NCD003446721_12011989_Celeanse Corporation - Shelby Fiber_FRBCERCLA SPD_Final Project Operations Plan - Revised-OCR

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Westinghoose Environmental
and Geotechnical Services. Inc.
PROJECT OPERATIONS PLAN
HOECHST CELANESE/SHELBY, NC FACILITY
WESTINGHOUSE PROJECT 4122-85-0S0SH
DOCUMENT CONTROL SS0S0H-0132
REVISED DECEMBER 1989
Prepared For
HOECHST CELANESE CORPORATION
Shelby, North Carolina
Prepared By
WESTINGHOUSE ENVIRONMENTAL AND
GEOTECHNICAL SERVICES, INC.
Atlanta, Georgia
December 1989
M. Kirk Mays, P.E.
Senior Environmental Engineer Project Manager
S0S0H000
A Westinghouse Eleclric Corporation subsidiary.
4000 DeKalb Technology Parkway, NE
Suite 250
Atlanta, Georgia 30340
I 4041 458-9309
FAX [phone]
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1.0
2.0
3.0
TABLE OF CONTENTS
OBJECTIVE AND SCOPE
1. 1 Objective
1.2 Background
1.3 Description of Facilities
1.4 Scope
SYSTEM CONSTRUCTION
2.1 Extraction Well and Piezometer Construction
2.2 Collection and Treatment system Construction
SYSTEM OPERATION
3.1
3.2
3.3
3.4
3.5
Personnel and Responsibilities for the
Groundwater Treatment and Extraction System
System Start-up
Treatment System Operation
Reference Publications
System Shut-down
4.0 SYSTEM INSPECTION AND MONITORING
4.1 System Inspection
s.o
6.0
7.0
4.2 Operational Monitoring
4.3 Remedial Action Monitoring
HEALTH AND SAFETY CONSIDERATIONS
5.1 Work Practice controls
5.2 Emergency Response
5.3 Record Keeping Requirements
5.4 Education and Training
REPORTING
REMEDIAL ACTION
APPENDIX I Proposed Location of Monitor Wells
Groundwater Extraction Operating Procedures
Responses to Comments
APPENDIX II
APPENDIX III
APPENDIX IV
APPENDIX V
Forms for Treatment System Operation
Equipment Specifications
1-1
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Figure
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List of Figures
Title
Site Plan
Site organization Groundwater Remedial
Action
Sample Collection Summary Sheet
Westinghouse Custody Seal
Sample Tag
Chain-of-Custody Form
Receipt of Sample Form
Water Surface Elevation Data Sheet
site Access Agreement -Drilling
and Sampling
Site Access Agreement -Water Sampling
Health Status Report
Certification of Respirator Training
Respirator Fit Training
Certification of Supervised Field Training
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Table
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4-4
4-5
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Westinghouse Project 4124-85-050H
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List of Tables
Title Page
Summary of Well Construction 2-2
Operational Steps to be Taken in Case of
Treatment System Component Failure 3-19
Operational Monitoring Plan 4-3
Monitoring Plan system Start-up 4-4
Extraction Water Level Monitoring Locations 4-6
Water Quality Monitoring Locations and
Frequencies 4-8
Recommended Sample Containers, Preservation
and Holding Times 4-13
Local Sources of Assistance 5-14
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1. 1 Objective
Project Operations Plan
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Westinghouse Project 4124-85-0SOH
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Page 1-1
1.0 OBJECTIVE AND SCOPE
I The objective of the Project Operations Plan (POP) is to provide
a working manual on the construction and routine operation of
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the groundwater extraction and treatment systems at the
RC/SHELBY, North Carolina Facility. This document will be
revised as needed to reflect conditions that change throughout
the life of the project. This revision was at the end of the
construction phase and incorporates specifications and
operations and maintenance documentation on the selected
equipment, and "as built" plans on the extraction and treatment
systems.
1.2 Background
Hoechst Celanese (HC) undertook a Remedial Investigation/
Feasibility Study (RI/FS) at their Shelby, North Carolina
Facility in 1985. The RI has identified both soil and
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I groundwater contamination resulting from past disposal practices
I in the vicinity of the plant's wastewater treatment plant. Due
to the unique nature of the sludges, it was mutually agreed with
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Westinghouse Project 4124-85-0SOH
Document Control 85050H-0132
Page 1-2
EPA that the site remediation should be divided into operable
units (OU) to treat the source and contaminated groundwater.
Groundwater remediation was identified as the first OU since
it's extent was better defined and it's remediation used
extraction and treatment technologies that are well
established. The Remedial Design Report presents the components
of the groundwater extraction and treatment system identified in
the Operable Unit 1 Record of Decision (ROD) dated March 23,
1988.
1.3 Description of Facilities
Groundwater will be extracted from a relatively uncontaminated
"outer tier" located near the southern and eastern plant
boundary and a heavily contaminated "inner tier" located
adjacent to, and hydraulically downgradient from, the source
area and west of the wastewater polishing ponds. The inner tier
is designed to remove contaminated groundwater from the source
area. The outer tier, which is hydraulically downgradient of
the inner tier, is designed to remove contaminated groundwater
that might escape the inner tier of extraction wells.
The inner tier of extraction wells will be operated at the
maximum rate possible, and the outer tier will be pumped at the
minimum rate necessary to produce overlapping cones of
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influence. This pumping plan was developed to: 1) collect more
highly contaminated groundwater at the maximum rate and as close
to the source as possible, and 2) to have the minimal effect on
nearby drinking water wells.
The outer tier extraction treatment system consists of eight
extraction wells, an equalization tank, an air stripping tower,
and a granulated activated carbon (GAC) adsorption system. The
inner tier extraction and treatment system consists of nine
extraction wells, an equalization tank, a metals treatment
process, a sequential batch reactor (SBR) with associated manual
nutrient and chemical feeds and sludge handling equipment, an
air stripping tower, and a GAC adsorption system. The treatment
systems were designed for installation on a common concrete pad
located between the polishing ponds of the existing plant
wastewater treatment system. This treatment area has provisions
for spill and stormwater containment and control using curbing
and a collection sump. Unit processes in the package system for
the relatively uncontaminated groundwater from the outer tier
extraction wells includes equalization, air stripping, and
carbon adsorption. Treatment processes for the inner tier
groundwater includes equalization, pH adjustment, iron
precipitation and removal as necessary to prevent inhibition of
the subsequent treatment processes, biological treatment, air
stripping, and carbon adsorption. The Treatment System
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schematic flow diagrams are shown in Figure 1-1.
The POP is a companion document to the Remedial Design (RD)
report for the groundwater operable unit. The RD report
presents a more detailed discussion of the extraction and
treatment program and the governing management plans, and is
incorporated by reference.
1.4 scope
This document presents:
0 a discussion of the construction operations
0 a discussion of the system operations
0 a discussion of the system inspection and monitoring
0 a discussion of the worker health and safety
0 a discussion of routine reporting
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- -- - - -
BACKWASH/SM SLUOGE
TO OICESTER
OUTER TIER EFFLUENT
TO #1 POLISHING POND
1"9£R TIER EFfll£NT
TO #1 PCLISHIHG POHD
lloiNER TIER INFLUENT
- - - - - - - - - -- -
----------------------------?--------------,
WESTINGHOUSE PROJECT 412-485050H
DESIGNED BY
DRAWN BY
CHECKED BY
FILE N.l>ME 5050N06
$00ll-"
HYOflOXIOE
"' STRIPPER
CUTER TIER INFLUENT
DATE
SEQUENCING BATCH REACTCR
I y
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- - - - - - - - --< - - - - - - - - - - - - - --'
AIR
STRIPPER
[OUALIZATIQril I
N(UTRAl. lZATIClil T-
EQUALIZATICN
TAN<
Westinghouse Environmental
and Geotechnicol Services, Inc.
OCCANT
CCl.LECTION
YARK
FIGURE 1-1
NOT TO SCALE
GROUNDWATER TREATMENT SYSTEM SCHEMATIC FLOW DIAGRAM HC / SHELBY
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2.0 SYSTEM CONSTRUCTION
Good construction practices adhering to Hoechst Celanese
Environmental Health and Safety Policies were followed in
I construction of the system components. Specific construction
practices relevant to proper system component performance are
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outlined in the following sections or were in accordance with
vendor recommendations. Where not identified, construction
practices conformed to the general level of quality for Hoechst
Celanese projects. Site specific health and safety
considerations are detailed in Section 5.0.
All applicable local, state and federal codes and regulations
applicable to the construction operations were followed. This
includes, but is not limited to, applicable fire, electrical, and
worker health and safety requirements.
2.1 Extraction Well and Piezometer construction
All extraction wells and piezometers were installed by a well
contractor licensed in North Carolina. Wells and piezometers
were installed by using rotary techniques (air rotary, mud
rotary, auger, or diamond coring) in accordance with North
Carolina Administrative Code Title 15, Subchapter 2c, Well
Construction Standards.
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Materials of construction, borehole and casing diameters, and
well depths were as shown in the Remedial Design Report and
summarized in Table 2-1. The extraction wells, pumps, and
control devices were in accordance with the RD report, and the
piezometers were secured with lockable protective casings/covers
to deter unauthorized entry and vandalism. The sequence of
drilling was to drill the piezometers and outer tier extraction
wells, and then to drill the inner tier extraction wells.
Additional piezometers were installed subsequent to the initial
drilling using hollow stem augering and diamond coring
techniques. During construction of extraction wells and
piezometers, all health and safety work practices and designation
of exclusion zones areas were followed as outlined in Section
5 .1.
Table 2-1
summary of Well construction Information
Inner Tier outer Tier
Extraction Extraction Piezometer
Total Depth (ft) 42.5 65 62 to 65
Screen Length (ft) 10 20 20
Screen Slot ( in) 0.020 0.020 0.010
Borehole Diameter (in) 6 9 4 or 6
Casing Diameter (in) 2 6 1
Casing Material Stainless Carbon Steel PVC
Screen Material Stainless Stainless PVC
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The drilling equipment was decontaminated on its arrival at the
site and at the completion of the well construction operations
prior to leaving the site. The outer tier extraction wells and
piezometers were installed prior to installation of the inner
tier for extraction wells. The drilling equipment was not
decontaminated between borings.
Decontamination of large equipment was:
1. steam clean
2. wash with Alconox and tap water solution
3. rinse with tap water
4. rinse with isopropyl alcohol
5. rinse with deionized water
2.2 Collection and Treatment system Construction
Prior to the installation of the treatment system operating
units, a concrete pad was constructed between the polishing
ponds of the existing plant wastewater treatment system. The
treatment system was designed for installation on the pad, and
the area had provisions for spill and stormwater containment and
control using curbing and a collection sump. The inner tier
treatment system was constructed by personnel on a medical
monitoring program and having completed training requirements in
compliance with 29 CFR 1910.120. The outer tier piping system
was done by Yergen Construction and construction oversight was
done by Hoechst Celanese Corporation.
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3.0 SYSTEM OPERATION
3.1 Personnel and Responsibilities for the Groundwater
Extraction and Treatment system
The treatment system is being operated by Hoechst Celanese
personnel. The following are the personnel and duty
responsibilities for the treatment plant.
R.E. Caldwell, Senior Environmental Engineer
Duties:
Ron Caldwell is the Remedial Action Coordinator (RAC) for the
Shelby NPL site. The RAC monitors the groundwater system and
operation for compliance with ROD, Consent Order, and other
applicable and relevant requirements, and assists in resolving
operational problems and implementing system improvements.
Information is relayed for inclusion into EPA required reports
and documents. The RAC notifies EPA of possible problems and
other conditions as required under the Consent Order and
maintains all related records. He coordinates outside lab
analytical work in compliance with the established sampling
plan/schedule is done by the RAC. The RAC is thoroughly
familiar with the extraction/treatment system and requirements I under the ROD and consent Order.
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A. Pittman, Utilities/Maintenance Supervisor
Duties:
Archie Pittman supervises the operation of the groundwater
extraction/treatment system and is responsible for maintaining
system operation and performance. He directs manpower as needed
for system operation and maintenance, and allocates materials as
necessary to maintain operational performance. He is
responsible for monitoring the system for performance and
notifies the RAC of problems or abnormal conditions. He is
responsible for supervised training of operational and
maintenance personnel involved in the groundwater
extraction/treatment system and ensures all on-site analytical
work, as required by the established sampling plan, is
appropriately performed and recorded. He is thoroughly familiar
with the operation, Project Operations Plan, operational manual,
and performance requirements of the extraction/treatment system.
Groundwater Operators: J. Pearson and J. B. Wright
(alternates: w. E. Coyle, G. F. Southared, F. E. Queen, B. P.
Grigg, and L. J. Costner).
Duties:
The groundwater operators function under the direction of the
Utilities Supervisor and operate the groundwater
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extraction/treatment system as outlined in the Project
I Operations Plan and operational manual. They monitor system
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performance and notifies the Supervisor of possible problems.
They collect in-house analytical samples and delivers the
samples to Lab and perform tasks as necessary to maintain
performance of the extraction/treatment systems. They maintain
operational log and record data as outlined in the Project
Operation Plan relating to flows, volumes, and on-site
analytical work and are thoroughly familiar with the
extraction/treatment system's components and method of operation
and are familiar with the operation of the extraction/treatment
system.
Utilities Maintenance Operators: P. Wesson, C. Manning, R.P.
Rippy, and J. Morrison.
The utilities maintenance operators function under the direction
of the Utilities Supervisor and are responsible for maintenance
and repair operations involving the groundwater
extraction/treatment system. They are thoroughly familiar with
the system components and intended performance.
K. B. Patterson, Utilities Lab Operator
The Utilities Lab Operator performs in-house analytical
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measurements in accordance with Project Operations Plan and
standards as related to the groundwater extraction/treatment
system.
Note: All the above personnel have attained the training as
required under 29 CFR 1910.120.
3.2 system start-up
The outer tier extraction system was activated by turning the
power switch at each well head to the on position. The
discharge valves were adjusted to obtain about the maximum
drawdown at each well without pulling the water level below the
pump. The discharge valve will be further adjusted, based on
water level measurements from adjacent monitor wells, to
maintain overlapping zones of influences.
The pumps in the interior extraction system were turned on by
opening the air valve at each wellhead. The pump controls were
adjusted per the manufacturer's instructions so that only water I is pumped through the discharge lines (i.e. air is not entering
I the discharge piping). The level controls were adjusted per the
manufacturer's instructions so that pumping would occur when the
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water level is 6 inches above the top of the pump. The wells
are yielding more water than anticipated and the pumping
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duration is being controlled by the volume of water that can be
treated by the SBR.
Start-up of the treatment plant was preceded by bench-scale
I testing. Bench-scale tests were used to determine the necessity
and dosage requirements of powdered activated carbon (PAC),
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polymer and nutrients. The start-up testing showed that PAC was
not needed and was deleted as a treatment step in the
operation. The post start-up testing was conducted for a 4 week
period. Influent and effluent samples were collected daily from
the treatment unit and analyzed for BOD, COD, TSS, P04 ,
I NH4-N and pH. Target Compound List (TCL) organics and Target
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Analyte List (TAL) metals were analyzed weekly. Jar testing was
performed to determine the optimal polymer and type of polymer
required. After the start-up tests, the analytical results were
evaluated and operational parameters established. System
start-up was as recommended by the equipment suppliers.
Monitoring requirements for system start-up are detailed in
Section 4.2.
3.3 Treatment System Operation
Hoechst Celanese has developed a groundwater extraction unit
operating procedures (Appendix II). The operating procedures
were developed after the equipment was selected and construction
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completed. The operating procedures include maintenance
procedures and treatment plant operation and should be used as
guidance.
I 3.3.1 Equalization
I After extraction, the groundwater is pumped into a 4500-gallon
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tank for equalization. The tank is provided with a drain for
maintenance purposes. High and low level switches activate a
pump to convey the water to the treatment system. An emergency
high level switch/alarm is provided to shut off the extraction
I we'ils if the tank is in danger of overflowing. Treatment plant
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personnel respond to the high level alarm by shutting down the
extraction system.
Equalization is used to store and mix the pumped groundwater
prior to treatment. Equalization simplifies plant operation,
and improves process control. Collection in the equalization
tank allows for treatment of the wastewater on a batch basis.
Operational Considerations
Mixing of the inner tier equalization tank is needed.
Settleable solids are present and the water needs mixing to
maintain a reasonably constant effluent concentration and
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prevent solids accumulation. Because of its high efficiency,
mechanical mixing is being used for the high suspended solids
wastewater.
3.3.2 Neutralization
The pH correction of the groundwater is required before
biological treatment. Additionally, adjusting the water to an
alkaline pH range induces the precipitation of the dissolved
iron. The pH adjustment takes place in the equalization tank
and is accomplished by the addition of sodium hydroxide.
Most bacterial organisms cannot tolerate pH levels above 9.5 or
below 4. Generally the optimum pH for bacterial growth lies
between pH 6.5 and 7.5.
The pH control system measures the pH of the solution and
controls the addition of the neutralizing agent on demand to
maintain the equalization tank effluent within acceptable pH
limits. During the filling of the equalization tank, the pH
electrodes sense that the solution is outside of the limits and
I activate the metering pump to add alkaline reagent. When the
tank is filled, the metering pump remains on until the proper pH
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is obtained. If a proper pH cannot be maintained an alarm will
sound, and the treatment plant operator will respond. Because
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of the logarithmic nature of the pH function, there is a large
change in pH for a small addition of alkaline reagent as the
solution approaches neutrality. The tank is mixed by a
propeller mixer to mix and distribute the alkaline material.
Operational considerations
o Frequent checks of the pH adjustment system are
necessary. The pH is monitored daily. The pH probe are
cleaned and calibrated as needed.
o Jar testing should be done frequently to determine
economical neutralizing chemical dosages or operating
controls.
o Sodium hydroxide drums should be inspected daily to
determine when one drum is empty and when the supply
line should be switched to the other drum. When one
drum is empty, a replacement drum should be ordered.
3.3.3 Iron Removal
Iron removal is indicated; hence, equipment for settling, I removal and dewatering are needed. The following describes the
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iron removal processes and required equipment.
The conventional method of removing iron is chemical
precipitation of the metal as a hydroxide; followed by
coagulation of the metal particles into larger, heavier floe
particles, which then separate from the water. Iron dissolves
under acidic conditions and precipitates under alkaline
conditions. Thus, increasing the pH of the solution to the
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alkaline pH range induces the precipitation of the dissolved
iron. However, iron may redissolve at very high pHs. The pH is
increased by the addition of sodium hydroxide. The iron ions in
solution react with the hydroxide ions to form solid particles.
Because achieving proper coagulation is a problem faced by water
treatment operators, jar tests may be required. Jar testing
consists of collecting and transporting a sample to the
laboratory where it is divided into several samples in beakers.
Varying coagulant dosages are added to each sample and, after an
appropriate period of mixing by a multiple paddle mixing device,
I stirring is stopped and the floe is allowed to settle. The
clarity of the supernatant then is used to determine the optimum I
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coagulant dosage. In many cases, the operator's inspection of
the supernatant is used to select the best dosage.
Jar tests have limitations that should be recognized by the
operators. Whether or not the coagulant dosage that provides
the optimum results in a beaker also will provide optimum
results on a full-scale basis depends on whether the same
efficiency of mixing is achieved in both cases. Therefore, the
system is monitored and the polymer adjusted to optimize the
system operation.
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Operational considerations
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o Frequent jar tests are required to optimize polymer
dosage and effectiveness. Jar testing should be done
periodically.
o The hydroxide precipitation/coagulation treatment process
is time consuming. Much time can be spent dewatering
sludge, preventing stoppage of sludge transfer pumping,
preparing chemical solutions, maintaining pumps, valves
and controls. Maintenance is important for successful
operation. Maintenance should be performed as
recommended by the Vendors or as indicated by Plant
Maintenance.
If the iron hydroxide precipitated by pH adjustment settle
rapidly and leave a clear supernatant, then polymer addition may
not be required. Jar testing is used to determine best polymer
and optimal dosage.
Solids separation
There are several ways to separate the solids produced during
neutralization/precipitation from the water phase. A plate
settler is used for ease of operation and due to space
requirements. The pH-adjusted, polymer-treated wastewater flows
upward through the plates as the floe particles settle onto the
plates and slide into the sludge holding area.
Dewatering
Dewatering is provided using a recessed plate filter press.
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Fluid pressure generated by pumping the slurry into the filter
I press provides the driving force for filtration. A typical
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filter press cycle begins with the closing of the press. Sludge
is fed for a 20 to 30-minute period until the press is
effectively full of cake. The pressure is maintained for a 1 to
4-hour period during which more filtrate is removed and the
I desired cake solids content is achieved. The filter is then
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mechanically opened and the dewatered cake dropped from the
chambers into a hopper and drums for removal.
Operational considerations
o Filter press cloths require routine washing with high
pressure water, as well as periodic washing with acid.
Washing schedule shall conform to the Vendor's
recommendations.
o The feed system should inject conditioned sludge into the
chamber as rapidly as possible but slowly enough to
permit formation of a uniform and thick cake to prevent
sludge from passing through the filter cloth.
3.3.4 Sequencing Batch Reactor
The sequencing batch reactor (SBR) treatment consists of a batch
biological activated sludge system and operates in a sequence of
cycles. The SBR cycle consists of fill, treatment, settle,
decant, and idle stages. At the beginning of the cycle,
nutrients are added as needed. At the suggestion of the
manufacturer, the entire cycle was divided into three partial
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fill cycles. Each partial fill cycle introduces one third of
the total volume into the SBR. Aeration continues throughout
the fill cycles and until the subsequent settling cycle. The
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fill cycle, the SBR continues to aerate until the settling and
I decant periods. one complete cycle occurs each day.
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Nutrients are added as needed. During the fill period, the
wastewater is mixed anaerobically with the biological solids.
The wastewater biological solids mixture is aerated for a
sufficient time to affect biological oxidation, assimilation of
biodegradable content of the wastewater. After aeration, a
coagulant is added, if needed, to aid the clarification of fine
solids. The mixture is then allowed to settle for a specific
time to separate the biological solids from the treated
wastewater. The clear supernatant is then decanted to a holding
tank.
The settled solids are retained in the reactor for the next I cycle. As needed, a portion of those solids are wasted from the
I SBR system. Section 4.2 and 4.3.3 detail the treatment system
monitoring requirements.
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Operational Considerations
The operation of the batch SBR is controlled by adjustment of
the specific process parameters. These are:
0 hydraulic residence time (HDT)
o solids residence time (SRT)
0
0
0
mixed liquor carbon suspended solids (MLCSS)
cycle length
fill/react time ratio
The hydraulic residence time (HRT) is calculated by dividing the
volume of the reactor basin (V) by the influent feed rate (Q),
HRT = V/Q
and is a measure of the length of time that the wastewater is in
contact with the biological solids. The solids residence time
(SRT) is a measure of the average time that the biological
I solids, are retained in the batch SBR system. The SRT is
usually calculated by dividing the total mass of solids in the
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reactor by the amount of solids removed (W) daily from the
system. Therefore,
SRT = (MLSS) X (V) / (W)
where MLSS is the total mixed liquor suspended solids
concentration which is comprised of mixed liquor, biological
solids (biomass), and inert suspended solids.
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Cycle length is determined by the waste characteristics and the
hydraulic flow rate. The number of cycles are chosen to
minimize the fraction of the operating time devoted to settling
and decanting. However, where a cycle might be shorter than 24
hours, it is convenient to maintain a 24 hour cycle length.
The Fill/React time ratio is determined based upon the nature of
the wastewater and prior experience.
system Start-Up
Before building up an activated floe and concentrating on
control of the system, it was necessary to ensure that all
equipment works as intended.
Before the SBR was expected to perform properly, it was
necessary that all operation and maintenance personnel
understand the function and location of each piece of equipment
and piping. In addition, the following had been verified:
o Direction of flow marked clearly on pipes
o Equipment lubricated and tested
o Lights, meters, indicators and recorders operational
o Manufacturer's instruction and maintenance manuals read
and stored in one location for ready reference
o Daily operating logs available to record each day's data
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To start the SBR or initiate an addition to existing facilities,
water is added to the aeration unit gradually. The air flow is
started gradually as the diffusers are submerged and the air
increased as the tank is filled. All drains, valves, gates, and
return sludge pumps are tested.
When the plant was checked out completely with water, the water
was drained and the SBR was seeded with activated sludge from
the existing wastewater treatment plant and or other suitable
source of activated sludge. Even with a seeded system, the
plant will not operate efficiently for a period of time. After
the waste activated seed material was added, inner tier influent
groundwater was slowly added.
After the plant is filled with activated sludge and wastewater
is introduced, a 4-week period is generally required to develop
I sufficient numbers of organisms for effective treatment.
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3.3.5 Air stripping
Air stripping is used to remove volatile organics from aqueous
waste streams. Generally components with Henry's Law constants
of greater than 0.003 can be effectively removed by air
stripping. Combined use of air stripping and activated carbon
is an effective way of removing the contaminants from
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groundwater. The inner tier groundwater utilizes biological
treatment prior to air stripping and activated carbon.
The air stripper removes the more volatile compounds and reduces
the load on the carbon; thus, reducing the frequency and
expense of carbon regeneration. The air-to-water ratio shall be
I between 250 to 300 to 1 according to manufacturers'
recommendations. I
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Operational Consideration
o The equipment for air stripping was relatively simple,
start-up and shut-down can be accomplished quickly.
Periodic maintenance of the blower is being done as
recommended by the Vendor or Plant Maintenance.
3.3.6 Activated carbon
Activated carbon treatment is used as a polishing step to remove
organics in the air stripper effluent. Not all organics are
adsorbed to the same degree. Activated carbon will remove a
wide variety of organics, but removal of any given organic is
subject to interference from other materials in the waste I stream. competition for available adsorption sites becomes a
I factor. Generally, higher molecular weight organics are
preferentially adsorbed on the activated carbon. The lower
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molecular weight organics are adsorbed by new or fresh carbon,
which contain smaller pores.
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Adsorption systems may be operated in several ways. The
activated carbon vessels contain the media through which the
water is passed and may be operated in series or parallel
depending on the preferred operating conditions. When
breakthrough occurs (when effluent concentration exceeds the
desired level), the canister is taken out of service and the
carbon is removed and replaced. In series the first bed is
always exhausted and the second then becomes first, with a newly
filled cannister placed in the last step in the series. In
parallel, the replacement dates are staggered so that only one
bed is exhausted at a time. Spent carbon will be returned to
the carbon supplier for regeneration or disposal.
operational considerations
Effective cleaning of the filter media during backwash is
essential to successful plant operation. If the bed is not
cleaned adequately, a long-term accumulation of biological I organisms could result in plugging problems. Adequate
backwashing assisted by surface wash or air-water backwash can I
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eliminate this problem. Optimum scouring of the particles
results when the media are just suspended, however. When
suspended, the shearing force past the grains of media is equal
to the weight in water and is not increased with further
expansion and higher wash rates. A wash rate corresponding to
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25 percent expansion of the carbon layer is adequate for the
I filter. The wash rate required to achieve a given expansion
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depends of the water temperature and the size and specific
gravity of the filter media. Backwash water quantities as high
as 8 percent of the total water throughput may be required.
o Monitoring of the activated carbon effluent is required
to establish when breakthrough occurs. Monitoring
requirements are detailed in Section 4.2.
3.4 Reference Publications
The following publications should be purchased for use at the
treatment plant "Principles of Water Quality Management", w.
Wesley Eckenfelder, Jr.; "Industrial Water Treatment Practice",
P. Hamer; and "Sewerage and Sewage Treatment", Harold E.
Babbitt.
3.5 system Shut-Down
Emergency procedures must be established to detail operations in
the case of power failure, treatment system malfunction or pump
failure. In case of power failure emergency, power must be
established as soon as possible. The inner tier wastewater will
become septic within 48 hours. Table 3-1 details the steps to
be taken in case of failure of one of the operational units. If
the sequencing batch reactor is out of service for more than 48
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Table 3-1
operational steps to be taken
in case of Treatment System component Failure
Operational Less than 2 -24 24 -48 >48
Unit 2 Hours Hours Hours Hours
Activated carbon 1 1,4 1,4 1,3,4
Outer Tier Air 1,2 1,2,4 1,2,4 1,2,4
Stripper
Outer Tier Equali-4,5 4,5 4,5 4,5
zation Tank
Inner Tier Air 1,2 1,2 1,2,3 1,2,3
Stripper
sequencing Batch 1,2,5 1,2,5 1,2,3,5 1,2,3,5,6
Reactor
Inner Tier Equali-3,5 3,5 3,5 3,5,6
zation Tank
1. Shut off pump to unit
2. Shut off blower
3. Shut off inner tier pumps
4. Shut off outer tier pumps
5. Shut down subsequent treatment units
6. Initial start-up procedures
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hours it should be drained, refilled and the initial start-up
procedures implemented. In the case of extraction pump
failure, it will be replaced as soon as practical. In the event
that the SBR unit is shut down, the clarified liquid will be
drained to the equalization tank and the balance of the contents
drained into the plant's wastewater treatment system or into
I tanker trucks.
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4.0 SYSTEM INSPECTION AND MONITORING
This section presents the routine operation and monitoring
requirements for the extraction and treatment systems.
4.1 system Inspection
I The pumping and collection systems is inspected on a weekly basis
to assure that the systems are functioning properly, that leaks
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have not developed, and that component deterioration has not
occurred that will jeopardize the system operation. All
deficiencies were noted and corrected as soon as practical.
The treatment systems is inspected on a daily basis for proper
operation and maintenance in accordance with Vendor
specifications. All deficiencies are noted and are corrected as
soon as practical. Deficiencies which could result in inadequate
treatment of the groundwater will result in shut down of the
extraction and treatment systems (Section 3.3).
Both the extraction and collection, and treatment systems will be
inspected as soon as practical after an extreme climate event
(i.e., high winds, extreme cold, etc.) which may have impaired
the operations of the systems to assure they are functional.
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Damage occurring during such events will be repaired as soon as
practical.
The results of the inspections will be recorded in ink in
separate, bound notebooks identified for use during inspections
of the extraction and collection, and treatment systems. The
inspection records will include the result of the inspection,
actions taken to correct deficiencies, date and name of
inspector.
4.2 Operational Monitoring
I To determine plant performance during remediation, samples will
be collected and analyzed. Table 4-1 is a list of the treatment
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unit, type of analyses and frequency of monitoring for routine
monitoring. Table 4-2 is a list of the treatment units type of
analyses and frequency of monitoring during system start up.
Sampling procedures shall be conducted as indicated in Section
4.3.4. according to the EPA Engineering Support Branch Standard
I Operating Procedures and Quality Assurance Manual, April 1, 1986.
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Table 4-1
operational Monitoring Plan
Operational
Unit
Outer Tier Influent
Inner Tier Influent
Sequencing Batch
Reactor
SBR Effluent
Air Stripper Effluent
Activated Carbon
Effluent
Type of
Analysis
TOC
BOD5 TSS
pH
TOC
COD
NH3-N
P04
MLSS
MLVSS
pH
BOD5 COD
TOC
TOC
TOC
-5-day biochemical oxygen demand
-total suspended solids
-total organic carbon
-chemical oxygen demand
-ammonia nitrogen
-phosphate
-mixed liquor suspended solids
Frequency
w
M
D
D w
D w
w
D
w
D
w
D
w
w
w
BOD5 TSS
TOC
COD
NH 3-N
P04 MLSS
MLVSS -mixed liquor volatile suspended solids
D -Daily
W -Weekly
M -Monthly
Note: See Table 4-4 for additional monitoring parameters for
the outer and inner tier influent and the final effluent.
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Table 4-2
Monitoring Plan System start Up
Operational
Unit
Outer Tier Influent
Inner Tier Influent
Sequencing Batch
Reactor
SBR Effluent
Air Stripper Effluent
Activated Carbon
Effluent
Type of
Analysis
TOC
BOD5 TSS
pH
TOC
COD
NH3-N
P04
MLSS
MLVSS
pH
BOD5 COD
TOC
TOC
TOC
TCL
TAL
-5-day biochemical oxygen demand
-total suspended solids
-total organic carbon
-chemical oxygen demand
-ammonia nitrogen
-phosphate
-mixed liquor suspended solids
Frequency
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
w
w
BOD5 TSS
TOC
COD
NH 3-N
P04 MLSS
MLVSS
TCL
TAL
-mixed liquor volatile suspended solids
-target compound list
-target analyte list
D -Daily
w -Weekly
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4.3 Remedial Action Monitoring
The purpose of the monitoring plan is to verify the
effectiveness of the groundwater extraction wells in controlling
contaminant migration and removing the contaminants from the
aquifer, and in monitoring the effectiveness of the treatment
system. This monitoring identifies when groundwater extraction
can cease, and documents the effectiveness of the remedy.
4.3.1 Groundwater Elevation
To assure that the extraction system is effectively minimizing
contaminant migration, overlapping cones of depression created
by the extraction wells are maintained. The creation of the
overlapping cones of depression are verified by the measurement
of groundwater levels in the vicinity of each tier of wells.
Drawdown and yield of each outer tier extraction well are
determined in addition to the water levels of the adjacent
monitor wells. Chapter 6 contains forms for use in data
collection and reporting.
Ten, 1-inch piezometers are installed down hydraulic gradient of
the outer tier extraction wells. Appendix I shows the proposed
locations for these wells. Since some of these wells are off
site, access rights for the installation and monitoring of these
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wells were required.
Groundwater levels were measured in selected monitor wells and
piezometers prior to initiation of the extraction pumping,
weekly for the first month of pumping, and monthly for a year.
If data indicate consistent results, the monitoring frequency
will be reduced to quarterly. Modification of this program may
be appropriate after stabilization of the extraction operations,
but will not be initiated without EPA approval. Wells for the
proposed elevation monitoring program are listed in Table 4-3,
and are shown along with the other site monitor wells in
Appendix I.
J-29.5
J-59.5
K-28
K-58
M-44.5
N-29
N-53.5
0-25
0-59.2
P-31.5
P-58.4
Q-33
R-17
R-42.5
Table 4-3
Extraction Water Level
Monitoring Locations
T-17
T-35.7
T-58.5
U-38.6
V-23.4
W-23.3
X-32.9
Y-38.8
Y-74.4
Z-78.4
AA-41
AA-54
CC-33
CC-64
DD-58
EE-58
FF-23.6
FF-34.5
FF-62.4
GG-25.8
GG-39
GG-61
HH-48
HH-77.4
PZ-1
PZ-2
PZ-3
PZ-4
PZ-5A
PZ-5B
PZ-6A
PZ-6B
PZ-7A
PZ-7B
Minor adjustments in the pumping rates of the extraction wells
will be made as needed to maintain overlapping cones of
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depression. The results of the monitoring are being reported to
EPA on a monthly basis until the system has obtained stable
operation and a modified schedule is agreed upon between Hoechst
Celanese and EPA.
4.3.2 Groundwater Quality
Groundwater quality monitoring is being performed to assess the
effects of the groundwater extraction on the contaminant plume.
Table 4-4 identifies the wells being sampled, the analyses being
performed, and the frequency of sampling, until the system
obtains stable operation. After the data indicate the system
has stabilized, the sampling and monitoring program will be
reviewed on a periodic basis and modifications proposed for EPA
approval and subsequent implementation.
The results of the monitoring are being reported to EPA on a
monthly basis until the system has obtained stable operation,
and a modified schedule is agreed upon between Hoechst Celanese
and EPA. Quarterly reports are also being issued evaluating the
data.
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I
I Table 4-4
~ater Quality Monitoring Locations and Frequencies1
I Location Leveli ~ Ill! Cond TDC TOX Cr voe fil ill. B002 coo
C-49 Q2 Q Q Q Q Q Q A A
I K-28 M M M M " M " Q A A
I P-58.4 Q Q Q Q Q Q Q Q A A
T-35.7 M " " M M " " Q A A
I V-23.4 M " M M M " " Q A A
AA·54 Q Q Q Q Q Q Q Q A A
I CC-33 M M M M M M M Q A A
I EE-58 M M M M M M M Q A A
FF-34.5 M M M M M M M Q A A
I FF-62.4 Q Q Q Q Q Q Q Q A A
GG-61 Q Q Q Q Q Q Q Q A A
I HH-48 Q Q Q Q Q Q Q Q A A
I HH-77.4 A A A A A A A A A A
\Jalker Q Q Q Q Q Q Q A A
I Lambert Q Q Q Q Q Q Q A A
Stein Q Q Q Q Q Q Q A A
I Martin Q Q Q Q Q Q Q A A
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Table 4-4, contin.aed
Water Quality Monitoring Locations and Frequencies1
Cond
M
M
M
M
M
M
£r.
M
M
voe
Q
Q
ill
M
M
coo
M
M
TCLP
I Treatment Effluent3
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Inner
Outer M
SBR Sludge
Filter Press Sludge
M
M
M
w
w
M
M
M
Notes: 1. Frequency until modified by agreement with EPA.
M
Q
Q
Q
2. W-Weekly; M-Monthly; C-Cuarterly; SA-Semi-Annual; A-Annual.
SA
SA
si
3. All analyses except TCLs will be performed weekly for the first
month.
4. Analyses to be performed
Level water level
Tell"!) water terrperature
pH pH
Cond specific conductance
TDC total organic carbon
TOX total organic halides
Cr total chromiun
voe TCL volatile organic corrpounds
TCL target corrpound organic list corrpounds
TAL target analyte list inorganic parameters
BOOS 5-day biochemical oxygen demand
coo chemical oxygen demand
5. To be analyzed monthly for the first 6 months, then Quarterly
until modified.
6. Semi-Annual for the first year, then annually until modified.
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SA
M
M as
SA
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4.3.3 Treatment System Monitoring
water Quality
The effectiveness of the treatment system is monitored by
periodically analyzing samples of the influent to the treatment
systems from each of the two tiers of wells and the effluent
from the air stripping towers or carbon units. The monitoring
program is presented on Table 4-4.
The results of the treatment system monitoring is reported to
EPA on a monthly basis and interpreted on a quarterly basis.
Evaluation of these data may indicate a revised monitoring plan
would be adequate to monitor the system performance. If so, the
revised plan will be submitted to EPA for approval prior to
implementation.
Sludge Quality
The quality of the sludge from the sequencing batch reactor
(SBR) is being sampled monthly for the first 6 months of
operation, and analyzed for Toxicity Characteristic Leaching
I Procedure (TCLP) compounds. After the initial 6 months, the
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operational history supports a modification to the monitoring
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I schedule. In addition to TCLP analyses, the SBR sludge will be
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analyzed for TCL/TAL compounds semi-annually for the first year,
then annually thereafter until modified through agreement with
the EPA.
The filter press sludge will be analyzed semi-annually for full
TCLP analyses.
The results of the analysis are submitted to EPA on a monthly
basis along with the other monitoring data, until modified by
written agreement with EPA.
Air Quality
The quality of the discharged air from the air stripping units
will be monitored for TCL volatile organic compounds after
obtaining stable operations. After the initial year's testing,
I the air stripping towers will be sampled every 3 years. Data
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will be sent to EPA in the routine monitoring reports.
4.3.4 Monitoring Protocols
Water Level
several of the monitor wells are fitted with Well Wizard
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HC/Shelby, NC Facility
Westinghouse Project 4124-85-0SOH
Document Control 85050H-0132
REVISED 12/89 Page 4-12
dedicated sampling devices. The water level indicators
incorporated in the sampling devices are used where available.
In the piezometers and wells not equipped with dedicated
sampling devices, a conductivity water level probe is used to
measure the depth of the water level from the reference point.
The water levels will be recorded to the nearest 0.01 foot with
the conductivity tape and the nearest 0.1 foot with the
dedicated sampling devices. Where the conductivity tape is
used, the probe will be decontaminated between wells.
water sampling
Sample containers for the analyses will be provided by the
laboratory doing the analyses or a qualified supplier of sample
containers such as IChem. Sample bottle type, and preservation
will be in accordance with EPA "Standard Operating Procedures
and Quality Assurance Manual (SOPQAM), April 1, 198611 • The
sample size and number will be in accordance with the SOPQAM or
equal. Table 4-5 summarizes container, preservation, and
holding requirements relevant to the analyses planned for the
I project.
I Monitor Well Sampling: Well sampling will be done by IEA or
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Westinghouse. Prior to sampling, the well closure is opened and
the well allowed to vent. Organic vapor concentrations are
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Document Control 85050H-0132
Page 4-13
Table 4-5
RECc»4MENDED SAMPLE CONTAINERS, PRESERVATION AND HOLDING TIMES
Holding
Parameter Container Preservative Time Reference
Liquid -Low to MediLJTI Concentration Sanples
Alkalinity 500-ml or 1-liter Coot, 4°c 14 days C
polyethylene with
polyethylene or
polyethylene
closure 1
lined
Acidity 500-ml or 1-liter Cool, 4°c 14 days C
polyethylene with
polyethylene or
polyethrlene lined
closure
Bacter i ol ogi cal 250-ml glass with Coo.l, 4°c 6 hrs. C
glass closure or
plastic capable of
being autoclaved
Biochemical Oxygen 1/2-gal. cool, 4°c 48 hrs. C
Dem and (BOO) polyethylene with
pol yethrene
closure
Chloride 500-ml or 1-liter None 28 days C
polyethylene with
polyethylene or
polyethylene lined
closure1
Chlorine Residual In-situ, beak.er or None Analyze C
bucket lrrmediately
Color 500-ml or 1-liter Cool, 4°C 48 hrs. C
polyethylene with
polyethylene or
polyethrlene lined
closure
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RC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 4-14
Table 4-5, Continued
RECOMMENDED SAMPLE CONTAINERS, PRESERVATION AND HOLDING TIMES
Holding
Parameter Container Preservative Time Reference
Liquid -Low to Mediun Concentration Sanples (continued)
Conductivity 500-ml or 1-liter Cool, 4°C 28 days C
polyethylene with (determine on
polyethylene or site if
polyethylene
closure1
lined possible)
Chromiun, Hexavalent 1-liter polyethylene cool, 4°c 24 hrs. C
with polyethylene
closure
Cyanide 1-liter or Ascorbic 14 days C
1/2-gal Ion Aci/•3
polyethylene with Sodiun
polyethylene or Hydroxide pH>
polyethylene lined 12, Cool 4°c
closure
Dissolved Oxygen In-situ, beaker or None Determine On C
(Probe) bucket Site
Dissolved Oxygen 300-ml glass, BOO Fix on site, 8 hrs. C
(Winkler) bottle store in dark (determine on
site if
possible)
EP Toxicity 1-gal. glass (arrber) Cool, 4°C ASAP· NS B
with Teflon liner
Fluoride 1-liter polyethylene None 28 days C
or 1/2-gal.
polyethylene with
polyethylene or
polyethtlene lined
closure
Metals 1-liter polyethylene SOX Nitric2 6 months C
with polyethylene Acid, pH <2
lined closure
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Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-0S0H
Document Control 85050H-0132
Page 4-15
Table 4-5, Continued
RECOMMENDED SAMPLE CONTAINERS, PRESERVATION AND HOLDING TIMES
Parameter Container Preservative
Liquid -Low to Mediun Concentration Sarrples (continued)
Metals, Dissolved
Nutrients4
Oil and grease
Organic Compound
Extractable and
Pesticide Scan
No Residual Chlorine
Present
Residual Chlorine
Present
Organic Corrpounds
Purgeable (VOA)
No Residual Chlorine
Present
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1-liter polyethylene
with polyethylene
lined closure
1-liter polyethylene
or 1/2-gal.
polyethylene with
polyethylene or
polyethylene lined
closure
1-liter widemouth
glass with Teflon
lined closure
1-gal. amber glass
or 2 1/2-gal. amber
glass with Teflon
lined closure
1-gal. amber glass
or 2 1/2-gal. amber
glass with Teflon
lined closure
2 40-ml vials with
Teflon lined septun
caps
Filter on
sit/ 50 X
Nitric Acid, pH
<2
SOX Sulfuric2
Acid, pH <2
Cool, 4°c
SOX Sulfuric2
Acid, pH <2
Cool, 4°C
Cool, 4°c
Add 3 ml 10%
Sodiun
Thiosulfate per
gallon, Cool,
4°C
4 drops Cone.
Hydrochloric
Acid, Cool,
4°c
Holding
Time
6 months
28 days
28 days
47 days5
47 days5
14 days
Reference
C
C
C
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C
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HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0l32
Page 4-16
Table 4-5, Continued
RECOMMENDED SAMPLE CONTAINERS, PRESERVATION AND HOLDING TIMES
Parameter Container Preservative
Liquid· Low to MediLm Concentration Sanples (continued)
No Residual Chlorine
Present
Residual Chlorine
Present
Organic COOl)Ounds
Specified and
Pesticides
(Non-Priority
Pollutants such as
Herbicides)
Organic Halides
Total (TOX)
pH
Phenols
Phosphate-Or tho
Phosphorus, Total
Dissolved
2 40-ml vials with
Teflon lined septllll
caps
2 40-ml vials with
Teflon lined septun
caps
1-gal. ant>er glass
or 2 1/2-gal. anber
glass with Teflon
lined closure
250-ml anber glass
with Teflon lined
sept1.n1 closure
In-situ, beaker or
bucket
1-liter arrber glass
with Teflon lined
closure
500-ml or 1-liter
polyethylene with
polyethylene or
polyethylene lined
closure
500-ml or 1-liter
polyethylene with
polyethylene or
polyethylene lined
closure
Cool, 4°c
Footnote 6
Footnote 7
Cool, 4°c
None
SOX Sulfuric
Acid, pH <2
Cool, 4°c
Filter-on-site
Cool, 4°c
Filter-on-site
SOX Sulfuric
Acid, pH <2
Cool, 4°c
Holding
Time
7 days
14 days
47 day/
ASAP· NS
Analyze
lmnediately
28 days
48 hrs.
28 days
Reference
C
C
C
D
C
C
C
C
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HC/Shelby, NC Facility
Westinghouse Project 4124-85-0SOH
Document Control 85050H-0132
Page 4-17
Table 4-5, Continued
RECOMl!ENDED SAMPLE CONTAINERS, PRESERVATION ANO HOLDING TIMES
Parameter Container Preservative
Holding
Time
Liquid· Low to Mediun Concentration Sanples (continued)
Solids, Settleable
Solids (Total and
Suspended, etc.)
Sul fates
Sulfides
Temperature
Turbidity
1/2·gal. Cool, 4°c 48 hrs.
polyethylene with
polyethylene closure
500-ml or 1-liter Cool, 4°c 7 days
polyethylene with
polyethylene or
polyeth,lene lined
closure
500-ml or 1-liter
polyethylene with
polyethylene or
polyethylene lined
closure1
500-ml or 1-liter
polyethylene with
polyethylene or
polyethylene lined
closure 1
In-situ, beaker or
bucket
500-ml or 1-liter
polyethylene with
polyethylene or
polyeth{lene lined
closure
Cool, 4°c 28 days
2 ml Zinc 7 days
Acetate2 Cone.
Sodi1.111 Hydroxide
to pH >9 Cool,
4°c
None Determine On
Site
Cool, 4°c 48 hrs.
Soil, Sediment or Sludge -low to Mediun Concentration
E.P. Toxicity
Metals
8-oz. widemouth
glass with Teflon
lined closure
8-oz. widemouth
glass with Teflon
lined closure
Cool, 4°C ASAP · NS
Cool, 4°c 6 months
Reference
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C
C
C
C
C
B
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HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 4-18
Table 4-5, Continued
RECOMMENDED SAMPLE CONTAINERS, PRESERVATION AND HOLDING TIMES
Parameter Container Preservative
Soil, Sediment or Sludge Low to Mediun Concentration (continued)
Nutrients Including:
Nitrogen,
Phosphorus, Chemical
Oxygen Demand
Organics -
Extractable
Organics -Purgeable
(VOA)
Other Inorganic
Compounds
Including Cyanide
Toxicity
Characteristics
Leaching Procedure
(TCLP)
Abbreviations:
Footnotes:
500-ml polyethylene Cool, 4°c
with polyethylene
closure or 8 oz.
widemouth glass with
Teflon lined closure
8 oz. widemouth
glass with Teflon
lined closure
4-oz. (120 ml)
widemouth glass with
Teflon lined closure
500-ml polyethylene
with polyethylene
closure or 8-oz.
widemouth glass with
Teflon lined closure
Cool, 4°C
cool, 4°c
Cool, 4°c
8-oz widemouth glass Cool, 4°c
with Telflon Lined
Closure
ASAP= As Soon As Possible
NS = Not Specified
Holding
Time
ASAP
ASAP
ASAP
ASAP
ASAP -Holding
Times for
Extract Per
Protocols for
Analytical
Fraction
Reference
A
A
A
A
E
1. Use indicated container for single parameter requests, 1/2 gallon polyethylene container
for lllJltiple parameter requests except those including BOO, or 1-gallon polyethylene
container for lllJltiple parameter request which include BOO.
2. Must be preserved in the field at time of collection.
3. Use ascorbic acid only if the sarrple contains residual chlorine. Test a drop of sa111Jle
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Project Operations Plan
RC/Shelby, NC Facility
Westinghouse Project 4124-85-0S0H
Document Control 85050H-0132
Page 4-19
Table 4-S, Continued
RECOMMENDED SAMPLE CONTAINERS, PRESERVATION AND HOLDING TIMES
Footnotes: (Continued)
with potassiun iodide-starch test paper; a blue color indicates need for treatment. Add
ascorbic acid, a few crystals at a time, until a drop of sa~le produces no color on the
indicator paper. The add an additional 0.6 g of ascorbic acid for each liter of sa"l)le
volume.
4. May include nitrogen series (anmonia, total Kjeldahl nitrogen, nitrate-nitrite), total
phosphorus, chemical oxygen demand and total organic carbon.
5. Samples must be extracted within seven days and extract rrust be analyzed within 40 days.
6. Collect the sa~le in a 4 oz. soil VOA container which has been pre-preserved with four
drops of 10 percent sodiun thiosulfate solution. Gently mix the sa~le and transfer to a
40 ml VOA vial that has been pre-preserved with four drops concentrated HC1, cool to
4°c.
7. See Organic C~unds -Extractable. The Analytical Support Branch should be consulted
for any special organic coopound analyses in order to check on special preservation
requirements and or sa~le voll.lTle.
References:
A. US-EPA, Region IV, Environmental Services Division, "Analytical Support Branch, Operations
and Quality Control Manual", June 1, 1985 or latest version.
B. EPA Method 1310, Extraction Procedures, 11S\I 84611 , US-EPA, Office of Sol id \lastes,
\./ashington, DC, 1982.
C. 40 CFR Part 136, Federal Register, Vol. 49, No. 209, October 26, 1984.
0. EPA Interim Method 450.1, 11Total Organic Halide", US-EPA, ORD, EMSL, Physical and Chemical
Methods Branch, Cincinnati, Ohio, Novenber 1980.
E. 40 CFR Part 261, Federal Register, Vol. 51, No. 114, June 13, 1986, pg. 21686.
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Document Control 85050H-0132
Page 4-20
measured for selection of appropriate respiratory protection.
The depth to water will be measured, and the volume of standing
water in the well will be calculated.
Each well will be purged at least 3 well volumes prior to
sampling to remove standing water and to induce fresh formation
water into the well. The wells will be purged with the
dedicated sampling devices, Teflon and stainless steel pneumatic
pumps using polyethylene air supply and discharge hoses, or
Teflon or stainless steel bailers. The purged water will be
discharged onto the ground. In the case of a slow recharge
well, the well will be pumped to dryness, and the pump removed
I before sampling. Specific conductivity, pH, and temperature
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will be measured after evacuation of each well volume and
recorded to serve as indicators of purging completion. Purging
will continue until three consecutive indicator measurements
compare within 10%. In the event that stabilization is not
attained, a maximum of 10 well volumes will be removed during
the purging operations.
Once the wells are purged, the non-dedicated pump and hoses will
be removed and the well sampled. Closed-top stainless steel and
Teflon bailers will be used for well sampling where dedicated
sampling devices do not exist. The bailer will be attached to a
new nylon rope and lowered slowly into the well to minimize
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HC/Shelby, NC Facility
Westinghouse Project 4124-85-0SOH
Document Control 85050H-0132
REVISED 12/89 Page 4-21
agitation of the water. One bailer volume will be extracted
from the well and wasted on the ground. Subsequent bailer
volumes will be used to fill the sample bottles. When the well
sampling is completed, the bailer will be removed, the nylon
rope discarded and the well closed and secured. Where dedicated
sampling devices exist, sample collection will be in accordance
with the manufacturer's recommendations. In the event that
tubing has to be added to the permanent tubing or the dedicated
Well Wizards sampling devices, Teflon Tubing will be used.
The Teflon tubing used on the non-dedicated purging pumps will
be either discarded after completion of the sampling of each
well or decontaminated and stored in plastic bags, marked with
the appropriate well number, and retained for later use. To
minimize the potential for cross-contamination between wells,
the tubing stored for later use will be dedicated to a specific
well. The non-disposable equipment will be decontaminated in
accordance with Section 4.3.5.
The samples will be placed on ice or refrigerated prior to
shipping to the laboratory for analysis using chain-of-custody
procedures. Delivery to the laboratory will be by next day
I package service or courier.
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Westinghouse Project 4124-85-0S0H
Document control 85050H-0132
REVISED 12/89 Page 4-22
Residential Well Sampling: Sampling of four residential wells
is part of the offsite water quality monitoring program. The
faucet nearest the pump will be used for sampling where when
possible. The faucet will be turned on, adjusted until a
uniform flow of water is obtained, and allowed to run for 5 to
15 minutes to attempt to purge the well casing and storage tank
prior to sample collection. At the time of sampling, the flow
will be estimated by timing the filling of a container of known
volume, the pH, temperature and conductivity measured, and the
sample bottles filled.
The samples will be placed on ice or refrigerated prior to
shipping to the laboratory for analysis. Delivery to the
laboratory will be by next day package service or courier.
Sludge Sampling
The SBR and filter press sludge samples will be collected using
decontaminated stainless steel equipment and packaged in
accordance with the protocol containers for the specific
I analyses. Samples for analyses will be refrigerated and
maintained at a temperature of about 4° Centigrade until
I testing.
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Westinghouse Project 4124-85-0S0H
Document Control 85050H-0132
Page 4-23
Air sampling
Air samples will be obtained from sampling ports on the exhaust
of the air stripping units in accordance with the specified
protocol.
4.3.5 Equipment Decontamination
The sampling equipment will be decontaminated prior to its
initial use, between sampling locations, and after completion of
the sampling event. The intent of the decontamination effort is
to minimize the potential for creating false data responses in
the sample analyses resulting from cross-contamination, or from
introducing contamination from external sources.
Decontamination procedures will be:
0 Bailers, spoons, buckets, pumps and small pieces of
equipment:
1.
2 •
3 •
Wash in Alconox and tap water solution
Rinse with tap water
Rinse with isopropyl alcohol
4. Rinse with deionized water
5.
6.
Wrap in aluminum foil
Seal foil with custody seal if equipment is to be
stored for later use
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HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0l32
Page 4-24
0 Outside of polyethylene hoses:
1. Wash in Alconox and tap water solution
2. Rinse with tap water
3. Rinse with deionized water
4. Place in plastic bags
5. Seal plastic bag with custody seal if hoses are to
be stored for later use
4.3.6 sample Packing and Shipping
Samples to an outside laboratory will be packaged and sent as
I environmental samples and transported to the laboratory by
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courier (i.e. Federal Express). Packaging requirements for
environmental samples are:
1.
2.
3.
4.
5.
6.
7.
Complete all documents, tags, and forms appropriate
to the samples to be shipped.
Ensure that all bottles have the appropriate labels
affixed, and all appropriate tags are securely
fastened.
Mark the sample volume level on each container with
an indelible marker.
Secure container lids to prevent
lids for added leak protection.
on lids.
leaks. Tape the
Use custody seals
Secure the drain plug at the bottom of the cooler
used for sample transport with duct tape.
Place approximately 1 inch of vermiculite in the
bottom of the liner as a cushioning material and as
an absorbent in case of leakage.
Seal each sample container in individual plastic
bags, and place upright in the lined cooler.
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HC/Shelby, NC Facility
Westinghouse Project 4124-85-0S0H
Document Control 85050H-0132
Page 4-25
8. Repackage ice in small, sealed plastic bags and
place loosely in the cooler. Do not pack ice so
tightly that it may break glass bottles or prevent
addition of sufficient cushioning material.
9. Place small containers, such as 40-ml septum vials
for VOAs, in small plastic sealed bags. When
shipping these with larger containers, additional
vermiculite will be added to prevent them from
being crushed.
10. Fill the remaining space in the lined cooler with
vermiculite.
11. Place the documents accompanying the samples in a
sealed, large plastic bag attached to the inside of
the cooler lid.
12. Close the lid of the cooler and fasten the latch.
13. Affix signed custody seals to both ends of the
cooler in such a manner that they must be removed
or broken in order to open the cooler.
14. Wrap duct, fiber, or clear packing tape around both
ends of the cooler several times, each time
slightly overlapping the custody seal.
15. Mark the cooler on the outside with the following
information: name and address of laboratory, return
address, and arrows indicating the "This End Up" on
all four sides.
4.3.7 Sample custody
Samples to be sent off-site will use a sample custody and
chain-of-custody procedures will be:
1.
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Place the sample in an appropriate bottle and log
the following information in the field notebook:
o sample and tag number
0 type of analysis
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Document Control 85050H-0132
Page 4-26
2 .
3.
4.
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0 date
0 sample bottle lot number
0 name(s) of sampler(s)
0 time (military)
0 location
0 comments
Fill in sample label with:
0 sample number
0 type of analysis
0 date
0 site name or code
0 time (military)
0 preservative used, if any
Place samples in coolers. Samples are to remain in
the custody of the samplers until they are brought
to the sample processing area.
Complete chain-of-custody forms including:
0 sample number(s)
0 date
0 project name and number
0 name(s) of sampler(s)
0 time (military)
0 type (grab or composite)
0 number of samples
0 volume of bottles
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Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 4-27
5. Relinquish the samples to the person designated to
receive them and have the chain-of-custody form
signed, and record the time of transfer and date.
6. Log the name of the individual receiving the sample
and the time relinquished in the sampler's field
notebook.
7. Tape the lids closed and affix custody seals over
the sample lids.
8. Prepare sample tags, signed by the sampler(s) and
attach to the bottle. Record the tag numbers in
the remarks column on the appropriate
chain-of-custody form.
9. Record the sample numbers, receipt of samples, tag
numbers, date and time samples were taken, etc., in
the sample tracking log books (one for organic
samples and one for inorganic samples).
10. Package the samples and deliver according to the
protocols described in this plan or store in a
designated refrigerator until packed for shipping.
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Westinghouse Project 4124-85-0S0H
Document Control 85050H-0132
Page 5-1
5.0 HEALTH AND SAFETY CONSIDERATIONS
Site operations will be in accordance with the Health and Safety
Plan contained in the Remedial Design Report, and summarized in
this section.
s.1 work Practice controls
s.1.1 standing orders
The Site Manager shall develop and post a set of standing orders
governing work practices and shall ensure than each person
I entering the site is trained in these standing orders. Standing
orders may be altered/amended based on the development of new
I information. At a minimum, standing orders will include the
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following:
o Activities which require hand-to-mouth contact such as
eating, drinking, smoking, etc. are prohibited in the
exclusion area.
o All personnel on-site must be briefed on all known
hazards associated with the area prior to entry.
s.1.2 site organization
The following site organization will be used for extraction well
and treatment system installation and groundwater sampling.
Isa-
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Westinghouse Project 4124-85-050H
Document Control 8~050H-0132
Page 5-2
o Exclusion Zone: For the inner tier wells, a JO-foot by
30-foot area surrounding a well during installation and
sampling will be considered the exclusion zone.
Additionally, 30 feet on either side of the limits of
invasive construction will be considered the exclusion
zone for the general construction. These areas will be
clearly marked and can be amended by the Site Manager as
dictated by site conditions.
o Contamination Reduction Zone: The permanent
decontamination pad will be used for contamination
reduction.
o Support Zone: The support zone will be the area directly
west of the decontamination pad.
Figure 5-1 shows the general layout of the site, specific
organizational areas and locations of emergency services.
5.1.3 standard Operating Procedures and Task-Specific Risk
Assessment
Groundwater Sampling
Groundwater samples will be collected from the selected monitor
wells as presented in Section 4.3. Prior to sampling, each well
will be opened and allowed to vent. The depth to water will be
I measured and recorded. The wells will initially be evacuated to
remove stagnant water, with pH, specific conductance, and
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temperature recorded in the field and used as a guide to
indicate when wells have stabilized and are ready to be
sampled. Once the purging is completed, water samples will be
collected and placed in containers as shown in Table 4-4.
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---
REVISIONS
- -
-cP
HI TRANCE
□
BY PRDJl:CI NO. 4124-85-QSQH
D£SIGl£0 8Y E.W. GLOVER
DR~WN BY LO. ROSS
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""" PRODUCTION
"'"
ACCESS Rom
D~TE
-- - -
n
INNER TIER
EXTRACTION AAEA
C0NT~ATI0N
RrnornoN J
LeeoRT ZON~ 0
RECREATION POND
~ Westinghouse Environmental ~ ond Geotechnical Services, Inc.
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EXCLUSION ZONE: The 30ft x 3011 area surrounding o well
- -
during installation and/or sampling ,..illbo considered the e,clusion zone.
Additionally, 30 feet on either side of the limits of construction will be considered
the exclusion zone for the general construction. These areas will be
clearly marked and con be emended by the Site ~lanoger as dictated
by site conditions.
CONTAMINATION REDUCTION ZONE: The permanent decontamination
pod willbe used for conlom1not,on reduction.
SUPPORT ZONE: The support zone will be the area
directly west of the decontominotion pod.
HOECHST CELAf,ESE
SITE ORGANIZATION
GROUNDWATER REMEDIAL ACTION
HCISHELBY, NC F ACIUTY
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-4
Monitoring well sampling will be performed by a 1-person
I sampling team. Each team will use an OVA or HNu monitoring
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device for the inner tier wells. The crew will monitor the
headspace in the well prior to sampling and also monitor
discharge water during well purging and sampling. Activities
will be performed at Level D. If monitoring devices detect
levels 5 ppm above background in the breathing zone, the
sampling activities will be upgraded at Level C.
Risk Assessment: The following have been identified as
general concerns to be addressed by the health and safety plan:
50SOHOOS
o Chemical Hazards -The risk of exposure to chemicals
present in groundwater is primarily due to water-soluble
organic compounds. Exposure to organic compounds by
inhalation and skin contact may occur during the purging
and sampling of monitor wells. Purging, bailing, and
sampling well water will promote volatilization of
organic compounds which are readily absorbed through the
lungs. Organic compounds and volatile organic compounds
present in groundwater may also be absorbed through
unprotected skin. Ingestion of contaminants through
hand-to-mouth activity may also increase the health
risks associated with exposure to these compounds.
Hand-to-mouth activity is prohibited during sampling
operations. Air monitoring will be conducted during
these tasks to ensure that the proper levels of personal
protection are maintained.
o Ph~sical Hazards -Exposure to cold weather, (below
50 F) particularly when wet or windy, may cause
hypothermia (dangerous lowering of body temperature) in
unprepared individuals. Signs and symptoms of
hypothermia include slurring of speech, fatigue,
uncontrollable shivering and confusion. Individuals
suspected of developing hypothermia should be taken
indoors to a warm area. Wet clothes should be removed.
Proper dress for conditions will prevent the development
of hypothermia. Hot weather precautions are outlined in
Section 4.6 of the Remedial Design Report.
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-5
Personal Protective Equipment: Level D personal protective
equipment (PPE) will include disposable Tyvek suits, neoprene
gloves, disposable surgical gloves, cotton glove liners (as
needed), hard hats (as needed) and face shields or safety
glasses. Level C will include full-face respirators with
organic vapor cartridges.
Extraction Well Installation
The extraction well borings will be drilled in potentially
contaminated soils. During the drilling process, the breathing
zone will be monitored with an OVA or HNu to evaluate the need
for respiratory protection.
All drilling equipment penetrating the land surface will be
decontaminated prior to leaving the site. The final
decontamination will include all parts of the equipment that may
have been affected by site operations.
If monitoring devices detect organic vapor levels 5 ppm above
the background, the installation activities will be upgraded
from Level D to Level c.
Risk Assessment: The following have been identified as
general risks to be addressed:
5050H005
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-6
o Chemical Hazards -Personnel may be exposed to chemical
contaminants by inhalation or skin contact during the
well drilling process and monitor well installation.
Organic vapors emanating from the borehole and cuttings
may be inhaled. Borehole cuttings and the breathing
zone should be monitored throughout the drilling process
and well development to ensure that appropriate health
and safety precautions are being taken.
o Physical Hazards -Drilling may cause serious injury to
fingers, hands and feet which may be inadvertently
caught in moving machinery. Great care should be taken
to avoid contact with moving parts. Loose clothing
should also be secured (for example, taping loose
portions of Tyvek coveralls) to minimize the potential
for entanglement with moving machinery.
Weather-related hazards may also occur during the
drilling process. Cold weather may cause frostbite and
hypothermia (a dangerous decrease in body temperature).
Lightning storms may be particularly hazardous to
individuals working on a drill rig. Tall structures
attract lightning strikes and pose the hazard of
electrocution to personnel at a drill rig. Individuals
should take cover indoors if threatening weather
approaches. Additionally, Section 4.6 outlines
appropriate hot weather precautions.
Noise associated with drilling operations may cause
permanent hearing loss. Hearing protection will be used
during drilling activities.
Personal Protective Equipment: Level D PPE will include
I disposable Tyvek suits, neoprene gloves, disposable surgical
gloves, cotton glove liners (as needed), steel toe and shank,
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chemical resistant boots (possibly thermal boots), hard hats,
disposable latex booties and face shields and safety glasses.
Level C will include full-face respirators with organic vapor
cartridges.
5050H005
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REVISED 12/89
Treatment system construction
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-7
If treatment system construction will disturb the subsurface,
the Westinghouse Site Manager will be notified before proceeding
with construction to determine the proper PPE for subsurface
construction. Normal work clothing is acceptable for this
activity, unless the Site Manager determines otherwise. Normal
work clothing refers that acceptable to the Hoechst Celanese
Health and Safety Program. Level Dor Level C PPE are required
if the workers will potentially come in contact with
contaminated groundwater and soil (such as during drilling).
Construction of the mechanical components of the treatment
system can be done without protective equipment except that
reqired by OSHA.
Risk Assessment: The following have been identified as
general areas of risk to be addressed during:
o Chemical Hazards -Response to chemical hazards will be
similar to those described under the section on
Extraction Well Installation where workers are exposed
to potentially contaminated subsurface materials.
o Physical Hazards -The previous discussions on
groundwater sampling and extraction well installation
address response actions to potential physical hazards
during subsurface disturbing activities. In addition,
during the general construction activities, relevant
OSHA guidelines for risk reduction should be followed.
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-8
Treatment system Operations
system operations will include treatment equipment operation and
maintenance, visual inspection of the plant and piping, and
water and sludge sampling. Normal work clothing acceptable to
the Hoechst Celanese Health and Safety Program with safety
glasses and gloves is acceptable for this activity. Plant
operations that subject the operator to potential exposure to
contaminated waters or direct contact with treatment chemicals
such as sodium hydroxide (NaOH) must wear eye protection and
splash protection.
Risk Assessment: The following have been identified as
general risks to be addressed:
o Chemical Hazard -The risk of exposure to chemicals
present in treatment system water is primarily due to
water-soluble organic compounds. Exposure to organic
compounds by inhalation and skin contact may occur
during treatment system operation. Ingestion of
contaminants through hand-to-mouth activity may also
increase the health risks associated with exposure to
water-soluble organic compounds. Rubber or vinyl gloves
should be worn to protect hands from contact with
treatment system water, and face shields or goggles
should be provided for eye protection.
5.2 Emergency Response
These operating procedures are to be followed in addition to
those outlined in the HC contingency plan (see Appendix V of the
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REVISED 12/89
Remedial Design Report).
5.2.1 Pre-Emergency Planning
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-0S0H
Document Control 85050H-0132
Page 5-9
All Westinghouse site personnel are certified and current in
cardiopulmonary resuscitation and Red Cross Multi-Media First
Aid and may be designated by the Site Manager to serve as
Emergency Response Team Members or to assist Hoechst Celanese
personnel. In addition, all site personnel will be briefed on
the contents and requirements of the Health and Safety plan.
Air-horns or other audible devices shall be maintained and used
to alert site workers of an emergency situation. The procedure
to be used upon hearing the air-horn shall be as follows:
o Cease work operations immediately.
o Return immediately to the Support Area for instructions
and head-count.
5.2.2 Emergency Recognition, Prevention and Reporting
Fire/Explosion
ABC type fire extinguishers (at least 20 lb size) shall be
available in the field with each work party. Any fire,
regardless of how small, or how contained, must be reported to
the plant emergency brigade immediately.
SOSOHOOS
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-0S0H
Document Control 85050H-0132
Page 5-10
The procedure for extinguishing/containing fire shall be:
o The Site Manager shall sound the emergency site alarm
and notify the plant emergency brigade.
o Site personnel shall turn fire-fighting responsibilities
over to the plant emergency brigade upon their arrival,
assisting only as specifically directed by emergency
brigade personnel.
o In the event of an evacuation order, personnel shall
assemble in the Support Area for instructions and
head-count by the Site Manager.
Personal Injury/Chemical Exposure
In the event of personal injury or exposure to a member of the
I work team, the site Manager shall be notified. The Site Manager
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may sound the emergency alarm and designate specific site
personnel to render assistance. This decision will be made by
the Site Manager based on the severity of the injury/exposure.
The site Manager will also make contact with offsite emergency
personnel to render assistance and transport to the nearest
emergency facility if required.
Injured persons must be accompanied to the emergency care
facility by a team member who can provide medical personnel with
information relative to possible chemical exposure, and a means
of contacting the physician or organization holding medical
surveillance records on the injured person(s).
SOSOHOOS
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-11
If the injured person's clothing is contaminated with
potentially toxic materials, remove as much clothing as
possible, given the type of injury, prior to transporting. (The
exception will be burned persons; never remove clothing from a
burned individual.)
In all cases, administer first aid, take measures to prevent
shock and conduct continuous monitoring of the injured
person(s).
Spills, Leaks and Discharges
In the event of a spill, leak, or discharge of contaminants
which may pose a threat to human health or the environment,
including nearby residents, the Site Manager must make an
immediate assessment of the threat. In making this assessment,
he/she should determine whether the accident may result in:
o a threat requiring an increase in levels of protection
o a threat to residents/workers or other members of the
community near the site requiring notification of local
authorities
o a threat to uncontaminated areas requiring immediate
action to protect these areas
o an increase or change in the potential environmental
hazards already present, requiring an alteration in
work plans
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-12
Actions which may be appropriate are:
o Halt all onsite activity and/or evacuate site.
o Call plant emergency authorities and evaluate potential
need for downwind evacuation of offsite personnel.
o Implement spill control/reduction procedures.
o Abandon work until incident has stabilized.
The assessment and response actions shall be taken in
coordination with applicable contract and government personnel
with authority/jurisdiction on the site.
Table 5-1 contains a contact list for local, state, and federal
I agencies/responders as well as project personnel who may be
needed.
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5.3 Record Keeping Requirements
The Site Manager shall maintain the following records:
5050H005
o documentation that safety plan requirements (medical
monitoring, training, etc.) have been met
o results of all monitoring activities
o reports on all safety plan exceptions and amendments
o reports on all "incidents", especially potential
exposures
o summary of safety related decisions, the basis for the
decisions and the concurrence of other professionals on
site
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-13
Table 5-1
sources of Assistance
Local Sources of Assistance
o Hospital:
Address:
Directions:
Cleveland Memorial Hospital
201 Grover street
Shelby, N.C. 28150
Turn right at plant entrance onto Highway
198 North. After 2 miles, this road
merges with Highway 226. Follow 226 N
for 6 miles (also merges with Highway 74)
to DeKalb Street, entrance is immediately
on right. See HC Plant Health and Safety
Plan in Appendix V of the Remedial Design
Report for map.
o Ambulance: Go to HC Security for HC ambulance
first. In the event the HC ambulance is
unavailable, call 482-4422.
o Fire Department: HC, then 482-4422
o Local Police:
o State Police:
HC, then 482-8311
HC, then 482-8311
o Job Site: Pull alarm or dial 4200 on HC phones.
National or Regional sources of Assistance:
0 Westinghouse Environmental and
Geotechnical Services 404/458-9309
0 Chemtrec (24 hours) 800/424-9300
0 Bureau of Explosives (24 hours) 202/293-4048
(Assn. of American Railroads)
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-14
Table 5-1 (Continued)
o Communicable Disease Center, CDC
(Biological Agents)
o National Response Center, NRC
(Oil/Hazardous Substances)
o DOT, Office of Hazardous
Operations
o DOT, Regulatory Matters
o U.S. Coast Guard
(Major Incidents)
o National Agricultural Chemical
Assn.
404/633-5313
800/424-3802
202/426-0656
202/426-9280
800-424-9280
513/961-4300
I 5050H005
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REVISED 12/89
5.4 Education and Training
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 5-15
All personnel involved in extraction system installation that
disturbs the subsurface, water, sludge or air sampling, and
treatment plant operation will be on a medical monitoring
program and have completed training requirements in compliance
I with 29 CFR 1910.120. At least one individual on the field team
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will be capable of administering first aid and CPR. An onsite
person must be designated as the site safety officer and must
have supervisory training in Level C.
Hoechst Celanese personnel involved with treatment system
operation have completed the medical monitoring and training
requirements of 29 CFR 1910.120.
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-0SOH
Document Control 85050H-0132
Page 6-1
6.0 REPORTING
The results of the monitoring program outlined in Section 4.3
will be reported to EPA on a monthly basis until the system has
obtained stable operation and a modified schedule is agreed upon
between Hoechst Celanese and EPA. Interpretation of the data
will be provided quarterly until modified by an agreement between
Hoechst Celanese and EPA.
Samples collected in the field will be reported on the Sample
Collection Summary Sheet (Figure 6-1). The lids of all samples
will be sealed with a custody seal (Figure 6-2) and a sample tag
(Figure 6-3) attached to each sample. All samples submitted to
an outside laboratory for analysis will be accompanied with a
chain-of-custody form (Figure 6-4). (Note: The forms presented
in this Chapter are for example only, and other organization/
agency paper work continuing the same information may be
substituted without specific approval or formal amendment in this
document.)
The chain-of-custody form will detail information on when the
samples were collected and what analyses are to be performed. If
samples are to be split with EPA or the State of North Carolina a
Receipt of Samples form (Figure 6-5) will be filled out. Water
SOSOH006
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-0S0H
Document Control 85050H-0132
Page 6-2
level measurement will be recorded on the Water Surface Elevation
I Data Sheet (Figure 6-6). Information such as date of well
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measurement, depth to water and weather condition are included on
the form. Sample analyses for the sequencing batch reactor will
be recorded in an Influent/Effluent Analysis Form (Figure 6-7).
The information will be summarized and submitted to the EPA
quarterly. A Site Access Agreement (Figure 6-8 and Figure 6-9)
will be completed and signed by the property owner prior to any
sampling activities on his property.
Specific forms/formats for recording system inspections, daily
operating parameters and equipment maintenance have been
developed during the start-up period after the equipment is in
place. These forms are included as Appendix IV.
Paper work documenting the training and medical monitoring
participation of the project operations personnel will be
maintained at the site in compliance with OSHA. This
documentation will be available for review as needed, but will
not be submitted to EPA. Examples of forms used for this purpose
are presented in Figures 6-10 through 6-13.
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Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 6-3
Figure 6-1
Westinghouse Environmental
and Geotechnical Services. Inc.
Sample Collection Summary Sheet
Project Numoer: ------------------------Date: ____ _
Sampled By: _________________________ Time: ____ _
Sampling Point Identification:
Site Name/City/County:
Weather Conditions:
Sample Type: Ground Water Pond/Lagoon Water
Well Depth: _____ (It.) Water Level: _____ (tt.) ABOVE
BELOW
Surface Water
LSD
MP
Sampling Method: __________ Splits/Spikes/Duplicates: _________ _
Sampling Containers: (Number/Size/Type) ___________________ _
Appearance al Sample:
Reason for Sampling:
Lab Performing Analysis: ___________________________ _
Respiratory Protection: ----------------------------
Personnel Present:------------------------------
PURGING SUMMARY
Purging Method: Time:
Volume Pumped (Gal) Temp( Conductivity (µMhos) pH Remarks
Volume Pumped (Gal) Temp( Conductivity (µMhos) pH Remarks
Volume Pumped (Gal) Temp( Conductivity (µMhos) pH Remarks
Volume Pumped (Gal) Temp( Conductivity (µMhos) pH Remarks
Volume Pumped (Gal) Temp( Conductivity (µMhos) pH Remarks
Volume Pumped (Gal) Temp( I Conductivity (µMhos) pH Remarks
"'
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5050H006
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-0SOH
Document Control 85050H-0132
Page 6-4
Figure 6-2
•
0 ..,,
:!! ,,, en nzo ; C> r ,-z g.
en m 3: l> ml>
~~-I .,, • m ... -"' mz_ en n l> ~ .... ...
" ~ "' 2 Cl l> z z " ~ l> " z ~ r m l> c::
" :D z
m m 0
l> z
0
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' ';.
'
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' ' -? ..._
0 l> ~ m
SEAL BROKEN BY
DATE
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REVISED 12/89
5050H006
i 0
~ ~
ij
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ci z
j
Cl)
j
'!! l
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-0SOH
Document Control 85050H-0132
Page 6-5
Figure 6-3
e 0
Weetlnghouse Environmental and
Geotechnlcal Services
Preservative:
~ Yes □ No □ Cl -ANALYSES
~ BOD Anions 8 Solids (TSS) (TDS) (SS)
COD, TOC, Nutrients
I Phenolics
Mercury
Metals ~ ~ Cyanide a. E Oil and Grease • Cl)
.Jrganics GC/MS
Priority Pollutants
'olatile Organics
Pesticides
PCB
C Remarks: 0 §
~
.~ ;;i
Cl)
Tag No. A ,J00568 Lab Sample No.
--~ 0 ~ 0 ~ 0 ~ (t) ---Westinghouse Environmental and Geotechnical Services. Inc. S&I.IE JuO IJu I ho1ec1 IJa,ne ti<1rnplt:r:, (S1y11;1lurt:/ ~liJIIOH No 0,,11~ Time 0 E 0 u n • 0 --Station Loca1,or1 ---CHAIN OF CUSTODY RECORD ,, ;; C a c 0 u a " 0 E , z ------Branch Dep,Htment REMARKS -------1-----/-f---l-l--+---+--1----------I -f---•-/-/--·---fkllnqu1,aa:d tJy 1~1un<11t11 t.:l \ Date T ,mc. H8t.:L'IVL'll u, i:.1u1,atur81 Relmqu,shed by. (s1gnatu1e) Dalt:. Tun.., Received by.(siuiiature) I lh:llnqu1:,11ed t,1. 1:.1un,1huq I [J;,Lt: lime Hece,·.-cd t,;· i:,,gri.,h,rc) 1------j J_ -Rdinqu,srwc:1 by. ts1gna1u,e) Ualc Tmic Hcct:rvt:l.l Dy t:.1~11a1tue1 lh:llriqu,:,l":d t,•j i:,1(Jll;t1lJlcJ [J.itl! l 1111e ____ ]_ __ _ I~/'., 01SlHH3lJll(Hl fh:1.,;1• . ..,,i Ir,· ti,,,J11.,1t,rt.:) -. ---L==1 D,IIL' T,rne --' ~\'1111" ,Ulo.l 1;,111.111 ,._.,p,.,:, .i,., ""'I""'• :.,111,J,1,-:,l1,pr11.:11I Pu,~ , opy m;1uu;11nc,I u1 ld,• Rem,.uks -"l ,-.. ~ 11 (1) CJ\ I ... - -Gl <: H C/l t'l 0 I-' "' ' OJ \D 'Cl Ill cO (1) ::E: (1) en rt ,-.. 0::, OcO n :::r ~ 0 s ~ ro en ::, (1) rt 'Cl ::c 11 no '"Cl .......... w. 011C/ll1> oo:::rn ::, w. (1) rt rt (1) I-' 1100-0 0 rt'<'O I-' -(1) ... 11 OJ I-' Z Ill UlN()rt 0 ,i::,,. t-'· Ull"JO OOJllJ::S ::c U1 n en I I I-'· O"IOOt-''"O I t--JtJlt-'·t-' mwortr:u "' ::c '< ::,
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Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-0SOH
Document Control 85050H-0132
Page 6-12
5050H006
Figure 6-10
WESTINGHOUSE ENVIRONMENTAL SERVICES
Certification of Respirator Training
Name __________ S51/ __________ Date _______ _
Title __________ Branch ________ Dept.
Type & Size Respirator:
I have been instructed on how to I) wear ____ , 2) adjust _____ , and
3) clean ____ the respirator listed above and ask questions concerning its fit,
condition, a.nd appropriate outside appearance
I was instructed that it ts my responsibility to do nothing which will impair the
facepiece fit ______ and should l be required to wear prescription glasses, a
"spec-kit" must be usea ____ . l was reminded that the respirator 1s Company
property, I am required to handle it as I have been instructed, and must report any
evidence of the respirator not working properly to the appropriate authority·----
! have initialed each section above to impress my full recognition of the seriousness
of the Respiratory Protection Program and the Company's efforts to provide a safe
and healthful work place.
Employee Signature ________________ _ Date
cc: Branch
Corporate File (t\ tlanta)
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 6-13
Figure 6-11
WESTINGHOUSE ENVIRONMENTAL SERVICES
Respirator Fit Testing
Name _________ SSII _______ _ Date _______ _
Title
Test/Hood Enclosure Used
Irritant Smoke Fit Testing:
No. of Saueezes
Branch _______ _
Activity
lni tial
Head/Neck Motion
Motion/Talking
Motion/Deep Brea thing
Dept. _______ _
Yes ___ No __ _
Reaction
yes __ _ no __ _
yes __ _ no __ _
yes __ _ no __ _
yes __ _ no __ _
(Total Squeezes)
Seal Obtained __ _ Type of Cartridge Used __________ _
Type of Respirator ____________ _
Size of Respirator ____________ _
Testing Performed By _______________ Date ______ _
Employee Signature ________________ Date ______ _
cc: Branch
Corporate (Atlanta)
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-Ol32
Page 6-14
Figure 6-12
WESTINGHOUSE ENVIRONMENTAL SERVICES
Certification of Supervised Field Experience -Three Days
Name 5511 Date ----------

-
-
-
-
-
-
-
-
-
-
--------
Title ----------Branch Dept. ----------------
participated in a 40-hour Hazardous Waste Site -1n_v_e_s_t-,g-a-t-,o-n--r-r-a1_n_m_g_""P,...r_o_gr_a_m in compliance with OSHA 29 CFR J 910. I 20 conducted by -----------------------------from _______ to ______ _
Supervised on-site activities In compliance with OSHA 29 CFR 1910.120 have been conducted at
on --------an-d----------~b---------------__________ y ________ _ ------
Date ----------Employee Signature -------------
Date Supervisor Signature -------------------------
cc: Branch Office
Corporate (Atlanta)
jQ~ .. v06
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REVISED 12/89
Project Operations Plan
HC/Shelby, NC Facility
Westinghouse Project 4124-85-050H
Document Control 85050H-0132
Page 7-1
7.0 REMEDIAL ACTION
Remedial action is proceeding and the treatment plant is
operational. The remedial design report has been revised to
reflect EPA comments and has been approved.
I 5050H007
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-------------------
NO. .t.T[ R[V1Sl0NS BY WESTJNGt-lOUS[ PROJCCT ,12,-n-o,OH OAT[ ~ Westinghouse Environmental ~ and Geotechnical Services, Inc.
Hoechst Celanese Corporation
Shelby, tl.C.
·+-UmtR / OUHR ll[R t>:TRA.CllOH "''[ll S
0 [)(JSWlG '-'ONITOR WELLS
A n1STING ~tZO><E:TtRS
• PROPOSED [~TRACT IOI/ W[l LS
.. PROPOSED PIEZOIAETERS
0 200 ,oo 800
FIGURE
WELL LOCATION M/.P
HC / SHELBY
WESTINGHOUSE PROJECT •i 124-85-0SOH
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1.0 References
GROUNDWATER EXTRACTION
UNIT 1
OPERATING PROCEDURES
10/31/89
REV. 1
"Unit 1 Operations Plan··; S&ME, Atlanta, Ga. 1989
"Unit 1 Vendor Information Notebook"; Hoechst Celanese
Drawings:
Y-10-11501 P&ID Groundwater Extraction Treatment
Also see Drawing List
Equipment List Unit 1
Instrument Index Unit 1
Maintenance Checklist
Groundwater Inspection Report
2.0 General
Operation is in three physical areas:
Inner tier wells (9 total)
Outer tier wells (8 total)
Treatment Building
2.1.1 Inner tier well pumps are intended to pump 2,430
gallons of water per day at an average 0.3 gpm from
each pump.
2.1.2 Outer tier pumps are to deliver a fixed volume given in
gallons per day. This volume can be adjusted if needed
based on water level data from the monitor wells.
(Ref: S&ME Model).
2.1.3 Water from the inner wells is preconditioned by pH
adjustment and iron removal; then the waste is treated
by aerobic biologic digestion. Inner Tier Water is then
passed over a stripper tower to remove volatile
compounds and through a carbon filter to remove trace
amounts of volatile compounds. Water from the inner
tier system is discharged to the Plant waste treatment
system Pond ''A''. Water from the outer tier system (OT)
passes only through a stripper tower and through two
carbon filters that are operated in parallel. OT Water
is discharged to either Pond "A" (or to designated
plant users -future). Sludge from the SER is pumped to
the Plant waste treatment system Digester Pond. Iron
sludge is press filtered and removed in drums.
3.0 Inner T..i.e..r. EwnP Operation
3.0.1 Vault entry requires removing the vault lid and then
standing upwind of the vault for one minute to allow
the vault to be purged with fresh air. Well flow
totalizers may then be read from above the vault. For
work inside the vault, use an OVA meter to obtain a
reading form the vault lip. If OVA readings are in
r·.
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excess of 100 PPM, air purifying respirators with
organic vapor cartridges are to be worn by all those
working within the breathing zone of the well vault.
3.0.2 Surgical gloves must be worn if there is a possibility
of contact with the inner tier water. Wash hands after
working in this area.
3.1 Inner Tier Pumps are air operated and delivered volumes
are adjusted by on and off timer adjustments at each
well.
3.1.1 At well vault #9 turn on the main, filtered air supply
to the pump air header from the plant air system.
3.1.2 Adjust air supply regulator at each pump to 60 PSI.
3.1.3 Adjust pump delivery volume to approximately 0.3
gallons per minute.
3.1.4 Observe inner tier flow totalizer at the treatment
Building and expect a flow of 1 to 5 gallons per
minute. If different, check overall well pump
operation for possible trouble and report observed
flows to the Utilities Supervisor.
3.1.5 No spillage of water from the inner tier is permitted
outside of the well vaults.
3.1.6 High water level at any inner tier pump causes a
bubbler tube (type) switch at each well to alarm in the
treatment building. This indication is for general
information and requires·no corrective action.
Do not adjust the bubbler tube regulator.
4. o Outer U= I:.wnR Operation
4.0.1 Use soap and water to wash hands after working in this
area.
4.1 The outer tier pumps are submersible electric motor type.
4.1.1 Adjust the pump controller cut-off to match the
horsepower of the well pump at each well. One third
horsepower (1/3) is at wells 3,4,5,& 7. Three fourths
hp (3/4) pumps are at wells 1,2,6,& 8.
4.1.2 Turn on the freeze protection heater at each well at
the beginning of cold weather and set the thermostat to
40 deg. F.
4.1.3 Observe the flow totalizer at each well. Adjust the
pump controller off-time timer to make the pump average
daily delivery match the flow specified on the drawing.
(Re; Dwg Y-09-11472). Some wells may pump dry.
4.1.4 During cold weather measure the water temperature at
the Treatment Building. If near freezing, raise the
well house temperature settings and check heat tape
operation.
5.0 Treatment Building Operation
Inner tier water is treated by aerobic biological
digestion and volatile stripping/absorption. Outer tier
water is treated by volatile stripping/absorption only.
Inner tier water is discharged to Pond A. Outer tier
water is discharged to Pond A. The SBR is to be charged
with living biological organisms obtained from a
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commercial sourceto a depth of 8......5. il...
5.1 Remove iron, digest, air strip volatiles, and pass water
throu~h carbon filters.
5.1.1 Turn on power to all equipment at the main MCC and at
the SBR control panel. Set all hand-off-auto switches
to aJ.l:t.Q. position. Turn on all local disconnects.
Turn control panel switch for IT pump air to "on".
5.1.2 Set inner tier well water neutralizing tank pH
controller to a set point of 1...-5. I!.H.. Set pump flow rate
to minimum. Insert caustic pump suction into caustic
drum containing sodium hydroxide (NaOH) of 2.5X
concentration. Expected usage of 25% caustic is (L)
gal/day.
5.1.3 Set Strenco Polyblend pump to fl.lll stroke (100%), and
iD. strokes per minute. Turn on water supply and set
rotometer to cil gallons per minute. Insert the
Polyblend pump suction into a drum containing 25
gallons of water and L.Q oz of Betz Chemicals number
1115L polymer or all concentration. The mixture
should be agitated daily to maintain even
concentration. The result of the polyblend mixing is a
delivery of lL..5. ounce~ polymer :t.o. 2..rul..D gallons o..f.
inner :t.i.e..r. water supplied to the gravity settler mixer.
5.1.4 Open all valves to and from inner tier pumps at the
large tanks. Use the inner tier pumps to put at least
(3.5) ft. and not more than (10) ft. of IT water in the
neutralizing tank.
5. 1. 5 At the SBR Panel push the ·cycle advance button to the
first stage as indicated by the top light. Press the
cycle start button.
5.1.6 The SBR controller will automatically call for IT
water, mix in polymer at the parallel plate separator,
fill the SBR tank in three stages, mix the incoming
water, turn on the bubbler, draw off sludge from the
SBR, and decant the surface water to the discharge
pump.
5.1.7 When the SBR discharge holding tank is filled to a
depth >5 ft., the pump from the SBR discharge tank to
the IT stripper tower will run if auto position is
selected at the pump switch. At the same time, the
inner tier stripper tower blower and discharge pump
will run. Throttle the SBR discharge tank pump to 25
GPM (:t..a.r:l.k. level d.r.QJ2 o..f. _Q_,__Q_l ft /min) and similarly
adjust the IT tower discharge pump by watching the
tower sump level gauge. The. ll tower™ l!l.lJJil,. ™
slightly rn t.h<ill 1b.e. 1b.e. filIB discharge t.ank pump,
Float switchs in the IT tower sump will control the IT
tower discharge pump in an on/off manner.
5.1.8 Water from the IT tower pump will be valved to the top
of carbon ~ ::..a..::_. The outlet of bed "A" (at the
bottom) will be valved to the pipe going to plant E.on.d.
-.:.K....
5.1.9 The SBR sludge removal pump Y-P-1006 is usually run in
the manual mode, but automatic sludge pumping can be
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selected at the pump switch. Pump Y-P-1011 is normally
in the Q.fi. position. The amount of sludge to be removed
is controlled by timer T7 as needed to hold a constant
sludge level in the SER. The desired sludge level is
roughly 3.5 ft.
5.1.10 From pint jar samples of SER mixed liquor, measure the
nitrogen content. If Nitrogen is <1.5 PPM add
approximately (1) quart of 30% liquid nitrogen.
Remeasure until mixed liquor is 2.0 PPM nitrogen.
5.2 Iron sludge is to be drained and dewatered.
5.2.1 At the bottom of the Parallel Plate Separator (Gravity
Settler) open the bottom sample port valve and
discharge a small amount into a five gallon container.
Repeat for the top sample valve. If floe has reached
the top sample port, turn the PP Separator sludge pump
on long enough to pump out~ dmm t..o. t..o. .the. bottom
sample :ruu:,t.. Experience will determine pumping time;
about :tHQ. minutes is estimated.
The sample port check is to be done daily during .the.
filiR settling cycle.
5.2.2 When the iron floe (sludge) tank begins to fill up,
operate the dewatering filter press. The iron sludge
tank discharge pump is automatically stepped up in
pressure by regulators in the dewatering filter press;
this pump is air powered:
5.2.3 Properly label and seal 55 gallon drums of iron sludge
before removing from the area.
5.3 Air strip/absorb volatiles from the outer tier well
water.
5.3.1 With a steady flow of water from the outer tier wells
to the outer tier holding tank, read the flow meter at
the tank. Expected rate is fill~ 7Jl. gallons per minute.
5.3.2 With holding tank discharge pump Y-P-1007A in aill&, set
pump discharge valve controller to keep tank level
nearly constant. Pump A or B may be in auto but n.o.t.
b,oth.
5.3.3 When the high level switch turns on the pump Y-P-1007,
the outer tier stripper blower and OT stripper
discharge pump Y-P-1008 A or B should automatically
come on.
5.3.4 Set the OT stripper discharge pump flow control valve
to hold a constant level in the OT stripper sump. Open
the sump level control recirculation valve to allow the
float valve to help hold a constant sump level.
5.3.5 Water from the OT stripper discharge pump will be
valved to the top of carbon filter beds "B" and "C".
The outlet of carbon beds "B" and "C" at the bottom
will be valved to the 3" effluent pipe to plant .E.and
~ o..r. t..o. plant users. If other plant users are chosen,
close the 3" valve in the vault at pond "A".
There is a closed valve between pipes serving carbon
beds A and beds B/C unless servicing is to be done.
5.4 Service and backwash or change carbon in carbon tanks on
high differential pressure or poor effluent quality.
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5.4.1 Inlet pressure to filter tanks should not exceed 12.
~-For higher pressure, initiate backwash procedures.
(Outlet pressure should not exceed 10 PSI to
discharge. i.e. expected filter pressure loss is 2
psi).
5.4.2 For poor quality effluent due to spent carbon, initiate
carbon change procedures.
6.0 Keep records and file reports as reqiured in the Unit 1
Operations Plan.
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DRAWING L.I.a.I.
Y-00-11551 Treatment Building Foundations
Y-00-11583 Foundation Sections and Details
Y-01-11585 Equipment Access Walkway
Y-02-11550 Groundwater Extraction Treatment Building
Y-02-11596 Treatment Building Elevation
Y-05-11501 Electrical 480V. Single Line Diagram
Y-05-11502 Electrical MCC 36000 Elementary Diagram
Y-05-11503 Electrical MCC 36000 Elementary Diagram
Y-05-11504 Electrical Control Panel & Elementary Diagram
Y-05-11505 Electrical Control Panel Annunciator Elementary D
Y-05-11506 Electrical Control Panel Layout
Y-05-11507 Electrical Treatment Area Power & Grounding Plan
Y-05-11508 Electrical Miscellaneous Details
Y-05-11509 Electrical Outer Tier Wells -Heat Trace Plan
Y-05-11510 Electrical Power Pole Layout
Y-05-11641 Electrical Miscellaneous Electrical Diagrams Bldg.
Y-05-11649 Electrical Schematic Sequence Batch Reactor
Y-07-11535 Treatment Building Equipment Layout
Y-08-11598 Gravity Settler General Arrangement
Y-08-11599 Gravity Settler Foundation
GFG-08-17205 4500 Gal Storage Tank
Y-09-11472 Outer Tier Pipe Line Profile
Y-09-11473 Inner Tier Pipe Line Profile
Y-09-11533 Outer Tier Piping Arrangement
Y-09-11534 Inner Tier Piping Arrangement
Y-09-11536 Piping Views and Details
Y-09-11575 Piping Underground
Y-09-11584 Piping Treatment Building
Y-10-11492 Topographic Survey Map Plate I
Y-10-11493 Topographic Survey Map Plate II
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I Date 7 /26/89
IQDIP!IIT LIST
DIIT 1 t 10. Description Quantity !anufacturer !ode! lo. Design Beuris Beq. lo. Yendor Dvg. lo.
------------------------------------------------------------------------------------------------------------------------------------------f-Y-1000 SS Tani 4500 Gal. 1 nsco 4500 Gal. On Site Gnvl. Pit. GFG-08-17205
1·1001 Sequence Batch Reactor 1 Duis INS 9221 Air Products Narreut 00731 Duis INS
-1002 SS Tani 4500 Gal. 1 nsco 4500 Gal. On Site Gui. Pit. GFG-08-17201
f-Y-1007 SS Tani 4500 Gal. 1 nsco 4500 Gal. On Site Gui. Pit. GJG-08-17205
--1012 Supply Tani filter Press 1 nsco 1500 Gal. On Site Gui. Pit.
-1004 Carbon !ilter Yessels 3 lncotech Job 0330 31 1500 lb. GAC 90730 incotech Vendor 1303
-1003 Stripper Tover Inner Tier 1 Delta Tovers AS-1-140 25 GP! Ill 00478 !artin Ing" ng DT-8-82-761
f-Y-1008 Stripper Tover Onter Tier 1 Delta Tovers S3-95T 120 GP! Ul 00112 !art in Ing" ng DT-8-82-764
1-1001 Canstic Pn1p 2 Cole-Pal1er J-7135-50 17 GPB t 10 PSI 00730 Cole-Palaer
f-P-1002 Separator !eed Pn1p 1 Caner lxl.518. 5 25GP!@ 50'TDB, 2 Hp. 00471 SPATCO 005-10022
,-1003 Pu1p -SBB to Tani 1 Caner lxl.518.5 25GP!@ 50"TDB, 2 Hp. 00471 SPATCO 005-10022
-1004 Pu1p -Tani to IT Tover I Caner !xi. 518. 5 25GP!@ 50"TDB, 2 Hp. 00471 SPATCO 005-10022
-1005 Pu1p -IT Tover to filter 1 Caner !xi. 518. 5 25GP!@ 50'TDB, 2 Hp. 00471 SPATCO 005-10022
--1006 Pn1p-SBH to Digester 1 Cron P02LA 212 35GP!, 35'TDB, 1.5Bp 00731 Duis INS 2COOD/fP-434
-1007 Pu1p to OT Stripper Tover 2 Buffalo CRO Siae 509 120 GP!@ 50'TDH, 3 Hp. 00698 John B Clari 311.519 141
-1008 OT Pn■p to Carbon Tanis 2 Bnffalo CHO Sixe 509 120 GP!@ 50"TDH, 3 Hp. 00698 John B Clari 311.519 14T
f-P-1009 Sn■p Pn■p 1 Zoeller 1/2 Hp. 3" 00522 D l ! Sales
1-1010 Bacivash Pn■p 0 Dae spare T-P-1012 Jon 5S1684
-1011 Pn■p-SBB to Hentral. Tani 1 Teel 1Pj95 60GP!@ 60'TDB, 2 Hp. 00475 D l ! Sales 60 GP!@ 60'
Y-P-1012 Plate Sep. Slndge Pn■p 2 Teel 3P681 50 GP!@ lO'TDH, 2 Hp. 00475 D l ! Sales
1·1013 Pn■p to filter Press 1 Wilden !4/P0/11/11/ JNI Press Controlled 00774 Tencana !achinery Fon II RGB
1014 Poly■er feed Pn■p 1 Strenco PB16-1 0.5 01 poly/2450 Gal/day 00791 Johnson, Inc.
-1017 J-Press Acid Nash Pu■p 1 Cole-Paner 1-07005-75 2. 2gp■ @ 20psi "II.IOI Cole-Paner
I Inner Tier Pn■ps 1/9 10 Westinghouse lnviro1 2· Arch 0.1 -3.0 Gal/day 89855 NIS Atlanta
Onter Tier Pn■ps, 3,4,5,7 5 Grnndfos 5S03-9 7GP!t 200' 90335 Drillers Ser,ices Vendor Cat
Outer Tier Pn1ps 1,2,6,8 5 Grnndfos 16S07-8 15GP!t 200. 90335 Drillers Ser,ices Vendor Cat
1-1000 !ixer lqniliaation Tani 1 Lightening 71-C-1 On Site Gui. Pit.
-1001 Blover IT Stripper 1 Delta De I ta Design N/Tover Delta Cooling Tovers
Y-!-1002 Slover OT Stripper 1 Delta Delta Design N/Tover Delta Cooling Tovers
--1003 SBB Air Blower 1 Hoots/DreBBer 59-0-BU 20 hp 00638 Parison Yendor J-341
-1004 Parallel Plate Separator 1 Parison 125/55 Parison LGS-3079 00638 Parison Vendor 3J-27
-1005 !ilter Press 1 JNI, Inc. 630!! 630G32-13/27/4/8DA 001275 JNI SI Job 2949
,-1006 Poly■er !ixer 1 Nins■ith 3!SJ llh. 1/2 hp. 00638 Parison
-1007 Tani !ixer 1 Lightening 71-C-1 On-site Green,ille Plant
-1008 Nall Fan 1 CICO Bldg. Syste■s 48" 3/4Bp.;220, 20000CF! N.I. Nood l Sons. In
f-!-1009 floe !ixer for f-!-1004 1 Nins■ith 3!SJ D.C. DriTe; 1/3 hp. 00638 Parison
,-1010 Drn1 !ixer for Poly■er D 1 !c!aster-Carr Cat 95 3492(63 1/2 Hp. 1750 RP! 00897 D l ! Sales
f-C-1000 &ir Co1pressor For Press Ingersoll-Rand 10D3 135 PSI@ 30 er! 00682 Air Co1ponents l Syste1s
1-1000 Strainer at SBB Outlet Process Strainers 6";316 BB. 00503 Process Strainers, Inc.
Outer Tier Plastic Pipe Lot Asahi/A■erica Pro 150 l 45 00192 Plastic Piping Syst Yendor Cat I Inner Tier Plastic Pipe Lot Asahi/A■erica Pro 150 l 45 00525 Plastic Piping Syst Vendor Cat
Nell Co,ers Outer Tier 8 llJer D!Ol 00465 Driller Senices, Inc.
!otor for Y-P-1012 2 Dayton 1.5 BP Fra■e 56C 00475 D l ! Sales
I !eta! Bnilding 1 CICO Bnildings Job 25245-48 44'174' 92355 W.N. Nood l Sons 25245-48
Organic Vapor Analyaer 1 roxhoro OYA128&11 Std. 91360 Kewco■b Assoc.
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GROOID NATIR TRIAT!IIT PROJICT
I DUI 10/30/89 !ASTIR IISTRU!IIT IIDII
'.ISTRU!IIT PURCHASI
TAG 10. DISCRIPTIOI fUDOR !ODIL ORDIR CO!!IITS
I============ ================================= -----------------------------------------------------------------------------------------------------------
Al-36001 pH SIISOR (SUB!IRSIBLI PROBI) GBIU LAUS 6040P0000!8 00126
lc-36001
IISTRU!IITS
pH IKDICATIIG COITROLLIR IUROTHIR! 818S/taa20/RRLY 00628 818s/t■a20/RRLY/!t■a20/JJLD/
/!t■a20/JJ!d/JHD/0/0 FHD/)/)/Sl/00/0.0/lt.0/PH/10/10/1/1
~IT-36001
/0/Sl/00/0/0/14.0/pH
/pH/no/no/1/1/a/n
pH IIDICATIIG TRAIS!ITTIR GHAT LUIS 690Plr5AOI 00126
,,-100 COITROL PAIIL AIIOICIATOR PAULAR! SIRIIS 00657 (5 POIIT, 12VDC
-36001 pH BICORDIR JOIHORO 760RIA-U6T 00658
-36001 OOTIR TIIR PO!P COITROLLIR COYOTI 230f 1/2-2 Hp 00651
rc-36002 IIIIR TIIR PO!P COITROLLIRS NISTUGHOOSI ICC-OD! NISTIIGHOOSI Tl!IRS ICC-001-SA
if-36003 OOTIR TIIR TARI LlflL CORTROL GRIHIILL 2"NC-8275-t-lS-t-t 95365 NITH IL-0-!ATIC C(I POSITIOHIR; CV6
f-3600( OT STRIPPIR TAil LlflL COITROL GRIIIILL 3"NC-8275-t-lS-t-t NITH IL-0-!ATIC Ct! POSITIOKIR; JAi
rIL-36001 AIR JILTIR PLAIT SUPPLY BALSTOI A62A-1-DI COALIS. 00(57 AOTODRAII N/Dlr PRIS IIDICATOR
,L-36002 AIR FILTIR PLAIT SUPPLY BALSTOI A62A-1-BI COALIS. 00(57 AOTODRAII N/DIJ PRIS 11D!CATOR
L-3006/11 AIR FILTIRS AT IT NILLS IORGRII 1/t" !IIATORI RIGO 007(9 IT NILL VAOLTS SIT 60 PSI
-36001/8 JLON SNITCH AT OT-I !C!ASTIR-CARR 497113 00458 BRASS BODY, 150 PSI !AI.,SPDT
,-36001 LIVIL ILl!IIT AT Y-V-1000 BISTOBILL CU !SP90-S!2B 00128 OLTRASOIIC SOORCI/RICIIYIR
-36002 LlflL ILl!IIT AT Y-V-1002 BISTOBILL CU !SP90-S!28 00128 OLTRASOIIC SOORCI/RICIIllR
-36003 LlflL ILl!IIT AT Y-V-1007 BISTOBILL CU . !SP90-S12B 00128 OLTRASOIIC SOORCI/RICIIllR
Ll-36004 LIVIL ILl!IIT AT Y-V-1001 BISTOBILL CU !SP90-Sl2B 00128 OLTRASOIIC SOORCI/RICIIVIR
,t-36001 LlflL IIDICATIIG TRAIS!ITTIR AT BISTOBILL CU !SP90-30 00128
Y-Y-1000 (N/PROG. DISPLAY) !SP90-IB
LIT-36002 LIVIL IIDICATIIG TRAIS!ITTIR BISTOBILL CU !SP90-30 00128
IIT-36003
AT Y-V-1002 (N/RIADOOT DISPLAY) !SP90-DD
LlflL IIDICATIIG TRAIS!ITTIR BISTOBILL CU !SP90-30 00128
AT Y-V-1007 (N/RIADOUT DISPLAY) !SP90-DD
,T-36004 LIYIL IIDICATIIG TRAIS!ITTIR BISTOBILL CU !SP90-30 00128
AT Y-Y-1001 (N/RIADOOT DISPLAY) !SP90-DD
-36001thru9 LIVIL SNITCH (HIGH l IT NILLS CO!P-AIR PS'3PIO NISTIIGHOOSI TOOL SYSTl!S,IIC. ATLAITA,GA.
LSH-36010 HIGH LIVIL SNITHC AT Y-f-1003 N.I.AIDIRSOI/DNYIR FLOTICT L6 DILU non SNITCH
18-36011 HIGH LlflL SNITCH AT Y-V-1008 N.I.AIDIRSOI/DNYIR FLOTICT L6 DILU non SNITCH
H-36012 HIGH LIYIL SNITCH AT ARIA SO!P AICHOR SCIIITIJIC S210 !OOIT THRO GRATI
LSHH-36010 HIGH/HIGH SNITCH AT T-V-1003 N.I.AIDIRSOI/DNYIR !LOTICT L6 DILU non SNITCH
IHH-36011 HIGH/HIGH SNITCH AT Y-f-1008 N.I.AIDIRSOI/DNYIR FLOTICT L6 DILU non SNITCH
L-36010 LON LlflL SNITCH AT Y-f-1003 1.1.AIDIRSOI/DNYIR !LOTICT L6 DILU non SNITCH
L-36011 LON LlflL SNITCH AT Y-f-1008 N.I.AIDIRSOI/DNYIR JLOTICT L6 DILU non SNITCH
,L-36012 LON LIYIL SNITCH AT &RIA SO!IP ZOILLIR ZOILLIR IHCLODID NIU PO!P 01 /OH SNITCH
-36003 LlflL SIGIAL TRAISDOCIR BILLOrRA! !ODIL 1000 95276 1/P TO V&LVI POSITIOIIR
-3600( LIVIL SIGl&L TRAISDOCIR BILLOrRl! !ODIL 1000 95276 1/P TO V&Lfl POSITIOIIR
Pl-36001thru8 PRISSORI IIDIC&TOR AT OT-I lSHCRO!T OR IQOAL 0-150 PSIG, 2 1/2" JACI I -36009 AIR PRISSUBI TO IT MILLS lSHCRO!T OR IQOAL 0-150 PSIG, 2 1/2" !ACI
T-3600!thru9 FLON IIDICATIIG TOTALLl!IR AT O!IGA !TB-5010 00(61 !" IID!ClTOR / TOTLALIZIR
IITl-9 !IPT,.29!11.GP!,15.(COIT.GP!,3
-T-36010 !LON IIDIC&TIIG TOTALLI!IR AT HIRSIY !ODIL 130 95552 2-30 GP!
IIIIR NILL HIADIR
T 360013-IT FLON IKDICATI/TOTALl!IR OT NILLS HIIISIY !ODIL 430 95552 2-30 GP!
-36011,12 FLON IIDICATI/TOTALIZIR OT NILLS HIRSIY !ODIL 430 95552 2-30 GP!
IT-360016, 18
T-36019 !LON INDIC&TIIG TOTALLl!IR AT A!ITII ar 100 00903 2" IIDIC&TOR / TOTALI!IR
OOTIR NILL RllDIR
,-360001 IIIIH NILL AIR SOPPLT SOLIIOID ASCO 8210851 1· 00922 I" 10
!&LU
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"AINTENAt-CE CHECKLIST
AIR STRIPPER TOWERS (2)
I.
2.
Check hell tension and condition of belts. Se•i-annually.
Lubricate blower bearings and motor, usinq low pressure
grease gun. Semi-annually.
. 3.
4.
Check internal media. Annually ..
Check su~p internals. Annually.
J-PRESS
I. Before operation blow down air regulator to remove any water
accu111alation.
I. Check alarms and flow switches.
Roars BLOWER
I. Check a i I 1 eve 1 • Daily.
2. Change oil once. Quarterly.
3. Grec1i;e bearings. "onthly.
4. In take filter inspection .. "onthly.
5. Check pressure drop. "onthly ( Change filter at lODp H 2 □).
6. Cherk be Lt condi lion. "on th I y.
7. Check belt tension. 11on th ly.
SHR
I. Inspect diffuser. Yearly.
2. Inspect tank for corrosion. Yearly.
3. Infrared scan switch gear. Yearly.
I. Check oil level. Daily.
2. Check belt condition. "onthly.
3. Check belt tension. "onthly.
SBR, RACO DECANT AR"
I. Lubrication. Annually.
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PARALLEL PLATE SEPARATOR
I. Gear B01 -High Speed
A. Change oil. Annually.
2. Gear B01 -Low Speed
A. Change oil . Annually.
CARVER PUl'IPS
Check oil levels. Daily. I.
2. Change oil. Yearly or 1500 Hour5 (Which ever co■es first).
BUFFALO PUMPS
1. Change grease. Annually.
pH METER
Check calibration. ~onthly.
STRIPPER TOWERS
1. Carbon filter
A. Check inlet and discharge pressures. Daily.
2. Backwash uni ts based on Dp of 10 pSL
A. Change carbon based on water quality.
B. Check pressure relief valves -set at 75 ps1q. Annually.
C. Check vacuua breakers. Annually.
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DATB:
TIME:
I. T.
WKLLS OH/OFF•
I. T.
MKTKBS WORKING?
o. T.
WELLS ON/OFF?
o. T.
METERS WORKING?
I. T.
STRIPPER ON/OFF?
0. T.
STRIPPER ON/OFF?
NEUTRALIZATION
TANK Ph
SBR OPERATION
MODE O. K.?
SBR SLUDGE LEVEL.
POLYMER PUMP
ON/OFF?
WATER VALVE ON
POLYMER PUMP 2.5
AIR COMPRESSOR
OH/OFP
AIR COMPRESSOR
OIL Lli:YEL O.K.?
ALL PUMPS
RUNN[NG O.K.?
SLUDGE WASTED IN
SBPARATOR BEFORE
1ST I/ 3 Fl LL?
SLUDGE TANK LEVEL.
PROCESSED AT MIXER
COUPLING.
NITROGEN ADDED?
TANK LEVELS O.K.?
o. T. WELL ROUSES
ABOVE 32 deg. F
WINTER OPERATION.
HEAT TAPE
TRACING CIRCUIT ON?
LBAKS YES/NO?
OPERATOR: INITIALS:
GROUNDWATBR INSPECTION REPORT:
REMARKS:
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REVISED 12/89
Comments and Responses, RD and POP report
RC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 1
COMMENTS TO THE REMEDIAL DESIGN REPORT
Conclusions and Recorrmendations
The current RD report should provide dimensions of
the carbon colums and explain why the nUTber of
carbon colums was changed from four to three.
The current
Westinghouse
Extraction
Modification11
RO
report,
System
dated
report should discuss the
up~
and
Test for Outer Tier
Proposed Design
February 13, 1989. In PRC's
March 8, 1989 review of this report, it was noted
that after purping well EXT-6, no drawdown was
observed in surrounding wells. Therefore, it may
be necessary to add additional extraction wells in
this area to "produce overlapping cones of
depression11 or purp EXT-6 at a higher rate.
The current RO report should describe the iron
removal process in more detail. Although Section
1.3 list the equipment that will be used to
process the sludge generated in the removal of
iron, a description of the process in Section
1.2.2 would be helpful.
Surrmary of Changes
The carbon coll.ffl'ls have been changed from four
units to three units and the new sizes are not
specified. The size of the units should be
specified especially with the increase in the flow
rate of the outer tier groundwater extraction
system.
RESPONSE
Conclusions and Reconmendations
Hoechst Celanese was able
could supply carbon rruch
to find a vendor that
cheaper than the
information used in the design. Since the vendor
could supply the same quantity of carbon and the
same level of protection could be afforded, the
nurber of vessels were reduced from four to three.
As was discussed in meeting among Michelle Glenn,
EPA groundwater staff, ~estinghouse and Hoechst
Celanese, there was a possibility that one or two
additional outer tier extraction wells may be
needed to accC11Tplish the desired overlapping cones
of influence. At the suggestion of the EPA
groundwater staff, Hoechst Celanese withheld
installing additional wells. The number and
location of additional wells will be determined
after the
operation.
treatment
extraction system has been
Provisions have been made in
system to handle additional flows if
wells are needed at a later date.
in
the
the
A description of the iron removal treatment system
has been included in the POP.
Surrnary of Changes
The specifications were changed to reflect a
quantity of carbon not vessel size. This would
allow Hoechst Celanese to choose among vendor
suppliers. They have been sized to handle the
anticipated additional flow if additional
extraction wells are installed.
I 50500161
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REVISED 12/89
Comments and Responses, RD and POP report
RC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 2
~
Changes Made in Response to EPA cooments
PRC previously noted an inconsistency in the
pneunatic pull) capacity for the inner well tier.
The equipment list indicated a capacity of 0.1 gpm
but the specifications indicated a capacity of
0.19 9PTI· The response to this error, as stated
in Appendix VI, was to change the purp capacity on
the equipment list to 0.19 gpm. However, this
change has not been made.
The flow rate specifications for the air stripper
still do not agree with the specifications on the
equii:rnent list or calculation briefs.
Other Specific Cooments
Cover Pages:
The main cover page list the preparation date as
April 1989 while the cover pages for Vollfl'le I and
II list the preparation date es March 1989
Table of Contents
The table of contents list Section 111.4 Plan
Drawings (In Map Pock.ets)11 • This should be
changed to 11 1 .4 Plan Drawing" since one foldout
map is included in the report and no map pock.ets
are included in the RO report.
Page 1-1, Section 1.0 last sentence:
The phrase 11 ••• at the c~letion of design." ...
was originally worded 11 ••• at the c~letion of
construction.11 The original phrase would be of
greater benefit since it would provide EPA with
"as bui l t11 plans after construction.
Page 1-2, Section 1. 1 . 2
This section discusses that the putl'ing rates for
the inner and outer tier extraction wells were
based on Extraction Well I (EW-1, inner tier) and
Extraction Well II (EW-11, outer tier). The
information on EW-11 (outer tier) indicated that
the outer tier wells will be~ at a flow rate
of 5 to 15 gpm. The increased flow rates in the
outer tier wells were docllllented in the report
RESPONSE
Changes Made in Response to EPA Comnents
The flow rate of 0.19 gpm is correct.
The air stripping flow is listed correctly in the
equipment list for the RO.
Other Specific Coornents
Ccmnent noted.
Conment noted: 11As built" plans are now included
in the revised POP.
The 11as built11 plans are provided in the revised
POP.
The results of the 11P~ Test for Outer Extraction
System and Proposed Design Modification11 , dated
February 18, 1989 were discussed in meeting among
Michelle Glenn,
Westinghouse and
EPA groundwater
Hoechst Celanese.
staff,
In the
meeting, Westinghouse indicated that there was a
possibility that one or two additional outer tier
extraction wells may be needed to accomplish the
desired overlapping cones of influence. At the
I 50500161
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 3
CCM4ENT
(continued)
11Plll'p Test for Outer Extraction System and
Proposed Design Modification11, dated February 18,
1989. The new puff' test report should be
discussed or slllmarized and the section changed
accordingly.
Page 1-7, Section 1.2, moddle of second paragraph
The amount of chromiun that could be discharged
through the cont>ined inner and outer tier
extraction
limit should
system without exceeding the NPDES
be 1.73 lb/day, not 1.75 lb/day as
listed in the report.
Page 1-9 Section
This paragraph describes that the outer tier wells
will be ~ at adequate rates to provide
overlapping
effective
cones of depression to create an
hydraulic barrier to contaminant
migration. However, in PRC's March 8, 1989 review
of the \.lestinghouse report "PlffP Test for the
Outer Tier extraction System and Proposed
Modification" dated February 19, 1989 it was noted
that after ~ing EXT-6, no drawdown was observed
in surrounding wells and that it may be necessary
to add additional extraction wells in this area to
achieve the desired capture zone. Therefore, the
RD report should discuss the results of the outer
tier put;> test and its ilff)lications on the capture
zone.
Page 1-12, Section 1.2.2, last sentence.
The sentence, "Each well head will be enclosed in
a below grade vault with transmission and
collection piping will be provided to drain
potential leakage into an adjacent vault/well.11
was originally stated, "Each well head will be
enclosed in a below grade vault with removable
lid. Secondary contairwnent of all below grade
transmission and collection piping will be
provided to drain potential leakage into an
adj a cent vault/well. 11 The removal of the words 11a
removable lid. Secondary contairwnent of all below
grade11 is assuned to be an error and not a design
change.
50500161
RESPONSE
(continued)
suggestion of the EPA groundwater staff, Hoechst
Celanese delayed installing additional wells. The
l"llll't,er and location of additional wells will be
determined after the extraction system has been in
operation. Provisions have been made in the
tre8tment system to handle additional flows if the
wells are needed at a later date.
Cooment noted. The amount of chromium discharged
though the NPDES outfall should not present a
problem to meet discharge limits.
As was discussed in meeting among Michelle Glenn,
EPA groundwater staff, \.lestinghouse and Hoechst
Celanese, there was a possibility that one or two
additional outer tier extraction wells may be
needed to acc~lish the desired overlapping cones
of influence. At the direction of the EPA
groundwater staff, Hoechst Celanese withheld
installing additional
additional
wells.
wells
The number and
will be determined location of
after the extraction system has been in
Provisions have been made in the
system to handle additional flows if the
operation.
treatment
wells are needed at a later date.
Agree
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 4
Page 1-13, Section 1.2.2:
This section describes the inner tier treatment
system but does not include a description of the
iron removal step.
Page 1-14, Section 1.3
Section 1.3, Technical Specifications, contains a
list of design criteria, an equipment list,
equipment specifications, and equipment data
sheets. This section is carplete except for some
inconsistencies in Table 1-2, the equipment list,
data sheets, and specifications. Moreover, a
specification and data sheet does not exist for
each piece of equipment listed on page 1-16.
Page 1-15, Table 1-2
The design criteria in this table may be correct,
however, the data are not consistent with the
other sections of the RD report
Equalization Tank Detention time -37 minutes.
Appendix I lists the detention time at 4 hours
(page 7/11) which is based on a flowrate of 25 gpm
maximum and 16 gpm average flow. However, the new
flow rates are 120 gpm maxilTUII and 70 gpm average
flow. Is the 37 minutes an adequate detention
time.
Air Stripping Tower flow -120 gpm. The equipment
list indicates
should not be
capacity of
criteria.
125 gpm maxinun. This discrepancy
a problem because of the greater
the equipment over the design
The air stripping tower removal rate is noted at
95% voe removal. However, the calculation briefs
(Appendix I, page 8/11) do not use 95% as the
design criteria but uses an effluent concentration
of less than 5 mg/l. Based on the influent
concentrations listed Appendix I, the removal
efficiencies are 75.5%, 83.3 and 93.8% for
Bis(2·ethyl)phthlate, · Oichloroethane and
Trichloroethane, respectively. If the influent
concentrations are concentrations are correct,
these removal efficiencies meet the conditions of
the Record of Decision (March 23, 1988).
50500161
RESPOOSE
A discussion on iron removal was added to the
Projects Operation Plan. The design drawings
reflect the addition of a iron removal step.
Equipment specifications were developed for each
major piece of treatment equipment. Minor
equipment or those provided as part of package
system were not included. Such equipment include
air coo.,ressor for filter press, mixer for
flocculator,inner and outer tier blowers.
The detention time of 37 minutes is an adequate
detention time for the outer tier equalization
tank at the maxirrun flow rate. At an average flow
rate of 70 gpm the detention time is slightly over
one hour. It expected that the outer tier flow
rate will decrease over time and the equalization
time will increase.
The air stripping tower flow is approximately
120-125 gpm.
The 95% voe removal in the specifications allow
for a margin of safety over what was calculated in
the calculation briefs.
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REVISED 12/89
Comments and Responses, RD and POP report
RC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-0S0D
Document Control No 85050D-179
Page 5
Inner Tier Design Criteria
The equalization tank detention time is indicated
at 2 days. The calculation briefs indicate 24
hours.
The wastewater treatment system with PAC 99X
removal. This criteria is not applicable since
PAC has been removed from use in the sequencing
batch reactor. In addition the removal efficiency
should specify what will be removed at 99X.
According to the treatability tests BOD and coo
have a removal efficiency greater than 99%, while
TOC removal is slightly below 99X (88.BX and 98.8%
on two different tests.)
The air stripping tower flow is indicated at 25
gpn. The other sections indicate 30 9?Tl, 25 ACF.
Page 1-16, Groundwater Unit No. 1 Equipment List
Page 1-16 contains a list of equipment for the
groundwater extraction system. The list is an
irrprovement over the equipment list in the
previous RD report. However, this list contains
two errors and is not c~letely consistent with
other sections of the RD report. The first errors
concern the model nunber for tag Y-M-1001 (blower
inner tier stripper of 1.5 HP. The model nunber
of 1.5 HP should correspond to tag nunber Y-M-1000
(mixer equalization tank as indicated on the mixer
data sheet (page 1-22). The second error is that
equipment list tag nunber Y-P-1004 has been used
twice. Once
air-stripping and
the flocculator.
for the Plf1'> to the inner
a second time for the mixer for
The inconsistencies are listed below:
Carbon vessels Y-V-1004 Parameter #8x300 -8/30
(see page 1-71). PRC was not sure if #8x300 and
8/30 refer to the same parameters.
Carbon filter Vessels 4500# -4000 pounds minirrun
quantity (page 1-71). This discrepancy should not
be a problem if the equipment is at greater
capacity over the specifications listed on page
1, 71.
50500161
RESPONSE
The correct detention time for the inner tier
equalization tank is 2 days.
It is very unlikely that PAC would be needed, but
the criteria for PAC was left in to allow for the
addition of PAC, if needed. The 99¾ removal was
for coo.
The air stripping tower for the inner tier has a
average design flow of 25 gpm.
The 1.5 HP refers to 1.5 horsepower and is not a
model nurber. The equipment listings have been
corrected in the revised drawings.
Refer to the "as built drawings11 •
Coornent noted.
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REVISED 12/89
Comments and Responses, RD and POP report
RC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-0S0D
Document Control No 85050D-179
Page 6
COlol4ENT
Slu::tge purp to digester 25 gpm -30 gpm max., 25
gpm ADF (page 1 ·54)
P~ to outer tier stripper tower 120 gpm -125
gpm.
Outer tier purp to carbon tank 120 gpm -125 gpm.
Page 1-70, Specification for Carbon Adsorption
Vessel System.
The design specification for the carbon adsorption
vessel system list the flow rate of the inner tier
wells at 2 gpm AOF and 25 gpm maxi nun. However,
the calculation briefs used 1.875 QF=fll (appendix I,
page 11/11) which conflict with these flow rates.
This discrepancy should not be a problem because
the equip,1ent is specified at a greater capacity
than the calculation briefs.
The process
regarding the
gpm peak. flow
at 120 gpm.
design requirements are unclear
source of the following values: 122
rate and 23 mg/l TOC corrbined stream
Each major piece of equipment has a equipment
specification and a data sheet. However, only
some of the supporting equipment have these
specifications and data sheets. Although not
crucial to the design a c~lete set of design
specifications and data sheets would make the RD
report c~lete.
Page 3-1, Section 3.1, last paragraph
This section references Plate I, which is not
included on the report.
RESPONSE
The sludge ~ is rated at 25 gpm with a maximun
of 30 gpm.
The outer tier stripper tower pump is 120 -125
gpm.
The outer tier carbon filter pump is 120 -125
gpm.
The 25 gµn reflects the fact that the plant is
operating in a batch mode. For equipment sizing,
a ADF of 2 gµn was used.
COlllTlent noted.
All major piece of equipment had a design
specification and data sheet. Hoechst Celanese
was responsible tor equiµnent procurement and
detailed design and was familiar with the minor
equipment not covered under the specifications.
COlllTlent noted
I 5050D161
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 7
COMMENTS TO THE PROJECTS OPERATIONS PLAN
C0!14ENT
Specific COITITlents
The revised POP address EPA's comnents by adding
text, revising text, and adding Appendix IV.
Appendix IV uses PRC 1s comnents on the draft POP
(subni tted to EPA on October 21, 1988) and
Westinghouse•s response. All of PRC 1s concerns
have been addressed in Appendix IV except those
regarding disposal of drill tailings. While
Appendix IV addresses the conments, the
corresponding text has not been revised to reflect
the Appendix in some cases. For exa~le, while
page 5 of Appendix IV concerning air stripping
states that the POP will be modified to include
operational considerations for the air-to·water
ratio; the text in Section 3.2.5 has not been
modified accordingly.
The following changes to the text should be made:
Section 3.2.1, Page 3-3, first paragraph; Section
3.2.2, Page 3-4, second paragraph.
Treatment plant personnel should be identified by
name, and alternates should be identified. Each
treatment plant person should have assigned
responsibilities including reacting to emergency
high level or pH alarms.
Section 3.2.3, Page 3-8, first bullet and other
places in the POP concerning operations and
monitoring. The word 11should11 should be changed
to 11shall".
Section 4.2 and Section 4.3 The Engineering
Support Branch Standard Operating Procedures and
Quality Assurance Manual, April 1, 1986 (SOP)
should be referenced and procedures adhered to for
any salll)l i ng.
RESPONSE
Specific Comnents
Air to water ratios have been reconrnended by
equipment vendors. For the inner and outer tier
treatment system, the air to water ratio is
approximately 250-300 to 1. The information is
included in the vendor literature supplied to EPA
with the POP. Due to the small volumes involved
the drill cutting were not contained.
Treatment pl ant personnel and their
responsibilities are included in the revised POP.
The change has been made.
A reference is included for The Engineering
Support Branch Standard Operating Procedures and
Quality Assurance Manual, April 1, 1986 (SOP).
I 50500161
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REVISED 12/89
comments and Responses, RD and POP report
RC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 8
COMMENT
Section 4.3.3, Page 4-10 Sludge Quality A
discrepancy exists between Section 4.3.3 and
Appendix IV page 4, Sequential Batch Reactor.
Section 4.3.3 states that the sludge will be
tested for TCLP and TCL c~unds, whereas
Appendix IV states that according to laboratory
testing, the slu::tge is not hazardous end can be
putl)ed to the existing wastewater digester. PRC
supports the testing of the sludge according to
the schedule proposed in Section 4.3.3 because
laboratory conditions may not prevail during
treatment system operation. As a result,
procedures to dispose of hazardous sludge should
be identified if the tests determine the sludge to
be hazardous during treatment system operation.
Information on the periodic analyses of the sludge
should also be added to Table 4-4 (Water Quality
Monitoring Locations and Frequencies) to make the
table more c~lete.
Appendix IV, Page 9, Second Item
The EPA Standard Operating Procedures and Quality
Assurance Manual (April 1, 1986) states that 11at
least one volune of water in the well casing
should be evacuated Ca 15 minute period is usually
sufficient for residential wells)." Five to 15
minutes may not be sufficient. PRC recorrrnends
calculating the hydraulic residence time to purge
at least one volune of water instead of relying on
the 5 to 15 minutes identified by Westinghouse and
the SOP.
RESPONSE
The sludge from the SBR and metal waste treatment
will be analyzed for TCLP parameters. If they are
determined to be hazardous, Hoechst Celanese will
dispose of them in the same manner it disposes of
other hazardous wastes from the plant. The SBR
sludge will be analyzed for TCL and TAL.
The information has been added to Table 4-4
The EPA Standard Operating Procedures and Quality
Assurance Manual Section 4.8, page 1, states, 11As
a rule of thutiJ, at least one volune of water in
the well casing or storage tank should be
evacuated (a 15-minute period is usually
sufficient for residential wells." The 15-minute
criteria is used since the well depths and static
water levels of some of the residential wells are
unknown and would make it irrpossible to calculate
the votune of water in the well to be purged.
I 5050D161
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REVISED 12/89
CoIDlllents and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 9
COMMENTS TO THE REMEDIAL DESIGN/REMEDIAL ACTION OVERSIGHT
COMMENT
Two additional sarrpling points should be installed
on the inner tier treatment system. One sarJpling
point should be installed to collect SBR
effluent. Saq:,les taken from the SBR effluent
will show the degree of treatment and the
efficiency of the SBR. The second S8111Jling point
should be installed to collect stripping tower
effluent. Saq:,les from the stripping tower will
show the degree of treatment and the efficiency of
the stripping tower.
Minor electrical deficiencies were noted.
Photograph No. 20 (Roll 2) in Appendix A shows
electrical conduits with missing covers. This was
a typical deficiency noticed throughout the site.
At the end of the inspection, all covers were
installed.
The electrical panels, including the motor control
center should have been installed on a concrete
slab so that they are located above the building
contairment curb. This would protect the power
outlet from an electrical short should flooding
inside the
electrical
practical,
could be
building occur. Since raising the
panels at this time may not be
a concrete curb with proper access
built around them to prevent water from
reaching the electrical equipment.
The connections of piping to the purps are direct
connections. This type of installation is not
recorrmended
weight of
and reduce
recorrmend
by puTf) manufacturers because the
the piping can cause damage to the~
its life. Manufacturers usually
that a flexible rubber joint be
installed at the pul'f)S discharge and suction to
reduce stress on the puTf) and eliminate
vibration. This also requires that the piping be
properly supported. The direct connections were
comnon to all pul'f)S installed in the treatment
building.
50500161
RESPONSE
S8'f1)ling points have been installed to collect the
SBR and air stripping tower effluents.
Corrment noted.
The electrical panel box is located on the
concrete slab. However, all of the electrical
wiring and instrunentation are above the concrete
curbing.
The direct connections of the pumps conform to
Hoechst Celanese standard practice, and the pumpts
have a universal joint in the drive assembly to
accoomodate some minor movements.
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REVISED 12/89
ComIDents and Responses, RD and POP report
RC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 10
CXM4ENT
Inner·Tier Extraction System
The purps• capacities exceeded the recharge rate
of the wells. Also, the total flow rate from the
inner tier extraction system was less than SOX of
the anticipated flow. This rate will effect the
operation of the SBR unit. One way of correcting
this problem is to change the cycle of the SSR
unit from once a day to once every 2 days.
Additional studies will be needed since the
increased period of aeration will require
reduction in the air flow to the unit. This
situation will need to be analyzed and the mixed
liquor concentration adjusted accordingly.
During start·up and as a result of the reduced
flow described above, the first SBR cycle did not
contain enough liquid to c001)lete the cycle.
Therefore, HC added outer tier influent to the
SBR. The addition of influent may.have reduced
the overall contaminants concentration in the
water treated by the system. As a result, the
iMer tier effluent sarrples taken may not be
representative of the inner tier effluent
The inner tier influent was sarrpled on August 1,
1989 at 16:55 (photograph No. 10, Roll 2 in
Appendix A). During sarrpling of the inner tier
influent, an excessive amount of air/gas was
noticed in the liquid. This air/gas could have
been caused by one of the purps that HC later
found to be discharging air into the collection
pipes. As a result, the analysis of the VOA
sarrple taken from the inner tier influent may not
be accurate. HC plans to correct this problem.
During start-up, HC moved the inner tier influent
sarrpling port from outside the building to inside
(see photograph Nos. 7 and 8, Roll 3 in Appendix
A). This move was an irrprovement in that any
spills occur during sarrpling are now contained
inside the building, which is equipped with
curbing, drains, and Sllll)S.
RESPONSE
Due to blockage in the lines during start-up, the SBR
did not contain enough liquid to COOl)lete the treatment
cycle. Outer tier influent was added to the SBR to
make up the additional volune. Once blockage was
removed from the inner tier lines, the problems in the
SBR related to insufficient volune were resolved.
Hoechst Celanese was aware that initial inner tier
effluent Satll)les may not be representative. The
addition of outer tier water was a one-time occurrence.
Hoechst Celanese is aware of the problems associated
with the inner tier. Air being introduced into the
lines continues to be a problem. The VOA samples may
not have been representative.
Cooment noted.
I 50500161
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 11
Neutralization/Equalization Tank
PRC noted two problems with the neutralization/
equalization tank. The first was that the
chemical feed system was not properly calibrated
prior to start-up. The neutralization/
equalization tank raises the pH of the influent by
adding sodiun hydroxide. During start-up, an
excessive amount of sodiun hydroxide was added and
had to be neutralized by adding acid.
The second problem concerns health and safety.
PRC noted that persoMel were not wearing goggles
during start-up of the system. Personnel should
wear goggles when working near or with chemicals
(see photograph No. 2, Roll 2).
RESPONSE
With minor adjustments, the pH adjustment system
operated without further problems.
The personnel in photograph No. 2, Roll 2 were not
working with the polymer or sodiun hydroxide system but
were observing treatment plant operations. The POP has
been changed to allow observation of the system without
safety goggles. Hoechst Celanese and Uestinghouse
personnel are required to wear safety glasses.
I Neutral ization/Egual ization Tank PUTp
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This PllTl) was started at approximately 11:00 on
August 1, 1989. The purp was transferring the
neutralized inner tier water to the parallel plate
separators. Shortly after start up, the purp was
damaged by a loose bolt. The purp was removed and
replaced. The work was c~leted at approximately
15:15. This replaced purp is shown on photograph
No. 24, Roll 2, in Appendix A.
Parallel Plate Separator
PRC' noted that the parallel plate separator worked
well during
neutralized
chant>er of
our oversight activities. The
liquid is ~ into the mixing
the parallel plate separator, where it
is mixed with polymer. From the mixing chant>er,
the liquid flows through the flocculation
chant>ers, and then to the parallel plate separator
(photograph No. 4, Roll 2). The heavy sol ids and
iron hydroxide are removed in this unit by
quantity settings, and the clear liquid overflows
a V·notch weir and enters the SSR unit. The
parallel plate separator, transfer purrfJ, polymer
mixer, and flocculator drive are interlocked with
the SBR unit. All this equipment is turned on
automatically during the SBR fill cycle.
5050D161
The purp was replaced on August 1, 1989.
Cooments noted.
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 12
~
Sequencing Batch Reactor
Major modifications to this reactor were discussed
in the general conments and reccmnendations. The
SBR was seeded with activated sludge from HC
wastewater treatment system prior of August 1,
1989. Start-up of the SBR began on August 2 due
to the 1JU1fJ failure in the neutralization/
equalization tank pull). The first cycle of the
SBR was CCll'Jl)leted in the afternoon of August 2.
To cO!Tl)lete the cycle, the SBR activated sludge
had to be supplemented with outer tier influent
because there was too little inner tier influent.
After c004>leting the aeration and settling
periods, the liquid was decanted and transferred
to the decant tank.
Two potential problems
first problem concerns
supply blower which
supported by the SBR
exist with the SBR. The
the location of the air
is mounted on a shelf
tank wall. PRC reconmends
relocating the blower or providing additional
supports to reduce vibration. Insulation should
also be installed on the blower and the discharge
piping which is also mounted on the tank wall.
This panel should be relocated since it is
possible that vibration from the SBR may cause
erroneous on/off switching of the automatic
controls.
Inner Tier Air-Stripping System
This system consists of the decant storage tank,
decant transfer pull), air-stripper and the
air-stripper effluent pull). All equipnent is
interlocked to operate in an automatic mode. The
system is designed to start automatically on a
high liquid level in the decant tank. During
start-up, the decant tank was only partially full
so the transfer ~ was started manually. The
decant liquid was then ~ to the top of the
air-stripping tower. ~hen the SUT4) below the
air-stripper filled to a present level, the
air-stripper effluent pull) turned on and the
liquid was purped from the air-stripper surp to
the activated carbon filter. Even though the
decant transfer pll'l1) and the air-stripper Pllf1l are
50500161
RESPONSE
The problem of insufficient volune in the SBR which
required the addition of the outer tier water was a
one-time occurence. The SBR is cycling once per day
with inner tier influent at the volune specified in the
the RD report.
Noise from the SBR blower motor required hearing
protecting to be worn inside the building.
Additionally, the blower created problems with
equipment instrunentation. To alleviate the noise
problems, the SBR blower motor was moved outside of the
treatment building. The SBR control panel has also
been moved to reduce problems associated with
vibration.
An additional level control systems and throttling
value in the discharge line were installed which
corrected the problems.
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 13
~ENT
Air-Stripping System (continued)
the same type of purp, the system did not work
well and required adjustments. The problem may
have occurred because the decant transfer purp
flow rate is constant because the water head
pressure is constant. On the other hand, the
air-stripper effluent purp discharge head varies
depending on the degree of pressure drop across
the activated carbon filters. This may have
caused the s~ to set off the high liquid level
alarms that automatically shut the decant purp
off. HC fixed this problem by installing
throttling ball valves in each purp discharge
line. This deficiency should be further corrected
by introducing a flow control valve to maintain a
constant level in the air-strippers~.
Activated Carbon Filters
The treated water is purped through the filter by
the air-stripper effluent ~-Only one of the
three carbon filters is used for the inner tier
treatment system. Carbon filter A is a dedicated
filter to the inner tier treatment system
(photograph No. 21, Roll and No. 1, Roll 2).
After running through the carbon filter, the inner
tier effluent is discharged to the polishing
ponds, where it is mixed with the effluent from
the wastewater treatment plant. Sa~les were
taken from the inner tier effluent on August 2,
1989 at 17:15 (photograph Nos. 4 and 5, Roll 3).
As described in Section 2.2, these effluent
sa~les were not representative of the inner tier
waste since outer tier water was introduced to the
process. This effluent should be resa~led after
all the problems are corrected and the inner tier
treatment system is treating only inner tier
water.
Oewatering System
This system consists of a sludge transfer pull),
sludge holding tank, sludge feed pull>, and a
filter press. During PRC 1s oversight visit, this
50500161
RESPONSE
The problems associated with clogged inner tier
influent lines were resolved shortly after start-up.
The inner tier treatment is working as designed.
Sa~les of the sludge from the filter press have been
taken and analyzed. Laboratory analyses of the sludge
indicate acetone at 4,100 micrograms per liter (ug/l)
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 14
(continued)
system was not in service because of an
insufficient volllne of sludge to start the
process. On August 3, 1989 at approximately
14:45, the filter press manufacturer's
respresentative came on-site to make adjustments
to put the system in service (photographs Nos. 16
and 18, Roll 3). At that time, the sludge from
the parallel plate separator was transferred to
the sludge holding tank. From the sludge holding
tank, the sludge was~ into
(photograph No. 17, Roll 3).
~ties into a 55-gallon drL.111.
the filter press
The dried sludge
PRC recoomends
tanking a sludge sa1Tple from the 55-gallon drun
when the drlll\ is full and prior to disposal.
Outer Tier Extraction System
A nunber of problems were encountered during outer
tier treatment system start-up. During the first
two days of start-up, HC noted problems in the
outer tier extraction ~s. The flow switches
were not properly set, which caused false alarms
and ~ shut downs. During outer tier influent
sall'f)le collection on August 1 at 15:40, only three
of the extraction well ~s (Nos. OT-5, OT-7, and
OT-8) were in service. As a result, the sarrples
collected were only representative of the three
wells that were in operation at that time. The
problems with the outer tier purps were corrected
on August 2 at approximately 14:51 and a second
sall'f)le was taken at 15:20 on this date
Photograph Nos. 21, 22 from Roll 2 show a typical
set-up of each of the outer tier wells.
Photograph No. 23 from Roll 2 shows an electrician
making adjustments to the flow switches at the
outer tier wells.
Outer Tier Air-Stripping System
This system consists of the outer tier storage
tank, outer tier holding tank, discharge purf>S,
outer tier air-stripping tower, and outer tier
air-stripping tower discharge~-
50500161
RESPONSE
and benzoic acid at 110 ug/l. The filter press sludge
collected in October indicate 2-butanone at 78 ug/l bis
(2-ethylhexyl) phthalate at 3,000 ug/l, and methylene
chloride at 6 ug/l.
During system start-up, false alarms resulted when
the ~ were shut off by the low level
controller. To alleviate this problem, a time
delay circuit was added which allowed the pumps to
operate properly without creating false alarms.
Cooments noted.
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 15
~ENT
(continued)
The problems encountered with the start-up of this
system were similar to the problems with the inner
tier air-stripping system. Photograph No. 1 from
Roll 3 in Appendix A shows the air-stripping tower
s~ overflowing through the air blower inlet. An
atten-.:,t was made to control the flow manually by
throttling ball valves in the discharge piping.
This system was placed in service manually in the
late afternoon on August 2 to collect effluent
sarrples. HC then corrected the overflow problem
by installing an automatic valve in the
air-stripper discharge ~ piping. Photograph
Nos. 9, 14, and 15 (Roll 3) show workers
installing a motorized butterfly valve in the
air-stripper discharge ~ piping. This valve
will automatically adjust the flow rate to prevent
air·stripper s~ overflow and will be controlled
by a liquid level controller installed on the
air·stripper SI.IJ1).
RESPOI/SE
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 16
CONCLUSIONS AND RECOMMENDATIONS
cot<ENT
Overall, the problems encountered during start-up
of Operable Unit 1 • Groundwater Extraction and
Treatment System were typical problems experienced
during treatment plant start-ups. It usually
takes a week to adjust all equipnent and another 2
to 3 weeks to reach a steady state operation. The
HC persomel responded well to the problems
encountered and cooperated with PRC 1s inspection.
The manufacturers 1 representatives were scheduled
so that all adjustments were being made as the
units were placed in service. As in any plant
start-up, some unforeseen problems will occur.
The problems here were handled well and in a
timely manner. PRC reconmends that after all the
problems are corrected and a steady state
operation is reached, additional SmT1Jling to be
performed to verify c~liance.
The Project Operations Plan should be revised to
indicate the changes made to the treatment system
construction and methods of operation. The
Project Operations Plan should also include a
maintenance schedule for each piece of equif:XT)ent
as reconmended by the equif:XT)ent manufacturers.
The Project Operations Plan should be revised to
indicate the changes made to the treatment system
construction and methods of operation. The
Project Operations Plan should also include a
maintenance schedule for each piece of equipment
as reconmended by the equif:XT)ent manufacturers.
RESPONSE
Hoechst Celanese is continuing to correct minor
problems associated with the treatment system.
A maintenance schedule is included in Appendix II.
I 5050D161
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REVISED 12/89
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 17
FIELD OVERSIGHT AND COLLECTION OF SPLIT SAMPLES
RESPONSE
Specific Conments
PRC noted the following eight minor problems or
reconmendations with the sarrpling:
Only 3 of the 8 outer tier extraction wells (Nos.
OT-5, OT-7, and OT-8) were working on August 1,
1989, when this safl1)le was taken. Therefore, this
sart'f)le is not representative of outer tier
influent.
Sarrple was brownish and effervescent on August 1,
1989. The effervescence could have been caused by
one of the ~ that was later found to be
discharging air into the collection pipes. As a
result, the VOA analysis for this safl1)le may not
be accurate.
VOA samples were slightly effervescent on August
2, 1989. The effervescence could have been caused
by one of the curps that was found later to be
discharging air into the collection pipes. As a
result, the VOA analysis for this saq::,le may not
be accurate. In addition, because outer tier
addition, because outer tier influent was mixed
into the SBR, this saq::,le may not be
representative of inner tier effluent.
The well sounder used to determine the depth to
water in the monitoring wells was not adequately
cleaned between uses. The sounder was only rinsed
with deionized water. EPA reconmended that the
well sounder be cleaned in accordance with the POP
and SOPCAM.
A stick-on label was used on the SalflJle
containers. The safT1)le location designation, type
of preservative, if any, date, analysis, and the
saq::,ler 1s initials were written on the label. The
POP stated that a tie-on tag would be used and
would include, in addition to the above
information, the saq::,ler•s signature and the time
of salJlJle collection.
All field information (i.e., pH, specific
conductivity, terrperature, and visual description)
was written on field sheets. EPA suggested that
field log books be used instead of, or in addition
to the field sheets.
50500161
OT-5, OT·7, and OT-8 were not working at the time the
sarrples were taken and the SalJlJle may not have been
representative of the outer tier influent.
Hoechst Celanese concurs.
Concur.
IEA has been informed of the POP requirements and the
well sounder is now cleaned in accordance with the POP.
IEA is now using procedures outlined in the POP.
Field sheets are easier to work with than the field log
book. The field sheets are retained in a notebook for
reference.
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REVISED 12/89
Comments and Responses, RD and POP report
RC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 18
Specific Conments
JEA personnel and the POP state that the new PVC
tubing is used for the discharge line at each
monitoring well that has a dedicated bladder
pl.111J. The discharge line is also used to collect
the safll)les. EPA reconmended that new or
dedicated Teflon tubing be used instead of PVC.
In addition, the length of the discharge tube
should be long enough to collect the sarrple end
short enough so the end of the tube does not rest
on the ground.
The POP states that organic vapor concentrations
from the well will be measured for the selection
of appropriate
Pages 4-12).
analyzer (OVA)
respiratory protection (see POP,
IEA did not use an organic vapor
initially. IEA began using an OVA
after its use was identified in the POP.
IEA 1s sarrple bottle size and nurbers were not in
strict accordance with the POP (Page 4·12).
However, the materiel of the container and the
preservatives were the same as those described in
the POP and SOPOAM. The variation in bottle size
and nll'!Ders is not a problem because of the
different laboratory requirements. However,, the
POP should be changed to reflect the different
requirements or be flexible to changes in
different laboratory requirements.
During the sarlf)ling and according to the POP,
purge water from the monitoring wells was disposed
of on the ground (see POP, page 4·20). However,
PRC recomnends that the purge water either be
collected from contaminated wells and disposed of
in the treatment system or treated through
portable carbon adsorption
disposal or treatment of
col urns. Proper
purge water will
eliminate recontamination of the site.
Collection of outer tier influent resulted in the
draining of uncollected influent on the ground.
During oversight, PRC reconmended the collection
and proper disposal of this liquid. This
procedure was irlf)lemented by using a S•gallon
bucket and disposing of the liquid in the
groundwater treatment unit. In addition, HC plans
5050D161
RESPONSE
The text has been changed to reflect Teflon tubing.
Comnent noted.
The POP has been changed to allow flexibility in the
safl1)le container size and nll'lt>er.
IEA purged water in accordance with the POP. The
little amount of purge water should not pose a health
risk and envirormental risk.
The SB1J1Jling port was moved inside the treatment
building to facilitate safl1)le collection and contain
spills.
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REVISED 12/89
Specific Cooments
Comments and Responses, RD and POP report
HC/SHELBY, Shelby, North Carolina
Westinghouse Project 4124-85-050D
Document Control No 85050D-179
Page 19
RESPONSE
to move the s~ling port inside the treatment
building to help contain any spills from the
s~l i ng port.
50500161
I
IUAH;
CROUHOWATER INBPRCTION REPORT:
__ 2...Jgu1rr _j ~~ ~l11""i 3rv, ... ---. ' ,,.-
TIME, II. T, WRLLS
SWlTCH ON/Off? f. T. HETERf WORKING"
0. T. Wiit.LS
SWITCH OH/OFF? ,0. T.
HKTBRS WORKJNQ? I. 1-xxxxx xxxxx xxxxx xxxxx
rTRIPPBR ON/Off~ xxxxx xxxxx xxxxx xxxxx
0. 7.
STRlPPBR ON/OFF?
-·--
TA.Nk Ph
'NEUTRAL IZA1' ION
--.. -· -------···. --------··--·-.-·-------•··· ---·
S0R OPl-""-TI ctJ
tlOP~ 0. I( ?
ls•R SLUDGE LEVEL.
POLYMSR PUMP
WATE'H VALVE ON
I ON/OFF?
POLYMER PUMP 2.5 OPH
~OMPNK660R orr1
AIR COMPlBSSOR
OIL LRVEL O.K.7
IALL PUMPS
RUNNING O,l.?
SLUDCE WASTED IN
ISBPARATOR D8fOR8
1ST 1/3 FILL?
SLUDGE TANK LBVBL.
IPROC8668U AT MIXER
COUPLING.
NITROGBN ADDED?
iANK LEVELS O.&.?
, 1. WELL HOUSBS
ABOVR 32 080.F
WINTRR OPBRATlON,
. --tBAT TAPR
RACJNO CIHCUIT ON?
LEAKS YE&/ NO?
lrBRAtOR, INITIALS;
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..
' ' xxxxx xxu:x xu:u xxxxx
XXXX>t XXXKX xxxxx xxxxx xxxxx xxxxx xxxxx xxxxx
xxxxx xxxxx xxxu xxxxx xxxxx xxxxx xxxxx xxxxx
n:xxx xxxxx xxxxx xxxxx xxxxx xxxxx xxxxx lCXXXX KXXXX xxxxx xxxxx XXXX:< xxxxx xxxxx xxxxx
xxxxx XXXXl xxxxx xxxxx xxxxx xxxxx XXXX)( xxxxx xxxxx XXXXk xxxxx xxxxx xxxxx xxxxx xxxxx
xxxxx xxxxx xxxxx KXXXX
---
HCCFOR.'1 II :,6
I
i
RRMARKS; I
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--
--······ ··------·-··
i
. -..
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INNRR TIBR COMB I NBD ,HYLUBNT
HCCFORM #63
CONDUCTIVITY BOD
DATE I/MONTH pH COD I/MONTH TSS
rIRST WED. DAILY DA l LY I• t WKD. DAILY
l
2
3
4
5
6
7
8
B
10 ·-------~ --'------·-·--.. -~---
l'
13
14
15
16
17
18
19
2D
21
22
23
24
25
26
27
28
29
30
31
AVG.
8108
LOW
MONTH YEAR __ _
N83N P04
1/WBEK 1/WBEK
WBD. WKD.
. -
-
-·--------·----·~···-···-·--··.
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-
HCCf"OR/1 061
CONDUCTIVITY
DATE I/MONTH
let, WBD,
J
2
3
4
5
6
7
B
9
10 --I I
I~
13
14
15
16
17
18
18
20
21
22
23
24
25
26
27
28
29
30
31
AVG.
BIOB
LOW
Mf!IU TIIR CARBON rILTSR HFLUBNT
MONTH
pH COD BOD TSS NB3N
I/WK, I/WK. 1/WBBK I /MO!'Tff I/MONTH
wso. WBD. WBD. lot.~'ED. lot.WHO.
I
YEAR __ _
P04 ' ' I/MONTH I lat.WED. I ' i I
I
I
:
j
i
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I
I
I
I
I
I
I
I
I
I
I
I.
I
I
I
I
I
I
HCCFORM 169
COD
DATH DAILY
I
2
3
4
6
6
7
8
9
10
I.
l'
13
14
10
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
AVG.
HIGH
LOW
SBR BfrLUBNT (DKC1lotl'r) HONTB ------YKAR ---
BOD 5 i 1/WKEK I
WBD, '
I i
1
' I
i
I
I
' : I ----
I i
i
' I
;
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
HCCf□RM 116'
pH
DATE DAI LY
...
l
2
3
4
5
6
7
8
9
10
..
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
AVG.
BIOH
LOW
--6BR MIXHD LIOUQR
MONTH-----YHAR -
MLSS MLVSS I AMMONIA D.O.
DAILY l/WUK N!TaDOEN DAll,Y
WED. j DAILY
'
i
. ;
i
l
!
'
'
[
i I
I
I
I
I
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I
I
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I
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I
I
I
I
I
HCCFORII lb;
CONDUCTIVITY
DATE I/MONTH
l • t. WKD.
I
2
3
4
0
6
7
8
9
10
,,
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
HO.
BIOB
LOW
OUTB~ T18R COMBIND JNrLU8~T
MONTH .
pH COD BOD I
DAILY I/MONTH I/MONTH I ' l ■ t. WBD l ■t.WBD. i
I
I !
i '
'
I :
:
I
: ------·-··
I
I
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I
I
I
I
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I.
I
I
I
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I
I
HCCFOI\M 162
CONDUCTIVITY
DATR I /MONTH
l•t-WED.
I
2
3
4
6
6
7
8
9
10
'" H
13
14
16
16
17
18
19
20
21
22
23
H
26
26
27
28
29
30
31
AYO.
HIGH
LOW
OUTER MRR CARBON flLTKR 6FrLURNT
MONTH------
pH COD BOD 1'SB NU3N P04
I/WK. I/WK, I /lfBEK 1/MOIITB I/MONTH !/MONTH
WBD, WRD. WBD, let.1fRD. lat .Wlrn. lat.WED.
I
. . . ·---·-. I
I :
!
I
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