Attachment 1.pdf

OPERATIONS AND MAINTENANCE MANUAL

VALLEY PARK TCE OU2 SITE

VALLEY PARK, MISSOURI

Superfund Technical Assessment and Response Team (START) 4 Contract

Contract No. EP-S7-13-06, Task Order 0152.000

Prepared For:

U.S. Environmental Protection Agency

Region 7

Superfund Division

11201 Renner Boulevard

Lenexa, Kansas 66219

February 7, 2019

Prepared By:

Tetra Tech, Inc.

415 Oak Street

Kansas City, Missouri 64106

(816) 412-1741

STATE 00000000524SL Attachment 1

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CONTENTS

Section Page

1.0 INTRODUCTION

2.0 SYSTEM OVERVIEW

GROUNDWATER CLEANUP LEVELS

PROCESS FLOW DIAGRAM

PHYSICAL SYSTEM OVERVIEW AND PROCESS FLOW

Extraction Well and Flow Measurement

Anti-Scaling System

Sediment Filtration

Air Stripper

Discharge to Storm Sewer

Controls

SVE Components Not In Use

3.0 OPERATION

MODES AND SEQUENCES OF OPERATION

CONTROLS AND INDICATORS

Control Panel (On Site)

Web-based Remote Interface

OPERATING PROCEDURES

Procedures for Normal Startup

Procedures for Normal Shutdown

Procedures for Emergency Shutdown

Winter Operation

4.0 MONITORING AND MAINTENANCE

REMOTE MONITORING

ON-SITE INSPECTION CHECKLIST

ROUTINE MAINTENANCE

Submersible Well Pump and Motor

Duplex Bag Filter Housing

Blower

Air Stripper

Antiscalant Feed System

Piping, Valves, and Flow Meter

GROUNDWATER, INFLUENT/EFFLUENT, AND CAPTURE ZONE

MONITORING

5.0 PROBLEM HANDLING

ALARM NOTIFICATION

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CONTENTS (Continued)

Section Page

ALARM DESCRIPTIONS AND SUGGESTED TROUBLESHOOTING

Well Level Alarm (LL-10)

Bag Filter Alarm (DP-10)

Air Stripper Blower Air Flow Alarm (AF-10)

Air Stripper Blower Differential Pressure Alarm (DP-11)

Air Stripper Sump Alarm (HLA-10)

Storm Drain Float Alarm (HLA-11)

VFD Fault (VFDFLT)

Loss of Power

6.0 UTILITIES, SERVICE PROVIDERS, AND CONSUMABLES

7.0 GENERAL SAFETY PRACTICES

CHEMICAL SAFETY

PERSONAL PRECAUTIONS

HOUSEKEEPING

FIRE PROTECTION

CONFINED SPACE AND CONTROL OF HAZARDOUS ENERGY

APPENDICES

Appendix

A PERIODIC INSPECTION CHECKLIST

ATTACHMENTS

Attachment

1 ANTISCALANT SAFETY DATA SHEET

2 DESIGN DRAWINGS AND DOCUMENTATION

3 MANUFACTURER’S DOCUMENTATION

TABLES

Table Page

1 GROUNDWATER CLEANUP LEVELS

2 H-O-A SWITCH POSITIONS FOR NORMAL STARTUP OF THE GETS

3 UTILITIES, SERVICE PROVIDERS, AND CONSUMABLES

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1.0 INTRODUCTION

The Tetra Tech, Inc. (Tetra Tech) Superfund Technical Assessment and Response Team (START) has been tasked by the U.S. Environmental Protection Agency (EPA) to implement long-term remedial action

(LTRA) related to the groundwater extraction and treatment system (GETS) at the Valley Park TCE

Operable Unit 2 (OU2) site (the site) in Valley Park, Missouri. These LTRA activities include operation and maintenance (O&M) and performance monitoring of the GETS. This document presents an updated

O&M plan for the GETS. In 2006, Black & Veatch Special Projects Corporation (Black & Veatch) installed the GETS at the Valley Technologies property at 555 St. Louis Avenue in Valley Park, Missouri, to address groundwater contaminated by former use of volatile organic compounds (VOC), primarily trichloroethene (TCE), at the site.

This O&M Plan is organized into the following sections:

Section 2.0: Overviews the system, including remedial objectives, a process flow diagram, and an overview of components of the system

Section 3.0: Describes modes and sequences of operation of the GETS and control systems, and provides procedures for operating the GETS

Section 4.0 Provides procedures for routine monitoring and maintenance of the GETS

Section 5.0: Provides information for problem handling, including descriptions of alarms and troubleshooting procedures

Section 6.0: Provides contact information pertaining to utilities serving the GETS and key vendors of equipment and consumables

Section 7.0: References the Health and Safety Plan and presents abbreviated safety practices.

The periodic inspection checklist is in Appendix A.

A safety data sheet (SDS) for the antiscalant, half-size record drawings and other design documents, and manufacturer’s data (including equipment manuals and specifications) are in attachments as follows:

Attachment 1: Antiscalant Safety Data Sheet

Attachment 2: Design Drawings and Documentation

Attachment 3: Manufacturer’s Documentation.

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2.0 SYSTEM OVERVIEW

The GETS is a pump and treat groundwater remediation system designed to provide hydraulic containment and treatment of VOC-contaminated groundwater in the vicinity of 555 St. Louis Avenue in

Valley Park, Missouri—the location of the Valley Technologies, Inc. facility where previous industrial activities resulted in release of VOCs (primarily TCE) into groundwater. The GETS pumps groundwater from a single extraction well within the treatment system building, and treats the water by use of a six-tray air stripper to remove VOCs before discharging the treated water to a storm drain that empties into the Meramec River. The GETS was originally designed to operate in conjunction with a soil vapor extraction system (SVE). Both the GETS and SVE systems were installed as a combined system in 2006;

however, following construction, the SVE wells failed to produce adequate air flow (likely due to flowable fill that had seeped into permeable soils in which the SVE wells were screened), and the SVE system was considered inoperable. The GETS portion of the system has been operated since 2006, and has provided ongoing hydraulic containment of the plume and treatment of groundwater. Under normal operation, the GETS pumps and treats approximately 180 gallons per minute (gpm).

The primary components of the GETS are:

• A 12-inch groundwater extraction well installed to approximately 63.5 feet below ground surface

(bgs). A 20-foot section of screen was installed from approximately 42.9 to 62.9 feet bgs.

• A 15-horsepower submersible electric pump powered by a variable frequency drive (VFD).

• A six-tray, stainless steel air stripper, including blower, willow trays, process piping, electrical power, and controls. Discharge from this system flows into the Metropolitan Sewer District

(MSD) storm sewer system, which discharges to the Meramec River.

The GETS is housed in an approximately 1,100-square-foot metal building equipped with electric space heaters to protect equipment during low temperatures. The layout of the building and system is illustrated on site drawings prepared by Black & Veatch (Attachment 2).

The following describes groundwater cleanup levels, process flow, and physical components of the GETS.

GROUNDWATER CLEANUP LEVELS

A 2001 Record of Decision (ROD) selected a groundwater remedy for the site that included installation of the GETS to address VOC-contaminated groundwater in the vicinity of the Valley Technologies’ property. The selected remedy in the 2001 ROD was designed to restore groundwater to drinking water standards. Table 1 lists groundwater cleanup levels established for the site in the 2001 ROD.

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TABLE 1

GROUNDWATER CLEANUP LEVELS

Chemical Groundwater Cleanup Level

(micrograms per liter [µg/L])

Trichloroethene (TCE) 5

Tetrachloroethene (PCE) 5

1,1-Dichloroethene (DCE) 7 cis-1,2-DCE 70 trans-1,2-DCE 100

1,1,1-Trichloroethane (TCA) 200

1,1,2-TCA 5

Vinyl chloride 2

A groundwater monitoring well network was installed to monitor performance of the GETS and ensure containment of the contaminant plume.

PROCESS FLOW DIAGRAM

VOCs in the extracted groundwater are removed and discharged to the atmosphere by use of an air stripper. Before entering the air stripper, the extracted groundwater is also treated with an antiscalant and is passed through a bag filtration system to remove sediment. Treated water exiting the air stripper

(effluent) is discharged to a storm sewer that empties into the Meramec River. Exhibit 1 presents a process flow diagram of the GETS.

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Exhibit 1. Process flow diagram for the Valley Park TCE OU2 GETS.

PHYSICAL SYSTEM OVERVIEW AND PROCESS FLOW

The following sections describe the physical components of the GETS and the process flow.

Extraction Well and Flow Measurement

The GETS extracts groundwater by use of one 12-inch extraction well installed to total depth of 63.5 feet bgs within the footprint of the treatment building. During development, the well produced a flow rate of approximately 205 gallons per minute (gpm), and based on development observations, achievement of a design rate of 250 gpm was anticipated. A water level control transducer (LC-10) in the well monitors the water level, and the programmable logic controller (PLC) shuts off the pump if the water level is too low.

From the extraction well, water is conveyed through 4-inch stainless steel piping. Water first flows through a flow meter (FM-10) that measures and reports the flow rate to the PLC (see Exhibit 2 below).

From the flow meter, water flows through a butterfly valve, a flanged check valve, and then through a

Y-strainer. A sample port is installed downstream of the flow meter.

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Exhibit 2. Flow meter (FM-10) measures water flow from the extraction well.

Anti-Scaling System

A ProMinent “gamma/L” dosing pump (see Exhibit 3) injects an antiscalant into the water flow to reduce scale deposition on piping and air stripping trays. The antiscalant is injected prior to the sediment bag filters. Dosing rate is a function of stroke length and stroke rate. Stroke length, which determines the volume of antiscalant injected per stroke, is set manually by use of the stroke length adjustment knob on the front of the pump. Stroke rate is calculated by the PLC based on water flow rate, and is sent as an analog control signal (a 4- to 20-milliamp span signal) to the dosing pump. The stroke rate calculation can be adjusted by manipulating the “DP-CH Setpoints” accessible via SiteLink, the web-based remote interface for the GETS (see Section 2.3.6).

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Exhibit 3. A prominent “gamma/l” dosing pump injects antiscalant into the water flow.

Sediment Filtration

The water then flows through a bag filter system before entering the air stripper for removal of sediment

(see Exhibit 4 below). The bag filter system has two bag filter units normally plumbed in parallel (valves can be used to isolate the units so that filters can be changed while the system is operating). The bag filter system is equipped with a differential pressure gauge (DP-10) to indicate plugging of the bag filters (see

Exhibit 5 below).

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Exhibit 4. Filter bag units remove sediment from extracted groundwater prior to flow into the air stripper.

Exhibit 5. A dwyer capsu-photohelic gauge monitors differential pressure of the influent and effluent of the filter bag system. This reading is used to assess loading of the filtration bags.

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Air Stripper

The extracted water enters at the top of the air stripper and cascades down a series of six shallow trays against a countercurrent air flow supplied by a blower and introduced through an air intake duct at the bottom of the air stripper (see Exhibit 6). The intake air duct is 18-inch galvanized steel that includes a louver, inlet silencer, and an air monitoring system. The louver can be adjusted to increase or decrease the amount of intake air to the blower. The diffusive effect of the countercurrent-current strips VOCs from the groundwater. Exhaust air is discharged to the atmosphere via a stack that exits the treatment building.

Exhibit 6. A carbonair stat 400 six-tray stainless steel air stripper removes volatile organic compounds from the extracted groundwater.

Discharge to Storm Sewer

Treated groundwater drains from the air stripper through an 8-inch-diameter pipe plumbed below grade, and discharges into a storm sewer manhole near the southwest corner of the treatment building. The storm sewer ultimately drains into the Meramec River. A sampling port is on the discharge piping near the air stripper to allow collection of samples for monitoring the effluent water to measure system efficiency and compliance with discharge limitations.

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Controls

The system is automatically controlled by a PLC housed in a control panel mounted on the east interior wall of the treatment building. The face of the control panel has various indicator lights, start/stop/reset buttons, emergency stop buttons, and hand-off-auto (H-O-A) switches to provide the on-site user control of the system. The GETS can also be controlled via SiteLink, a web-based remote interface hosted by the control system designer Newterra. Section 3.2 includes illustrations of the on-site control panel and

SiteLink. Section 3.3 conveys information about operation of the GETS via the on-site control panel and

SiteLink. Control system alarms are described in Section 5.0.

SVE Components Not In Use

Although not in use, components of the SVE system remain inside the treatment system building. These components should not require attention by operators of the GETS. However, because these SVE components and associated controls and status lights will be observed during operation of the GETS, they are listed as follows for reference:

• SVE Blower (SVE-20)

• SVE Condensation Pump

• SVE Liquid Separator High High Alarm (LSHH or HLA-20)

• SVE Liquid Separator High Alarm (LSH or HL-20)

• SVE Liquid Separator Low Alarm (LSL or LL-20)

• SVE Differential Pressure Vapor-Liquid Separator (DP-VLS).

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3.0 OPERATION

The GETS should be operated only by qualified individuals who understand the system and the way it is intended to operate. Failure to operate the system properly could result in personal injury, release of contaminants to the environment, or damage to equipment.

The following sections describe modes and sequences of operation, the on-site (control panel) and off-site

(SiteLink website) control systems, and operating procedures. Various operations can be initiated by use of either the on-site control panel or via the SiteLink website. For clarity, when describing a control accessed from the control panel, the notation Control Panel::Control is used (e.g., Control

Panel::START WATER). Likewise, the notation SiteLink::Control is used when describing controls accessed from the SiteLink website.

MODES AND SEQUENCES OF OPERATION

GETS H-O-A switches allow pumps (extraction well and antiscalant dosing pump) and the air stripper blower to run in either HAND mode or AUTO mode. The HAND mode of operation is generally used for testing (e.g., to troubleshoot failed equipment or during repair work). In HAND mode, the equipment controlled by the switch operates regardless of alarm activation (except the low level well water alarm

[LC-10] that shuts down the extraction well [P-10] even if in HAND mode). If any equipment is being operated in HAND mode, the operator should be continuously present to manually shut down equipment if alarms are signaled.

The GETS is designed to normally operate in AUTO mode and without continuous operator attention.

When the system is operated in AUTO mode, all alarm systems are activated, and an alarm signal automatically shuts down equipment as described below and in Section 5.0.

The following describes sequences of operation of GETS components:

Well Pump P-10 Sequence of Operation

1. When the H-O-A switch for well pump P-10 (Control Panel::P-10) is in the “AUTO” position, the well pump will start if all of the following conditions are met:

a. Water level in groundwater extraction well is above the low alarm level for level control

(LC-10).

b. Water level in the sump of air stripper ASP-10 is below the high alarm level switch

(HLA-10). HLA-10 is a physical float switch in the sump of the air stripper.

c. The motor for the air stripper ASP-10 blower is energized.

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d. Confirmation signal from the Air flow switch AF-10 is received, indicating flow through the air stripper.

e. Confirmation signal from Differential pressure switch DP-11 is received, indicating positive blower pressure for ASP-10.

f. Water level in storm drain inlet manhole #2 is below the high level alarm switch HLA-11.

Note: The “HAND” position for the well pump P-10 selector switch (Control Panel::P-10) bypasses all of the above-listed interlocks except low water level at LC-10, and allows the pump to run under any condition other than low water level in the extraction well.

2. When the PLC detects a water level (LC-10) below the operator selectable low alarm set point

(set in SiteLink), the red LOW WELL ALARM WELL LC-10 light on the control panel is illuminated, and well pump P-10 is stopped. If the water level in the well rises above the operator selectable recovery level (see Section 3.3.1), the red light is extinguished, and well pump P-10 restarts. The water level is displayed for the user on the SiteLink main page.

3. If the water level in the sump of air stripper (ASP-10) rises high enough to activate high level alarm switch HLA-10, the red HIGH STRPR SUMP ALARM HLA-10 light on the control panel is illuminated, and well pump P-10 is stopped if in the “AUTO” position. A 20-second time delay relay minimizes false trip signals by requiring that the high level condition persist for

20 seconds before pump P-10 is stopped.

4. If the water level in storm drain inlet manhole rises high enough to activate the high level alarm switch HLA-11, the red HIGH STORM MANHOLE LEVEL ALARM HLA-11 light on the control panel is illuminated, and well pump P-10 is stopped if in the “AUTO” position. A 20-second time delay relay minimizes false trip signals by requiring that the high level condition persist for 20 seconds before pump P-10 is stopped.

5. If differential pressure switch DP-11 senses inadequate pressure across the air stripper ASP-10 blower, the red ASP-10 AIR FLOW ALARM AF-10/DP-11 light on the control panel is illuminated, and well pump P-10 is stopped if in the “AUTO” position.

6. If air flow switch AF-10 senses inadequate air flow through the air stripper ASP-10, the red ASP-

10 AIR FLOW ALARM AF-10/DP-11 light on the control panel is illuminated, and well pump

P-10 is stopped if in the “AUTO” position.

7. The flow rate of water pumped by the groundwater extraction well pump P-10 is sensed by flow meter FM-10. Flow controller FC-10 modulates the speed of well pump P-10 via the VFD as needed to achieve the operator-input water flow set point as measured at flow meter FM-10.

8. Chemical metering pump CHEM-10 receives a flow signal from the PLC and adjusts the delivery rate of antiscalant proportional to water flow signal from meter FM-10.

Duplex Bag Filter

If differential pressure switch DP-10 senses excess pressure across the duplex bag filter, the red

DP-10 BAG FILTER REPLACE light on the control panel is illuminated. This alarm is informational only, and does not shut down the GETS.

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Air Stripper ASP-10

1. When the HOA switch for the air stripper ASP-10 blower (Control Panel::ASP-10) is in the

“AUTO” position, the blower will start. Upon blower start, if water flow is not detected at flow meter FM-10 within 15 minutes, the blower stops. If the blower is already running and water flow stops at flow meter FM-10 for a period of 15 minutes, the blower will stop. The “HAND” position on the blower selector switch bypasses the flow interlock and allows the blower to run without water flow at FM-10.

2. Motor-operated damper MOD-10 is interlocked with the ASP-10 blower such that the damper opens when the blower motor is energized and closes when it is de-energized.

CONTROLS AND INDICATORS

The system is automatically controlled by the PLC housed in a control panel mounted on the east interior wall of the treatment building. The system can be controlled by use of the on-site control panel or

SiteLink, the web-based remote interface. These systems are described further in the following sections.

Control Panel (On Site)

The face of the control panel has various indicator lights, start/stop/reset buttons, emergency stop buttons, and H-O-A switches (see Exhibit 7 below).

Exhibit 7. The control panel installed in the treatment building provides an on-site interface to the system.

Operation by use of the control panel is described in Section 3.3.

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Web-based Remote Interface

The GETS can be monitored and controlled remotely via a web-based system developed and hosted by

Newterra, and referred to as “SiteLink.” A screenshot of the main page of SiteLink is shown in

Exhibit 8 below.

Exhibit 8. The system developed and hosted by Newterra, and referred to as “SiteLink,” is remote and web-based.

Operation by use of SiteLink is described in Section 3.3.

OPERATING PROCEDURES

The following sections convey procedures for operation of the GETS.

Procedures for Normal Startup

During normal operation, groundwater is pumped to the treatment system through discharge piping from the well at the northwest corner of the treatment building. A Teco Westinghouse VFD powers the extraction well pump and controls the discharge flow rate.

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Normal operation occurs with switches in the AUTO position, enabling automatic startup and alarm sequences. Normal startup is completed as follows:

1. Verify that system is not in an alarm state. If an alarm is indicated, investigate the alarm and address the event, state, or condition that triggered the alarm (see Section 5.0). Reset the alarm by either pressing Control Panel::RESET WATER or SiteLink::RESET SYSTEM.

2. Verify proper valve positions. Generally, all valves between the extraction well and the air stripper should be open except for sample port valves and the bag filter bypass valve. The filter bypass valve should be in the closed position so that water flow is conveyed through the bag filters (see Exhibit 9, which shows the bypass valve in the closed position).

Exhibit 9. During normal operation, the bag filter bypass valve should be in the closed position

(as shown).

3. The antiscalant feed pump (P-11/DP-CH) automatically starts dosing antiscalant when the PLC detects water flow. Verify the following settings for the antiscalant feed pump:

a. Verify that the pump is powered, and check the level of antiscalant in the drum.

b. At the pump, verify the pump’s stroke volume. The default set point is 36%.

c. At the pump, verify the antiscalant pump is in “ANALOG” mode.

d. Within SiteLink, verify the pump’s dosing frequency set points. Default set points are shown below (see Exhibit 10).

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Exhibit 10. This exhibit shows the user selectable chemical feed pump (P-11/DP-CH) setpoints in

SiteLink.

4. Set H-O-A switches for operation of the GETS.

a. At the control panel or via SiteLink, set the ASP-10 blower switch to AUTO.

b. At the control panel or via SiteLink, set the P-10 pump switch to AUTO.

c. Verify that the antiscalant dosing pump is set to AUTO in SiteLink. This switch is accessible only via SiteLink (there is no switch for the dosing pump on the control panel), and can be left in the AUTO position while the system is shut down.

Because the SVE system will not be activated, the SVE blower and SVE condensate pump switches will remain in the OFF position. Switch positions for normal startup of the GETS are listed in Table 2.

TABLE 2

H-O-A SWITCH POSITIONS FOR NORMAL STARTUP OF THE GETS

Switch Switch controls… Switch Location(s)

Position for

Normal

Startup of the

GETS

ASP-10 BLOWER …air stripper blower Control Panel and SiteLink AUTO

SVE-20 BLOWER …SVE blower Control Panel and SiteLink OFF

SVE-20 COND-PUMP …SVE condensate pump Control Panel and SiteLink OFF

VFD P-10 BYPASS …VFD bypass Control Panel OFF

VFD P-10 …groundwater pump Control Panel and SiteLink AUTO

DP-CH …antiscalant dosing pump SiteLink AUTO

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H-O-A switch positions for normal startup of the GETS as viewed on the on-site control panel and on the remote SiteLink web interface appear below in Exhibits 11 and 12, respectively.

Exhibit 11. Control panel H-O-A switches are shown in their positions for normal operation of the GETS.

Exhibit 12. SiteLink H-O-A switches are shown in their positions for normal operation of the GETS.

5. Initiate the startup sequence by pressing either Control Panel::START WATER or

SiteLink::START SYSTEM. This enables an orderly system start as follows:

• The blower starts after MOD-10 Inlet Air Damper proves open after 20 seconds. If

HLA-10, DP-11, and AF-10 alarm switch indicate satisfactory conditions, the well pump start sequence is initiated. If HLA-10, DP-10, and AF-10 air flow rate do not meet preset conditions within 15 seconds, a service alarm is indicated, the blower shuts off, and the well pump is not started.

• The GETS well pump starts in sequence from P-10 provided the LC-10 level transmitter proves that enough water is available in the well. Chemical feed pump Chem-10 starts immediately after the first water flow meter registers. The flow rate is hardcoded in the PLC to 180 gallons per minute.

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Procedures for Normal Shutdown

Normal shutdown stops all motors in an orderly manner. Normal shutdown occurs when the operator makes a deliberate decision to stop operations for maintenance or other elective reason.

Initiate the shutdown sequence by pressing either Control Panel::STOP WATER or SiteLink::STOP

SYSTEM. This initiates an orderly system shutdown, as follows:

1. Well pump P-10 stops immediately.

2. Antiscalant feed pump P-11 stops immediately.

3. Air Stripper Blower B-1 stops 5 minutes after well pump P-10 stops.

After the air stripper blower has stopped, the system is completely shut down. Valves, motors, piping, and other system components can now be opened and serviced, following safety procedures outlined in the Health and Safety Plan. Before any work on electrical equipment, appropriate disconnects must be locked out and tagged out in accordance with the Health and Safety Plan or to industry standards.

Procedures for Emergency Shutdown

To initiate an emergency shutdown, press the red Control Panel::ESTOP WATER. This immediately stops all motors and pumps.

Winter Operation

The GETS is designed to operate full time through winter. The Air Stripper and piping will not freeze provided the building’s heat system is operational. If the system is shut down for maintenance (i.e., normal shutdown), or if an emergency shutdown occurs (e.g., power failure), a freeze could occur during winter. This could cause severe damage to portions of the GETS piping, filtration, and air stripper equipment.

Procedures for Winter Startup

Winter procedures for startup are no different than fair weather startup, as discussed in Section 3.3.1.

Procedures for Winter Shutdown

Procedures for shutting down during winter are the same as those described in Section 3.3.2, except for freeze protection. The operator should ensure that the bag filter, air stripper sump, and pipe are drained in the event of prolonged shutdowns during periods of below-freeze outside temperatures.

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4.0 MONITORING AND MAINTENANCE

This section describes remote monitoring, on-site inspection procedures, and routine preventative maintenance procedures.

REMOTE MONITORING

The GETS status can be monitored via the SiteLink website, which provides alarm status, treatment flow rate (gpm), a treated volume totalizer (gallons), and equipment runtimes (hours) for the ASP-10 blower and P-10 extraction well. In addition, the SiteLink software provides a daily automated system status message (“SiteLink E-Monitor”) consisting of an emailed PDF file that lists the alarm status; last alarm;

minimum, maximum, and average treatment flow rates; the volume totalizer value; and equipment run times.

ON-SITE INSPECTION CHECKLIST

On-site inspection of the GETS should occur periodically to observe the physical condition of equipment, record equipment readings not available through SiteLink, and measure the water level in the extraction well and nearby monitoring wells MW-55 and MW-56. On-site inspections should follow the on-site inspection checklist in Appendix A.

ROUTINE MAINTENANCE

This section addresses routine preventative maintenance procedures for GETS components.

Submersible Well Pump and Motor

Extraction well EW-1 is equipped with a submersible pump. Aside from monitoring flow and pressure in the influent pipe to ensure operation, little field maintenance is necessary to prolong the pump’s effective life. The submersible pump contains sealed bearings that do not require field lubrication, and typically is expected to operate continually for 3 to 5 years or longer without significant maintenance.

Duplex Bag Filter Housing

The air stripper is protected from sediment via a parallel duplex bag filter system. The filter system is equipped with a differential pressure gauge/switch to indicate bag fouling and need for replacement. If the differential pressure gauge/switch senses a pressure exceeding the set point differential pressure, the differential pressure sensor (DP-10) is activated, and the red DP-10 BAG FILTER REPLACE light on

X9025.17.0152.000 19 the control panel is illuminated to indicate need for bag filter replacement. The differential setpoint is established manually by adjusting the red needle of the DP-10 Dwyer Capsu-Photohelic pressure gauge.

A setpoint of 100 to 300 inches of water (in H2O) is suggested.

To replace filter bags:

1. Obtain a replacement filter bag. Use a Farrar Pump & Machinery Company Model DE5D2C bag or equivalent.

2. Isolate one filter unit at a time by closing the top and bottom valves of the filter unit to undergo change.

3. After isolating the filter unit, remove the top cover of the unit by loosening the eye bolts securing the cover.

4. With the cover removed, remove the filter bag and replace with the new filter bag.

5. Secure the top cover with the eye bolts, and open the top and bottom isolation valves of the unit to return water flow through the unit.

6. Observe the DP-10 Dwyer Capsu-Photohelic pressure gauge and confirm that the pressure reading is below the alarm setpoint (a setpoint of 100 to 300 in H2O is suggested).

Blower

The air stripper is equipped with a blower (centrifugal fan) to supply air for the VOC stripping process. A louver and silencer are attached to the intake side of the fan. Aside from monitoring the blower to verify its operation, little maintenance is necessary to prolong its effective life. The blower can be expected to operate from 3 to 5 years continuously without significant maintenance. At that time, the blower may need service such as:

• Bearing replacement

• Motor lubrication

• Fan balancing.

Signs that indicate one or more of the above service needs include heat generation, vibration, loss of performance efficiency, excessive current demand, or unusual noises. Blower failure is not likely to happen suddenly, and, with routine monitoring, ample time should be available to schedule major blower maintenance tasks.

Air Stripper

The air stripper contains six sieve trays and a sump. Based on past operating history, gradual buildup of calcium mineral deposits on the trays is expected—usually on the underside of the bottom-most tray.

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Heavy buildup will interfere with flow of air and water, and reduce contaminant removal efficiency of the air stripper. If airflow is reduced severely, the AF-10 air flow switch will activate and trip the AF-10 air flow alarm, which will shut down the GETS.

Because of potential for gradual mineral buildup, the sieve trays should be monitored by visual inspection through inspection ports on each end of each tray. If significant mineral buildup is noted during an inspection, the sieve tray can be cleaned by pressure washing with water, physically removing the buildup by use of hand-tools, or performing a light acid treatment according to the manufacturer’s instructions.

Cleaning air stripper trays requires careful consideration of health and safety factors, and should occur only according to Health and Safety Plan requirements that specifically address the operations to be performed.

Antiscalant Feed System

An antiscalant feed system is provided to inject antiscalant chemical at an effective concentration into the extracted water just before it reaches the bag filter system. The antiscalant chemical helps control the amount of mineral buildup in the air stripper system. A copy of the SDS for the antiscalant chemical is included as Attachment 1.

The pump, chemical drums, and delivery system should be inspected routinely for leaks and, if found, these should be promptly repaired. Chemical pump settings should be recorded during inspections. The chemical drums should also be monitored to ensure availability of adequate supplies, and for the drum in service, adequate inventory of chemical to last until the next inspection/maintenance site visit.

Personnel working with the low pH (3.7) antiscalant concentrate must follow handling procedures that accord with requirements specified by the chemical manufacturer and the Health and Safety Plan.

Piping, Valves, and Flow Meter

Aboveground piping is welded or flanged Schedule 40 stainless steel. Treatment building piping should be inspected routinely for leaks. The inspection should start at the extraction wellhead, and follow the piping to the chemical injection system, bag filter, air stripper and effluent sump. Pressure gauge readings on each influent pipe and on the effluent pipe should be recorded during inspections. Water meter (instantaneous) flow rates and totalizer (cumulative flow since system installation) readings of influent groundwater should also be recorded.

X9025.17.0152.000 21

Valves should be manually opened and closed monthly, slowly and carefully—preferably when the system has been shut down for other maintenance. This ensures that they operate properly, and reduces likelihood of scale/corrosion interference with valve seating.

GROUNDWATER, INFLUENT/EFFLUENT, AND CAPTURE ZONE MONITORING

Sampling of the Valley Park TCE OU2 groundwater monitoring network, as well as groundwater influent and effluent of the GETS, occurs periodically in accordance with a Sampling and Analysis Plan. Data from this sampling can be used to evaluate performance of the GETS with respect to removal of contaminated groundwater and efficiency of contaminant removal by the air stripper.

X9025.17.0152.000 22

5.0 PROBLEM HANDLING

This section provides information regarding problem handling, including descriptions of alarms and troubleshooting procedures.

ALARM NOTIFICATION

Alarms are signaled by lights on the control panel and on SiteLink. An alarm notification service provided by Newterra sends email and text messaging notifications of alarms (see Section 5.2). The email and text messaging contact list for alarm notification can be modified by contacting Newterra.

Note that an autodialer system was originally installed; however, this system is disconnected and has been replaced by SiteLink and Newterra’s alarm notification service. Some disconnected autodialer equipment remains in the control panel.

ALARM DESCRIPTIONS AND SUGGESTED TROUBLESHOOTING

The GET has various built-in alarm conditions that signal specific problem conditions. This section lists alarm conditions and provides general troubleshooting procedures for various alarms.

Well Level Alarm (LL-10)

The extraction well (EW-1) is equipped with water level transmitter sensors that continuously monitor well water level and signal a low level alarm. To prevent pump cavitation, the low well water level setpoint is set above the pump intake. This setpoint can be adjusted in SiteLink. Excessive drawdown could result from gradual plugging of the well screen or from pumping at too high a flow rate.

In AUTO mode, the low well water level alarm shuts off the submersible well pump. The pump will automatically restart after the well water level returns to a preset start level followed by a 5-minute time delay.

If a low well water level alarm occurs, the operator should closely monitor the well water level to determine if excessive low level shutdowns are occurring (more than four per day). At that point, the level sensor should be removed, inspected, and evaluated following manufacturer's recommendations.

If the sensor is found to be operating normally, the well should be examined for possible cleaning.

X9025.17.0152.000 23

Bag Filter Alarm (DP-10)

The bag filter package is equipped with differential pressure indicators on each housing and differential pressure switch. Differential water pressure is measured across the bag filters, and a service alarm is indicated locally and through SiteLink. In the event of a service alarm condition, the indicated bag filter must be removed and replaced. Activation of this alarm does not shut down the GETS.

Air Stripper Blower Air Flow Alarm (AF-10)

The blower is equipped with a mechanical air flow proving switch that is activated if enough air volume is moving through the duct before the air stripper. If the air flow rate falls below the switch set point, a service alarm is activated, and a normal system shutdown occurs (i.e., all motors are stopped), as described in Section 3.2.3.2.

The alarm switch is pre-set for the air flow rate that will adequately treat influent water. Low air flow could indicate any of the following problems:

• The blower's motor and/or fan are not operating correctly. See the manufacturer's troubleshooting data in Attachment 3.

• Air stripper trays are plugged or starting to plug.

• Mod-10 Damper is not fully open, or intake louver screen is plugged.

Air Stripper Blower Differential Pressure Alarm (DP-11)

The air stripper blower is equipped with a differential pressure switch to measure differential pressure across the blower fan. When differential air pressure exceeds the pre-set level, a service alarm is activated, and a normal system shutdown occurs (i.e., all motors are stopped), as described in

Section 3.2.3.2.

The blower differential pressure could indicate any of the following problems:

• The blower's motor and/or fan are not operating correctly. See the manufacturer’s troubleshooting data in Attachment 3.

• Air stripper trays are plugged or starting to plug.

• Mod-10 Damper is not open or not fully open, or intake louver screen is plugged.

X9025.17.0152.000 24

Air Stripper Sump Alarm (HLA-10)

The air stripper sump is equipped with a high level switch. If water level in the sump reaches a pre-set high level, a service alarm is activated. If water level in the sump continues to rise and exceeds a pre-set emergency stop level, the service alarm continues, and the system shuts down.

An air stripper sump high level could indicate either of the following problems:

• The influent flow rate to the air stripper exceeds hydraulic capacity of the system.

• Storm drain float HLA-11 is in alarm status, and the storm drain is backing up.

Storm Drain Float Alarm (HLA-11)

The discharge storm drain is equipped with a float switch. If water level in the storm drain exceeds a pre-set high level, a service alarm activates. The operator should inspect the storm drain to determine the cause of the alarm.

VFD Fault (VFDFLT)

A fault in the Pump P-10 VFD controller causes an immediate shutdown of the GETS. See the manufacturer's troubleshooting data in Attachment 3.

Loss of Power

If power to the treatment building is interrupted, the system shuts down and an alarm signal is sent by the

Newterra notification system. The GETS will not automatically restart when power is restored—an operator must restart the system via the on-site control panel or remotely using SiteLink.

Power failure during winter operation could result in freezing water in the air stripper sump, filtration system, and influent piping. Therefore, the air stripper and aboveground exterior water piping must be allowed to drain if a power failure occurs and temperatures are forecast below 32 degrees Fahrenheit within the next 24 hours.

X9025.17.0152.000 25

6.0 UTILITIES, SERVICE PROVIDERS, AND CONSUMABLES

Information pertaining to key utility providers, service providers, and consumables necessary for the operation and maintenance of the GETS is in Table 3 below. An inventory of consumables should be maintained to minimize downtime and help ensure efficient operation of the GETS.

TABLE 3

UTILITIES, SERVICE PROVIDERS, AND CONSUMABLES

Utility/Service/Consumable Provider/Vendor Account Number and

Other Information

Electricity Ameren Missouri

1-877-426-3736 5475159008

Water American Water

1-866-430-0820

1017-220021816419

Meter No.: 52716145

Telephone and DSL Line

(not currently used)

AT&T

att.com

636 825-9860 851 0

Phone numbers: 636-825-9860, 636-825-9490

Sewer Metropolitan St. Louis Sewer District

1-866-281-5737 0584570-6

Remote Access and PLC

Support

Newterra, Inc.

1-800-420-4056 Newterra Project 9975

Scale Inhibitor/Dispersant Analtyix Technologies, LLC

281-286-7562 Inhibitor Name: AN-100 NP

Bag filters Farrar Pump & Machinery Co

314-664-1050 Filter: DE5D2C

X9025.17.0152.000 26

7.0 GENERAL SAFETY PRACTICES

This section describes general safety practices to be followed at the site. These practices and procedures are provided for informational purposes and should be referenced in addition to an approved site-specific

Health and Safety Plan.

CHEMICAL SAFETY

The greatest chemical safety concern from an acute standpoint is employee skin/mucous membrane contact with the antiscalant agent water treatment chemical injected into the groundwater upstream from the air stripper. The trade name of the treatment chemical is AN-100NP, which can be an irritant through inhalation or contact (see Safety Data Sheet in Attachment 1).

PERSONAL PRECAUTIONS

All employees participating in site O&M activities should observe basic personal precautions including wearing appropriate personal protective equipment such as gloves, safety glasses, and steel-toed boots.

If working around loud equipment in the Treatment Building or elsewhere on site, personnel should wear hearing protection. Care should be taken to wear clothing appropriate for the Treatment Building environment, where rotating equipment, slippery surfaces, and pinch points may be encountered.

HOUSEKEEPING

The site will be kept clean and neat at all times. Trash must be containerized immediately after generation. If maintenance or repair projects extend through overnight periods, the work area should be secured and cleaned at the end of each work shift. Any liquids released from process piping/equipment or maintenance activities must be removed from floors and other surfaces.

Any leaking equipment/piping associated with the treatment systems will be promptly isolated and repaired. Emergency response spill clean-up kits are maintained at the site, and are equipped with sorbent material that can be used to clean up spills or dripped fluids. All O&M workers should have a supply of sorbent materials on hand to contain releases associated with treatment system operations.

FIRE PROTECTION

At least one 20-pound Class A/B/C fire extinguisher will be wall mounted in the Treatment Building, maintained as specified by Occupational Safety and Health Administration (OSHA) requirements, and

X9025.17.0152.000 27 accessible for fighting incipient (beginning stage) fires. All employees working on site will be familiar with operation of emergency response equipment, including fire suppression equipment.

CONFINED SPACE AND CONTROL OF HAZARDOUS ENERGY

Before commencing any maintenance/repair activity, operators will survey the area to assess potential for entry into a confined space or presence of any mechanical, electrical, hydraulic, or other equipment that could be inadvertently energized, possibly causing injury to space occupants. If such hazards are identified, the operator will consult with his/her supervisor and Health and Safety personnel to determine the appropriate training and procedures for addressing entry into confined spaces or control of hazardous energy (e.g., mechanical, electrical, or hydraulic energy).

APPENDIX A

PERIODIC INSPECTION CHECKLIST

Date Inspected: ___________________ System Status At Arrival: [ ] running [ ] stopped [ ] alarmed

Time Inspected: ___________________ [ ] running [ ] stopped [ ] alarmed

Inspected By: ______________________

Check Physical Components

Component Reading Units (typical operating range)

Extraction Well and Flow Meter

E+H Flow Meter gpm (178 to 182 gpm)

E+H Flow Meter Kgl

E+H Flow Meter gal (use the plus sign only)

Extraction Well Water Level ft below TOC (35 to 40 ft.)

Extraction Well Pressure Gauge psi (8 to 15 psi)

Antiscalant and Metering Pump

Metering Pump Freq (29)

Metering Pump % Set Point (36%)

Antiscalant On-hand gal

Sediment Bag Filters

Pre Bag Filter Pressure psi (5 to 9 psi)

6591A-pre psi (5 to 9 psi)

6591A-post psi (5 to 7 psi)

6591A-pre psi (5 to 9 psi)

6591B-post psi (5 to 7 psi)

Post Bag Filter Pressure psi (5 to 8 psi)

Capsu-Photohelic Reading (black) (DP-10) in H2O

Capsu-Photohelic Gauge Setpoint (red) (DP-10) ~ 300 in H2O Note: 300 in H2O = 11 psi

Air Stripper Blower

Air Stripper Pressure in H2O (35 to 42 in H2O)

Air Stripper Input Flow cfm x 100 (120 to 180)

TECO-Westinghouse Variable Frequency Drive (VFD)

VFD Freq. Cmd Hz (37 to 42)

VALLEY PARK TCE SITE

GROUNDWATER EXTRACTION SYSTEM MONITORING

System Status When Leaving:

Form Revised 10/12/2017

Control Panel and PLC

Site Walk-Around, Well Gauging, and Other Items

Check Each Visit Check Monthly (first week of month)

[ ] Site walk-around [ ] Check antiscalant level

[ ] Check outfall in storm grate [ ] Check air stripper trays

[ ] Drain air stripper stack [ ] Tighten Fernco fittings on air stripper trays

[ ] Gauge monitoring wells

MW-55

MW-56

SiteLink Controls (https://sitelink.newterra.com/)

Flow Meter Readings

FM-10 Flowrate gpm (178 to 182 gpm)

FM-10 Total Volume gal.

Water Level Readings

LC-10 Well ft.

Low Water Well (Low SP) ft. (30 ft)

Pump On Level (ON SP) ft. (175 ft)

Runtimes

VB-SVE & FAN HRS 0 hrs

ASP-10 Blower HRS hrs

P-10 WELL HRS hrs

DP-VLS PUMP HRS 0 hrs

Notes

Depth to Water

(ft btoc)

Total Depth

(ft btoc)

Verify: Are ASP-10 BLOWER-ON and VFD P-10 ON lights illuminated red and all others are off?

[ ] yes [ ] no, explain:

Verify: Are switch positions: AUTO, OFF, OFF, OFF, AUTO [ ] yes [ ] no, explain:

Form Revised 10/12/2017

ATTACHMENT 1

ANTISCALANT SAFETY DATA SHEET

Analytix Technologies, LLC. Safety Data Sheet

AN-100NP

. Date Prepared: 5/20/2015

1. CHEMICAL IDENTIFICATION

Product Name ..................................................................... AN-100NP Recommended Use......................…………………………Water Treatment Antiscalent, Descaler Restrictions on Use......................…………………………Not Determined Emergency Number............................................................ Infotrac 1-800-535-5053 Customer Service Hotline............…………………………281-286-7562 (8 AM to 5 PM CST)

Supplier of SDS:

Analytix Technologies LLC PO Box 590466 Houston TX 77259-0466 Tel: (281) 286-7562 Web: www.analytixtechnoloies.com Email: analytix@earthlink.net

2. HAZARD IDENTIFICATION

This material is not hazardous under the criteria of the Federal OSHA Hazard Communication Standard 29CFR 1910.1200.

3. COMPOSITION / INFORMATION ON INGREDIENTS

Mixture of water treatment chemicals

Chemical Name CAS No. GHS Classification Sodium Polycarboxylate Not Hazardous None Water 7732-18-5 None

Specific chemical identity and/or percentages of composition have been withheld as a trade

4. FIRST AID MEASURES

Eyes ...............................Immediately flush with water for at least 15 minutes, lifting the upper and lower ....................................... eyelids intermittently. See a medical doctor or ophthalmologist immediately.

Skin................................Immediate first aid is not likely to be required. Wash with plenty of soap and water.

.......................................Get medical attention if irritation occurs and persists.

Ingestion ........................Immediate first aid is not likely to be required. Rinse mouth with water. Dilute by .......................................giving 2 glasses of water. Do not induce vomiting. Never give anything by .......................................mouth to an unconscious person. A physician can be contacted for advice.

Inhalation.......................Immediate first aid is not likely to be required. Remove to fresh air. If breathing .......................................difficulty or discomfort occurs and persists, contact a medical doctor.

NOTES TO MEDICAL DOCTOR: The product is corrosive to the eyes and is expected to be irritating to the mucous membranes of the respiratory and gastrointestinal tracts. Treatment is controlled removal of exposure with symptomatic and supportive care.

AN-100NP Page 2 of 4

5. FIRE FIGHTING MEASURES

SUITABLE EXTINGUISHING MEDIA: alcohol resistant foam, CO2, powder, water spray

UNSUITABLE EXTINGUISHING MEDIA: Water jet

SPECIAL FIRE FIGHTING PROCEDURES Wear self-contained breathing apparatus with a full face piece operated in the positive pressure demand mode when fighting fires.

HAZARDOUS DECOMPOSITION: CO, CO2

6. ACCIDENTAL RELEASE MEASURES

PROTECTIVE PRECAUTIONS AND EMERGENCY PROCEDURES Keep unnecessary personnel away.

Wear appropriate protective equipment and clothing during clean-up. Do not breather mist or vapors. Ensure adequate ventilation

CONTAINMENT PROCEDURE Prevent further leakage or spillage if safe to do so. Contain spills to prevent migration and entry into waterway.

CLEANUP PROCEDURE Contain large spills with dikes and transfer material to appropriate containers for reclamation or disposal.

Absorb remaining material or small spills with inert material and then place in a chemical waste container. For small quantities flush away with plenty of water.

7. HANDLING AND STORAGE

Handling – Avoid contact with eyes, skin and clothing. Avoid breathing vapor or mist and use approved splash goggles and vapor respirator fitted with approved organic cartridge if vaporization or misting occurs. Use with adequate ventilation.

Storage: Store at between 34 – 120 oF. Keep from freezing. Stability may be affected by freezing.

Thaw and stir well before using.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION EQUIPMENT

Control Parameters:

Active Ingredients CAS # Source

OSHA ACGIH NIOSH

Sodium Polycarboxylate Non-Hazardous NE NE NE NE: No Limit Established

Exposure Controls:

Eye Protection: Wear safety glasses with side shields meeting ANSI Z87.1 or approved equivalent.

Hand & Body Protection: Minimize skin contact by wearing protective Neoprene gloves,…