the

excess gas released from the boiler and any gas that may build up in PW-1. The vapor phase

carbon unit, therefore, treats all offgas before it is released.

F:VPROJECTS\3-1612\DOCS\O&M2.PLN 4-14 June 6, 1996AR400633

The excess boiler gas is vented automatically by the boiler, but production well gas must

be manually relieved via Valve # 83. Production well gas should be relieved daily or more

frequently, if necessary.

The vapor phase carbon unit will need minimal Operator attention except daily inspection

to ensure that connections are properly maintained. The Operator will immediately correct any

defects in the vapor phase carbon unit connections.

4.5.2 Liquid Phase GAC Unit Backwash and Disinfection Procedures

There are situations where it becomes necessary to disinfect granular activated carbon

(GAC) beds due to the presence of bacteria. The bacteria are usually present because of oxygen

depletion in wastewater applications.

The procedure described below is intended for in situ disinfection and neutralization of

carbon in LP-2,000 units. By adjusting the amount of sodium hydroxide, larger or smaller carbon

beds can be disinfected with this procedure.

CAUTION: Due to the hazardous nature of sodium hydroxide (NaOH) and hydrochloric acid

(HC1), appropriate protective clothing such as a face shield, goggles, gloves, and

impervious clothing must be worn when handling these chemicals. For specific

information on each chemical to be used, refer to the Material Safety Data Sheets

(MSDS's) that will be kept on-site.

4.5.2.1 Disinfection

1. Take the adsorber off line. Make sure that a line on top of the adsorber is open to

serve as a vent.

2. Drain the water from the adsorber through the adsorber effluent line into the

tankfarm sump and pump it into tank 1.

3. Pump a 5% NaOH solution into the adsorber through the effluent line. This will

require about 600 gallons of NaOH solution.

4. Stop pumping when the NaOH solution overflows through the vent line.


5. Allow the carbon to soak in the NaOH for at least four hours.

6. Repeat step 2 above.

4.5.2.2 Neutralization

7. Wash the carbon by adding contaminant-free or clean water through the effluent

line for 7-10 hours at a flow of 5-10 gpm in order to wash out the residual NaOH

and neutralize the carbon. The disinfection is then complete.

8a. An alternate, faster procedure for neutralizing the carbon includes acid treatment.

After the NaOH solution is drained from the adsorber, pump ^-gallon of reagent

grade hydrochloric acid (37% HC1) into the adsorber through the effluent line.

8b. Fill the adsorber with clean water by backfilling through the effluent line at 10-20

gpm so as to thoroughly mix the contents of the adsorber. Shut off the backfill

water when it begins to overflow through the vent line.

8c. Allow the carbon to soak for 60 minutes, then drain the adsorber. Check the pH

of the water, which should be in the range of 8 to 10.

8d. Wash the carbon by adding clean water through the effluent line at a rate of 5-10

gpm until the pH of the effluent water is the same as the influent water or within

the desired pH range. The neutralization is then complete.

4.6 Boiler Operation

National Vapor Industries, Inc. will provide the natural gas powered, compact Vapor

Superior Steam Generator (SSG). The <300 pound boiler reaches operating temperatures in

minutes and shuts down in seconds and can run in full operation for the duration of the project.

The boiler does not require pre-treatment, is automatically micro-processor controlled, and

contains an automatic safety shutoff. Also, the boiler is virtually maintenance free with few

moving parts, a weatherproof design, and a firing chamber that eliminates build-up. The release

of excess gas is automatically performed by the boiler.


The operation and maintenance procedure for the boiler includes Logbook recording of

flow and temperature through the boiler and ensuring the integrity of external piping connections.

Logbook recordings will be entered twice daily and according to instruction set forth in the

Logbook.

4.7 Tankfarm Sump Operation Procedures

The grade of the concrete tankfarm pad has been designed to direct all liquids that fall

within the tankfarm berms into the sump. The tankfarm sump pump is manually operated. The

sump has been designed this way to prevent automatic discharge of contaminated waters in the

event of a pipe or tank failure. The sump pump should be operated whenever water levels within

the sump exceed a field-established height. Only clean sump water will be pumped over the berm

and onto the surrounding ground surface.

The tankfarm sump pump will be connected to a high level indicator that will automatically

shut down both production wells if it is engaged. This protective measure prevents contaminated

water from overflowing the tankfarm berms in the event of a leak within the tankfarm.

If a spill of contaminated liquid occurs within the tankfarm, all future tankfarm water will

be considered contaminated. Contaminated sump water will be pumped directly into the water

treatment system and all future water collected in the sump will be pumped to the treatment

system.

4.8 CROW™ Shutdown

The point selected for the termination of the CROW™ process at the UGI Columbia Gas

Plant Site has been determined to be when the increase in cumulative recovery drops to 0.5% or

less per pore volume of water flushed through the relief holder. Based on previous laboratory data

from the Brodhead Creek Site and field data from the Bell Lumber and Pole Site, it is at this point

that 98.5% of the total recoverable coal tar will have been recovered. Therefore, continued

operation of the process will yield little benefit.

Cumulative recovery will be monitored using a flow meter to measure the total flow of oil,

per pore volume, to the oil storage tank. To calculate the percent of cumulative recovery per pore

volume injected, the following formula will be used:


Total oil collected during last pore volume

Total oil collected during all previous pore volumes

The minimum measurable quantity of recovered coal tar is determined by the flow meter's

capabilities. The specified flow meter is capable of measuring 1-gallon volumes with a ±1%

accuracy.

When the cumulative recovery of coal tar drops to 0.5 % or less per pore volume injected,

the system will continue to be operated for a period of 10 days during which cumulative recovery

rates will continue to be monitored. If, during the 10 days extension period, cumulative recovery

rates exceed criterion for shutdown, the 10 day period will be restarted.

Experience at the Brodhead Creek Site has shown us that flow meters and pressure

transducers can be unreliable instruments for measuring coal tar volumes. In the event that more

manual measuring methods are required, RETEC will notify EPA and discuss the alternative

methods. Also, tar volume can be difficult to measure. Measured "tar" is usually a solution of

tar, inorganic particles, and water. For shutdown criteria, we will measure the accumulating

volumes of "tar solution" as this is likely to be a conservative measure of the system's efficiency.

However, we will attempt to quantify the true organic fraction of the tar solution prior to shutting

down the system. This can be difficult because obtaining a representative sample of "tar solution"

can be difficult. EPA will be notified if, for technical reasons, tar measuring techniques are

amended. EPA will be provided with sufficient data to review and confirm RETEC's calculations

that shutdown levels have been reached.


5.0 RELIEF HOLDER PUMPDOWN OPERATION

NOTE: Before pumpdown commences, the contracted pressure grouters must be informed

of an established mobilization date for grouting the holder.

Following the termination of the CROW™ Process in the relief holder, relief holder

pumpdown will occur. PW-1 will pump the liquid content of the relief holder through the

treatment system without reinjection. All water removed from the relief holder will be treated

with the separation system and the carbon adsorption system and then be discharged to the

Susquehanna River. Discharge water will be monitored as specified in the Sampling and Analysis

Plan to ensure compliance with established criteria.

The point at which pumpdown will be terminated is when the water level of the relief

holder is lowered to its lowest level possible without starving the production pump. If the liquid

level in the holder stabilizes at a point above the production pump, it will be assumed that

subsurface water is entering the relief holder and pressure grouting will begin.

The pumpdown rate will be dependant on two parameters:

1) the PW-1 recharge rate; and

2) the achievable CA unit flow rate.

The pumpdown will proceed as quickly as possible given these two limitations. EPA will be

notified as to the pumpdown rate achieved and will approve the termination of the pumpdown.


6.0 GAS HOLDER PUMPDOWN OPERATION

NOTE: Before pumpdown commences, the contracted pressure grouters must be informed

of an established mobilization date for grouting the holder.

Following the termination of the relief holder pumpdown, gas holder pumpdown will

occur. PW-2 will pump the liquid content of the holder through the treatment system. All water

removed from the gas holder will be treated with the separation system and the carbon adsorption

system and then be discharged to the Susquehanna River. Discharge water will be monitored as

specified in the Sampling and Analysis Plan to ensure compliance with established criteria.

The point at which pumpdown will be terminated is when the water level of the gas holder

is lowered to lowest level possible without starving the production pump. If the liquid level in

the gas holder stabilizes at a point above the production pump, it will be assumed that subsurface

water is entering the holder and pressure grouting will begin.

All pumpdown information will be transmitted to EPA, in the same manner as with the

relief holder. EPA will have final approval as to when pumpdown is complete and reserves the

right to modify pumping techniques as necessary to get a more thorough pumpdown.


7.0 LEAK DETECTION

A visual inspection will be made daily by the Operator to determine if any leaks are

present. The Daily Leak Detection Checklist in the Operator's Logbook presents the major

process piping categories where inspection is required. Immediately following a leak detection,

attempts will be made to seal the leaking component. If immediate control measures fail, alternate

control measures such as component replacement may be applied. If a system shutdown is

required for leak repairs, startup will commence as soon as possible following EPA Regional

Project Manager's approval. If the leaking pipe contained contaminated material, cleanup of the

spill will occur according to the guidelines presented in the section titled "Spill Prevention and

Cleanup". If the leak exceeds a Reportable Quantity (RQ), the EPA Regional Project Manager

will be notified within 24 hours, and a report will be submitted to him within 30 days.

The PADEP Reportable Quantities are as follows:

• > 25 gallons spilled into a containment system;

• > 10 gallons spilled onto a synthetic surface;

• > 1 gallon spilled onto the soil; and

• Any spill that reaches a surface water body.


APPENDIXA

MSDS's

AR400641

HYDROGEN PEROXIDE HPO

Common Synorryma

PeroxideAlboneSuperoxol

Slightly sharp odor

Strifes and motes with water, irntttmg vapor a produced

AVOID CONTACT WITH LIQUID AND VAPOR Keeo peoo'e awayWear cnemicai protective suit inciudir*; self-contained breathing apparatusStop oiscf ar<;e .1 sossitiie Call 'ice deoartment•soiaie .ant! fpirove O'Scfwqed material^oiitv local rieaitri and ooiiutron control aqenoes.

Fire

Exposure

WaterPollution

Not flammableMay causa lire and explode on contact with comtxisbbtes and

metats.Containers may eupkxJe when healed.vear cnerr-icai cxotecuve suit including s«ii-cc mailed

Dreairnnq apparatus-!ooa discharge area with water

,:.ALL ^OR MEDICAL AID

VAPORIrritating to eyes, nose and throatHarmful il inhaled

LIQUID//ill txjjn skin and eyesHarmful il swallowed.

EHeci ol tow concentrations on aauanc nfe 'S unknownWay oe dangerous if it enters water mianes

I. RESPONSE TO DISCHARGE

(See Response Method* Handbook)

Issue wamtog-coffosive

Restncl access

Disperse and Hush

3. CHEMICAL DESIGNATIONS

3.1 CG Compatibility Claw: Noi listed

3.2 Formula: H2Oi HiO3.3 lUO/UN Dealgnattoo: 5 1/20153.4 DOT ID No.: 2015

3.5 CAS Registry Ho~ Data not available

2. LABEL

2.1 Category: Oxt

2.2 Claaa: 5

4. OBSERVABLE CHARACTERISTICS

4.1 Physical State [as shipped): bquid4.2 Cotor Colorless

4.3 Odor SMghtfy sharp

5. HEALTH HAZARDS

PermonaJ Protective Equipment Protectrve garments, both outer arx) inner, made of a wovenpcJyester fabnc or of mooacryitc or ptoywryboene labncs; impermeable apron made of porywryl

chlonde or poryelhytene him; neoprene gloves and boots; 9009(01.Symptom* Following Exposure Although solutions and vapors are nontoooc. they are irritating.

Vapor causes discomfort ot eyes and nose. Moderately concentrated fiquri causes whrterwig ofthe sktn arxi severe stinging sensat»n. In most cases the sbngtfxj subsides qutcKK; and the sk*igraoualfy returns to normal withouT any damage. Highry concentrated !«nxJ can cause bfcstenng

ol sXin it left on tor any length ot time, can aJso cause eye damage.

Treatment of Exposure: Contact should be avoided, but immediate flushing with water willprevent any reaction tn case of acodentai contaci

ThremhoM Umlt Vahi*: 1 ppmShorl Term Inhalation Umrtv: Data not avaiiaUeToxlctty by Ingesttorc Data not available

Ut» Toxtetty: NoneVapor (Gas) Irrrtant Cnanderistfc*: Vapors cause moderate imtatxxt. such that persorvrer wtf

find h»gh concentratiorra unpteasant The ertect is temporary.UqukJ or Solid Irrttam Charvcterlsbcs: Tairty severe skin mtanL May cause pam and second-

degree Sums after a few minutes' contact.Odor Threshold: No: pertinenl1DLH V«K>« 75 ppm

S. FIRE HAZARDS

$.1 Flaan Point: Not flammable out may causefire and react wotentry on contact wthcombusttoles and metals.

&_2 FTammatote Umtt* to AJr Not AanvnaDto.

'Bsurang from spMag*

Uaect Not pertinent45 Special Hazard* ot Combusoon

Products: Not oerboent

fkft Pehavtor Hi Fire: May explode rn Fre

6-7 Ignrbon Temperature: Not ftammaofe6.* Electric* Hazard: Not pertinent

6.9 Burning Rat*: Not flammable6.10 Adtatwnc Ham* Temperature:

Data not avaiaotei. 1 1 Sto+cntorrwtrtc A* to Fuel Rattot

Data not ava4aWe

4.12 Flame Temperature Data not avariable

7. CHEMICAL REACTlVrTY

7.1 Reactivity Wttti Water No reaction

7.2 Reacttvtty with Common Materials: Ot

and many metals cause a racxd oe-composjbon wrrh liberaDon ot oxygen

gas; occurs particularly rf concentrationrs above -»0%

7.3 Stability During Transport Pure gradesa/e quite stable, but contamination <vrthmetals or din can cause rap*3 V vxjJenidecomposition.

7.4 HeutraUztng Agent* for Acrid* andCauabcs: Not pertnem

7.5 PotymertzaUorr Noi pertinent

7.6 Inhtbrtor of Porymertzatkin:Not perrinent

7.7 Motar Ratio (Reactant toProduct): Data not available

7.3 Reactivity Group: Data not available

S. WATER POLLUTION

8.1 Aquatic Toxlcrty:

> 40 ppm/Vfirtgerting trout/toxic/sarlwater

Time period noi specified3J Waterfowt Toxlcrty: Data not availaole8.3 Blotogtcal Oxygen Demand (BOD):

None8.4 Food Chain Concentration Potential:

None

9. SHIPPING INFORMATION

9.1 Grades of Purity. Common commercial

strengths are 27 S%. 35%. 50%, 70%.90% and 98%. "High Strength" means

greater than 52%. Punty: TechneaJ; Ml.

Spec.; ACS. The hazard increases withthe strength.

9.2 Storage Temperature: Ambient

9,3 Inert Atmosphere: No reomremern

9.4 Venttng; Safety retiel or pressure-vacuum

10. HAZARD ASSESSMENT CODE

(Se« Hazard Aswwmenl Handbook)

A-P-Z

11. HAZARD CLASSIFICATIONS

1 1.1 Cod* of Federal Regulation*:Owctttr

11 J MAS Hazard Rating lor Bulk WaterTransportation:

Category RatingFre _... 0

Hearth

Vapor imtant _ 2Uquri or Sow imtant 3PotSOftS 1

Water POH/KXI

Human To»aty 1Aquatx; Toxiaty 0

Aesineoc E«ect _ \Reactrvrty

Other Chen>cals 4Water iSetf Reaction 3

1U NFPA Hazard Class! ncatlorr.

Category Classification

Heaiih Hazard (8lue( 2FlaomaWrty (Red) 0Seactrv'ty (Veilow) 3

oxy

it PHYSICAL AND CHEMICAL PROPERTIES

12,1 Physical State at IS'C anJ 1 Urn:Uouid

12.2 Molecular Weight: 3' Ol12.3 Boiling Point at 1 a tin:

257-F = 125'C = 398'K12.4 Freezing Point

— 405'F = JQ3*C = 232 9'K12.5 Crroca* Temperature: Not pertinent12.6 Critical Pressurr. Not pemnent12.7 Specrnc Gravity:

1.29 at 20'C I'hamdl12.8 UquW Surtaca Tension: Not pertinent

12.9 Uquid Water InterfacM TenslorrNot pemneni

12.10 Vapor (Ga«) Specific Gravity:Noi pertinent

12.11 Ratio of Specific Heats of Vapor (Gaa>:1.241

12.12 Litvnt Heat of VaponzattomS426tu/ib = 301 cai/g=1 12 6 X io» J/kg

12.13 H«*t of Combustion: .Not perbnent12.14 H«at of Decomposttlort: — 1220 Btu/lb

= —676 wl/g - —28 3 X iO1 J/kg12.15 Heat of Solution: 20 2 3tu/ib

= -11 2cal/g = -0*69 X 10* J/kg

12.16 Heat of Porymerlzatkxt: Not pertment12.25 Heat of Fustorr 8.58 caj/g

12-2« Umtting Vatue: Data not available

M27 RaW Vapor Pressure: Vanes

'Physical prooerftes appry 10 70%

solution

NOTES

JUNE 1985

AR400642

SODIUM HYDROXIDE SHD

Caustic sodaLye

Sow flakes or pedets Wnrta

Avo«d coniacl with sow and Oust f.oeo peoow awayWear rubber overclotning (irxrludinq giovesiStOD -iiscfiarqe >> [X)s^ibieisoiaie jrx] remove ciiscnarqoo materialNotiiy '<ocal r>eartn ana poiluKxi ccniroi agendas

Fire

Exposure

WaterPollution

Not flammable.May cause fire on contact with combuanbies.Flammable gas may be produced on conzaci wnth metals.Wea/ rvjooer wprcicinmg imnuOing g'Cves:F'ooa aiscnaiqe area witn ^siei

CALL FOR MED'CAL AID

DUSTIrrrrating to eye». fx>se arW irxcat.

SOLIDWill bum skm and eyes.Harmlm .) swallowed.

Dangetous 10 aouatic irfe >n hign concentrattonsMay be oangefous >l >t enters waief miaxes

1. RESPONSE TO DISCHARGE

(See Re*pon*e He modi Handbook)

Issue warning-corrosiveRestrict accessDisperse and tlusfi


1.1 CG Compatibility Claam: Not listedX2 Formula: NaOHX3 IUO/UN De«ignatton: 80/18233.4 DOT ID MOJ 1623

3.5 CAS RegUtry MOJ 1310-73-2

2. LABEL

2.1 CatftOX'T2.2 Clasa: 8


4.1 Pm/ucal State (a* tntpped): Solid.,2 Color Whrte4.3 Odor: CWoriess

5. HEALTH HAZARDS

Ptreonal ProtectNe Equipment OemicaJ safety goggles; lace snwrtd; fitter or dust-typeresprator. rubber boots: rubber gloves.

Symptom* Following Expoaure; Strong conosrve action on contacted tissues. INHALATION: dustmay causa damage to upper reapratory trad and lung itsett. producing tmm mild nose imtabonto pneumonttis. 1NGESTJON: severe damage to mucous membranes: severe scar formation orperrora&on may occur. EYE CONTACT: produces severe damage

Treatment of Exposure: INHALATION: remove from exposure: support respraftorr. cat! physician.INGESTK)N ^ve water or rralk loJkwed by dilute vinegar or rrurt jura: do NOT indues vomrtmg.SKIN: wasri immediatety wrth !a/ge quantrbes of water under emergency safety shower wfHtaremoving ctomtng; continue wasntng until medtcal rwlp amves, call physKian. EYES: imgateimmediately with copious amounts of water for at least IS mm.; call physoan.

Thr»«ho*d Umtt VaJu* 2 mg/m'Short Term Inhalation Umtt*: Not pertinentToxlctty by lnge*ttort (10% solution) oral rabbrt LCV. = 500 mgykgLate Toxlctty: NoneVapor (Gas) Irritant Charactertadca: Non-volableUquH or SoUd Irritant Charactaritttcs: Severe skin irritant Causes second-find third-degree

bums on snort contact and a very injurious to the eyes,Odor TnrvanxXd: Not pertinentIDLH Value: 200 mg/m"

6. FIRE HAZMW

0.1 rTaah Pofctt Not ftamrnaWe8 J Flammable LJmtta In Air. Not ftammabteW Rt» Extinguishing Agenta: Not partner*9,4 Fir* ErtngutoNng Agerrta Hot to be

LJaed: Not pertinenttS Special Hazard* of Co*f*>u*t)on

Product* Not pertnertB.6 Behavior m Fir* Mot pertinent6.7 Ignfflon Temperature: Not flammable6J Electrical Hazard: Not pertnerrtft.9 Burning Rate Not fUmmaWe4.10 AdMwtic Flam* Temperature:

Data rot avaAatteft.11 Stotchtometrtc Air to Fuet Ratkx

Data not avariatXe8.12 Ram* Temperature: Data not available

7. CHEMICAL REACTIVITY

7.1 ReactMty Wtth Water: Dissolves withliberation of much heat may slaam antssplatter

7.2 R*«ctMty wttti Common Uataflata; Whenwet. attacks metals such as aluminum.bn. lead, and zinc to produceflammable nydrogen gas

7.3 Stabtttty Dudng Transport Stable7.4 Neutraltitng Agents for Acida and

Caoatlca: Flush wrtfj waiar. nnse wrtndHuie acetic aod

7.5 Porymertzation; Moi perttnerrt7.6 Inhibitor of Polymerization:

Mot pertinent7.7 Uoiar Ratio (Heactam to

Product); Data not available7.8 Reecttvtty Group: Data nol available

8. WATER POUUTION

8,1 Aquatic Toxtctty:125 ppm/96 hr/mosqurtofish/TLV^**^180 pptn/23 hr/cysiefS/l«Tnal/sartwatef

aj Waterfowl Toxlctty: Data not availablea.3 Biological Oxyg*n Demand (BOD):

.Monoa. 4 Food Chain Concentratkxi Potential:

Nooe


9.1 Grade* of Purity; TecnracaJ tl«kes: USPpelteta

» J Storage Temperature: Amb*ent9u3 Inert Atmoaphera; No roqursmem9.4 VentJniF Open

10. HAZARD ASS£SSM£AT CODE

(See Hazard Aaaamamant Handbook)

SS

1L HAZARD CLASSIFICATIONS

11.1 Cod* of Federal RegUationcCorrosne matenai

11J NA5 Hazard Rating for Buft WaterTranaportattore h4ot tered

11J NFPA Hazard CtaaarflcatkxcC^egory Cta*aMcatlon

Health Hazard (Blue) _. 3FtammaWrtv (Red) 0Reactivity (VeHow) I

12. PHYSICAL AND CHEMICAL PROPERTIES

12.1 PhyHcaJ St«t« «1 15'C and 1 ttm:Soft)

12.2 Molecular W Bight 400012.3 BoJItog Point at 1 atnv ve^1 h^n12.4 Frevxmg Point:

604'F = 318'C = 591'K12^ Crtttca* T*mp*r*tunr Mor fwrtuwnT12.6 CrtOcal Pratauro: Not pertment12-7 Specmc Gravity:

2.13 at 20*C (solid)12.8 Uqutd Surfac* Tarnkxr Not pertinent12-9 UquM Water Intcrfaciaf Ttnatort:

Not pertinent12.10 Vapor (Gas) Specmc Gravity.

Not pertinent12.11 Ratio of Spectnc HeaU of Vapor (Gaa):

Not pertinent12.12 Latent H«t of Vaportzattort

Not pertment12. 13 H**t of Combustion Not pertnent1Z14 Heat of D*compo*mort Not pertnAni12.15 Heat of Solution: Not pemnent12.18 Heat of Pon/mertzatton: Not peronem12^5 Heat of Fualorr 50 0 caJ/g12.28 Limiting Value: Data not available1127 Reid Vapor Pretauf*: Data not available

NOHS

JUNE 198S

169-147 0 - 86 - 60 : QL 3 AR400643

SULFURIC ACID SFA

CM 01 vitriolSattarv aodFerMtzer sodChamber acxj Sinks and mnes violently with, water, frrrtatmg rmt is produced.

AVOID CONTACT WITH LlO'JlD. Keep oeoote awayWear goggles, sell -contained breathing apparatus andStoo discharge ii oossiOleisolate and rernove discharged rnaienai^Jotiry local "eaitn and pollution control agencies

Fire

Exposure

WaterPollution

Not Mammable.May cause tire on contact wrtti combustibles.Flammable oas may be produced on contact wrrh meiata.POISONOUS GAS MAY BE PRODUCED IN FIRE.//ear goggles 5«it-contair>ed brearning acoaraius. arxi 'bODO NQT'USC WATER ON ADJACENT F'RES=xnnguisn with orv cnemtcai w caroon a>oi»o*

CALL rOR L AID

MISTImtating to eyes, nose and ttvoat-II mhated. will cause coughing, ditficull breatnmg. or loss o

consciousness

' : '-MT-ny s :.H'Cu-'. ~ 'Vt

LIQUIDWill bum sJun and eyesHarmful rl swallowed

HARMFUL TO AQUATIC LIFE IN VERY LOW CONCENTRATIONSMay M dangerous '* it enters waier intakes

1. RESPONSE TO DISCHARGE

{Se* Rempon** Method* Handbook)

Issue waming-corrosrveflestnct accessDisperse and i'usn witn care


11 CG CompallbJttty Clasa: Sultunc acxJ

3J Formula: HiSO*13 IMC/UN De**gn»tk>n: 3.0/18303.4 DOT ID No.: 1830

3.5 CAS Regtetry Noj 76W-93-9

2, LABEL

2.1 Category: Corrosrve2.2 CUsm: 8


4.1 Physical State (a* shipped): Liquid

4.2 Cfttor. Cotorie^s ['puret lo dark brown4.3 Ckior Odortesa unless not, then crtotong

5. HEALTH HAZARDS

5,1 Personal protectNe Equipment Safety snower eyewash (ountatrr, safety goggles: face sh*e*d;

approved respirator (setf-contajned or air-line); rubber safety shoes; rubber apron.5J Symptom* FoOowtng Exposure: inhalation crl vapor from hot, concentrated aod may injure lungs.

Swallowing may cause severe injury or death. Contact with skin or eyes causes severe bums.SJ Treatment of Exposure: Call a doctor. INHALATION: observe victim fa- delayed pulmonary

reaction. INGESTION: have victim dnnh water rf possrt>ta-. do NOT induce vommng. EYES AND

SKIN: wash with la/oe amounts ol water lor at least l S rrnn., do not use oris or ointmentt m

eyes: treat sx»n bums.

5.4 TTtrwcrwM Umrt VWue: t mq/m3

SJ Short Term Inhalation LJmrte: 10 mg/m" for S mm.; 5 mg/m3 ror 10 mm.; 2 mg/m» for 30 min.; t

mg/mj for 60 m»n.5.6 Toxtctty by Ingeatlon: No affects except those secondary to tissue oamaoe.

1.7 Ut» Toxterry: NoneSJI Vapor (Gas) Irrflant Charvctertotics: Vapors from hot aod (77-96%) cause moderate irritation ol

eyes and respwtory s-ysiem. Effect is temporary.5.9 LJqukl or SoW Irritant Cheractertatica; 77-98% aod causes severe second- and thirrXleg/ee

bums of skm on short contact and is very injunous 10 Che eyes.5.10 Odor Threshold: Greater than i mg/m»

5.11 IDLH Value: BO mg/m3

& FIRE HAZARDS

U Flarrimabte Umit* ki Air Not flammableaj rV» fcrHnojMaWr Aoert*: Not pertrient8.4 Fir* ExttnguteMng Agent* Not to be

Otedt Water inod on adjacent fVesshould be caretuey handled.

6-5 Special Hazard* of CombustionProduct*: Not pertinent

«.« Behavior In Fir*: Not nammabte

ft.7 (gnrtton Temperam*. Not flammable

OJ Electric* Kazan* None6.9 Burning Rate: Not flammable

8.10 AxftabattC Flame Temperature;

D«ta not available8.11 Stotehtometrie Air To Fuel Ratta

Data not available

8,12 Flame Temperature: Data not available

7. CHEMICAL REACTR/ITY

7.1 Reactivity Wtth Water Reacts viotonOywrth avokrbon ol heal Scattering

occurs when water rs aotlea to thecompound

7J Reecttvrry wttti Common Material*:Extremery hazardous m contact witn

many materials. parbcula/V metals andcombustibles Dilute aod reacts wrmmosl metals, 'ewasmg Hydrogen wtucncan 'orm explosive mortures wrtfi ar in

confined space*.7.3 SUbilrry During Transport Stable7.4 Heutratatng Agent* for Adds and

Cau*tica; Ohjte witn water, men

neutralize wrth time, limestone, of soda

ash.7.5 Potymertzattorr Hot pertinent

7.6 InhltHtOf of Polymerization:Not oertineni

(ContmjBtf)

1 WATER POLLUTION

8,1 Aquabc Toxlctty:

24.5 pom/ 24 hr/bluegill/terhai/fresh

water*2.S ppm/4a hr/prawn/LCio/salt wale*

8J Waterfowl To Hetty: Data not available8J Btotoflteal Oxygen Demand (BOD):

None8.4 Food Chain Concentration Potential

None


9.1 Grate* of Purity: CP". US . TechnrcaJ, at33% to 9d% (SO* Be to 66* Be).

9-2 Storage Temperature: Ambient9JJ Inert Atmocpnere: No requremam

9.4 VerrUng: Open

10. HAZARD ASSESSMENT CODE

A-P-O

1L HAZARD CLASSIFICATIONS

11.1 Cooe of FeOeni Regutrtom:

Corrosive material

11.2 HAS Hnard Rating for Bulk W*tw

Tr«neport»ttoncCrt ory Rating

Fira _ 0Health

Vapor lmtant _. 2LXMd or SoW Irritant „ ._ 4Potsons 2

Water POM*XI

Human Tcnoory 2Aquaoc Tojocrty 3Aestfwbc Eflect 2

Reactrvrry

Other Chemicats 4Wsiw 3

Sett fleacoon 011.3 NFPA Hazard ClaMmcatkMV

Category CteMlftcattonHearth Hazard (BK^e) 3

Flam rnab<lrty (Reo) .0Reactwty (Yellow) 2

u:

12. PHYSICAL AND CHEMICAL PROPERTIES

12.1 PhyBieaJ State at 15*C and 1 atm:LiQU>0

12.3 Molecular Weight 96 03

12.3 BoHIng Portii at 1 atm:644'F = 340'C = 613'K

12.4 Freezing Point Nol pertinent12J> Crtttcat Tftmoeratur*: Not pertneni

12.8 Critical Prewore: Not pertinent12.7 Soectflc Gravtty:

1.84 at 20'C (iKjmd)12.6 Liquid Surface rerwton: Hoi pertinent12.9 Liquid Water InterfaciaJ Tension:

.Sk)t perbnent12-10 Vapor (G*») SpecrMc Gr»vily:

No) portinenr

12.11 Ratio of Spectflc H«ats of Vapor (Ga*Not pertinent

12,12 Latent Heat of VaportzattorcNot pertinent

12.13 Heat of Combuvtton: Nol pertinent12.14 Heat of Decompo tkxr Not pertinent12.15 rtwt olSduttorr — *l8.0Btu/lb

= -232.2 cal/g = —9.715 X 10* J/kg12.16 Heat of Potymertzation: Not perbnent

12.25 Heat of Fusion: Data not avariabtel2-2« Umtttng Value: Data not available12.27 Reid Vapor Prewwre: Low

•Phys^aJ properbes apply TO

concentrated (96%) aodunteu otherwise staled More driute

aod s mxe water-like

7. CHEMICAL RWCTlVrTY (Continued)

7.7 Molar Ratio (Reactant to Prodocit Data not available7J Reacttvtty Group: 2

JUNE 1985

AR400644

DREW A HISTORY OF RESULTSPolymers

PRODUCT DATA

DREWFLOC® 2270 Anionic Flocculant

Description

DREWFLOC 2270 is a very high molecular weight,highly anionic, single component, emulsion polymer.

Applications

DREWFLOC 2270 is highly effective in dewateringindustrial slurries as well as in water clarificationapplications. When used as a flocculant or a coagu-lant aid, typical addition levels range between 0.2-5.0ppm. For sludge conditioning, typical treatment levelsrange between 1-20 Ibs/ton dry solids.

Applications where DREWFLOC 2270 has experi-enced excellent results include enhancement ofphosphorus and heavy metals removal, mineralbeneficiation, paper mill and air scrubber waterclarification, inorganic sludge filtration, food process-ing industry and nonpotable water clarification, andoily waste treatment.

Typical Properties

Appearance:Specific Gravity (25'C):Product Viscosity (25'C):Freeze Point:Flash Point (closed cup):

Pale gray, opaque liquid1.00±0.02500-2500 cps-18'C(OT)Greater than 200'F

Solution Preparation

Before preparing a solution of DREWFLOC 2270, stirthe contents of the drum to insure product uniformity.Since solutions can be more viscous than the neatproduct, a maximum concentration of 1% is recom-mended. Because this polymer is already in liquidform, it is extremely easy to dissolve in water. To

prepare a solution, fill the polymer make-up vesselhalf full with clean water at a temperature below 50'C(120*F). Turn on the mixer and add the appropriatevolume of emulsion to the vortes. Then add theremaining volume of water and mildly agitate for 15-20 minutes.

To insure a continuous supply of polymer solution, aholding tank is recommended in addition to a mixtank. For best results, the solution should be furtherdiluted inline or in the holding tank. Addition of thepolymer solution to the point of application should bewith a variable speed positive displacement meteringpump. Dilute polymer solutions should be used withseven (7) days.

Storage and Handling

DREWFLOC 2270 should be stored where tempera-ture conditions are between 40-95*F. Avoid freezingand direct sunlight which could degrade the product.Product and solution handling should be done withcorrosion resistance positive displacement pumps.Recommended materials for storage and handling areplastic, glass, epoxy lined, or stainless steel equip-ment.

DREWFLOC 2270 will retain its high molecular weightand activity in storage for periods up to six months.

Polymer spills are very slippery and should be wipedup immediately.

Do not take product internally. The use of rubbergloves and a face shield is recommended whenhandling the product.

DREWFLOC is a registered trademark of Ashchem I.P., Inc., used by Drew Industrial Division of Ashland Chemical.JiAll statements, inlormation and data presented herein are believed to be accurate and reliable but are not to be taken as a guarantee, express warranty or ""implied warranty of merchantability or fitness tor a particular purpose, or representation, express or implied, for which seller assumes legal responsibility.and they are offered solely for your consideration, investigation and verification. Statements or suggestions concerning possible use of this product arernade without representation or warranty that any such use is free of patent infringement and are not recommendations to infringe on any patent

Drew Industrial Division • One Drew Plaza, Boomon, New Jersey 07005 • Phone: (201) 263-7800 • Fax: (201) 263-4483

Ashland Chemical

Ashland Chemical CompanyDivision of Ashland Oil. Inc

°1992 Ashland Chemical. Inc. All Rights Reserved. Printed in U.S.A. PYW-DS-31 Rev. 1AR400645

Packaging

DREWFLOC® 2270 is available in bulk or in 55 gallondrums with a net weight of 465 pounds.

Important Information

Drew maintains Material Safety Data Sheets on allof its products. Material Safety Data Sheetscontain health and safety information for yourdevelopment of appropriate product handlingprocedures to protect your employees and custom-ers.

Our Material Safety Data Sheets should be readand understood by all of your supervisory person-nel and employees before using Drew's products inyour facilities.

PYM-DS-31 Rev. 1AR400646

V... .*EW CHEMICAL CORPORATIONDIVISION OF ASHLAND INC.

ONE DREW PLAZA, BOONTON, NJ 07005(201) 263-7600

DREWFLOC 2270 FLOCCULANT PAGE: 1

THIS MSDS COMPLIES WITH 29 CFR 1910.1200 (THE HAZARD COMMUNICATION STANDARD)

24-HOUR EMERGENCY TELEPHONE: 1-800-ASHLAND OR 1-800-274-5263

PRODUCT NAME: DREWFLOC 2270 FLOCCULANT

DATA SHEET NO: 0004749-003.009PREPARED: 02/10/95SUPERSEDES: 01/30/95PRINT DATE: 06/13/95

SECTION I-PRODUCT IDENTIFICATION

GENERAL OR GENERIC ID: FLOCCULANTDOT HAZARD CLASSIFICATION: NOT APPLICABLE

SECTION II-COMPONENTS

IF PRESENT, IARC, NTP AND OSHA CARCINOGENS AND CHEMICALS SUBJECT TO THE REPORT-ING 'REQUIREMENTS OF SARA TITLE III SECTION 313 ARE IDENTIFIED IN THIS SECTION-

SEE DEFINITION PAGE FOR CLARIFICATION

INGREDIENT PERCENT NOTE

ACRYLAMIDE, POLYMER WITH ACRYLIC ACID 85-100 '

( 1 ): PEL/TLV NOT ESTABLISHED FOR THIS MATERIALTHIS MATERIAL CONTAINS HYDROLYZED POLYACRYLAMIDE (CAS tt 250B5-02-3) ;PROPRIETARY INGREDIENTS, WATER, AND AN ISOPARAFFINIC PETROLEUMHYDROCARBON (CASK 64742-47-8) WHICH HAS AN OSHATWA OF 400 PPM.

SECTION III-PHYSICAL DATA

PROPERTY REFINEMENT MEASUREMENT

BOILING POINT UNAVAILABLE

VAPOR PRESSURE UNAVAILABLE

SPECIFIC VAPOR DENSITY UNAVAILABLE

CONTINUED ON PAGE: 2

JUN-13-1995 13 = 52 98X P. 03AR400647


SECTION III-PHYSICAL DATA (CONTINUED)

PROPERTY REFINEMENT MEASUREMENT

SPECIFIC GRAVITY .980 - 1.0806 77.00 DEC F( 25.00 DEC C)

PERCENT VOLATILES 55-70%

EVAPORATION RATE SLOWER THAN ETHER

APPEARANCE OPAQUE, MILKY WHITE

STATE LIQUID

FORM HETER SOLN

SECTION IV-FIRE AND EXPLOSION INFORMATION

FLASH POINT(TCC ) > 200.0 DEC F( 93.3 DEC C)

EXPLOSIVE LIMIT UNAVAILABLE

EXTINGUISHING MEDIA: ALCOHOL FOAM OR CARBON DIOXIDE OR DRY CHEMICAL

HAZARDOUS DECOMPOSITION PRODUCTS: MAY FORM:, CARBON DIOXIDE, CARBON MONOXIDE,AMMONIA, NITROGEN OXIDES

FIREFIGHTING PROCEDURES: WEAR A SELF-CONTAINED BREATHING APPARATUS WITH A FULLFACEPIECE OPERATED IN THE POSITIVE PRESSURE DEMAND MODE WITH APPROPRIATETURN-OUT GEAR AND CHEMICAL RESISTANT PERSONAL PROTECTIVE EQUIPMENT.REFER TO THE PERSONAL PROTECTIVE EQUIPMENT SECTION OF THIS MSDS.

SPECIAL FIRE & EXPLOSION HAZARDS: NO SPECIAL FIRE HAZARDS ARE KNOWN TO BEASSOCIATED WITH THIS PRODUCT.

NFPA CODES: HEALTH- 1 FLAMMABILITY- 1 REACTIVITY- 0

SECTION V-HEALTH HAZARD DATA

PERMISSIBLE EXPOSURE LIMIT: NOT ESTABLISHED; SEE SECTION VIII.

EFFECTS OF ACUTE OVEREXPOSURE:

EYES - EXPOSURE CAUSES EYE IRRITATION. SYMPTOMS MAY INCLUDE STINGING,TEARING, REDNESS, AND SWELLING.


— JUN-13-1995 13:52 98* P.04

AR400648

' DREWFLOC 2270 FLOCCULANT PAGE: 3

SECTION V-HEALTH HAZARD DATA (CONTINUED)

SKIN - EXPOSURE MAY CAUSE MILD SKIN IRRITATION. SYMPTOMS MAY INCLUDE REDNESSAND BURNING.

BREATHING - EXPOSURE TO VAPOR OR MIST IS POSSIBLE.SYMPTOMS MAY INCLUDE:

-IRRITATION (NOSE, THROAT, RESPIRATORY TRACT)- PRE-EXISTING LUNGDISORDERS, E.G. ASTHMA-LIKE CONDITIONS, MAY BE AGGRAVATED BY EXPOSURE TOTHIS MATERIAL.

SWALLOWING - SINGLE DOSE ORAL TOXICITY IS LOW. SWALLOWING SMALL AMOUNTSDURING NORMAL HANDLING IS NOT LIKELY TO CAUSE HARMFUL EFFECTS; SWALLOWINGLARGE AMOUNTS MAY BE HARMFUL.

SYMPTOMS MAY INCLUDE:-GASTROINTESTINAL IRRITATION (NAUSEA, VOMITING, DIARRHEA)-

THIS MATERIAL CAN ENTER THE LUNGS DURING SWALLOWING OR VOMITING AND CAUSE LUNGINFLAMMATION AND/OR DAMAGE.

FIRST AID:

IF ON SKIN: REMOVE CONTAMINATED CLOTHING. WASH EXPOSED AREA WITH SOAP ANDWATER. IF SYMPTOMS PERSIST, SEEK MEDICAL ATTENTION. LAUNDER CLOTHINGBEFORE REUSE.

IF IN EYES: IF MATERIAL GETS INTO THE EYES, IMMEDIATELY FLUSH EYES GENTLY WITHWATER FOR AT LEAST 15 MINUTES WHILE HOLDING EYELIDS APART. IF SYMPTOMSDEVELOP AS A RESULT OF VAPOR EXPOSURE, IMMEDIATELY MOVE INDIVIDUAL AWAYFROM EXPOSURE AND INTO FRESH AIR BEFORE FLUSHING AS RECOMMENDED ABOVE.SEEK IMMEDIATE MEDICAL ATTENTION.

IF SWALLOWED: DO NOT INDUCE VOMITING. THIS MATERIAL IS AN ASPIRATION HAZARD.IF INDIVIDUAL IS DROWSY OR UNCONSCIOUS, PLACE ON LEFT SIDE WITH THE HEADDOWN. SEEK MEDICAL ATTENTION. IF POSSIBLE, DO NOT LEAVE INDIVIDUALUNATTENDED.

IF BREATHED: IF SYMPTOMS DEVELOP, IMMEDIATELY MOVE INDIVIDUAL AWAY FROMEXPOSURE AND INTO FRESH AIR. SEEK IMMEDIATE MEDICAL ATTENTION; KEEPPERSON WARM AND OUIET. IF PERSON IS NOT BREATHING, BEGIN ARTIFICIALRESPIRATION. IF BREATHING IS DIFFICULT, ADMINISTER OXYGEN.

PRIMARY ROUTE(S) OF ENTRY:

INHALATION, SKIN CONTACT

SECTION VI-REACTIVITY DATA

HAZARDOUS POLYMERIZATION: CANNOT OCCURSTABILITY: STABLEINCOMPATIBILITY: AVOID CONTACT WITH:, STRONG OXIDIZING AGENTS, IRON, COPPER,

AND, ALUMINUM, CONTACT MAY RESULT IN CORROSION & PRODUCT DEGRADATION.


JUN-13-1995 13 = 53 98X P. 05AR400649


SECTION VII-SPILL OR LEAK PROCEDURES

STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED:

SMALL SPILL: ABSORB LIOUID ON VERMICULITE, FLOOR ABSORBENT OR OTHER ABSORBENTMATERIAL.

LARGE SPILL: PREVENT RUN-OFF TO SEWERS, STREAMS OR OTHER BODIES OF WATER. IFRUN-OFF OCCURS, NOTIFY PROPER AUTHORITIES AS REQUIRED, THAT A SPILL HASOCCURED.PERSONS NOT WEARING PROTECTIVE EQUIPMENT SHOULD BE EXCLUDED FROM AREA OFSPILL UNTIL CLEAN-UP HAS BEEN COMPLETED. STOP SPILL AT SOURCE, DIKE AREAOF SPILL TO PREVENT SPREADING, PUMP LIQUID TO SALVAGE TANK. REMAININGLIQUID MAY BE TAKEN UP ON SAND, CLAY, EARTH, FLOOR ABSORBENT, OR OTHERABSORBENT MATERIAL AND SHOVELED INTO CONTAINERS.SPILLS OF THIS MATERIAL ARE VERY SLIPPERY.THE AREA SHOULD BE THOROUGHLY FLUSHED WITH WATER AND SCRUBBED TO REMOVERESIDUE. IF SLIPPERINESS REMAINS APPLY MORE DRY-SWEEPING COMPOUND.

WASTE DISPOSAL METHOD:

SMALL SPILL: DISPOSE OF IN ACCORDANCE WITH ALL LOCAL, STATE AND FEDERALREGULATIONS.

LARGE SPILL: DISPOSE OF IN ACCORDANCE WITH ALL APPLICABLE LOCAL, STATE ANDFEDERAL REGULATIONS.

SECTION VIII-PROTECTIVE EQUIPMENT TO BE USED

RESPIRATORY PROTECTION: IF WORKPLACE EXPOSURE LIMIT(S) OF PRODUCT OR ANYCOMPONENT IS EXCEEDED (SEE SECTION II), A NIOSH/MSHA APPROVED AIRSUPPLIED RESPIRATOR IS ADVISED IN ABSENCE OF PROPER ENVIRONMENTALCONTROL. OSHA REGULATIONS ALSO PERMIT OTHER NIOSH/MSHA RESPIRATORS(NEGATIVE PRESSURE TYPE) UNDER SPECIFIED CONDITIONS (SEE -YOUR INDUSTRIALHYGIENIST). ENGINEERING OR ADMINISTRATIVE CONTROLS SHOULD BE IMPLEMENTEDTO REDUCE EXPOSURE.

VENTILATION: PROVIDE SUFFICIENT MECHANICAL (GENERAL AND/OR LOCAL EXHAUST)VENTILATION TO MAINTAIN EXPOSURE BELOW TLV(S).

PROTECTIVE GLOVES: WEAR RESISTANT GLOVES SUCH AS:, NITRILE RUBBEREYE PROTECTION: CHEMICAL SPLASH GOGGLES IN COMPLIANCE WITH OSHA REGULATIONS

ARE ADVISED; HOWEVER, OSHA REGULATIONS ALSO PERMIT OTHER TYPE SAFETYGLASSES. CONSULT YOUR SAFETY REPRESENTATIVE.

OTHER PROTECTIVE EQUIPMENT: TO PREVENT REPEATED OR PROLONGED SKIN CONTACT,WEAR IMPERVIOUS CLOTHING AND BOOTS.


JUN-13-1995 13=53 9BX p.0£AR400650

DREWFLOC 2270 FLOCCULANT PAGE: 5 iff.

SECTION IX-SPECIAL PRECAUTIONS OR OTHER COMMENTS

AVOID CONTACT WITH WATER. THIS MATERIAL IS SLIPPERY WHEN WET.THE INFORMATION ACCUMULATED HEREIN IS BELIEVED TO BE ACCURATE BUT IS NOT

WARRANTED TO BE WHETHER ORIGINATING WITH THE COMPANY OR NOT. RECIPIENTSARE ADVISED TO CONFIRM IN ADVANCE OF NEED THAT THE INFORMATION ISCURRENT, APPLICABLE, AND SUITABLE TO THEIR CIRCUMSTANCES.

LAST PAGE- -LAST PAGE

JUN-13-1995 13-' 54 BQ'/. P. 07AR400651

AR400652

SOP No: 110Rev. Date: 9/01/95

Rev By: LDN/AMC

SOP 110

PACKAGING AND SHIPMENT OF SAMPLES

1.0 PURPOSE AND APPLICABILITY

This SOP describes proper packaging methods and shipment of samples to: (a) minimize

the potential for sample breakage, leakage, or cross contamination, and (b) provide a clear record

of sample custody from collection to analysis. Specific project requirements as described in an

approved Work Plan, Sampling Plan, Quality Assurance Project Plan, or Health & Safety Plan

will take precedence over the procedures described hi this document.

The EPA RCRA regulations (40 CFR Section 261.4 [d]) specify that samples of solid

waste, water, soil, or air collected for the purpose of testing are exempt from regulation when any

of the following conditions apply:

• Samples are being transported to a laboratory for analysis;

• Samples are being transported to the collector from the laboratory after analysis;

• Samples are being stored: (a) by the collector prior to shipment for analyses, (b)by the analytical laboratory prior to analyses, or (c) by the analytical laboratoryafter testing but prior to return of sample to the collector or pending the conclusionof a court case.

Samples collected by RETEC are generally qualified for these exemptions. This SOP deals only

with these sample types.

2.0 RESPONSIBILITIES

The field sampling coordinator is responsible for the enactment and completion of the

chain-of-custody and the packaging and shipping requirements outlined here and in project specific

sampling plans.

I o f 8AR400653


Rev By: LDN/AMC

3.0 SUPPORTING MATERIALS

The following materials must be on hand in sufficient quantity to ensure that proper

packaging and shipping methods and procedures may be followed:

• Chain-of-custody forms and tape;

• Sample container labels;

• Coolers or similar shipping containers;

• Duct tape or transparent packaging tape;

• Zip-lock type bags;

• Protective wrapping and packaging materials;

• Ice or cold packs;

• Shipping labels for the exterior of the ice chest; and

• Transportation carrier forms (Federal Express, Airborne, etc.).

4.0 METHODS AND PROCEDURES

All samples must be packaged so that they do not leak, break, vaporize, or cause cross-

contamination of other samples. Waste samples and environmental samples (e.g., groundwater,

soil, etc.) should not be placed in the same container. Each individual sample must be properly

labeled and identified. Each shipping container must be accompanied by a chain-of-custody

record. When refrigeration is required for sample preservation, samples must be kept cool during

the time between collection and final packaging.

All samples must be clearly identified immediately upon collection. Each sample bottle

label (Figure 1) will include the following information:

• Client or project name, or unique identifier, if confidential;

2 of 8

AR400654

R E M E D I A T I O NT E C H N O L O G I E S I N C

23 Old Town SquareSuite 250

Ft. Collins, CO 80524(303) 493-3700

Fax* (303) 493-2328

SAMPLE l.D.

LOCATION _

DATE TIME SAMPLED BY

TEST(S)_

PRES.

SAMPLE LABEL FIGURE 1

3 of 8AR400655


Rev By: LDN/AMC

• A unique sample description;

• Sample collection date and time;

• Sampler's name or initials;

• Indication of filtering or addition of preservative, if applicable; and

• Analyses to be performed.

After collection, identification, and preservation (if necessary), the samples will be

maintained under chain-of-custody procedures as described below.

4.1 Chain-of-Custody

A sample is under custody if it is in one's possession, in one's view, or in a designated

secure area. Transfers of sample custody must be documented by chain-of-custody forms (Figure

2). The chain-of-custody record will include, at a minimum, the following information:

• Client or project name, or unique identifier, if confidential;

• Sample collector's name;

• Company's (RETEC) mailing address and telephone number;

• Designated recipient of data (name and telephone number);

• Analytical laboratory's name and city;

• Description of each sample (i.e., unique identifier and matrix);

• Date and time of collection;

• Quantity of each sample or number of containers;

• Type of analysis required; and

• Date and method of shipment.

4 of 8

AR400656

CUSTODY SEAL

DATEo>-hoo SIGNATURE

SEAL NO.

R E M E D I A T I O NT E C H N O L O G I E S I N C

REMEDIATION TECHNOLOGIES23 Old Town Square

Suite 250Ft. (Collins, CO 80524

(303) 493-3700Fax* (303) 493-2328

CHAIN OF CUSTODY SEAL FIGURE 2

AR400657


Rev By: LDN/AMC

Additional information may include type of sample containers, shipping identification airbill

number, etc.

When transferring custody, both the individual(s) relinquishing custody of samples and the

individual(s) receiving custody of samples will sign, date, and note the time on the form. If

samples are to leave the collector's possession for shipment to the laboratory, the subsequent

packaging procedures will be followed.

4.2 Packaging for Shipment

To prepare a cooler for shipment, the sample bottles should be inventoried and logged on

the chain-of-custody form. At least one layer of protective material should be placed in the

bottom of the container. As each sample bottle is logged on the chain-of-custody form, it should

be wrapped with protective material (e.g. bubble wrap, matting, plastic gridding, or similar

material) to prevent breakage. Each sample bottle should be placed upright in the shipping

container. Each sample bottle cap should be checked during wrapping and tightened if needed.

Avoid overtightening, which may cause bottle cap to crack and allow leakage. Additional

packaging material such as bubble wrap or styrofoam pellets should be spread throughout the

voids between the sample bottles.

Most samples require refrigeration as a minimum preservative. Reusable cold packs or

ice placed in heavy duty zip-lock type bags should be distributed over the top of the samples.

Two or more cold packs or bags should be used. Additional packing material should then be

placed to fill the balance of the cooler or container.

Place the original completed chain-of-custody record in a zip-lock type plastic bag and

place the bag on the top of the contents within the cooler or shipping container. Alternatively,

the bag may be taped to the underside of the container lid. Retain a copy of the chain-of-custody

record with the field records.

Close the top or lid of the cooler or shipping container and rotate/shake the container to

verify that the contents are packed so that they do not move. Add additional packaging if needed

and reclose.

6 of 8

AR400658


Rev By: LDN/AMC

Place signed and dated chain-of-custody tape (Figure 3) at two different locations (front

and back) on the cooler or container lid and overlap with transparent packaging tape. The chain-

of-custody tape should be placed on the container in such a way that opening the container will

destroy the tape. Packaging tape should encircle each end of the cooler at the hinges.

Sample shipment should occur via an overnight express service that can guarantee 24-hour

delivery. Retain copies of all shipment records as provided by the shipper.

5.0 QUALITY ASSURANCE/QUALITY CONTROL

Recipient of sample container should advise shipper and/or transporter immediately of any

damage to container, breakage of contents, or evidence of tampering.

6.0 DOCUMENTATION

The documentation for support of proper packaging and shipment will include RETEC's

or the laboratory's chain-of-custody records and transportation carrier's airbill or delivery invoice.

All documentation will be retained in the project files.

7 of 8AR400659

OO

O>-tioo

' t C H M O I O O I I f I N C

PROJECT HAHE:

SEND REPORT TO:

PHOME:

REID SAMPLE ID

by: (Signature)

REMEDIATION TECHNOLOGIES23 Old Town Square. Sle 250

Fl. Collins, CO 80524(303) 493-3700

Fax (303) 493-2328

CHAIN OF CUSTODY RECORD

Relinquiirrtd by: (Signotun)

Helinqulirua' by: (Signature)

PROJECT NUUBCR:

(PRIM NAME)

(PRINT NAME)

SHIPMENT METHOD:

AIRBta NUUBER:

UBORATORY RECEMNC:

SAMPLEDATE

SAMPLEHUE

SAMPLEMATRIX

Received by: (Signature)

Received by. (Sljnatufi)

Received by: (Signature)

NUMBER OFCOHUIHERS

PAGE _OF_

COMMEHIS, SPECW.. nc.

LAB SAMPLE D(In ti ccmpl.UJ tr lab)

SAHPU CUST001AH REMARKS (COMPLETEO BY LABORATORY):

LEVEL

LEVEL I O

LEVEL II D

LEVEL HI a

OTHER O

TURNAROUND:

ROUTINE D

24 HOUR a

t WEEK O

OTHER

SAMPLE RECEIPTTOTAL f COMilHERS RECEIVED ?

COC SEALS PRESENT

COC SEALS INTACT 7

RECEJVCD CONTAINERS INTACT ?

TEMPERATURE ?

CHAIN OF CUSTODY RECORD FIGURE 3

AR400660


Rev. By: LDN/AMC

SOP 230

GROUNDWATER SAMPLING

1.0 PURPOSE AND APPLICABILITY

This SOP describes the collection of valid and representative samples from groundwater

monitoring wells. Specific project requirements as described in an approved Work Plan, Sampling

Plan, Quality Assurance Project Plan, or Health & Safety Plan will take precedence over the

procedures described in this document.

2.0 RESPONSIBILITIES

The field sampling coordinator will have the responsibility to oversee and ensure that all

groundwater sampling is performed in accordance with the project specific sampling program and

this SOP. In addition, the field sampling coordinator must ensure that all field workers are fully

apprised of this SOP.

3.0 SUPPORTING MATERIALS

The list below identifies the types of equipment which may be used for a range of

groundwater sampling applications. From this list, project specific equipment will be selected

based upon project objectives and site conditions (e.g., the depth to groundwater, purge volumes,

analytical parameters, well construction, and physical/chemical properties of the analytes). The

types of sampling equipment are as follows:

Purging/Sample Collection

• Bailers and bailer cord;

• Centrifugal pump;

1 of 10

AR400661


Rev. By: LDN/AMC

• Bladder pump; or

• Peristaltic pump.

The most widely applicable equipment that will contact the water must be made of inert

materials, preferably stainless steel or fiuorocarbon resin.

Sample Preparation/Meld Measurement

• pH meter;

• Specific conductance meter;

• Thermometer;

• Filtration apparatus; and

• Water-level measurement equipment.

All equipment will be calibrated before use following the manufacturer's specifications.

General

• Distilled water dispenser bottle;

• Methanol or isopropyl dispenser bottle;

• Decontamination equipment;

• Personal protection equipment as specified in the Project Health andSafety Plan;

• Field data sheets and field book;

• Sample containers, labels, and preservation solutions;

• Buckets and drums;

2 of 10

AR400662


Rev. By: LDN/AMC

• Coolers and ice; and

• Paper towels or chemical-free cloths.

4.0 METHODS AND PROCEDURES

The following sections describe the methods and procedures required to collect

representative ground water samples.

4.1 Water-Level Measurement

After unlocking and/or opening a monitoring well, the first task will be to obtain a water-

level measurement. A static-water level will be measured in the well prior to the purging and

collection of any samples. The water level is needed for estimating the purge volume and may

also be used for mapping the potentiometric surface of the groundwater. Water-level

measurements will be made using an electronic or mechanical device following the methods

described in SOP 231.

The measuring point location for the well should be clearly marked on the outermost casing

or identified in previous sample collection records. This point is usually established on the well

casing itself, but may be marked on the protective steel casing in some cases. In either case, it

is important that the marked point coincide with the same point of measurement used by the

surveyor. If not marked from previous investigations, the water level measuring point should be

marked on the north side of the well casing and noted in the groundwater sampling form (Figure

1). Whatever measuring point is used, the location should be described on the groundwater

sampling form.

To obtain a water level measurement lower a decontaminated mechanical or an electronic

sounding unit into the monitoring well until the audible sound of the unit is detected or indicates

water contact. At this time the precise measurement should be determined by repeatedly raising

3 of 10

AR400663

CtA

REMEDIATION TECHNOLOGIES, INC.Groundwater Sampling Form

PROJECT WELL NO.PROJECT NO. SAMPLERS

1. WELL CONDITION CHECKLISTa. Bump posts Pro. casing/lock Surface padb. Well visibility (paint) ~c. Well label

WATER LEVEL MEASUREMENTDATE TIMEWEATHER CONDITIONSa. Location of measuring pointb. Depth of water table from measuring pointc. Height of measuring point above ground surfaced. Total depth of well below measuring pointe. Length of water column (line 2d—2b)

3. WELL PURGINGDATE TIMEWEATHER CONDITIONS _a. Purge methodb. Required purge volume at 3 well volumes

Pumping Duration/Vol Rmvd pH Cond. T(C) Appearance

4. SAMPLE COLLECTIONDATE TIMEWEATHER CONDITIONS _a. Collection Methodb. Meter Calibration: Date Model

pH MeterConductivity Meter

c. Sample Information pH Cond. T(C)Analysis Containers Sample Prep./Preservation

d. Chain of Custody Form COCTapee. Shipping Container

5. COMMENTS:

4 of 10 FIGURE 1

AR400664


Rev. By: LDN/AMC

and lowering the tape or cable to converge on the exact measurement. The water-level

measurement should be entered on the groundwater sampling form. The water-level measurement

device shall be decontaminated immediately after use following the procedures outlined in SOP

120.

4.2 Purging and Sample Collection Procedures

Well purging is the activity of removing some volume of water from a monitoring well in

order to induce "fresh" groundwater to flow into the well prior to sampling. Under most well

construction and hydrogeologic conditions, this provides water that is more representative of the

groundwater hi saturated materials adjoining the well.

The volume of water to be removed, referred to as the purge volume, is a function of the

water-yielding capacity of the well, the well diameter and depth, and the depth to water made just

prior to purging. The well depth should be sounded with the water-level cable or tape just before

or after measuring the static depth to water. A well volume is defined as the product of the length

of water column and the volume per unit length of well casing, a function of casing inside

diameter. The following data can be used in this field calculation:

Inside Diameter, inches Gallons/foot

1 1/4 0.077

1 1/2 0.10

2 0.16

3 0.37

4 0.65

6 1.64

According to the TEGD (USEPA, 1986), the purge volume should equal at least three well

volumes when the earth materials will yield relatively large quantities of water, and between one

and two well volumes when the earth materials will only yield small quantities to the well. From

5 of 10

AR400665


Rev. By: LDN/AMC

a field operations viewpoint, large quantities (high yield) means that the well can not be pumped

or bailed "dry" by removing three well volumes. Small quantities (low yield) are identified when

the well can be pumped or bailed "dry".

Based on experience and recent scientific literature, it will be RETEC's policy to minimize

the generation of water turbidity when purging. Turbidity is especially of concern when testing

the samples for metals or for selected organics that may be sorbed to the sediment. Turbidity will

be minimized by :

• using a low-pumping rate submersible pump such as a compressed-gasdriven bladder pump; or

• slowly moving the bailer hi and out of the water column; avoid droppingthe bailer and removing it quickly.

Purging will be performed for all groundwater monitoring wells prior to sample collection.

Three general methods are used for well purging. Well purging may be achieved using

bailers, surface pumps, or down-well submersible pumps. In all cases pH and specific

conductance will be monitored during purging. Field parameter values will be entered on the

groundwater sampling form along with the corresponding purge volume. The following sections

explain the procedures to be used to purge and collect samples from monitoring wells.

4.2.1 Bailing

Obtain a clean decontaminated bailer and a spool of polypropylene rope or equivalent

bailer cord. Using the rope at the end of the spool, tie a bowline knot, or equivalent, through the

bailer loop. Test the knot for adequacy by creating tension between the line and the bailer. Tie

again if needed.

Lower the bailer to the bottom of the monitoring well and remove an additional five feet

of cord from the spool. Cut the cord at the spool and secure the rope to the well head

or the wrist of the person who shall perform the bailing.

6 of 10

AR400666


Rev. By: LDN/AMC

Raise the bailer by grasping a section of cord using each hand alternately. This bailer liftmethod is used so that the bailer cord will not come into contact with the ground or otherpotentially contaminated surfaces.

Samples collected by bailing will be poured directly into sample containers from bailerswhich are full of fresh groundwater. Samples will be collected in the following order:

• Volatile organic compounds;

• Semivolatile organic compounds;

• Pesticides/Herbicides/PCBs/Dioxins;

• Organic indicator compounds;

• Metals (total and/or dissolved);

• Miscellaneous inorganic compounds;

• Radiometric compounds; and

• Microbial analyses.

During sample collection, bailers will not be allowed to contact the sample containers.

4.2.2 Pumping

Groundwater withdrawal using pumps is commonly performed with centrifugal, peristaltic,submersible, or bladder pumps. Peristaltic and centrifugal pumps are limited to conditions wheregroundwater need only be raised through approximately 20 to 25 feet of vertical distance.Submersible or bladder pumps can be used when groundwater is greater than 25 feet below grade.Specific methods for pumps will be discussed in the project specific sampling plan. Pumping forcollection of samples to be analyzed for volatile organics will only be with bladder pumps.

7 of 10AR400667

SOP No: 230Rev. Dale: 9/01/95

Rev. By: LDN/AMC

Samples collected by pumping will be transferred directly from the pump discharge tubing

into the sample containers. Samples will be collected in the following order:

• Volatile organic compounds;

• Semivolatile organic compounds;

• Pesticides/Herbicides/PCBs/Dioxins;

• Organic indicator compounds;

• Metals (total and/or dissolved);

• Miscellaneous inorganic compounds;

• Radiometric compounds; and

• Microbial analyses.

During sample collection, the discharge tubing will not be allowed to contact the sample

containers.

4.3 Sample Preparation and FUtration

Specific procedures pertaining to the handling and shipment of samples shall be in

accordance with SOP 110. A clean pair of gloves and decontaminated sampling tools will be used

when handling the samples during collection to prevent cross contamination.

Prior to transport or shipment, groundwater samples may require preparation and/or

preservation. Field preparation may entail filtration, preservation in the form of chemical

additives, or temperature control. Specific preservation requirements will be described hi the

project specific sampling plans.

Groundwater samples collected for dissolved metals analyses will be filtered prior to being

placed in sample containers. Groundwater filtration will be performed using a peristaltic pump

and a 0.45 micron water filter unless otherwise specified in the project specific sampling plan.

8 of 10

AR400668


Rev. By: LDN/AMC

For most dissolved metal analyses, pH adjustment of the sample is also required and shall be

performed after filtration.

5.0 QUALITY ASSURANCE/QUALITY CONTROL

QA/QC requirements include, but are not limited to, blind field duplicates, blind rinsate

blanks, and blind field blanks. These samples will be collected on a frequency of one QA/QC

sample per 10 field samples or a minimum of one QA/QC sample per day unless otherwise

specified in the project specific sampling plan.

6.0 DOCUMENTATION

A number of different documents will be completed and maintained as a part of

groundwater sample collection. The documents will provide a summary of the sample collection

procedures and conditions, shipment method, the analyses requested, and the custody history. The

documents may include:

• Field book;

• Groundwater sampling forms;

• Sample labels;

• Chain of custody; and

• Shipping receipts.

All documentation will be stored in the project files.

9 of 10

AR400669


Rev. By: LDN/AMC

REFERENCES

Handbook of Suggested Practices for the Design and Installation of Ground-Water Monitoring

Wells, EPA 600/4-89/034, published by National Water Well Association, 1989.

RCRA Ground Water Monitoring Technical Enforcement Guidance Document, published by

National Water Well Association, 1986.

A Compendium of Superfund Field Operations, EPA 540/P-87/001, published by the Office of

Emergency and Remedial Response, Office of Waste Programs Enforcement, US EPA, 1987.

10 of 10

AR400670

AR400671

f tPOR T E C H INC 5103T39T36 P . 01

Facsimile Transmission Cover Sheet

To i ivia.ir3-c

Receiving FAX telephone : 508/369/9279

2 pages follow this cover page

Sent by :

David Jewell (President)

Vapor Tech Inc.2222 Second Street #1

Livermore, CA 94550

FAX Telephone : 510/373-9736Voice Telephone : 510/373/9692

In case of trouble, contact : Same as Above

Sent on 05-09-1996 at 09:13

AR400672

VrtPOR TECH INC P. 02

Please read the operating instructions before operatingOPERATING INSTRUCTIONS

i SERIES 1 VAPOR GENERATOR

Three elements necessary for the operation of this unit. Theyaie as follows;

a)b)

AirWaterFuel

The Flow and Pressure rate of these elements are contiengent onthe desired result. RE: BTU etc.

Instructions are as follows;

1) All Valves should be in the. closed position,the unit open the Exhaust Valve 50%.

To :operate

2) Open the Inlet Valves by energizing the Solenoid Valves.Plug the control into 100 VAC. Pull Red Emergency Switch, thiswill energize Valves.

3) Open the Manual Air Valve 25%

4) Turn on Air 100%. This should give throughput out theexhaust,

5) Open the Water Valve until water is emitted from the ex-haust of the generator.

6) Press the start button and gradually open the Fuel Valve.Ignition will take place and steam will be generated.NOTE PRESSING THE STOP BUTTON ON THE CONTROL PANEL WILL ACTI-VATE ALL SAFETY FEATURES IMMEDIATELYThe Vapor Generator has the capability of being completely varia-ble contingent on the requirements of the application. See Belowillustration on cause and effect....

EFFECTS.OF ADDITION AND SUBTRACTION OF COMBUSTION ELEMENTS:

ELEMENT

FUEL ^

AIR

WATER

ACTION

ADD +SUB -

ADD +SUB -

ADD +SUB -

EFFECTONTEMP

INCRE.DECRE .

DECRE.DECRE.

DECRE.INCRE.

EFFECTON

BTU'S

INCRE.DECRE .

DECRE .DECRE .

DECRE.INCRE.

EFFECTON

STEAMSATURATION

DECRE.INCRE.

DECRE .INCRE.

INCRE.DECRE.

AR400673

VftPOR TECH INC 5 1 0 3 T3 9 T :=> 6

OVERVIEW

The Vapor Generator has been designed to produce steam In anextremely wide range of outputs from very high to very low tem-peratures at super saturated or super heated vapor instantaneous-ly. The Vapor Generator also requires less fuel and operates atmore than double the efficiency of conventional boilers. •

Almost all structural units operate at or near ambient /tempera-ture. Conservatively, the Vapor Generator can operate safely intemperature ranges up to 1200F and at pressures upwards oflOOpsi.

With the Generator running, a visual inspection through the "FIREEYE" sight glass into the combustion chamber will give an indica-tion of the combustion efficiency of the valve settings. UsingNatural Gas as a fuel a 100% burn would be indicated with a clearblue flame within the chamber. A yellow flame would indicate aneed for more back-pressure within the combustion chamber.Correcting this is accomplished by fine tuning the outflow valveon the 'Generator. The results of adjusting this valve is veryapparent in smoothness of sound (steady purr or rumble) and asignificant increase in steam production. Once this is accom-plished, other valve adjustments could be made to increase ordecrease output temperature, BTU values, saturation, and fuelconsumption. :

Included for your information:

Combustion Constants of Gases

Combustion Constants and Composition of Representative Manufac-tured and Natural Gases :

Constants for Certain Gases and Vapors

Ignition Temperatures for Various Substances and Limits of In-flammability of Gases

This is;general information, public domain and available at anypublic library. Vapor Tech, Inc. does not represent this informa-tion as its own.

AR400674

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