ATT4_Slug_Prevention_and_Control_Plan.pdf

Slug Prevention and Control Plan DFSP Point Loma Remediation System

Naval Base Point Loma 199 Rosecrans Street, Bldg. 604

San Diego, CA 92106-0051

IUDP # 08-0008-06-A

DLA Installation Support for Energy

8725 John J. Kingman Road Fort Belvoir VA 22060-6222

(Issued September 2015)

(Issued September 30, 2015)

Table of Contents

1. General Information 5

a. Operating Hours

b. Location of the Slug Plan, Inspections, and Records

c. Personnel having a role in the implementation of a spill response plan

d. Process Overview

2. Facility Description and Layout 6

a. Field Recovery Systems

b. SPAWAR Transfer Compound

c. Groundwater Recovery Compound

d. Remediation Processing Compound (w/ discharge connection 220)

3. Spill Containment and Drainage 12

4. Slug Discharge Prevention and Control 14

5. History of Groundwater Recovery 16

6. Classification by Federal Point Source Category 16

7. Personnel Training 17

8. Security 17

9. Notification Procedures 17

Appendix A: Facility Diagrams A-1 Remediation System Figure A-2 Piping & Instrumentation Diagrams (P&IDs) D-1 P&ID – Existing System Transfer Equipment D-2 P&ID – Phase Separation Equipment

D-3 P&ID – Remediation Equipment D-4 P&ID – Storage Equipment

Appendix B: Emergency Response Plan (form to document slug discharges)

PAGE INTENTIONALLY LEFT BLANK

DFSP POINT LOMA REMEDIATION SYSTEM

1. GENERAL INFORMATION

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

b. A copy of the (1) Slug Plan Prevention and Control Plan, (2) internal notification procedures, and (3) the Industrial User Discharge (IUDP) Permit (# 08-0008-06-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 Remediation System office.

c. Personnel having a role in the implementation of slug prevention and a spill response plan include the following:

Title Name Phone Number DLA Energy Remedial Project Manager

Nicholas Carros Off: 703.767.6624

Naval Facilities Engineering Command Water Program Manager

James Craft Off: 619.226.5395 Cell: 858.472.0403

DLA Energy Contractor (CB&I Federal Services

LLC [CB&I])

Project Manager

Chris Corey Off: 619.533.7330 Cell: 949.466.4816

DLA Energy Contractor

(CB&I)

Project Engineer

James Horna Off: 619.533.7320 Cell: 619.865.3856

DLA Energy Contractor

(CB&I)

Construction Manager

Dennis Talbot Off: 619.222.2927 Cell: 864.505.6784

DLA Energy Contractor

(CB&I)

Remediation System Lead Operator

Alonzo Beehler

Off: 619.222.2927 Cell: 619.990.1777

d. Process Description: The DLA Energy-owned, contractor-operated DFSP Point Loma

Remediation System recovers light non-aqueous phase liquids (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 reclaim and/or disposal, and treats the water for discharge either to the San Diego sanitary sewer system 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). Recovered LNAPL and TPH-contaminated groundwater are extracted through field recovery systems, including vertical recovery wells (6), collection trench and sump systems (2) and a horizontal recovery well (with four additional horizontal recovery wells operational in 2016). The Remediation System includes three facilities where the recovered LNAPL and water are handled; the Space and Naval Warfare Systems Command (SPAWAR) Transfer Compound, Groundwater Recovery Compound, and the Remediation Processing Area.

The SPAWAR Transfer Compound collects recovered LNAPL and TPH-contaminated groundwater from three vertical recovery wells: the recovered LNAPL and water is temporarily held in a transfer tank (204-TK-1-EFF) before being transferred to the Groundwater Recovery Compound for initial processing.

The Groundwater Recovery Compound collects recovered LNAPL and TPH-contaminated groundwater transferred by pipelines from the SPAWAR Transfer Compound, horizontal well HW-01, the northern boundary vertical recovery wells, and both collection trench sumps. At this compound, the influent fluid flow is balanced in the influent tank (604-TK-1-INF) and gravity-fed to an oil/water separator. A booster pump pushes the water fraction through various filters to the dual reverse osmosis (RO) units for treatment; the treated water is pumped by the RO units directly to the Remediation System effluent tanks for site use or discharge to the sanitary sewer thru connection 220.

All untreated influent fluids, oil/water-separated LNAPL, filter back-flush liquids, containment area liquids and water not passing through the RO membranes are transferred to the Remediation Process Compound from the discharge tank (604-TK-2- EFF) for further treatment.

The Remediation Process Compound is comprised 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. This compound is where discharge to City of San Diego sewer connection 220 occurs. Influent piping includes the wastewater from the Groundwater Recovery Compound discharge tank (604- TK-2-EFF) and recovered LNAPL from the oil skimmer systems on the trench collection sumps. These fluids are processed along with future processing of the LNAPL and TPH-contaminated groundwater to be recovered directly from four horizontal wells in the former Tank 63 area (to be fully operational in 2016). The recovered LNAPL is held in a 12,000-gallon capacity steel double-walled tank (46-TK-3-LOF) and a 20,000-gallon-capacity steel double-walled tank (46-TK-2-HIF), prior to transfer to a tanker truck for offsite disposal or reclamation. After processing through the oil/water separators, the recovered groundwater is collected in an influent balancing tank (46-TK-1-INF) then processed through various bag filters, activated clay vessel, and granulated activated carbon vessels. The treated water is then either contained in two 10,000-gallon-capacity effluent tanks (46-TK-4-EFF and 46-TK-5-EFF) or discharged to the sanitary sewer through connection 220.

2. FACILITY DESCRIPTION AND LAYOUT

The DFSP Point Loma Remediation System is located along Rosecrans Street in the north eastern corner of the Naval Base Point Loma (NBPL). The entire system includes four major component areas or aspects which have evolved as a result of the delineation, recovery, and monitoring of the contaminant plume. These include the field recovery components, the SPAWAR Transfer Compound, the Groundwater Recovery Compound, and the Remediation Process Compound. The system operates with a programmable logic control (PLC) system which monitors and records numerous input parameters, system set points and controls from operators, 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.”

a. In order to address fuel plume contaminants resulting from historic releases associated with fuel terminal operations, various field recovery components have been installed as described above. The LNAPL and TPH-contaminated groundwater recovery components are located within the DFSP Aboveground Storage Tank (AST) Facility on the west side of Rosecrans Street and south of the entrance to the Naval Base Point Loma, at the northern property boundary at Rosecrans Street, and in the SPAWAR System Command (SSC) Bayside parking lot. The recovery system currently extracts LNAPL and impacted groundwater from six vertical wells, a horizontal well, and two recovery trench and sump systems. Additional horizontal wells have been installed in the AST Facility. These wells are in the process of having pumps installed and piping completed to the Remediation Process Compound (fully operational in 2016).

The six vertical recovery wells include three SPAWAR wells within the SPAWAR Bayside parking lot and three wells installed along the northern property line west of Rosecrans Street.

The SPAWAR wells are 4-inch diameter polyvinyl chloride (PVC) extending to depths of approximately 43 feet below ground surface (bgs); the northern property line wells are 6-inch diameter PVC that extend to depths of approximately 62 feet bgs. The installed recovery pumps are pneumatically-operated fed by a centrally-located compressed air source. 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). The fluids recovered from the SPAWAR parking lot and northern boundary vertical recovery wells are pumped through double-contained high-density polyethylene (HDPE) piping to the SPAWAR Transfer Compound and Groundwater Recovery Compound, respectively.

The two collection trenches, each constructed of 6-inch diameter perforated HDPE pipe placed at an elevation of 5 feet below mean sea level (msl). The trenches begin near the northern property boundary and extend approximately 900 feet to the south, west and parallel to Rosecrans Street.

Each collect trench is connected to a 36-inch diameter HDPE vertical sump. Within each sump is mounted an electric grinder pump. The pumps are automatically controlled by level sensors to maintain drawdown during normal operations and each discharge at a regulated flow of 50-60 gpm, with interlocking controls to match the RO treatment system flowrates. Also mounted within each sump is an oil skimming system with a rotating oleophilic belt to raise LNAPL from the sump liquid level, and then pump directly to tank number 46-TK-2-HIF.

The final aspect of field collection components are the horizontal wells. The first horizontal well (HW-01) was installed in the south end of the SPAWAR Bayside parking area, pumping to the

Groundwater Recovery Compound. This is a 4-inch diameter well, constructed of perforated and solid stainless steel casing that is 870 feet in length and has a dedicated electric submersible pump. This well is automatically controlled with a level-sensing transducer which cycles the pumping operations at 10 gpm to maintain well draw down during normal operation. The remaining four horizontal wells are located beneath the DFSP AST Facility. 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 will be installed to recover LNAPL and TPH-contaminated groundwater at 5 gpm during normal operations (fully operational in 2016). The wells will pump to separate oil/water separators; three wells (HW-02, HW-03, and HW-04) will pump recovered fluids to one oil/water separator, while HW-05 will pump to a different oil/water separator. Both of these oil/water separators are located at the Remediation Process Compound.

All of these field recovery components convey the recovered LNAPL and TPH-contaminated groundwater through below- and above-ground double-contained HDPE piping to the Groundwater Recovery Compound. 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.

b. The SPAWAR Transfer Compound is a stand-alone facility which supports the field recovery efforts of the SPAWAR vertical well pumps (3) and transfers the recovered LNAPL and TPH-contaminated groundwater to the Groundwater Recovery Compound. Located at the eastern edge of the SPAWAR Bayside parking lot, the compound is a fenced area with a control panel, air compressor, recovery well manifold area, and holding tank (204-TK-1-EFF) with submersible transfer pump. The SPAWAR 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), allowing the operator access to only operations at the SPAWAR compound (system on/off/reset, tank pump hand/off/auto and air to field hand/off/auto settings). The holding tank is a 1,000-gallon double-contained convault tank and 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;

while the mechanical level switch provides backup alarm/shutdown. The well manifold (valves, air pressure indicator/regulators and pump cycle counters to monitor and control SPAWAR wells) and inlet filter (25 micron bag in stainless steel canister) area has a containment berm and leak detection to shut down the SPAWAR system. All recovered fluids are conveyed through double-contained nylon tubing and HDPE piping between the wells and to the Groundwater Recovery Compound.

c. 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 handles the majority of the groundwater produced from the extraction field. The influent is conveyed to the inlet balancing tank (604-TK-2-INF), through the oil/water separator, a series of pretreatment filters, and finally two parallel RO units. The treated water is conveyed by underground piping to the Remediation Process Compound treated water effluent tanks and/or discharge monitoring system to connection 220. The recovered oil fraction, oily water filter backwash fluids, and water that does not pass through the RO membranes is collected in the discharge tank (604-TK-

1-EFF) and pumped to the Remediation Process Compound for processing before discharge to connection 220.

The inlet balancing tank (604-TK-2-INF) is a 1,000-gallon single-walled steel vertical cylindrical tank with an operating (high level) setpoint of approximately 800 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.

The oil/water separator 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.

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. The LNAPL holding tank is plumbed to an air diaphragm pump which automatically transfers separated fluids to the discharge tank at operator-defined intervals as programmed in the PLC.

The pretreatment system includes a control system-operated, variable-frequency-driven booster pump; a 120-gallon diaphragm tank; a fiberglass filtration tank filled with organophilic sand filtration media; a 25-micron bag filter; and a 10-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, 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 membranes is transferred to the discharge tank (604-TK-1-EFF) for treatment at the Remediation Process Compound.

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 Remediation Process Compound “604 oil/water separator” with a permissive signal from the PLC, which is confirmed by monitoring instrumentation at the Remediation Process Compound.

Fluids from the Groundwater Recovery Compound pumped to the Remediation Process Compound are conveyed 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.

d. The Remediation Process Compound is located south of Seifert Road, west of Rosecrans Street, behind Building 46. 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. The compound includes a tanker truck loading pad (fully operational in 2016); an equipment and material storage conex; a site control room and operations conex; and the process containment area where the raw water separation equipment, recovered LNAPL holding tanks, treatment process components, and the treated water discharge monitoring system and tanks are located. This containment area is where recovered LNAPL is stored pending offsite transfer, where the final treatment of extracted groundwater is completed, and where all discharge monitoring and controls for compliance with the IUDP requirements for connection 220 are performed.

Recovered LNAPL and groundwater from the horizontal wells (fully operational in 2016), and the untreated water from the Groundwater Recovery Compound each have separate inlet pipelines and oil/water separators. From all oil/water separators, the separated water is pumped to the 10,000-gallon cross-linked HDPE inlet holding tank, 46-TK-1-INF. The recovered oil from the oil/water separator receiving lower flashpoint LNAPL is pumped to the 12,000-gallon horizontal steel double-walled tank, 46-TK-3-LOF. The recovered oil from the oil/water separators receiving the higher flashpoint LNAPL are each separately pumped to the 20,000-gallon horizontal steel double-walled tank, 46-TK-2-HIF.

Following separation, the LNAPL is held in each of the double-walled steel tanks (based on the makeup of the LNAPL). The tank discharge pumping system and truck loading pad system (scheduled for completion in 2016) will be 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 will work within the PLC to control operations and display on the HMI touchscreen the various levels within the tanks upon completion of the system.

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.

Remediation treatment system components include filtration, activated clay, and activated carbon treatment. Flow, pressure, and temperature instrumentation continuously monitor water treatment conditions and allow PLC system shutdown when conditions are outside established parameters. The filtration part of the process includes two stainless steel duplexed basket strainer systems, primary filtration with 25 micron bags and secondary filtration with 10 micron bags. The activated clay vessel is an oleophilic 6,000-pound (lb) epoxy-coated carbon steel vessel. The activated carbon treatment includes two vessels connected in series, each filled with 3,000-lb of liquid-phase activated carbon. 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.

The discharge system with options, monitoring, and control are the final aspect of the DFSP Point Loma 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 # 08-0008-06-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 Coreolis Mass flow-measuring totalizer with a local display of flowrate and total flow, and a 4-20mA 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, which is 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 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.

The compound locations and operational areas of the DFSP Point Loma Remediation System are shown in Appendix A on A-1 “Remediation System Figure.” The system components, piping connections, and instrument locations are shown in the four pages of P&ID figures of A-2 in Appendix A.

3. SPILL CONTAINMENT AND DRAINAGE

Secondary containment structures and/or drainage systems provide adequate containment for the tanks at each compound of the DFSP Point Loma 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. All recovery components are double contained in the field with leak detection sensors to provide containment and to prevent uncontrolled spills from the recovery systems. Spill containment and drainage for each of the three compounds are detailed below.

Within the SPAWAR Transfer Compound, 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 recovery well manifold piping to tank inlet and 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 three extraction well pumps have flow rates of 5 gpm each and the tank discharge pump operates at 50 gpm; 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.

The Groundwater Recovery Compound at Building 604 has two distinct containment areas associated with each of the tanks. The effluent tank (604-TK-1-EFF) and discharge monitoring and controls (pressure indicator, flowmeter, automated control valve, etc.) are all mounted within a common containment area exceeding 14 feet by 19 feet by 6 inches deep. This containment area can hold over 800 gallons, has a blind sump for drainage, and is protected from rainfall with partial 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 partially covered with a temporary canopy (a permanent, full coverage canopy is scheduled for completion in 2016). Both of the containment areas have lighting for illumination.

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. While the tanker truck loading pad is not in operation (scheduled for completion in 2016), the loading area 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 and there are no truck loading operations, 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. Once truck loading operations begin, containment area drainage will be performed with an installed pump and will follow 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 pad is 45 feet wide and 140 feet long with a depth of containment up to 1-foot-deep at central blind sump. Equipment mounted within this containment area includes the three oil/water separator units (OWS-604, 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 & 46-TK-5-EFF) and discharge monitoring pipe rack, and the compressed air system. The volume of this containment area is over 17,800 gallons; it is presently 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. At present, the pad is emptied using a portable pneumatic diaphragm pump to move water; a permanent pump is scheduled to be installed in the sump. A spill kit is maintained at all times adjacent to the process pad.

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.

DFSP Point Loma Remediation System Tank Capacities Table

4. SLUG DISCHARGE PREVENTION AND CONTROL

Potential source of a slug discharge to sewer is from a rupture of tanks and the aboveground pipeline connected to the sewer caused by a catastrophic material failure, seismic event, or other devastating natural phenomenon; however, this would have to coincide with 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 catastrophic failure would cause release to the surrounding ground surface or containment structure. Regardless, the potential for catastrophic tank failure creating a slug discharge to connection 220 will be discussed herein for completeness.

The maximum spill from a single tank is estimated at 20,000 gallons, which is the largest tank volume in the DFSP Point Loma Remediation System. 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 those tanks. The risk of possible 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 combined maximum volume of all recovered LNAPL holding tanks is 32,000 gallons. Therefore, should one or both recovered LNAPL storage tanks rupture, there is a

TANK

ID #

TANK

(Description)

VOL

(U.S.

Gallons)

SIZE

(Dimension)

CONTENTS

SPILL CONTAINMENT

CAPACITY

(U.S. Gallons)

604-TK-

1-EFF

GW Recovery Compound

Effluent Tank 2,000

8’ Wide x 11.25’ Long x 5.5’ High

Wastewater 2,306 gallons

604-TK-

2-INF

GW Recovery Compound

Influent Tank

1,000

6’ Diameter x 8’ High

LNAPL and

TPH

contaminated groundwater

Tank secondary containment & 814 gal concrete area

204-TK-

1-EFF

SPAWAR

Transfer Tank

1,000

5’ Wide x 11’ Long x 4.5’ High

TPH

contaminated groundwater

Tank Secondary & 112 gal piping area

46-TK-1-

INF

Remediation

Process Influent Tank

10,000 12’ Diameter x 14’

High

Wastewater & groundwater w/dissolved phase TPH

Containment area holds approximately

17,803 gallons

46-TK-2-

HIF

High Flash Tank

20,000

10’ Diameter x 34’- 8” Long

Recovered

LNAPL

(DFM/JP5)

Tank secondary plus 17,803 gallon containment area

46-TK-3-

LOF

Low Flash Tank 12,000 8’ Diameter x 32.5’

Long

Recovered

LNAPL

(Av/Mogas)

Tank secondary plus 17,803 gallon containment area

46-TK-4-

EFF

Effluent Tank # 1 10,000

12’ Diameter x 14’ High

Treated Water 17,803 gallon containment area

46-TK-5-

EFF

Effluent Tank # 2 10,000

12’ Diameter x 14’ High

Treated Water 17,803 gallon containment area 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 outside the containment area and would not be impacted.

The DFSP Point Loma Remediation System connection to the 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.

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. These operations include continuous discharge flow rate monitoring (including totalized flow), pH monitoring, and oil-in-water monitoring. 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 (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.

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. The system is equipped with an alarm-annunciating automated telephone dialer, which is programmed to call the Project Engineer, System Operator and Project Manager continuously until an active response is given and the alarm condition is resolved and cleared.

Monthly compliance sampling is performed on the connection 220 discharge, and additional sampling will be performed as necessary. Sampling for the permit condition parameters is performed under supervior guidance, and a sampling log is used to document the flowrate, total flow, pH, and oil-in-water concentration at the time of sampling.

There have been no slug discharges to Connection 220 since operations began in November 2014.

5. HISTORY OF GROUNDWATER RECOVERY

The DLA Energy has designed and constructed a groundwater and LNAPL extraction 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. Several releases have been documented during the operational life of the fuel terminal. A comprehensive series of soil and groundwater investigations have been completed to ascertain the spatial extent and characteristics of fuel hydrocarbons beneath the facility. Several groundwater monitoring wells have been installed throughout the fuel terminal to monitor water quality, and a LNAPL and impacted groundwater recovery system has been designed and constructed. The majority of the remediation system is presently operational and maintains hydraulic control while recovering available LNAPL.

6. CLASSIFICATION BY FEDERAL POINT SOURCE CATEGORY

This facility does not conduct any operations subject to federal categorical pretreatment standards. However, since the industrial user wastewater discharge permit capacity exceeds 25,000 gallons per day (gpd) and LNAPL is present in the groundwater, the DFSP Point Loma Remediation System has previously been part of an IUDP which was classified as a Category 2 Significant Industrial User. According to review of 40 CFR Part 113, the DFSP Point Loma Remediation System could be defined as a “class IV small on-shore oil storage facility.”

The table below lists the required monitoring parameters including flow rates, regulated pollutants and their applicable limits.

Parameter Units Instantaneous Daily Maximum Maximum Dry Weather Imported Flow/minute gpm 170 --

Maximum Wet Weather Imported Flow/minute gpm 75 --

Flash Point Deg F must be >140 -- TPH, DOHS modified 8015 mg/L -- 500 Oil & Grease, SGT-HEM mg/L -- 500

Pretreatment Standards and Point of Compliance

Based on a permitted industrial wastewater flow of approximately 50,000 gpd, DFSP Point Loma Remediation System is required to monitor the wastewater at the point of discharge for the following:

Characteristic or Pollutant Units Sample Type Frequency Ending Meter Read and Date gals Evaluation only Monthly Beginning Meter Read and Date gals Evaluation only Monthly Imported Flow During Period gals Evaluation only Monthly Maximum Dry Weather Imported Flow/minute gpm Evaluation only Monthly

Maximum Wet Weather Imported Flow/minute gpm Evaluation only Monthly

TPH, DOHS modified 8015 mg/L Grab BiMonthly Flash Point-Instantaneous Deg F Grab BiMonthly

Deg F = degrees Fahrenheit mg/L = milligrams per liter Note: Grab samples and 24-hour composite is performed by the City of San Diego personnel.

7. PERSONNEL TRAINING

On-the-job training is performed over several months so that new employees are able to familiarize themselves with the system operations. DFSP Point Loma Remediation System employees attend weekly training meetings covering spill response/prevention and health and safety issues. In addition, personnel receive 40 hours of HAZWOPER training and annual 8-hour refresher training required by 29 CFR 1910.

8. SECURITY

DFSP Point Loma Remediation System facilities are located on NBPL within fenced compounds that are routinely patrolled by Base Security units. Access is limited by regulation to authorized personnel only; access gates to each fenced compound are secured when areas are unattended. Signage is posted to advise NBPL personnel of the system, hazards, and provides contact information.

9. NOTIFICATION PROCEDURES

The Industrial Wastewater Control Program (IWCP), the DLA Energy contracting officer’s representative, the NBPL Environmental compliance officer, and the NAVFAC-SW Water Program Director must be notified of slug discharges, including any discharge that would violate a prohibition under 40 CFR 403.5(b). The Water Program Director will in turn notify the City IWCP within 24 hours.

The following points of contact shall be used:

NAVFAC-SW Water Program Director

(619) 226-5395

Compliance Supervisor Industrial Wastewater Control Program (IWCP)

(858) 654-4103 or (858) 654-4100 FAX (858) 654-4110

DLA Contracting Officer’s Representative (703) 767-6624

Listed below are the title(s) of facility personnel who are designated to immediately notify the City of San Diego Metropolitan Wastewater Department in the event of a slug discharge to the sewer:

Title Designated to:

Phone Number

DFSP Point Loma Remediation System Operator

Immediate notification to DLA Energy (Primary)

619.222.2927

DLA Contracting Officer’s Representative

Immediate notification to IWCP (Secondary)

703.767.6624

NAVFAC Water Program Director

Immediate notification to IWCP (Alternate) 619.226.5395

The internal procedures for identifying and notifying the designated person(s) of a slug discharge are identified within this section of the plan. A copy of the Slug Prevention and Control Plan and internal notification procedures will be posted at the Remediation System operations office, located at Building 604. The original documents will be kept in the DLA Energy’s contractor home office in downtown San Diego, California.

Slug discharge documentation procedures shall be performed in accordance with the NBPL Integrated Facility Response Plan. A copy of the form used to document a slug discharge may be found in Appendix B.

The NAVFAC Water Program Director shall submit written notification of a slug discharge to the IWCP Supervisor within 5 days.

Appendix A: Facility Diagrams

FIGURE A-1

DFSP POINT LOMA

REMEDIATION SYSTEM

S p ar k s

Hi ne s

Ry de r

Ca rro ll

Kemp

Cr aig

Ab eli a

Ry de r

Strothe

Gate

Warhead

Fitch Fro nt

Mc inn ey

Webb

Warh ead

Holco mbe

Roberts

Troutman

Se ife rt

Ro se cra ns

Almy Rehberg

Bolt

Du rh am

Jenkins

Ro se cra ns

Ho op

HW-04

HW-04

HW-04

HW

-03

HW-03

HW-03

HW

-02

HW-02

HW-02

HW-05

HW-05

HW-05

HW Manifold Area

Remediation Processing Compound Building 46 Area

South Sump A Area Groundwater Recovery Compound Building 604 Area

VEX Well Area

HW-01 Area

North Sump B Area

HW-05N Vault Area

HW-02-03N Vault Area

SPAWAR Transfer Compound Building 204 Area

HW-04N Vault Area

VEX-02 VEX-04

10MW-17

10MW-2010MW-14

VEX-03

DEFENSE LOGISTICS AGENCY (DLA) ENERGY

H:\DLA_Pt_Loma\GIS_Documents\Project_Maps\TEMP\PTL_TEMP_001_FigureA-1_RemediationSys_2015.mxd 04/20/15 MBarbour

Site Location

0 100 200 300 400 500

Feet 1 inch = 250 feet

LEGEND

Naval Base Point Loma Boundary

Remediation System Vertical Extraction Well

Trench

NAPL Horizontal Wells Blank

Screen

Interconnect Piping Above Grade

Below Grade

Remediation System Tank NAPL and Contaminated Groundwater

Recovered Product

CB&I Work Areas Work Area

DFSP POINT LOMA

SAN DIEGO, CA

Appendix B: Emergency Response Plan (Form to document Slug Discharges)

EMERGENCY RESPONSE PLAN

The Emergency Response Plan (ERP) must be kept with the Slug Discharge Plan and SPCC Plan at all times. It must be followed in the event of a 'worst case scenario release" that requires rapid/emergency response, such as, when human health & safety is at immediate risk, the release could potentially reach the bay if not contained immediately, or when the release of any known quantity has reached the bay.

Facility Name: DFSP POINT LOMA REMEDIATION SYSTEM Facility Address: NBPL Bldg 604, 199 Rosecrans Street, Point Loma, CA 92106

1. If an unauthorized release occurs, the following actions will be performed:

A. RESTRICT ACCESS TO SPILL AREA. CONTAIN SPILL, IF POSSIBLE. NOTIFY SUPERVISOR

B. ANSWER THE FOLLOWING QUESTIONS:

Substance spilled?

Quantity Spilled: Estimated: Actual:

Location of Spill:

Date Occurred: Time:

Description of Affected Area:

WEATHER CONDITIONS: Wind Direction/Speed: Tide:

Surface Water conditions:

SOURCE: Ship Fuel Dept: Other:

Cause:

Action Taken: _ Estimated Manpower, Material Equipment to Clean/Control Spill:

Assistance from Outside Activities/Agencies:

Actual Man Hours Expended:

Samples were/were not taken:

Containment Method:

Removal Method:

DATE/TIME OF: Discharge stopped:

Corrective action cleanup complete:

Person Making Report: Name:

After Action Report Sent: Y ( ) N ( )

2. THE FACILITY INCIDENT COMMANDER OR FUEL DEPOT DISPATCHER SHALL NOTIFY

AUTHORITIES AS FOLLOWS:

A. WATER OR LAND SPILL: If the hazardous substance is listed on the Business Inventory Plan, and meets or exceeds the reportable quantity, or if oil spill on land is more than 5 gallons; or visible sheen is formed on water surface, every effort possible should be made to notify the Facilities Incident Commander within the first 15 minutes of discovering the spill for instructions. It is important to remember that containment takes precedent over notification, but every effort should be made to notify both the Facilities Incident Commander (FIC), the state Office of Emergency services (OES), and National Response Center (NRC) as soon as possible after the spill has been discovered. Notification of additional authorities can follow later, but not more than 24 hours later.

EMERGENCY RESPONSE PLAN

1. Qualified Individual Facility Incident Commander (619) 726-7423 (CDO); (619) 553-7400 (Base CO)

POC at agency Control number Date: Time: Notified: Y ( ) N ( )

2. NBPL Environmental Department (619) 533-0526

3. National Response Center (NRC) 1-800-424-8802

Control number Date: Time: Notified: Y ( ) N ( )

4. Office of Emergency Services 1-800-852-7550 POC at agency

Date: Time: _ Notified: Y ( ) N ( )

5. Fuel Depot OSOT personnel if required and other OSOT backup if needed.

6. Department of Environmental Health (DEH) Work Hrs (619) 338-2222 After Hrs (619) 565-5659

POC at agency

Date: Time: _ Notified: Y ( ) N ( )

7 Department of Fish and Game (916) 445-0045

8. FLC Terminal Director (619) 553-1314 (office)

(619) 250-9806 (cell) (858) 292-8834 (home) CDO (Pager) (619) 556-5500 PIN 8777

9. NBPL Port Operations Office (if required) (619) 553-9785 (Dispatch)

10. SSC Pacific Marine Mammal Enclosures (water spill only) (619) 206-6828

POC at agency Scott Price; Alt – Dr. Mark Xitco (619) 204-1307

EMERGENCY RESPONSE PLAN

11. Federal Fire Department. 9-911

POC at agency

12. Regional Water Quality Control Board (RWQCB) (619) 516-1990

13. California Highway patrol (if spill is on public highway) 911

13. NAVFAC-SW Water Program Director (619) 532-2273

POC:

Person making notifications:

B. FAX SPILL REPORT ASAP TO THE ENVIRONMENTAL COMPLIANCE MANAGER (Luis Perez) AT 619-553-8657.

C. CLEANUP/CONTAIN SPILL:

1. Water: Activate the On-Scene Operations Team.

2. Land: If substance is relatively harmless and your personnel are trained and have proper protective equipment/tools, clean spill. If substance is hazardous or you are in doubt, contact the Federal Fire Department at 9-911 or Super Facility Incident Commander for assistance.

D. SEND UNIT SITREP AND AFTER ACTION REPORT AS REQUIRED