ATTACHMENT 7 - DFSP Pt. Loma Remediation System SLUG PLAN.pdf

Slug Prevention and Control Plan

DFSP Point Loma Remediation System

For

DLA INSTALLATION SUPPORT FOR ENERGY

NAVAL BASE POINT LOMA

SAN DIEGO, CALIFORNIA

199 Rosecrans Street, Bldg 604 San Diego, CA 92106-0051

Defense Fuel Suport Point Industrial User Permit 08-0008-07A

Connection 220

October 2021

DFSP Pt. Loma Environmental Services SPE60323D5002 Attachment 7

DLA Installation Support for Energy

8725 John J. Kingman Road

Fort Belvoir VA 22060-6222

(Issued October 2021)

Table of Contents

1 GENERAL INFORMATION

1.1 OPERATING HOURS

1.2 LOCATION OF SLUG PLAN AND RECORDS

1.3 PERSONNEL ROLES

1.4 HISTORY OF GROUNDWATER RECOVERY

1.5 PROCESS OVERVIEW

1.5.1 Field Recovery Components

1.5.2 NBPL Bayside Transfer Compound

1.5.3 Groundwater Recovery Compound

1.5.4 Remediation Process Compound (Upper Treatment Area)

2 REMEDIATION SYSTEM DESCRIPTION AND LAYOUT

2.1 FIELD RECOVERY COMPONENTS

2.1.1 Trench Recovery System

2.1.2 Vertical Recovery Wells

2.1.3 Horizontal Wells

2.2 NBPL BAYSIDE TRANSFER COMPOUND

2.2.1 Air Compressor

2.2.2 Control Panel

2.2.3 Recovery Well Manifold Area

2.2.4 Transfer Tank (204-TK-1-EFF)

2.3 GROUNDWATER RECOVERY COMPOUND

2.3.1 H2S Air Venturi Treatment System and H2S SVE Recovery Treatment System ... 15

2.3.2 Influent Holding Tank (604-TK-2-INF)

2.3.3 Oil/Water Separator (OWS-RO)

2.3.4 Equalization Holding Tank (604-TK-1-EFF)

2.3.5 Pretreatment Filtration System and RO System

2.3.6 Filter Press and Waste Tank

2.4 REMEDIATION PROCESS COMPOUND (UPPER TREATMENT SYSTEM)

2.4.1 Oil/Water Separators

2.4.2 Recovered LNAPL Holding Tanks

2.4.3 Inlet Holding Tank (46-TK-1-INF)

2.4.4 Treatment Process Components

2.4.5 Discharge System

3 SPILL CONTAINMENT AND DRAINAGE

3.1 FIELD RECOVERY COMPONENTS AND PIPELINES

3.2 NBPL BAYSIDE TRANSFER COMPOUND

3.3 GROUNDWATER RECOVERY COMPOUND

3.4 REMEDIATION PROCESS COMPOUND

4 SLUG DISCHARGE PREVENTION AND CONTROL

4.1 PREVENTION: SECONDARY CONTAINMENT

4.2 CONNECTION 220 DISCHARGE CONTROLS

4.3 PROGRAMMABLE LOGIC CONTROL

4.4 OPERATOR CONTROL

5 DISCHARGE MONITORING

5.1 CLASSIFICATION BY FEDERAL POINT SOURCE CATEGORY

5.2 PRETREATMENT STANDARDS AND POINT OF COMPLIANCE

6 PERSONNEL TRAINING

7 SECURITY

8 DISCHARGE NOTIFICATION AND DOCUMENTATION PROCEDURES

8.1 NOTIFICATION

8.2 DOCUMENTATION

APPENDICES

Appendix A: Facility Diagrams

A-1 Remediation System Figures A-1 DFSP Point Loma Recovery System / Work Areas A-2 NBPL Bayside Transfer Compound Facility Diagram A-3 Groundwater Recovery Compound Facility Diagram A-4 Remediation Ptocess Compound Facility Diagram A-2 Piping & Instrumentation Diagrams (P&IDs) E-1 P&ID – NBPL Bayside Transer Compound, Building 204 Area E-2 P&ID – Groundwater Recovery Compound, Building 604 Area

E-3 P&ID – Upper Treatment System, Building 4 Area

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Slug Prevention and Control Plan DFSP Point Loma Remediation System

Record of Changes and Reviews

Date Section/Page Number Reason For Change/Review By Approved 6/22/15 Entire Document Initial submittal of Slug Plan, which isolated the groundwater treatment plant and incorporated the recovery system components in order to create a stand-alone Slug Plan for the DFSP Point Loma Remediation System

A separate plan is required for IUDP Compliance

James Horna 9/03/15

9/30/15 Entire Document Incorporate NAVFAC review comments James Horna 9/30/15 7/28/18 Entire Document Review and revision required by contract. Tracy Rich /

Mark Unruh / Dezbah Jesus

10/5/21 Entire Document Annual review Kayla Carpenter / Mark Unruh

The Slug Plan shall be implemented, reviewed at least annually and then revised and submitted to the City Industrial Wastewater Control Program (IWCP) within 30 days of making any changes at the facility affecting the potential for a Slug Discharge.

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DFSP POINT LOMA REMEDIATION SYSTEM

1 GENERAL INFORMATION

1.1 OPERATING HOURS

The DLA Installation Support for Energy (DLA Energy)-owned, contractor-operated Defense Fuel Support Point (DFSP) Point Loma Remediation System operates continuously, with manned operational hours of Monday through Friday 0700-1530 local time.

1.2 LOCATION OF SLUG PLAN AND RECORDS

A copy of the (1) Slug Plan Prevention and Control Plan, (2) internal notification procedures, and (3) the Industrial User Discharge (IUDP) Permit (# 08-0008-07-A) will be posted at the on-site Remediation System office (Building 604). The original documents will be kept on file in the DLA Energy contractor’s office. Daily log book entries of facility operations (including calibration records, maintenance records, and continuous monitoring instrumentation recordings), tank inspections, prior spills, and permit application information are also available at the DFSP Point Loma Remediation System (Remediation System) office.

1.3 PERSONNEL ROLES

Personnel having a role in the implementation of slug prevention and a spill response plan are listed in Table 1. Section 8 discusses the notification procedure for personnel, in the event of slug discharge to the City of San Diego sanitary sewer system.

Table 1. Slug Prevention and Spill Response Contacts

Title Name Phone Number

DLA Energy Project Manager Remedial and Contracting Officer’s Representative

Bill Potter Off: 571-767-3022

NBPL Installation Environmental Program Director Rob Chichester Off: 619-553-0526

Cell: 619-548-5787

DLA Energy Contractor (APTIM) Program Manager Chris Corey Off: 925.288.2385

Cell: 949.466.4816

DLA Energy Contractor (APTIM) Project Manager Mark Unruh Cell: 951-805-5650

DLA Energy Contractor (APTIM) Remediation System Lead Operator

Alonzo Beehler Off: 619.222.2927 Cell: 619.990.1777

1.4 HISTORY OF GROUNDWATER RECOVERY

Several releases to the groundwater table have been documented during the operational life of the fuel terminal. The tanks and piping that released the fuels have either been removed from service or repaired and are no longer a source. A comprehensive series of soil and groundwater investigations have been completed to ascertain the spatial extent and characteristics of fuel hydrocarbons beneath the facility. Groundwater monitoring wells have been installed throughout the fuel terminal to monitor water quality.

In an effort to prevent the migration of light non-aqueous phase liquid (LNAPL) toward San Diego Bay, several interim-action pumping systems were installed in former observation/monitoring wells while the assessment work was performed. The first of these interim systems began operation in 2000 and was expanded to include the NBPL Bayside compound in 2003. During a multiple-tank site assessment, the interim system was extended toward the northern boundary of NBPL. A second interim-action pumping system was installed farther north in 2006. Both systems utilized pneumatically-powered total fluid pumps in vertical extraction wells for removal of groundwater and LNAPL to be processed at the FLC-operated FOR plant. A third interim-action recovery system was installed in the area of former Tank 63 in 2006. The interim Tank 63 system utilized pneumatic-powered skimmer pumps to recover LNAPL on the groundwater. The interim-action recovery systems were dismantled after a replacement recovery system (RRS) was designed and installed.

The DLA Energy has designed and constructed a replacement groundwater and light non-aqueous phase liquids (LNAPL) extraction system (currently referred to as the DFSP Point Loma Remediation System) to facilitate the remediation of historic fuel releases at the DFSP Point Loma fuel terminal. The system was designed to extract LNAPL and groundwater with separate and dissolved phase petroleum hydrocarbons. The Remediation System began operation in November 2014 and is now fully-operational.

1.5 PROCESS OVERVIEW

The DLA Energy-owned, contractor-operated Remediation System recovers LNAPL and total petroleum hydrocarbon (TPH)-contaminated groundwater associated with historic fuel releases from fuel terminal operations at various locations in and around the DFSP Point Loma. The Remediation System is used to recover the oil for reclamation and/or disposal, and treats the groundwater for discharge either to Connection 220 or for site reuse. The LNAPL and TPH contaminants include aviation gasoline (AvGas), motor gasoline (MoGas), jet propellant number 5 (JP-5, also known as NATO F-44), and diesel fuel, marine grade (DFM, also known as NATO F-76).

The Remediation System is located along Rosecrans Street in the northeastern corner of the Naval Base Point Loma (NBPL). The entire system includes four major component areas or compounds which have evolved as a result of the delineation, recovery, and monitoring of the contaminant plume. The compound locations and operational areas of the Remediation System are shown on Figure A-1 in Appendix A and are summarized below. Locations of the equipment withing the individual codmpounts are shown on Figures A-2 through A-4. Table 2 lists the tank numbers, locations, contents, and dimensions, as well as describing secondary containment.

1.5.1 Field Recovery Components

Recovered LNAPL and TPH-contaminated groundwater are extracted through field recovery systems. These include six vertical recovery wells, two trench and sump collection systems and five horizontal recovery wells.

1.5.2 NBPL Bayside Transfer Compound

The Naval Base Point Loma Bayside (NBPL Bayside) Transfer Compound collects TPH-contaminated groundwater and recovered LNAPL from three vertical recovery wells (10MW-14, 10MW-17, and 10MW-20). The recovered LNAPL and contaminated groundwater are temporarily held in a transfer tank before being transferred to the Groundwater Recovery Compound (Building 604 Area) for initial processing and treatment. Horizontal well HW-01 is located in the NBPL Bayside parking lot. System details are provided in Section 2 and Table 2.

1.5.3 Groundwater Recovery Compound

The Groundwater Recovery Compound (Building 604 Area) collects TPH-contaminated groundwater and recovered LNAPL transferred by pipelines from the field recovery components, including fluids transferred via the NBPL BAYSIDE Transfer Compound. This compound includes an influent balancing tank, an effluent tank, an oil/water separator, various filters for treatment (including a sand filter), two parallel revserse osmosis (RO) units, chemical storage tanks, a hydrogen sulfide (H2S) air venture treatment system, and a H2S soil vapor extraction (SVE) recover treatment system. System details are provided in Section 2 and Table 2.

1.5.4 Remediation Process Compound (Upper Treatment Area)

The Remediation Process Compound consists of various influent and effluent handling systems for the treatment and disposition of all fluids associated with the groundwater recovery and remediation efforts at the DFSP Point Loma plus a filter press and waste tank. This compound is where discharge to Connection 220 occurs. System details are provided in Section 2 and Table 2.

Table 2. DFSP Point Loma Remediation System Container and Secondary Containment Capacities

CONTAINER

NO.

TANK

(Description)

CONTENTS VOLUME

(Gallons)

SIZE

(Dimensions)

SECONDARY

TANK

CONTAINMENT

SPILL

CONTAINMENT

STRUCTURE

NBPL Bayside Transfer Compound 204-TK-1-EFF Transfer Tank LNAPL and TPH contaminated GW 1,000 Width: 5 ft;

Length: 11 ft;

Height: 5.5 ft

Tank secondary:

Double-walled steel tank

Asphalt-bermed area:

112 gallon capacity

Groundwater Recovery Compound 604-TK-1-EFF Effluent Tank LNAPL, TPH contaminated GW, RO treatment waste water, filter back flush

2,000 Width: 8 ft;

Length: 11.25 ft;

Height: 5.5 ft

Tank secondary:

Double-contained convault tank

Containment area:

814 gallon capacity

604-TK-2-INF Influent Tank LNAPL and TPH contaminated GW

1,700 Diameter: 6 ft;

Height: 8 ft

Tank secondary:

None

Concrete containment area: 2,306 gallon capacity

OWS-RO OWS for RO System at Building 604

TPH contaminated groundwater and recovered LNAPL

240 Width: 3.5 ft;

Length: 6 ft;

Height: 4.5 ft

Tank secondary:

None

604-TK-3-CHEM Chemical Storage Tank

Chemical Storage:

anti-scalant

75 Diameter: 2 ft;

Height: 4 ft

Tank secondary:

None

604-TK-5 CHEM Chemical Storage Tank

Chemical Storage:

anti-scalant

75 Diameter: 2 ft;

Height: 4 ft

Tank secondary:

None

604-TK-6 RES Separator Tank Recovered oil? and waste water

10 Width: 18 inches;

Length 18 inches;

Height: 18 inches

Tank secondary:

None

Remediation Process Compound Tanker Truck Loading Pad

Loading Pad Capture spills during truck loading

Not applicable

Width: 20 ft;

Length: 83 ft;

Height: varies (9 inches to 1 ft)

Not applicable Concrete containment area: 9,500 gallon capacity

TANK

(Description)

CONTENTS VOLUME

(Gallons)

SIZE

(Dimensions)

SECONDARY

TANK

CONTAINMENT

SPILL

CONTAINMENT

STRUCTURE

46-TK-1-BO Truck Rack Blow

Out Tank #1 Wastewater and recovered LNAPL from High Flash and Low Flash Tanks

120 Diameter: 5.75 ft;

Height: 2.25 ft

Tank secondary:

None

Located in Concrete containment area of the Tanker Truck Loading Pad: 9,500 gallon capacity

46-TK-1-INF Remediation Process Influent Tank

Wastewater from OWSs

10,000 Diameter: 12 ft;

Height: 14 ft

Tank secondary:

None

Containment area:

17,803 gallon capacity

46-TK-2-HIF High Flash Tank Recovered LNAPL

(DFM/JP5)

20,000 Diameter:10 ft;

Length: 34 ft and 8 inches

Tank secondary:

double-walled steel tank

46-TK-3-LOF Low Flash Tank Recovered LNAPL (Avgas/Mogas)

12,000 Diameter: 8 ft;

Length: 32.5 ft

Tank secondary:

double-walled steel tank

46-TK-1-CLY Clay Vessel # 1 Clay and water 1000 Diameter: 3 ft;

Height: 6 ft

Tank secondary:

None

46-TK-1-CAR Carbon Vessel # 1 Carbon and water 1000 Diameter: 3 ft;

Height: 6 ft

Tank secondary:

None

46-TK-2-CAR Carbon Vessel # 2 Carbon and water 1000 Diameter: 3 ft;

Height: 6 ft

Tank secondary:

None

46-TK-1-EFF Filter Press Effluent Tank

Wastewater 200 Diameter: 2.5 ft;

Height: 6 ft

Tank secondary:

None

OWS-HIF High Flash OWS TPH contaminated GW and recovered

LNAPL (DFM/JP5)

600 Width: 4 ft;

Length: 6 ft;

Height: 5 ft

Tank secondary:

None

OWS-LOF Low Flash OWS TPH contaminated GW and recovered

LNAPL

(Avgas/Mogas)

600 Width: 4 ft;

Length: 6 ft;

Height: 5 ft

Tank secondary:

None

604-OWS OWS for fluid rejected from RO System at Building

TPH contaminated GW, RO treatment waste water, filter

1200 Width: 5 ft;

Length: 7.5 ft;

Height: 5 ft

Tank secondary:

None

TANK

(Description)

CONTENTS VOLUME

(Gallons)

SIZE

(Dimensions)

SECONDARY

TANK

CONTAINMENT

SPILL

CONTAINMENT

STRUCTURE

back flush and Recovered LNAPL

46-TK-4-EFF Effluent Tank # 1 Treated GW 10,000 Diameter: 12 ft;

Height: 14 ft

Tank secondary:

None Included in

Containment area:

17,803 gallon capacity 46-TK-5-EFF Effluent Tank # 2 Treated GW 10,000 Diameter: 12 ft;

Height: 14 ft Tank secondary:

None

Notes:

The tanks listed in BOLD are those that are subject the requirements of 40 CFR 112. The remaining containers are part of the wastewater treatment process and do not store oil; they included for completeness.

Avgas = Aviation gas DFM = Diesel fuel, marine grade ft = foot (feet) GW = groundwater JP5 = Jet propellant 5

LNAPL = Light non-aqueous phase liquid Mogas = Motor gas OWS = Oil/water separator RO = Reverse osmosis TPH = Total petroleum hydrocarbons

2 REMEDIATION SYSTEM DESCRIPTION AND LAYOUT

The Remediation System operates with a programmable logic control (PLC) system, which monitors and records numerous input parameters, system setpoints and operational controls, and provides defined output signals for actuated system components. The DFSP Point Loma Remediation System PLC has operator interface or human machine interface (HMI) locations at each compound and a desktop computer inside Building 604 for on-site operations, as well as an internet connection for remote access and monitoring. The entire system layout is shown in Appendix A, Figure A-1 “DFSP Point Loma Remediation System.” The system components, piping connections, and instrument locations are shown in the three pages of P&ID Figures of A- 2 in Appendix A.

2.1 FIELD RECOVERY COMPONENTS

The recovery system currently extracts LNAPL and TPH-contaminated groundwater from a trench and sump recovery system, six vertical wells, and five horizontal wells. Four of the five horizontal wells were installed in the Aboveground Storage Tank (AST) Facility in 2016, and pump directly to the Remediation Process Compound. The remaining horizontal well (HW-01) is located beneath the NBPL Bayside parking lot and Rosecrans Street and pumps to the Groundwater Recovery Compound. All of these field recovery components convey the recovered LNAPL and TPH-contaminated groundwater through below- and above-ground double-contained high density polyethylene (HDPE) piping to the Remediation System. The conveyance piping systems have leak detection in all below-grade interconnect or valve vaults which will alarm and shutdown recovery operations should liquid be detected in the vaults.

2.1.1 Trench Recovery System

The trench recovery system is comprised of two extraction trenches that begin near the northern property boundary, run end to end parallel to the west side of Rosecrans Street, and extend approximately 900 feet to the south. Each trench is:

• Constructed of 6-inch diameter perforated HDPE pipe placed at an elevation of 5 feet below mean sea level (msl), and

• Has a 36-inch diameter HDPE vertical sump at each end (North Sump and South Sump).

Each sump has one product belt skimmer and an electric grinder submersible pump. The pumps are automatically controlled by level sensors to maintain drawdown during normal operations and each discharge at a regulated flow of 50 to 60 gpm, with interlocking controls to match the RO treatment system flowrates. The product belt skimmer is an oil skimming system with a rotating oleophilic belt to raise LNAPL from the sump liquid level, and then pump directly to the 20,000-gallon steel double-walled tank (46-TK-2-HIF). The North Sump pump is controlled by level switches through the PLC, while the South Sump pump is controlled by a transducer through the PLC.

2.1.2 Vertical Recovery Wells

The six vertical recovery wells include:

• Three NBPL Bayside wells (10MW-14, 10MW-17, and 10MW-20) which o Are located within the NBPL Bayside parking lot;

o Are constructed of 4-inch diameter polyvinyl chloride (PVC);

o Extend to depths of approximately 43 feet below ground surface (bgs) o Convey fluids through double-contained high-density polyethylene (HDPE) piping to the NBPL Bayside Transfer Tank (204-TK-1-EFF) in the NBPL Bayside Transfer Compound.

• Three VEX (VEX-02, VEX-03, and VEX-04) wells which o Are installed along the northern property line west of Rosecrans Street;

o Are constructed of 6-inch diameter PVC;

o Extend to depths of approximately 62 feet bgs; and o Convey fluids through double-contained HDPE piping to the Groundwater

Recovery Compound.

The recovery pumps installed in the six vertical recovery wells are pneumatically-operated and operate on air supplied by a centrally-located well field air compressor. Each pump operates continuously to maintain a predetermined water level for hydraulic control of the plume. Pump flowrates will vary based on groundwater conditions and the aquifer. In general, the flowrate is 2 to 7 gallons per minute (gpm).

2.1.3 Horizontal Wells

The final field collection component is the five horizontal wells.

Horizontal well (HW-01):

• Was installed in the south end of the NBPL Bayside parking area;

• Has dedicated piping and pumps directly to the Groundwater Recovery Compound;

• Is a 4-inch diameter well, constructed of perforated and solid stainless steel casing 870 feet in length; and

• Has a dedicated electric submersible pump.

Horizontal well HW-01 is automatically controlled with a level-sensing transducer which cycles the pumping operations at approximately 10 gpm to maintain well draw down during normal operation.

The remaining four horizontal wells (HW-02, HW-03, HW-04 and HW-05):

• Are located beneath the DFSP AST Facility;

• Pump to the Remediation Process Compound o Three wells (HW-02, HW-03, and HW-04) pump recovered fluids to one oil/water separator (OWS-HIF), o One well (HW-05) pumps to a different oil/water separator (OWS-LOF);

• Each well is constructed of 6-inch diameter perforated and solid stainless steel casing, varying in length from approximately 1,100 feet to 1,800 feet.

Electric submersible pumps and controlling liquid level monitoring transducers were installed to recover LNAPL and TPH-contaminated groundwater at flow rates between 0.5 and 6 gpm during normal operations, as signaled through the PLC.

2.2 NBPL BAYSIDE TRANSFER COMPOUND

The NBPL Bayside Transfer Compound is a stand-alone facility that transfers the recovered LNAPL and TPH-contaminated groundwater from the three vertical wells (10MW14, 10MW17, and10MW-20), to the Groundwater Recovery Compound. All recovered fluids are conveyed through double-contained nylon tubing and HDPE piping between the wells and to the Groundwater Recovery Compound. Located at the eastern edge of the NBPL Bayside parking lot, the compound is a fenced area with:

• An air compressor,

• A control panel,

• A recovery well manifold area, and

• A transfer tank (204-TK-1-EFF) with submersible transfer pump.

2.2.1 Air Compressor

The three NBPL Bayside vertical well pneumatic pumps operate on air supplied by an Ingersoll Rand® air compressor located at the NBPL Bayside Transfer Compound.

2.2.2 Control Panel

The control panel has an HMI and is part of the main control system (receiving input and permissive signals from the main PLC while also providing output signals and alarms to the controller). The control panel only allows the operator access to operations at the NBPL Bayside Compound (system on/off/reset, tank pump hand/off/auto and air to field hand/off/auto settings).

2.2.3 Recovery Well Manifold Area

The recovery well manifold area is comprised of the well manifold and the inlet bag filter. The well manifold includes valves, air pressure indicator/regulators and pump cycle counters to monitor and control NBPL Bayside wells. The inlet filter is a 25-micron bag in stainless steel canister. The vertical well pumps have flow rates of 2 to 7 gpm each.

2.2.4 Transfer Tank (204-TK-1-EFF)

The transfer tank (204-TK-1-EFF) is a 1,000-gallon double-contained steel convault tank. The level transducer inside the tank monitors tank level, provides a signal for gallon readout on the control panel HMI, automated transfer pump start and stop levels, and high-high level alarm shutdown. The mechanical level switch provides backup alarm/shutdown. The tank discharge pump operates at 50 gpm.

2.3 GROUNDWATER RECOVERY COMPOUND

The Groundwater Recovery Compound is located on the western side of Rosecrans Street, across from Gate Road at the Post 6 guard entrance and adjacent to Building 604. Building 604 is the site operations office for the DFSP Point Loma Remediation System, with on-site records retention, and telephone and internet services. This compound contains a vapor recovery system and a groundwater treatment system. Major components of the Groundwater Recovery Compound include:

• Vapor Treatment o Hydrogen Sulfide (H2S) Air Venturi Treatment System and o H2S Soil Vapor Extraction (SVE) Recovery Treatment System

• Aqueous Treatment o Influent holding tank (604-TK-2-INF), o Oil/water separator (OWS-RO), o Equalization holding tank (604-TK-1-EFF), o A series of pretreatment filters, preceding an RO system, and

2.3.1 H2S Air Venturi Treatment System and H2S SVE Recovery Treatment System The vapor recovery system treats vapors from the influent holding tank (604-TK-2-INF) and the equalization holding tank (604-TK-1-EFF). The system re-circulates tank liquid, injecting air by an air/water mixing jet to release H2S and volatile organic compounds.

The H2S SVE Recovery Treatment System (hydrocarbon and Midas H2S Carbon Absorbers) accepts vapor directly from the influent holding tank (604-TK-2-INF), the equalization holding tank (604-TK-1-EFF), and the oil/water separator (OWS-RO). The treatment system has an H2S Midas® Carbon breather. H2S readings are recorded weekly at the effluent, between carbon, influent, and ambient air. H2S and volatiles recovered by the system are then pushed through primary and secondary carbon drums for capture.

2.3.2 Influent Holding Tank (604-TK-2-INF)

Fluids from the, trench recovery system, vertical wells, and horizontal well HW-01 are pumped into the influent holding tank (604-TK-2-INF) for balancing. Tank 604-TK-2-INF is a 1,700-gallon single-walled steel vertical cylindrical tank with an operating (high level) setpoint of approximately 1450 gallons. Operational controls on tank 604-TK-2-INF include a level transducer with both high- and low-level failure signals to the PLC (in addition to pump on/off and high/high level alarms), and inlet and outlet actuated valves to control the tank level during normal operations. Tank level indications to the PLC will not only control actuation of all inlet valves and the oil/water separator outlet valve, but will also cause shutdown of field recovery components in the event of failure or high/high level alarms. Fluid in the influent holding tank flows by gravity to the oil/water separator (OWS-RO) or to the equalization holding tank (604- TK-1-EFF) via an air diaphragm pump which automatically transfers separated fluids at operator-defined intervals as programmed in the PLC.

2.3.3 Oil/Water Separator (OWS-RO)

The oil/water separator (OWS-RO) is constructed of stainless steel with a sludge and baffle separation chamber, clean water discharge chamber, and a LNAPL holding chamber. It is designed for a 50 gpm flow rate to remove all free and dispersed, non-emulsified oil and settleable solids. Raw water pumps out of the separator using a RO booster pump with a pressurized expansion tank, and is conveyed through the pretreatment filters and RO system.

Conductance level detectors in the water discharge chamber provide a signal to the control system to maintain flow rate and separation by actuation of the inlet valve and control of the discharge pump.

2.3.4 Equalization Holding Tank (604-TK-1-EFF)

Fluids (such as the recovered oil fraction, oily water from the sand filter backwash fluids, and water that does not pass through the RO membranes) are collected in the equalization holding tank (604-TK-1-EFF). Tank 604-TK-1-EFF is a 2,000-gallon double-contained convault tank (steel primary with secondary containment before concrete shell) mounted within a concrete containment area, along with discharge components to transfer untreated water and LNAPL from the Groundwater Recovery Compound to the Remediation Process Compound. The discharge tank controls include a level transducer within the tank to monitor level and provide low- and high-level failure signals to the PLC (in addition to pump on/off and high/high level alarms), and a backup mechanical level-sensing switch. The submersible pump within the tank discharges to the oil/water separator in the Remediation Process Compound (604-OWS) with a permissive signal from the PLC, which is confirmed by monitoring instrumentation at the Remediation Process Compound.

2.3.5 Pretreatment Filtration System and RO System

The pretreatment system includes a control system-operated, variable-frequency-driven booster pump; a 120-gallon diaphragm expansion tank; two 75-gallon chemical storage tanks containting anti-scalant (604-TK-3 and TK-5-CHEM), a fiberglass filtration tank filled with organophilic sand filtration media; a 10-micron filter; and a 5-micron tube filter assembly. The sand filter is periodically back-flushed into the discharge tank using a control system-operated three-way valve (as directed by the system operator). System pressure is monitored automatically by the PLC, with operator-defined setpoints to assure proper functioning and maintenance of the system.

The RO systems are programmed into the PLC for operation of the entire system to coordinate field recovery with RO operation. Each RO system contains a recirculation pump and a feed pump to add an antiscalant chemical to the stream from two tanks (604-TK-3 and TK-5-CHEM), along with a display panel to monitor system flow rate, pressure, and recovery rate. Each RO unit can process 35 to 55 gpm of feed water and recovers approximately 60 percent as treated water during normal operations. The RO units have PLC-actuated inlet control valves and require permissive start signals for normal operations, with the treated water being discharged to the Remediation Process Compound with a permissive signal from the PLC, as confirmed by discharge monitoring instrumentation at the Remediation Compound. The raw water not passing through the RO membranes is transferred to the equalization holding tank (604-TK-1-EFF) for treatment at the Remediation Process Compound. The treated water is pumped by the RO units through a pH meter, oil/water meter, and electronic recorded flow meter. The water is then pumped to the effluent tanks at the Remediation Process Compound System for site use or discharge to Connection 220.

2.3.6 Filter Press and Waste Tank

The waste tank (604-TK-6-RES) collects fluids from the OWS in the Groundwater Recovery Compound and the three OWSs in the Remediation Process Compound during cleanout of the separators. Backflush from the sand filter tank is also directed to the waste water tank. The fluid from the waste tank is conveyed through the filter press.

2.4 REMEDIATION PROCESS COMPOUND (UPPER TREATMENT SYSTEM)

The Remediation Process Compound is located south of Seifert Drive, west of Rosecrans Street, behind Building 46. Four waste streams enter the upper recovery treatment system: the concentrate from Building 604, the recovered LNAPL from the oil skimmers in the recovery sumps, the recovered water and low-flash fuel from horizontal well HW-05, and the recovered water and high-flash fuel from horizontal wells HW-02, HW-03, and HW-04.

The compound includes:

• A tanker truck loading pad;

• Oil/water separators,

• Recovered LNAPL holding tanks (46-TK-2-HIF and 46-TK-3-LOF),

• Inlet holding tank (46-TK-1-INF),

• Treatment process components,

• Discharge system with o Two treated water effluent tanks (46-TK-4-EFF and 46-TK-5-EFF), and o The treated groundwater discharge monitoring system for discharge to

Connection 220.

The tanker truck loading pad is utilized by tanker trucks to remove and transport LNAPL from recovered LNAPL holding tanks (46-TK-2-HIF and 46-TK-3-LOF) to an off-site location.

An 8-foot by 20-foot Conex container is utilized for storage of equipment, materials, and tools. A second conex is used as the Site Control Room for system operations. The entire compound is secured with chain-link fence and lockable access gates for pedestrian and vehicle traffic. A paved access road connects the compound to both Seifert Road and Rosecrans Street.

2.4.1 Oil/Water Separators

Recovered LNAPL and groundwater from the horizontal wells, and the untreated water from the Groundwater Recovery Compound each have separate inlet pipelines and oil/water separators.

Concentrate from Building 604 (604-TK-1-EFF) is pumped to a 100 gpm oil/water separator (604-OWS). The separator has coalescent plates and chambers and is monitored by a level transducer. The OWS has two pumps to transfer water and product. Water from 604-OWS is pumped to the inlet holding tank (46-TK-1-INF), while product is pumped from 604-OWS to 46- TK-2-HIF (20,000-gallon AST).

Lower flashpoint LNAPL from horizontal well HW-05 is pumped to a 50 gpm oil/water separator (OWS-LOF). Water from OWS-LOF is pumped to the inlet holding tank (46-TK-1- INF), while the recovered oil from OWS-LOF is pumped to the 12,000-gallon horizontal steel double-walled tank (46-TK-3-LOF).

Higher flashpoint LNAPL from HW-02, HW-03, and HW-04 is pumped to a 50 gpm oil water separator (OWS-HIF). Water from OWS-HIF is pumped to the inlet holding tank (46-TK-1- INF), while the recovered oil from OWS-HIF is pumped to the 20,000-gallon horizontal steel double-walled tank (46-TK-2-HIF).

2.4.2 Recovered LNAPL Holding Tanks

Following separation, the LNAPL is held in each of the double-walled steel tanks; based on the makeup of the recovered LNAPL the fluid conveys to either tank 46-TK-3-LOF or 46 TK-2-HIF.

The tank discharge pumping system and truck loading pad system is used to convey the LNAPL from each holding tank to a tanker truck for transportation off-site. A phase-specific level sensing instrument, transducer, and backup mechanical high-high level switch in each tank works within the PLC to control operations and display on the HMI touchscreen the various levels within the tanks upon completion of the system.

2.4.3 Inlet Holding Tank (46-TK-1-INF)

From all oil/water separators, the separated or raw water is pumped to the 10,000-gallon cross-linked HDPE inlet holding tank (46-TK-1-INF). The separated water within the inlet holding tank (46-TK-1-INF) is pumped to the remediation treatment system components via a centrifugal pump and 2-inch Schedule 80 PVC piping within the containment area. The pump is controlled within the remediation system programming for manual operator actuation or based on transducer level sensing within the inlet holding tank (46-TK-1-INF). Tank-level sensing instrumentation and PLC programming not only control the pump but will also shut down recovery operations, along with a backup mechanical high-high level switch. Valves and instrumentation allow the flow of untreated water at varying rates to the treatment system components.

2.4.4 Treatment Process Components

Remediation treatment system components include filtration, activated clay, and activated carbon treatment. Water from the inlet holding tank (46-TK-1-INF) is filtered through two parallel stainless steel duplexed basket strainer systems, through two parallel 25-micron filters, then through two paralell 10-micron filter bags, and into a 6,000-pound (lb) clay vessel. The water flows from the clay vessel through a primary (lead) 3,000-pound, liquid-phase, carbon vessel followed by a secondary (lag) 3,000-pound carbon vessel. The carbon vessels are filled with 3,000-lb of liquid-phase activated carbon. Flow, pressure, and temperature instrumentation continuously monitor water treatment conditions and allow PLC system shutdown when conditions are outside established parameters. Valves and piping between the treatment system components allow for continued operation during maintenance and servicing of components in treating the water to meet discharge limits.

2.4.5 Discharge System

The discharge system with options, monitoring, and control are the final aspect of the Remediation System. Treated water can either be pumped to the two 10,000-gallon cross-linked HDPE holding tanks (46-TK-4-EFF and 46-TK-5-EFF), reused on-site if needed, or discharged to the City of San Diego sanitary sewer Connection 220 location in accordance with IUDP # 08- 0008-07-A. Piping and manual valves allow the operator to adjust the discharge location to fit the needs/requirements.

All discharge locations are monitored with flow-metering totalizers. The Connection 220 discharge has additional monitoring and controls, including a flow-measuring totalizer with a local display of flowrate and total flow, and a 4 to 20mA transmitter which provides the flow rate to the PLC for HMI touchscreen display and data recording. Another monitoring instrument in the discharge piping is the pH electrode sensor and transmitter for local display of the measured pH of the treated water. The pH readings are also sent to the PLC for HMI touchscreen display and data recording. The last instrument in discharge piping is an in-line, continuous hydrocarbon detecting oil-in-water monitoring system which utilizes ultraviolet (UV) florescence in an optical chamber, specifically calibrated to the LNAPL recovered on site. This means the system has a lamp bulb for the light source with a finite lifetime (approximately 1 year for the oil in water monitor [OWM-220]). The OWM-220 system is designed to "fail high" with readings of a greater concentration of oil as the bulb decays. Thus should the bulb fail, the monitoring system will alarm and shutdown the Remediation System, prior to an actual discharge outside the permit conditions. This instrument is used to determine parts per million (ppm) levels of any oil in the water stream not removed by the treatment process. These measurements of the concentration of oil in the treated water are displayed at the sensor, then through signal transmission and PLC interpretation, are also displayed on the HMI touchscreen while being recorded within the PLC.

All three of these discharge monitoring systems (flow, pH, and oil-in-water) are also programmed to the PLC to automatically shut down the system should any of those parameters approach the established permit limits.

3 SPILL CONTAINMENT AND DRAINAGE

Secondary containment structures and/or drainage systems provide adequate containment for the tanks at each compound of the Remediation System. Spill kits and absorbent materials are stored in each compound to contain and recover liquids released to the ground surface in and around each containment area. The pipelines operating in the Remediation System are situated underground, except at the three treatment compounds where piping is situated within the concrete containment areas. Spill containment and drainage for each of the four component areas or compounds are detailed below. The DFSP Point Loma Remediation System maintains a separate Spill Prevention, Control and Countermeasure (SPCC) plan in conjunction with the NBPL SPCC and as part of the NBPL Integrated Contingency Plan (ICP) onsite. Table 2 summarizes tank capacities, contents, and spill containment characteristics.

3.1 FIELD RECOVERY COMPONENTS AND PIPELINES

The double-contained collection and transfer pipelines in the Remediation System have leak detection systems installed in all below-grade interconnect or valve vaults. The concrete vaults are installed within sumps and contain mechanical float level switches which will actuate upon transfer pipeline leak and shutdown the Remediation System. There are 15 vault locations within the various collection and transfer pipelines. Emptying the concrete vaults is accomplished by vacuum truck.

3.2 NBPL BAYSIDE TRANSFER COMPOUND

The NBPL Bayside Transfer Compound has a containment berm and leak detection to shut down the NBPL Bayside system. The holding tank 204-TK-1-EFF is a double-walled convault tank with spill containment and detection between the inner tank lining and outer shell. The tank, the recovery well manifold piping to tank inlet, and the tank discharge piping are contained in a 6-foot by 5-foot area with a 6-inch-high coated asphalt berm, beneath a roof structure. The 112-gallon capacity of the containment area will prevent spill or discharge outside of the containment because a leak detection sensor within the containment area is set 3 inches below top of curb, and the signal to the PLC will immediately shut down the recovery well pumps and tank discharge pump. Emptying the containment area is performed manually using a pneumatic diaphragm pump to transfer water in the containment to the holding tank. A spill kit is maintained adjacent to the holding tank, within the fenced compound.

3.3 GROUNDWATER RECOVERY COMPOUND

The Groundwater Recovery Compound at Building 604 has two distinct containment areas associated with each of the tanks. Both of the containment areas have lighting for illumination.

The first containment area contains the effluent tank (604-TK-1-EFF) and discharge monitoring and controls (pressure indicator, flowmeter, automated control valve, etc.). These are all mounted within a common containment area exceeding 14 feet by 19 feet by 6 inches deep. This containment area can hold over 814 gallons, has a blind sump for drainage, and is protected from rainfall by roofing. A level switch in the containment area signals the PLC which executes an immediate shut down of the remediation system components that feed to tank 604-TK-1-EFF, as well as the transfer pump within that tank. The transfer pump can also be operated in hand mode to empty the tank once the operator confirms the liquid in the containment area is not resulting from a leak in the discharge piping. The containment area has a dedicated pneumatic diaphragm pump which is plumbed to the effluent tank and a spill kit is stored just outside the containment area.

The second containment area at the Groundwater Recovery Compound is a large, triangular area that contains the influent recovery system tank (604-TK-2-INF), and the RO treatment system components (oil/water separator, booster pump, diaphragm tank, sand filter, pre-filters, and RO membranes). This containment area holds over 2,300 gallons and has a blind sump at the south end and a dedicated pneumatic diaphragm pump plumbed to tank 604-TK-1-EFF. The containment area is covered with a canopy. The containment area has a spill kit that is stored just outside the containment area.

Fluids from this compound are conveyed to the Remediation Process Compound through a subsurface HDPE utility conduit. The conveyance piping is a double-contained system with transfer vaults at both ends to monitor the pipeline and has active leak-detection level sensing within each vault at all times to assure proper operation. Between the vaults, the secondary containment is the 14-inch diameter HDPE conduit which contains the tank 604-TK-1-EFF discharge pipeline, treated water discharge from the RO units, a spare conduit for future expansion needs, protected communications cabling (PLC link and leak-detection wiring), and LNAPL piping from the sump skimmers to tank 46-TK-2-HIF. Should leak detection be indicated at any point of the continuously double-contained pipelines, the PLC will actuate a complete system shutdown alarm.

3.4 REMEDIATION PROCESS COMPOUND

The Remediation Process Compound behind Building 46 has two containment areas: the tanker truck loading containment area and the remediation process treatment equipment containment pad.

The tanker truck loading pad is designed with containment to capture potential spills during truck loading. The concrete pad is 83 feet long, 20 feet wide, and varies in depth from 9 inches to 1 foot, with a blind sump in the center of the pad. The total volume for the truck loading containment area is over 9,500 gallons. Since the containment area is open to rainfall, current containment drainage operations are to inspect for a sheen and if clean, install a pneumatic or electric pump in the sump and direct rainfall to the adjacent storm drain in accordance with NBPL Environmental guidance. Containment area drainage is performed with an installed pump and follows standard operating procedures for emptying the pad as needed. A spill kit is located in the truck loading equipment area pad, adjacent to the containment area.

The second containment area at the Remediation Process Compound is the remediation process treatment equipment containment pad (process pad). This process pad is approximately 45 feet wide and 140 feet long with a depth of containment up to 1-foot at the central blind sump. The volume of this containment area is 17,803 gallons. Equipment mounted within this containment area includes the three oil/water separator units (604-OWS, OWS-HIF, and OWS-LOF) and transfer pumps, the inlet balancing tank (46-TK-1-INF) and treatment system pump, LNAPL holding tanks 46-TK-2-HIF and 46-TK-3-LOF, the treated water holding tanks (46-TK-4-EFF and 46-TK-5-EFF) and discharge monitoring pipe rack, and the compressed air system. The containment area is open to rainfall and has a central blind sump. Rainwater on the pad is inspected following a rain event, documented, and disposed of in accordance with NBPL environmental requirements. A permanent pump is installed in the sump. A spill kit is maintained at all times adjacent to the process pad.

4 SLUG DISCHARGE PREVENTION AND CONTROL

The potential for tank and/or pipleline failure creating a slug discharge to Connection 220 exists, but would have to coincide with a catastrophic (systemic material failure, seismic event, other devastating natural phenomenon, etc.) and failure of the adjacent surface outside of the remediation process pad at Connection 220 in order to create a preferential pathway to the sewer.

Without such a failure of the area around Connection 220, any tank and/or pipeline failure would result in a release to the surrounding ground surface or containment structure. Nevertheless, this section discusses the potential for catastrophic tank failure creating a slug discharge to Connection 220 for completeness. There have been no slug discharges to Connection 220 since operations began in November 2014.

4.1 PREVENTION: SECONDARY CONTAINMENT

All tanks for the Remediation System are either double-walled or surrounded with concrete secondary containment that can accommodate the volume of spillage or leaks from the largest tank plus sufficient freebard to allow for precipitation (Table 2). The secondary containment structures of unsheltered single-walled ASTs have been checked to ensure containment of 100 percent of the contents of the largest tank plus additional freeboard to accommodate the 3.5 inches (24 hour) precipitation of the historical San Diego, California 25-year storm event.

The risk of possibly releasing of any fluids in uncontrolled environments is negligible, unless a major catastrophic event occurs. The combined volume for all the tanks, piping and containment areas is estimated at approximately 100,000 gallons. The maximum spill from a single tank is estimated at 20,000 gallons (46-TK-2-HIF), which is the largest tank volume in the Remediation System. The combined maximum volume of the recovered LNAPL holding tanks is 36,000 gallons (46-TK-2-HIF and 46-TK-3-LOF). Therefore, should one or both recovered LNAPL storage tanks rupture, there is a secondary tank wall capacity to prevent a major spill from exceeding containment area capacity. Failure of both the primary and the secondary tank wall would result in tank volume being held in the concrete containment area and any volume over the 17,803-gallon containment capacity discharge would be released. However, it should be noted again that the sanitary sewer connection is located outside of the containment area and would not be impacted.

4.2 CONNECTION 220 DISCHARGE CONTROLS

The Remediation System connection to the City of San Diego sanitary sewer (Connection 220) is located near the northwest corner of the Remediation Process Compound between the remediation process equipment pad and the access road in a gravel landscaped area, protected from vehicle traffic. This above-grade 4-inch HDPE pipeline connection has sewer cleanouts and a sample port in accordance with NBPL utilities and IUDP requirements, respectively. Sampling and reporting is coordinated through the NBPL Environmental office. The Connection 220 discharge location is monitored with a totalizing flow meter, pH electrode senor, and an oil-in-water monitoring system. All three of these discharge monitoring systems are programmed to the PLC to automatically shutdown the system should any of those parameters approach the established permit limits.

4.3 PROGRAMMABLE LOGIC CONTROL

Controls to prevent the accidental slug discharge of untreated fluids or fluids not meeting the IUDP requirements are integral to the PLC, instrumentation and actuated component programming. The remediation system operational logic assures proper tank levels, pipeline pressures, temperatures, pump function, and valve positions based on instrument readings, PLC setpoints, and operator-defined parameters within the HMI. This aspect assures proper treatment and disposition of all recovered fluids. The discharge monitoring and control portion of the PLC logic assures compliance with IUDP requirements. All monitoring discharge conditions are continuously recorded within the PLC and monitored by the PLC to assure proper operation.

Within the PLC, the monitored conditions have programmed setpoints for maximum flowrate (75 gpm), pH out of range (≤5.5 or ≥ 12), and high oil-in-water concentrations (50 milligrams per liter [mg/L], which is 10 percent of the permit limit of 500 mg/L). Should any monitored discharge parameter exceed the operator-defined setpoints, the PLC will execute a shutdown of the electro-pneumatically-actuated discharge control valve for Connection 220, located at the edge of the process pad. Closure of the actuated control valve prevents any and all flow to Connection 220, and the valve is “fail close”; meaning that should the system experience a loss of compressed air, electrical power, or signal from the PLC, the valve will automatically close.

The operator-defined discharge setpoint parameters within the HMI of the PLC are password protected, and programming logic limits the potential setpoints to values within the acceptable range of IUDP parameters in order to assure permit compliance. The only way the system could automatically discharge outside of IUDP requirements would be if the program logic itself was re-written within the PLC. Access to the PLC program requires a connection with the site computer; software that is specific to the PLC; the username, password, and knowledge of the existing program in order to make any potential changes that would impact the discharge to Connection 220.

4.4 OPERATOR CONTROL

Although the remediation system runs in automatic mode, remedial systems personnel direct the entire system operation, monitor system performance, and staff are present during standard working hours, Monday through Friday. There are high-level controls and high-high level alarms on all the tanks in place. The remediation system is equipped with alarms in case of emergency and component malfunctions. If there is a malfunction within the treatment process, the operation is automatically shut down by automated system overrides. There are at least two visual walkthrough inspections performed during an 8-hour work shift. Additionally, an emergency notification phone number (posted at each compound) is maintained 24 hours a day, 7 days a week, should any problem occur.