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HomeMy WebLinkAbout4101_CityofHighPointRiverdaleMSWLF_CAProgressReport_DIN26886_20161019SEABOARD GROUP II AND CITY OF HIGH POINT Remedial Action Construction Progress Report Page 1 of 5 October 18, 2016 Mr. Joe Ghiold, Project Manager North Carolina Department of Environmental Quality Division of Waste Management 1646 Mail Service Center Raleigh, North Carolina 27699-1646 Re: Quarterly Remedial Action Construction Progress Report, 3rd Quarter 2016, Seaboard Chemical Corp. and City of High Point Riverdale Drive Landfill Site, Jamestown, North Carolina Dear Mr. Ghiold: Seaboard Group II and the City of High Point, NC (Parties) provide this 3rd Quarter 2016 Remedial Action Construction Progress Report for the former Seaboard Chemical Corporation facility (SCC) and closed Riverdale Drive Landfill (Landfill) located in Jamestown, NC (collectively the Site). Background Information The Remedial Action Pre-Construction Report for the physical treatment systems was submitted to North Carolina Department of Environmental Quality (NCDEQ)1 on December 28, 2009. The report was subsequently approved by NCDEQ on March 22, 2010. Although the Natural Treatment Systems Remedial Action Pre-Construction Report has not been formally approved by NCDEQ, it was submitted on October 25, 2010 and the Parties have included any appropriate comments on activities associated with those processes as well. Collectively these two reports are referred to herein as the Pre-Construction Report IPCR). Construction of the remedial system described in the Pre-Construction Report began at the Site in April, 2010. Previous Progress Reports have updated NCDEQ on Site activities from that time through the 2nd quarter of 2016. During the summer of 2015, the Parties determined from operating experience that the system, as it was then configured, would not achieve the objective of efficient long-term operation without excessive need for maintenance, cleaning and shutdowns. This was due to the greater than expected amount of solids that precipitated out of the groundwater and leachate fouling piping and equipment throughout the system. In spite of repeated efforts to prevent these precipitation problems, the system could not handle the amount of sludge generated. This overloaded the sludge handling capabilities of the existing equipment and 1 NCDEQ is used in this report to refer to the North Carolina Department of Environment Quality, and collectively the associated Division of Waste Management, Solid Waste Section, Hazardous Waste Section, and the Inactive Hazardous Sites Branch, all of which are involved in the regulatory oversight of this remedial action. Remedial Action Construction Progress Report Page 2 of 5 allowed the sludge to deposit on pipes, pumps and equipment throughout the system including the pumps, valves, and irrigation lines in the phytoremediation system. As a result, the Parties retained the services of Hazen and Sawyer (HS) to conduct a study to determine the best approach to sludge separation and handling and recommend any additional modifications to the system that were needed. HS conducted extensive on site testing during the 3rd quarter of 2015. This resulted in the HS report submitted to NCDEQ in prior correspondence (see 3rd quarter 2015 Progress Report), which recommended that a clarifier and sludge handling equipment be installed ahead of the existing Filter Building. During the 3rd quarter of 2015, the Parties approved an initial budget to prepare a request for proposal (RFP) and an engineering design for the installation of a Clarifier System as recommended by HS. On October 1, 2015, the Parties approved the budget to install the recommended equipment, and a RFP for the entire scope of work was sent to prospective bidders. During early December 2015, the Parties reviewed the proposals submitted by the contractors that replied to the RFP and approved the final budget to install the proposed revisions. A contractor was engaged in late December to begin construction activities on January 4, 2016. This modification affected the system operation, which was shut down at the end of December to begin site construction preparation activities. As reported in the 1st quarter 2016 Progress Report, actual construction began on January 4, 2016 and progressed slightly behind schedule due to weather delays. At the end of the 1st quarter the contractor had completed the Site rough filling and grading work, the LS-1 flow modifications, the chemical feed tank containment wall installation and the concrete for the clarifier floor. During the 2nd quarter of 2016, the remaining major construction activities at the site were completed. Several periods of adverse weather resulted in delays during the 1st quarter causing the construction progress to fall approximately 2-weeks behind schedule. The original construction completion date was scheduled to be April 30, 2016, but delays due to weather and other factors extended the completion to mid-May 2016. At that time, the Parties began control loop checks before wetting the modified system with city water for the first time late in May 2016. This allowed the Parties to perform logic tests and confirm the alarms and interlocks during early June. After several SCADA coding refinements, logic modifications and other necessary items were addressed, groundwater and leachate were started into the system on June 27, 2016. Activities Conducted During the 3rd Quarter During the early third quarter of 2016 the Parties continued the startup of the system. Several early issues were detected and corrected. This included drive problems with the progressive cavity pumps that transfer sludge from the Clarifier to the Sludge Dewatering System and from the Equalization Tank to the Clarifier. After switching the VFDs to constant torque mode, the problem continued. As a result, the contractor installed 3:1 gear reducers on all 4 pumps and the VFDs were set to start at 60 Hz for 5-seconds then to decrease to the operator set-point. Remedial Action Construction Progress Report Page 3 of 5 Following this, the system was struck by lightning. It was repaired in 4-days and returned to service. Following that, the system was inspected by an equipment vendor before resuming normal operations. During early August and September of 2016 the Parties retained the services of Arcadis Design and Consultancy (Arcadis) to provide an experienced engineer to provide oversight of a test program to determine the capabilities of the PhotoCat unit to destroy the contaminants of concern in the treated process water. The tests included nine separate test runs at varying conditions of flow, UV lamp power and system chemistry. A copy of the Arcadis final report is attached. As noted, the engineer concluded that the system failed to achieve the treatment levels required during the tests due to several identified causes, including very high levels of radical scavengers in the process flow. Arcadis determined the PhotoCat unit is undersized and cannot achieve the rate constants required to meet the required performance. The existing PhotoCat unit would require approximately 5-times the existing UV-lamp power to achieve the treatment levels necessary to discharge to the City treatment works and such operation would not be practical due to the extremely high level of heat generated by the lamps and the excessive energy costs. Based on the poor performance of the AOP unit during testing, and the challenging influent water quality, Arcadis does not believe the existing AOP system, Photo-Cat, could be successfully implemented at the Site to consistently reduce 1,4-dioxane concentrations in the existing pre-treated process water to below design effluent concentrations (3 μg/L). Arcadis also identified some additional significant potential long-term operational issues with the Photo- Cat unit that are detailed in the report. The Parties have pursued arbitration against the manufacturer of the PhotoCat seeking return of the PhotoCat unit, refund of their purchase price and compensation for damages. A ruling in the arbitration is expected in the first quarter of 2017. The Parties also continued the system startup process and debugged several minor issues. Startup is now complete, and a NCDEQ inspection has been scheduled for October 25, 2016 to seek approval to commence full operation of the system. Summary The remedial system startup has fallen behind schedule based upon the original Scope of Work included in Remedial Action Settlement Agreement (RASA). However, significant progress has been made at this time, and the items required for the restart after modification are complete. The system is ready for the DEQ Certification of Construction Completion Inspection and, thereafter, to commence operation of the Phytoremediation natural treatment system. Please contact Mr. Gary D. Babb, P.G. (919-325-0696) or James C. LaRue (210-263-7580) if there are any questions or comments. Please direct correspondence related to this matter to: Gary D. Babb, P.G. Seaboard Group II and City of High Point c/o Babb & Associates, P.A. Remedial Action Construction Progress Report Page 4 of 5 P.O. Box 37697 Raleigh, NC 27627. Communications via electronic mail should be directed to gbabb@nc.rr.com and jlarue@swenv.com. Respectfully, Seaboard Group II and City of High Point James C. LaRue Seaboard Group II Gary D. Babb, P.G. City of High Point Attachments - Project Schedule Arcadis Report cc Dave Nutt, Esq. - Seaboard Trustee Steve Anastos - Seaboard Trustee Jeffrey Moore - City of High Point Trustee Randy Smith - Financial Trustee Terry Hauk - City of High Point Amos Dawson, Seaboard Group II Counsel John Burns, Seaboard Arbitration Counsel Jackie Drummond - NCDENR Division of Solid Waste Remedial Action Construction Progress Report Page 5 of 5 PROJECT SCHEDULE 2016 September - December Complete punch list items, complete system restart and continue testing and operating the system. Facilitate NCDEQ Certifiction of Construction Completion Inspection of the system on October 25, 2016. Seaboard Group II and City Of High Point AOP SYSTEM TESTING REPORT Purifics Photo-Cat System Jamestown, NC 19 August 2016 AOP SYSTEM TESTING REPORT arcadis.com AOP SYSTEM TESTING REPORT Purifics Photo-Cat System Jamestown, NC Prepared for: John Burns Williams Mullen 301 Fayetteville Street, Suite 1700 Raleigh, North Carolina 27601 Prepared by: Arcadis U.S., Inc. 3109 W. Dr. M. L. King Jr Boulevard Suite 350 Tampa Florida 33637 Tel 813 903 3100 Fax 813 903 9115 Our Ref.: TF001589.0001 Date: August 19 2016 This document is intended only for the use of the individual or entity for which it was prepared and may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this document is strictly prohibited. John F. Perella, P.E. Principal Engineer (Licensed in Florida) AOP SYSTEM TESTING REPORT arcadis.com i CONTENTS Acronyms and Abbreviations ........................................................................................................................ iii 1 Introduction ............................................................................................................................................. 1 1.1 AOP Operational Experience .......................................................................................................... 1 1.2 Document Review ........................................................................................................................... 1 1.3 Summary of Initial Pilot Testing ...................................................................................................... 2 1.4 Summary of 2014 Full Scale System Testing ................................................................................. 2 2 Existing Pretreatment System ................................................................................................................. 3 2.1 Influent Water Quality ..................................................................................................................... 4 3 AOP System Testing ............................................................................................................................... 5 3.1 AOP System Tests Performed ........................................................................................................ 6 3.1.1 AOP System Testing Operational Parameters .................................................................... 7 3.2 AOP System Testing Results ......................................................................................................... 8 3.3 Conclusions .................................................................................................................................. 11 TABLES Table 1. Initial Pilot Testing Results Summary Table 2. 2014 Full Scale System Testing Results Summary Table 3. 2014 Full Scale System Reaction Rate Constants Table 4. Influent Water Quality Data Table 5. Photo-Cat Testing Plan Table 6. Advanced Oxidation Process (AOP) Testing Results Table 7. Advanced Oxidation Process (AOP) Reaction Rate Constants FIGURES Figure 1. Process Flow Diagram Figure 2. Test 0 and Test 1 AOP Performance Decay Curves Figure 3. Test 2 and Test 3 AOP Performance Decay Curves Figure 4. Test 4 and Test 6 AOP Performance Decay Curves Figure 5. Test 5 AOP Performance Decay Curves AOP SYSTEM TESTING REPORT arcadis.com ii Figure 6. Test 7 and Test 8 AOP Performance Decay Curves APPENDICES A Curriculum Vitae – John Perella B Field Data C Laboratory Analytical Reports AOP SYSTEM TESTING REPORT arcadis.com iii ACRONYMS AND ABBREVIATIONS ADX Adsorption Xcelerant AOP Advance Oxidation Process Arcadis Arcadis U.S., Inc. COD Chemical Oxygen Demand CRU Catalyst Recovery Unit CVOCs Chlorinated Volatile Organic Compounds DPCV Discharge Pressure Control Valve FG Food Grade gpm Gallons per Minute H2O2 Hydrogen Peroxide K First Order Rate Constant kW Kilowatts kW-hr/m3 Kilowatt Hours per Cubic Meter Lpm/kW Liters per Minute per Kilowatts LS-2 Lift Station 2 µg/L Microgram per Liter µm Micron mg/L Milligram per Liter ml/min Milliliter per Minute nano Nanoparticle ND Non Detect % Percent psi Pounds per Square Inch R2 Coefficient of Determination SFCV Slurry Feed Control Valve SLCV Slurry Loop Control Valve SU Standard Unit TDS Total Dissolved Solids TiO2 Titanium Dioxide AOP SYSTEM TESTING REPORT arcadis.com iv UV Ultraviolet VOCs Volatile Organic Compounds AOP SYSTEM TESTING REPORT arcadis.com 1 1 INTRODUCTION Arcadis U.S., Inc. (Arcadis) was retained by Williams Mullen to test and evaluate the performance of the existing Advance Oxidation Process (AOP) unit located at the Seaboard Group II facility in Jamestown, NC to determine system capabilities for reducing 1,4-dioxane concentrations in pretreated process water. Testing was performed between August 1 and 3, 2016. An Arcadis Remediation Engineer was present for Tests 0 through 6. Due to travel schedule constraints, the Arcadis Remediation Engineer assisted in initiating Test 7 and Test 8, but was not present for collection of effluent samples or during additional sampling performed on August 16, 2016. This Expert Report is prepared for submission in the arbitration matter Seaboard Group II and the City of High Point, North Carolina v. Purifics, ES, Inc. (ICC Case No. 20995/RD). Other than this engagement, Arcadis and the undersigned are independent of any of the parties to this dispute as well as the Arbitrator, Edna Sussman. The statements herein are based upon the knowledge and experience of the undersigned and, as stated below, upon review of the testing conducted in August 2016 and other documentary reports. This statement represents the genuine belief and opinion of the undersigned. 1.1 AOP Operational Experience The Arcadis Remediation Engineer (John Perella) present during testing has 15 years of experience with the design and operation of AOP systems at environmental remediation sites, including the Calgon RayOx, Applied Process Technologies HiPOx and Purifics Photo-Cat. Direct experience with the Purifics Photo-Cat system includes one full scale and two pilot scale systems. John Perella’s Curriculum Vitae is provided in Appendix A. 1.2 Document Review Historical documents reviewed prior to testing and referenced for this report include: •Seaboard Site Groundwater Remediation On-Site Verification Test Program, January 21, 2009 (Purifics, 2009a) •Draft Photo-Cat Pilot Test & Sample Plan, March 16, 2009 (Purifics, 2009b) •Preliminary On-Site Test Report Photo-Cat Treatment of Leachate and Groundwater at the Seaboard Site, May 4, 2009 (Purifics, 2009c) •On-Site Test Report Photo-Cat Treatment of Leachate and Groundwater at the Seaboard Site, June 1, 2009 (Purifics 2009d) •Response to Proposal Questions Seaboard Site, September 21, 2009 (Purifics, 2009e) •Seaboard Site Mobile Groundwater Treatment System (Proposal), April 28, 2010 (Purifics, 2010) •Operation & Maintenance Support Information Manual, December 5, 2011 (Purifics, 2011) •Jamestown Landfill Leachate Treatment System Treatment Process Study, September 28, 2015 (Hazen, 2015) AOP SYSTEM TESTING REPORT arcadis.com 2 •Draft Construction Completion Report, May 14, 2015 (Seaboard Group, 2015). 1.3 Summary of Initial Pilot Testing On-Site testing or pilot testing was originally proposed by Purifics in January 2009 (Purifics, 2009a). A pilot scale system to include pretreatment systems (air stripping and iron and manganese removal) and primary AOP unit were proposed. Based on information in the proposal, the pilot scale system had a maximum starting load of 12 kilowatts (kW) and was capable of operating within a range of approximately 1 to 13 gallons per minute (gpm). Pilot testing was performed on-Site between March 18 and May 10, 2009. During this period the pilot scale system was operated for nine days and 18 AOP treated effluent samples were collected. Pilot testing resulted in concentrations of 1,4-dioxane in AOP treated effluent between <2.0 and 1,650 micrograms per Liter (µg/L). It should be noted, of the 18 effluent samples collected, three showed no detection for 1,4-dioxane (<5.0 µg/L on April 28, 2009 [SEA-PUR-6-EFF] and <2.0 µg/L on May 9 and 10, 2009 [SEA-PUR-8-EFF and SEA-PUR-9-EFF]). These three results are referred to as “optimal test condition” in the On-Site Test Report (Purifics, 2009d). A summary of initial pilot test results is provided in Table 1. Based on these results, Purifics recommended a Photo-Cat AOP unit with approximately 145 kW for treatment of Site process water with an operational flow rate of 50 gpm (Purifics, 2009d). Assuming a 1,4- dioxane design influent concentration of 3,000 µg/L and a design effluent concentration of <3.0 µg/L, the resulting AOP unit needs to reduce the concentration by 99.97 percent (%). A mathematical equation is used to provide a predictive tool to evaluate the performance of the AOP unit, the equation is referred to as the first order reaction equation. Within this equation is a term referred to as the first order reaction rate constant. This value provides a number that can be used to compare the performance of AOP treatment systems; the higher the number, the better the treatment. For example, a first order rate constant of 10 provides twice as much treatment as a value of 5. Additional discussion of the first order rate equation is provided in Section 3. The first order rate constant was calculated by Arcadis to treat 1,4-dioxane from the expected influent concentrations of 3,000 µg/L to the design effluent concentration of <3.0 µg/L; the rate constant was calculated to be approximately 9 liters per minute per kilowatt (Lpm/kW). It should be noted, in the Purifics Proposal (Purifics, 2010), the AOP unit power was increased from 145 kW to 245 kW and the resulting 1,4-dioxane rate constant for the final proposed AOP unit was calculated by Arcadis to be approximately 5.3 Lpm/kW. There is no explanation for the increased power requirement within the Purifics Proposal 8P1205v5. Verification of rate constants observed during the Purifics pilot tests was not possible since key data used in the rate constant calculation, such as flow rate, power and chemical dose were not provided in the On- Site Reports, Proposal or Operations and Maintenance Manual documents provided by Purifics. 1.4 Summary of 2014 Full Scale System Testing In 2014 Seaboard Group II representatives tested the full-scale water treatment system, including the PhotoCat unit, to verify its performance. All tests completed were performed with the system operating under full power (240kW) and at a consistent flow rate of 35 gpm. Variables adjusted during testing were AOP SYSTEM TESTING REPORT arcadis.com 3 pH, hydrogen peroxide (H2O2) dose, and whether titanium dioxide (TiO2) catalyst was used. Catalyst used during the 2014 event was a food grade (FG) TiO2. All tests performed during the 2014 event were completed by Jamestown Engineering. Full scale system testing occurred on September 29, October 2 and October 9, 2014. During these tests, 3 AOP system influent samples (one each day of testing) and 16 effluent samples were collected. These samples were sent to ENCO Laboratories for analysis. Full scale testing resulted in concentrations of 1,4- dioxane in AOP treated effluent between <2.0 and 1,420 µg/L. It should be noted, of the 16 effluent samples collected, one showed no detection for 1,4-dioxane (<2.0 µg/L on October 9, 2014 [AOP 16-4]) and a second resulted in relatively low concentration for 1,4-dioxane (15.8 µg/L on October 9, 2014 [AOP 16-3]). These two results are best case results for testing performed in 2014. A summary of 2014 full scale test results is provided in Table 2 and a summary of resulting full scale system testing rate constants is provided in Table 3. The two best case testing results above, both utilized a H2O2 concentration of approximately 54 milligrams per Liter (mg/L); however, influent pH was varied between tests (4 standard units (SU) for AOP 16-4 and 3 SU for AOP 16-3). Of note for these best case tests, is that no TiO2 catalyst was utilized for either test, i.e. the only production of hydroxyl radicals was by the disassociation of H2O2, the same as traditional ultraviolet (UV)/H2O2 AOP systems. The resulting 1,4-dioxane rate constants were calculated by Arcadis to be approximately 4.0 Lpm/kW and 2.9 Lpm/kW for AOP 16-4 and AOP 16-3, respectively. Both of these rate constants are less than the final design rate constant of 5.3 Lpm/kW, as discussed in Section 1.3. Other tests performed with TiO2 catalyst in use (denoted with “TiO2” in the sample name, e.g. AOP 16-4 TiO2), resulted in calculated 1,4-dioxane rate constants of approximately 1.1 Lpm/kW, similar to results of Test 7 and Test 8 performed during the August 2016 event, which are discussed in Section 3.2 below. Influent source water and concentrations for chlorinated volatile organic compounds (CVOCs) and 1,4- dioxane were similar based on analytical results for both 2014 and 2016 testing, hence based on the similarity of these results, incoming water quality for testing completed in 2014 and 2016 appear to be similar and consistent. 2 EXISTING PRETREATMENT SYSTEM The purpose of the pretreatment systems installed at the Seaboard Site are to stabilize hardness (calcium and magnesium), remove iron and manganese, remove suspended solids, and remove volatile organic compounds. A clarifier and sludge handling equipment were recently added to the pretreatment process in 2016. Their design is based on field testing completed by Hazen and Sawyer in September 2015. The purpose of the clarifier is to remove solids and stabilize calcium (Hazen, 2015). Prior to its installation, calcium and solids precipitation resulted in short filter runs and operational issues due to scaling in piping and pumps. Based on discussions with Site operations staff, following the installation of the clarifier, solids precipitation and scaling has been minimized or eliminated. The current pretreatment processes include the following: Extracted groundwater and leachate from the Site are combined in a pipe manifold located in Lift Station 2 (LS-2). Pre-slaked lime and ferric chloride are then injected into the combined process water stream prior to the clarifier, to increase pH, promote the development of an iron and manganese floc and stabilize calcium. Following the clarifier, process water AOP SYSTEM TESTING REPORT arcadis.com 4 gravity drains into an aeration tank followed by an equalization tank and is then pumped through media filters. These processes further oxidize, precipitate and mechanically filter remaining iron and manganese. Following the media filters, process water is pumped to a low profile air stripper, in which the majority of volatile organic compounds (VOCs) are removed. Following the air stripper, process water is pumped to a baffled settling tank and then pumped through 25 micron (µm) and 5 µm nominal bag filters that are in series for additional solids removal. When the AOP is not in operation, process water is discharged to the phytoremediation irrigation system following the bag filters. However, if the PhotoCat AOP is utilized, a final filtration step through a 1 µm absolute cartridge filter is performed prior to the PhotoCat AOP unit. Additionally, with the PhotoCat AOP in operation, pH adjustment and chemical oxidant injection is performed prior to the 1 µm absolute cartridge filter. A general process flow diagram of all treatment systems is provided in Figure 1. 2.1 Influent Water Quality Influent water quality samples were collected from the combined process water, prior to any treatment processes (Test 0 INF 080116) and from the AOP system influent following pH adjustment but prior to final 1 µm filtration (Test 0 PC INF 080116). Chemical oxidant injection, prior to the AOP, was turned off during the collection of this sample. The groundwater recovery and pretreatment systems were operated for approximately 24 hours prior to samples being collected. A summary of influent water quality is provided in Table 4. Analytical laboratory reports are provided in Appendix C. The source of influent water was primarily from groundwater extraction well PW-DR1 and a lesser amount was leachate. To best match groundwater and leachate design flowrates as described by Purifics (Purifics 2009a and Purifics 2010) during testing, approximately 80 % of the water was groundwater and 20% leachate. The compounds of concern, notably chlorinated VOCs and 1,4-dioxane, were observed in the influent water at the combined process water influent and are in general relatively high in concentration compared to most groundwater remediation systems for chlorinated VOCs and 1,4-dioxane. Approximate concentrations included total VOCs of 20,000 µg/L and 1,4-dioxane of 3,000 µg/L. From a remediation treatment perspective, although the dissolved organic concentrations are relatively high, they are certainly within range for treatment using multiple technologies. There were some inorganic water quality conditions that are noteworthy that can affect both treatment performance and long-term operations and maintenance of treatment equipment. Of special note, the water is considered to have very high hardness (660 mg/L). Hardness is generally based on the concentrations of calcium and magnesium in the water and water is generally considered to be very hard above 180 mg/L. Hard groundwater can cause fouling of treatment equipment by causing excessive scale build-up on the equipment. Iron and manganese were present with iron concentrations of 7.25 mg/L and manganese of 5.69 mg/L. Iron is a very common compound in shallow impacted aquifers and iron can cause fouling of treatment equipment. Usually iron concentrations exceeding 2 mg/L require pre-treatment and removal to prevent equipment fouling. Manganese can also foul equipment, but it does not precipitate as easily as iron and may or may not act to foul treatment equipment. AOP SYSTEM TESTING REPORT arcadis.com 5 Other constituents of interest that can affect treatment using AOP technologies include alkalinity, bromide, chloride, and chemical oxygen demand. All of these parameters can act as hydroxyl radical scavengers which make AOP treatment of the 1,4-dioxane and chlorinated VOCs more challenging. Elevated concentrations of alkalinity, bromide, chloride and chemical oxygen demand (COD), may present challenges for treatment through an AOP. From review of sample results, each of these conditions is present in the groundwater and leachate at the Site. The pre-treatment process improved the ability of the AOP system to treat the 1,4-dioxane; however, there are hydroxyl radical scavengers present (bromide, chloride) that may affect the treatment performance of AOP technologies to remove 1,4-dioxane. An additional discussion of bromide is presented in Section 3.2. 3 AOP SYSTEM TESTING Contaminant destruction in AOP systems can be modeled using first order reaction principles and can be confirmed with field tests operated under various flow rate and power conditions while other operational parameters are kept constant, such as pH and chemical oxidant dose. As described in Section 1.3, the first order reaction equation is a method to provide a simple way of comparing the performance of the AOP treatment system. The first order rate constant (k) is the number that is used to make performance comparisons; the higher the k value, the better the performance. For example, a k value of 10 provides twice the treatment as a k value of 5. Evaluating and understanding the k value provides a way to compare different tests and is the primary way to compare the treatment performance of tests described in this testing program. The following first order equations apply for AOP systems: C = Co • e-k•x (Eqn. 1) or: k = ln(Co/C) • 1/x (Eqn. 2) where: Co = Initial Contaminant Concentration C = Final Contaminant Concentration k = first order rate constant x = Dose per Volume Treated x = P/Q (Eqn. 3) P = ln(Co/C) • Q/k (Eqn. 4) where: P = Power (kW) Q = Flow Rate The goal of testing is to determine the first order rate constant, typically calculated in units of Lpm/kW. The first order rate constant can be calculated or converted to alternative units (e.g. kilowatt hours per cubic meter [kW-hr/m3]), however for the purposes of this report the units Lpm/kW will be utilized.. AOP SYSTEM TESTING REPORT arcadis.com 6 The first order rate constant is specific for each contaminant, provides a general gauge of AOP performance and can be used for the design of full scale systems. The first order rate constant provides the ability for the designer to determine the power requirement (kW) for the full scale AOP system (see equation 4 above). In the units Lpm/kW utilized here, higher rate constant values indicate better potential performance (ability to reduce contaminant concentrations) and lower power requirement for the AOP system. Based on experience, typically a first order rate constant for 1,4-dioxane greater than 10 Lpm/kW is desired when selecting an UV based AOP system, due to the first order kinetics of AOP systems. Specifically, because of first order kinetics, an AOP system power requirement will double if the rate constant is halved, e.g. an AOP designed with a rate constant of 10 Lpm/kW and requiring 100 kW, would require 200 kW if the rate constant was reduced to 5 Lpm/kW and 1,000 kW if the rate constant was reduced to 1 Lpm/kW. In cases where water quality is consider challenging, lower rate constants (i.e. higher power requirements) may be acceptable, however the designer must consider the operational parameters (flow rate, initial contaminant concentrations and desired final contaminant concentrations) of the full scale system. For example, if the flow rate and/or initial concentration of contaminant are relatively low and/or the desired final contaminant concentration is relatively high, a low rate constant may be acceptable, since the relative power requirement may be considered reasonable. However, if flow rate and/or initial contaminant concentration are relatively high and/or the desired final contaminant concentration is low, the designer should evaluate methods to increase the rate constant (i.e. pretreatment prior to the AOP) or alternative methods for treatment of contaminant(s). For the purpose of verifying first order reaction kinetics, a consistent testing strategy was employed for all tests completed during August 2016. During each Test performed, chemical oxidant concentration, catalyst utilized and pH were held constant, while flow and power combinations were varied. The variation of flow and power during testing are identified as “Runs.” Each Test utilized three (3) Runs, which were maintained at approximately 40 gpm at 240 kW, 40 gpm at 120 kW and 30 gpm at 120 kW, i.e. power to flow ratios of 1.5, 0.75 and 1.0 Lpm/kW, respectively. Analysis of AOP system effluent concentrations collected from the three (3) Runs, allows for the verification and modeling of first order kinetics for the respective Test. To best match groundwater and leachate design flowrates as described by Purifics (Purifics, 2009a and Purifics, 2010), testing of the AOP system was performed utilizing an approximate blend of 80% groundwater and 20% leachate throughout all testing. Water was pre-treated as described in Section 2 of this report. Variation of AOP system power was achieved by operating the system with all lamps in operation for 240 kW Runs and by shutting down all lamps on one half of the reactor for 120 kW Runs. 3.1 AOP System Tests Performed AOP system testing was performed on-Site between August 1 and 3, 2016. A total of nine distinct Tests (Test 0 through Test 8), were completed, with each Test including three (3) Runs (as described in the previous section). At the start of each Test, a pre-treated process water sample was collected from the AOP system influent. For each Run, the Photo-Cat unit was operated for a minimum of 30 minutes at consistent operating parameters, after which an effluent sample was collected. A summary of all testing AOP SYSTEM TESTING REPORT arcadis.com 7 completed and key operating parameters is provided in Table 5. Field data collected from each Test during the August event is provided in Appendix B. A brief description of all tests completed is provided below: Test 0 – UV only, no catalyst, no chemical oxidant. System performance by photolysis only. Test 1 – UV and Food Grade (FG) Titanium Dioxide (TiO2) catalyst. System performance with non- spec catalyst. Test 2 – UV, FG TiO2, 100 mg/L Adsorption Xcelerant (ADX). System performance with non-spec catalyst and ADX chemical oxidant. Test 3 – UV, FG TiO2, 60 mg/L ADX. Same as Test 2, with reduced concentration of ADX. Test 4 – UV, no catalyst, 100 mg/L ADX. System performance with no catalyst and ADX chemical oxidant. Test 5 – UV, no catalyst, 150 mg/L hydrogen peroxide (H2O2). System performance with no catalyst and H2O2 chemical oxidant. Test 6 – UV, no catalyst, 200 mg/L H2O2. Same as Test 5, with increased concentration of H2O2. Test 7 – UV, nanoparticle (nano) TiO2, 150 mg/L H2O2. System performance with spec catalyst and H2O2 chemical oxidant. Test 8 – UV, nano TiO2, 100 mg/L ADX. System performance with spec catalyst and ADX chemical oxidant. 3.1.1 AOP System Testing Operational Parameters A discussion of key operational parameters utilized for AOP system testing is provided below: pH To reduce the number of variables tested, all tests were performed with the AOP system influent pH maintained at approximately 4.2 SU (on a scale of 1 (highly acidic) to 14 (highly alkaline)). The reduced pH was selected for the purpose of eliminating bicarbonate alkalinity and maintaining consistent AOP unit operation. Reduction of pH was achieved using phosphoric acid injected into the process water stream prior to the AOP system influent. Chemical Oxidant AOP units such as the PhotoCat at the Site use a chemical oxidant to improve performance in the elimination of 1,4 dioxane. The tests performed in August 2016 on the Site were conducted with either H2O2 or ADX, a proprietary material provided by Purifics. Chemical oxidant concentrations were determined based on field COD (Chemical Oxygen Demand) samples collected on August 1, 2016. COD samples were collected from the AOP system influent sample port and results were 78 and 82 mg/L. For the purpose of the testing a general rule for traditional UV/H2O2 AOP systems was applied where the COD concentration is doubled to determine the AOP SYSTEM TESTING REPORT arcadis.com 8 approximate H2O2 dose required. Therefore, based on the COD results, H2O2 dose requirements were estimated to be between 150 and 200 mg/L. ADX concentrations were selected based on the recommended mixed ADX solution concentration of 12% (Purifics, 2011) and the pumping capacity of the metering pump (maximum flow rate = 7.5 Lpm). Based on these criteria, concentrations of 60 and 100 mg/L were selected. Concentrations of chemical oxidant (ADX or H2O2) are provided as pure product concentration in process water. Approximately 27.5 lbs of ADX powder (obtained from Purifics) was mixed with 24 gallons water to produce a 12% by weight concentration. A 12% ADX solution concentration was selected to match the same concentration identified in the Operations and Maintenance Manual (Purifics, 2011). Based on that concentration and the calculated specific gravity of the solution, the chemical metering flow rate required was calculated for various flow rates and concentrations. For example, to achieve a 100 mg/L concentration of ADX in a process water flow of 40 gpm, the chemical must be metered at approximately 122 ml/min or 98% capacity of the metering pump utilized. H2O2 at the Site is 32% concentration, therefore achieving a 200 mg/L concentration at 40 gpm process water flow rate requires a chemical metering flow rate of approximately 84 milliliter/minute (ml/min) or 68% of the metering pump capacity. AOP Unit Operation During testing in which catalyst was used, the AOP unit was operated with the slurry loop control valve (SLCV) partially open to maintain a pressure between approximately 25 and 35 pounds per square inch (psi) on the slurry loop pressure transmitter. The discharge pressure control valve (DPCV) was partially opened to maintain a pressure between approximately 20 and 30 psi on the discharge pressure transmitter. Additionally the accumulator level was maintained at approximately 60% full, the slurry feed control valve (SFCV) was maintained at approximately 25% open and the catalyst recovery unit (CRU) back pulse was initiated once per minute. The operational set points described above are consistent with typical operational set points for other Photo-Cat AOP systems. Both a food grade and nanoparticle TiO2 catalyst were tested. The nanoparticle TiO2 catalyst was the material obtained from Purifics during initial receipt and testing of the Photo-Cat at the Site. During testing in which catalyst was not used, the AOP unit was operated under the same approximate conditions with the exception that the SFCV was closed, and the CRU back pulse was disabled. Under these conditions the AOP unit was operated as a traditional UV/Oxidant AOP, i.e. single pass and no catalyst. 3.2 AOP System Testing Results AOP system testing was performed on-Site between August 1 and 3, 2016. Analytical testing results are summarized in Table 6 and first order rate constants and AOP performance data are summarized in Table 7. Plotted data and modeled decay curves for each test are provided in Figures 2 through 6. Analytical lab reports are provided in Appendix C. A description of test results are provided below: Test 0 – UV only, no catalyst, no chemical oxidant AOP SYSTEM TESTING REPORT arcadis.com 9 Test 0 was performed to provide a baseline for AOP performance and a comparison to treatment of process water by photolysis alone. Photolysis is the disassociation of molecules by light alone and can be an indication of UV lamp performance. Concentrations of 1,4-dioxane were reduced by 36% to 57% during this test and the resulting first order rate constant (rate constant) for 1,4-dioxane was modeled to be approximately 0.54 Lpm/kW. This test had excellent correlation between Runs, with a coefficient of determination (R2) factor of 0.99. The results of this test indicate the AOP unit lamps are in good working condition. Test 1 – UV and FG TiO2 catalyst Test 1 was performed to determine the performance of the AOP unit utilizing a FG TiO2 catalyst. Typically, the Photo-Cat AOP uses a nano TiO2 catalyst, which has a much smaller diameter than the FG TiO2 and should theoretically be more effective. Results of this test allow for a comparison between catalyst types. Concentrations of 1,4-dioxane were reduced by 47% to 60% during this test and the resulting rate constant was modeled to be approximately 0.63 Lpm/kW. This test had very good correlation between Runs, with a R2 factor of 0.91. The results of this test show minor improvement over Test 0, indicating moderate production of hydroxyl radicals with the FG TiO2. Test 2 – UV, FG TiO2, 100 mg/L ADX Test 2 was performed to determine the performance of the AOP unit utilizing the FG TiO2 catalyst and ADX chemical oxidant. ADX is a proprietary chemical provided by Purifics and is supposed to enhance operation of the AOP. During this test, ADX was injected into the AOP system influent at an approximate concentration of 100 mg/L. Concentrations of 1,4-dioxane were reduced by 52% to 62% during this test and the resulting rate constant was modeled to be approximately 0.64 Lpm/kW. This test had very good correlation between Runs, with a R2 factor of 0.93. The results of this test show effectively no improvement over Test 1, indicating limited effectiveness of the ADX during this test. Test 3 – UV, FG TiO2, 60 mg/L ADX Test 3 was performed the same as Test 2, except the concentration of ADX was reduced to 60 mg/L to allow comparison between different concentration of ADX. Concentrations of 1,4-dioxane were reduced by 48% to 73% during this test and the resulting rate constant was modeled to be approximately 0.83 Lpm/kW. This test had excellent correlation between Runs, with a R2 factor of 0.99. The results of this test show moderate improvement over Test 2, which may indicate the ideal concentration of ADX is closer to 60 mg/L than 100 mg/L for this process water. Test 4 – UV, no catalyst, 100 mg/L ADX Test 4 was performed to determine performance of the AOP unit utilizing no catalyst and ADX. During this test the AOP unit was operated as a traditional UV/Oxidant AOP, i.e. single pass and no catalyst. ADX was injected into the AOP system influent at an approximate concentration of 100 mg/L. Concentrations of 1,4-dioxane were reduced by 57% to 67% during this test and the resulting rate constant was modeled to be approximately 0.67 Lpm/kW. This test had good correlation between Runs, AOP SYSTEM TESTING REPORT arcadis.com 10 with a R2 factor of 0.79. The results of this test show moderate reduction in performance compare to Test 3, but similar results to Test 2. Test 5 – UV, no catalyst, 150 mg/L H2O2 Test 5 was performed to determine performance of the AOP unit utilizing H2O2, but no catalyst. During this test the AOP unit was operated as a traditional UV/Oxidant AOP, i.e. single pass and no catalyst. H2O2 was injected into the AOP system influent at an approximate concentration of 150 mg/L. Concentrations of 1,4-dioxane were reduced by 38% to 100% during this test. Run A, operating at 30 gpm and 120 kW produced a result of non-detect (ND) for 1,4-dioxane in effluent. This result is considered anomalous when compared to Runs B and C. If Run A is included in the model analysis of data the resulting R2 factor is 0.07 and effectively shows no correlation. While in comparison, if Run A is removed from the model analysis of data the resulting R2 factor is 1.0 and shows perfect correlation. Further Run A represents the mid-point operational power to flow ratio (1.06 kW/Lpm) of Test 5, hence since Run A did not utilize the maximum power to flow ratio for the Test and both the low and maximum power to flow ratio results have perfect correlation, the likelihood of Run A being an anomaly is very high. Therefore for the purpose of this report, Run A data is not used for the model analysis of the rate constant, e.g. the rate constant accepted as the result for this test is approximately 0.59 Lpm/kW. The effective results for this show only slight improvement compared to the baseline test (Test 0). Test 6 – UV, no catalyst, 200 mg/L H2O2 Test 6 was performed the same as Test 5, except the concentration of H2O2 was increased to 200 mg/L to allow comparison between different concentration of H2O2. Concentrations of 1,4-dioxane were reduced by 40% to 64% during this test and the resulting rate constant was modeled to be approximately 0.63 Lpm/kW. This test had excellent correlation between Runs, with a R2 factor of 0.99. The results of this test show moderate improvement over Test 5, which may indicate the ideal concentration of H2O2 is greater than 200 mg/L for this process water. Test 7 – UV, nano TiO2, 150 mg/L H2O2 Test 7 was performed to determine the performance of the AOP unit utilizing the standard Photo-Cat specified nano TiO2 catalyst and H2O2. During this test, H2O2 was injected into the AOP system influent at an approximate concentration of 150 mg/L. Concentrations of 1,4-dioxane were reduced by 54% to 78% during this test and the resulting rate constant was modeled to be approximately 0.89 Lpm/kW. This test had good correlation between Runs, with a R2 factor of 0.82. The results of this test show moderate improvement over previous testing with FG TiO2 and H2O2 alone. Based on these results the nano TiO2 catalyst provides better performance than the FG TiO2. Test 8 – UV, nano TiO2, 100 mg/L ADX Test 8 was performed to determine the performance of the AOP unit utilizing the standard Photo-Cat specified nano TiO2 catalyst and ADX. During this test, ADX was injected into the AOP system influent at an approximate concentration of 100 mg/L. Concentrations of 1,4-dioxane were reduced by 65% to 78% during this test and the resulting rate constant was modeled to be approximately 1.02 Lpm/kW. This test had very good correlation between AOP SYSTEM TESTING REPORT arcadis.com 11 Runs, with a R2 factor of 0.93. Results from this test were the best of all test performed during the August testing event. Based on these results, the combination of ADX and nano TiO2, are the most effective for the reduction of 1,4-dioxane in this process water, but H2O2 and nano TiO2 appear to be equally effective. Additional Bromide Sampling Bromide is an aggressive radical scavenger and can adversely affect the performance of AOP systems, by consuming hydroxyl radicals and limiting their availability for the destruction of target contaminants. Bromide was detected in all samples analyzed for bromide during the August 2016 AOP testing event. To determine the source of bromide in process water, additional samples for bromide were collected on August 16, 2016. Water samples were collected and analyzed for bromide from extraction well PWDR-1 and combined Leactate and from chemical solutions utilized by the clarifier (Ferric Chloride and Lime). Analytical results for these samples are provided in Table 6. Results from these samples indicate that the source of bromide in process water is Site groundwater and leachate, as bromide concentrations were 6 mg/L and 10 mg/L for PWDR-1 and Leachate, respectively. Ferric Chloride and Lime samples were both ND for bromide, and therefore were shown not to contribute to bromide concentrations in process water. 3.3 Conclusions Of the nine tests performed, the best AOP unit performance was observed when both the nano TiO2 catalyst and chemical oxidant (H2O2 or ADX) were used (Tests 7 and 8). 1,4-dioxane concentrations were reduced by 78% for both tests and rate constants were modeled to be approximately 0.89 and 1.02 Lpm/kW for Test 7 and Test 8, respectively. However, these rate constants for 1,4-dioxane are considered extremely low. As stated previously, a rate constant of 10 Lpm/kW or greater is generally desirable when designing an AOP system. In cases where water is considered very difficult to treat, a lower rate constant may be acceptable, however in those instances in which a low rate constant would be acceptable the influent concentration of the contaminate and/or the system flow rate should be relatively low, otherwise the cost of operating the system due to power requirements becomes much less attractive. In the case of the Seaboard Site, based on the testing results, the best case rate constant observed was approximately 1 Lpm/kW. With no safety factor, the AOP unit power required to treat the Site process water at the design flow rate of 50 gpm, an influent concentration of 3,000 µg/L and a design effluent concentration of <3 µg/L would be approximately 1,250 kW, more than five times larger than the existing AOP unit. An AOP unit this large would not be attractive for this Site, due to costs for power and extreme temperature increases to the process water through the AOP unit, which would require additional systems to reduce the water temperature to levels acceptable by other infrastructure. As discussed in Section 2.1, it is recognized that the water at the Site presents challenges for treatment of 1,4-dioxane. Radical scavengers, such as alkalinity, bromide, chloride and COD are known to consume hydroxyl radicals within an AOP reactor, limiting radical availability for the destruction of contaminates, such as 1,4-dioxane. As seen in the test results, photolysis alone (Test 0) was shown to remove 1,4- dioxane concentrations by 36 to 57%. Therefore, even for the best case scenario tested (Test 8) at least half of the 1,4-dioxane reduction can be contributed to photolysis. This result may implicate radical scavengers are contributing to the limited performance of the AOP. AOP SYSTEM TESTING REPORT arcadis.com 12 Based on the poor performance of the AOP unit during testing and the challenging influent water quality, Arcadis does not believe the existing AOP system, Photo-Cat, could be successfully implemented at the Site to consistently reduce 1,4-dioxane concentrations in the existing pre-treated process water to below design effluent concentrations (3 µg/L). Purifics states in the final On-Site Test Report (Purifics, 2009d), “Purifics has concluded that the groundwater at the Seaboard site contains very high levels of radical scavengers.” Section 4.4 “Radical Scavengers,” following that statement discusses the potential for the presence of surfactants. While acknowledging the presence of very high levels of radical scavengers within the same On-site Test Report, Purifics proposes the full-scale Photo-Cat system power requirement will be “approximately 145 kw” for “full-scale operation at a flow rate of 50gpm.” As discussed previously, a 1,4-dioxane rate constant of at least 9 Lpm/kW would be required to meet the design objective for 1,4-dioxane effluent concentrations for a 145 kW Photo-Cat. Within the Purifics Final Proposal (Purifics, 2010) the final proposed AOP system is a “245 kW DQL Photo-Cat.” As discussed previously, a 1,4-dioxane rate constant of at least 5.3 Lpm/kW would be required to meet the design objectives for 1,4-dioxane effluent concentrations for a 245 kW Photo-Cat. There is no explanation for the increased power requirement within the proposal and there is no discussion concerning the need to reduce surfactant or other radical scavenger concentrations. As stated previously, based on the testing performed during the August 2016 event and comparison to the similar results of the 2014 testing event, the existing Photo-Cat is undersized and cannot achieve the rate constants required to meet the required performance. Based on the analysis of the data collected from the August 2016 event, the Photo-Cat would require approximately 5 times more power than the existing system to achieve design criteria. In order for the existing PhotoCat unit to meet the design criteria and performance requirements of reduction of 1,4-dioxane concentrations to < 3 µg/L, additional pretreatment to remove radical scavengers and thereby increase the AOP first order rate constant for 1,4-dioxane would also be required. These additional pretreatment measures were not included in the delivered system and would likely add significantly to the cost of the overall system. Long Term Operational Issues with Photo-Cat Some additional significant potential issues were noted with the Photo-Cat unit during the August 2016 event at the Seaboard Site that may cause operational issues if this system is operated long term. Specifically, based on our inspection of the lamps currently utilized by this Photo-Cat, the lamps are believed to use a defective insulation on the lamp power cables. The defective insulation may degrade over time and cause lamp failure or limited UV transmittance through the quartz sleeves. Lamps currently utilized by Purifics use an upgraded insulation, and we understand Purifics had replaced these lamps in units similar to the one at the Site. Additionally, the lamp drivers utilized to power the lamps are proprietary to Purifics and are not available through an alternative vendor. Currently at the Seaboard Site, within the existing Photo-Cat, there are two spare lamp drivers. As these drivers fail, replacement drivers would have to be purchased directly through Purifics. Finally, the seal plug removal tool could not be located at the Site. This tool is required to remove quartz sleeves, so they may be inspected or replaced. This tool is only available through Purifics. TABLES Table 1 Initial Pilot Testing Results Summary Seaboard Group High Point, North Carolina DRAFT "Privileged and Confidential - Attorney Work Product"Page 1 of 4 Sample ID SEA-PUR-1-IN SEA-PUR-1-AS SEA-PUR-1-EFF SEA-PUR-2-IN SEA-PUR-2-AS SEA-PUR-2-EFF SEA-PUR-2a-AS SEA-PUR-2a-EFF SEA-PUR-2b-IN SEA-PUR-2b-AS SEA-PUR-2b-EFF Date 3/18/2009 3/18/2009 3/18/2009 3/19/2009 3/19/2009 3/19/2009 3/19/2009 3/19/2009 3/19/2009 3/19/2009 3/19/2009 Time 1600 1600 1600 1100 1100 1100 1315 1315 1600 1600 1600 1,4-Dioxane ug/L 2100 --171 --1470 829 1840 963 --2130 1650 1,1,1-Trichloroethane ug/L 729 ND ND 796 ND ND ----935 ND ND 1,1-Dichloroethane ug/L 1570 ND ND 1670 ND ND ----1990 ND ND 1,1-Dichloroethene ug/L 652 ND ND 633 ND ND ----745 ND NDAcetoneug/L ND 10.3 187 ND 7.3 74 ----ND 20.6 46.8 Benzene ug/L 72.7 ND ND 75 ND ND ----88.1 ND ND Chlorobenzene ug/L 2380 ND ND 2590 ND ND ----3210 ND NDChloroethaneug/L 383 ND ND 183 ND ND ----445 ND ND Cis-1,2-Dichloroethene ug/L 3070 ND ND 3190 ND ND ----3880 ND ND Tetrachloroethene ug/L ND ND ND ND ND ND ----ND ND ND Toluene ug/L 163 ND ND 173 ND ND ----188 ND 2.9 Vinyl Chloride ug/L 414 ND ND 448 ND ND ----508 ND ND Iron mg/L 5.9 0.05 --5.4 0.05 ------6.3 0.05 -- Manganese mg/L 8.3 0.045 --8 0.013 ------7.8 0.01 -- Footnotes on Page 4. Parameter Table 1 Initial Pilot Testing Results Summary Seaboard Group High Point, North Carolina DRAFT "Privileged and Confidential - Attorney Work Product"Page 2 of 4 Sample ID Date Time 1,4-Dioxane ug/L 1,1,1-Trichloroethane ug/L 1,1-Dichloroethane ug/L 1,1-Dichloroethene ug/LAcetoneug/L Benzene ug/L Chlorobenzene ug/LChloroethaneug/L Cis-1,2-Dichloroethene ug/L Tetrachloroethene ug/L Toluene ug/L Vinyl Chloride ug/L Iron mg/L Manganese mg/L Parameter SEA-PUR-3-AS SEA-PUR-3-EFF SEA-PUR-3a-AS SEA-PUR-3a-EFF SEA-PUR-3b-IN SEA-PUR-3b-AS SEA-PUR-3b-EFF SEA-PUR-4-IN SEA-PUR-4-AS SEA-PUR-4-EFF 4/7/2009 4/7/2009 4/7/2009 4/7/2009 4/7/2009 4/7/2009 4/7/2009 4/8/2009 4/8/2009 4/8/2009 1430 1425 1530 1530 1630 1630 1630 1330 1330 1330 1300 44.5 1400 98.3 --1470 229 --1830 443 --------826 ND ND 901 ND ND --------1680 2 1.6 1850 ND ND --------676 ND ND 822 ND ND--------545 28 167 1940 230 159 --------72.1 ND ND 92.9 ND ND --------2340 6.5 ND 2820 ND ND--------423 ND ND 508 ND ND --------3060 5.5 ND 3770 ND ND --------21.9 ND ND 18.9 ND ND --------197 ND ND 187 ND ND --------478 ND ND 583 ND ND --------5.3 0.025 --5.5 ND -- --------8.1 ND --7.7 0.44 -- Footnotes on Page 4. Table 1 Initial Pilot Testing Results Summary Seaboard Group High Point, North Carolina DRAFT "Privileged and Confidential - Attorney Work Product"Page 3 of 4 Sample ID Date Time 1,4-Dioxane ug/L 1,1,1-Trichloroethane ug/L 1,1-Dichloroethane ug/L 1,1-Dichloroethene ug/LAcetoneug/L Benzene ug/L Chlorobenzene ug/LChloroethaneug/L Cis-1,2-Dichloroethene ug/L Tetrachloroethene ug/L Toluene ug/L Vinyl Chloride ug/L Iron mg/L Manganese mg/L Parameter SEA-PUR-5-AS SEA-PUR-5-EFF SEA-PUR-5a-EFF SEA-PUR-5b-EFF SEA-PUR-5c-EFF SEA-PUR-5d-IN SEA-PUR-5d-EFF SEA-PUR-6-EFF SEA-PUR-6a-IN SEA-PUR-6a-EFF 4/16/2009 4/16/2009 4/16/2009 4/16/2009 4/16/2009 4/16/2009 4/16/2009 4/28/2009 4/28/2009 4/28/2009 1000 1000 1130 1250 1445 1700 1700 1115 1325 1315 1350 194 308 87.7 522 2240 250 <5.0 1600 16 3.7 3.2 ------878 7.4 ND 960 3.3 12.8 11.5 ------1880 25.4 ND 1700 9.5 ND ND ------722 ND ND 1000 ND58.1 192 ------102 175 440 ND 380 ND ND ------81.6 ND ND 90 ND 22.5 ND ------1780 1.9 ND 2800 ND1.9 1.7 ------296 2.1 ND 560 ND 16.4 ND ------3790 2.6 ND 3600 ND ND ND ------12.2 ND ND 19 ND ND ND ------147 ND ND 170 ND ND ND ------383 ND ND 560 ND -------------------- -------------------- Footnotes on Page 4. Table 1 Initial Pilot Testing Results Summary Seaboard Group High Point, North Carolina DRAFT "Privileged and Confidential - Attorney Work Product"Page 4 of 4 Sample ID Date Time 1,4-Dioxane ug/L 1,1,1-Trichloroethane ug/L 1,1-Dichloroethane ug/L 1,1-Dichloroethene ug/LAcetoneug/L Benzene ug/L Chlorobenzene ug/LChloroethaneug/L Cis-1,2-Dichloroethene ug/L Tetrachloroethene ug/L Toluene ug/L Vinyl Chloride ug/L Iron mg/L Manganese mg/L Parameter SEA-PUR-6b-EFF SEA-PUR-6c-EFF SEA-PUR-7-IN SEA-PUR-7-EFF SEA-PUR-7a-EFF SEA-PUR-8-IN SEA-PUR-8-AS SEA-PUR-8-EFF SEA-PUR-9-IN SEA-PUR-9-AS SEA-PUR-9-EFF 4/28/2009 4/28/2009 4/29/2009 4/29/2009 4/29/2009 5/12/2009 5/12/2009 5/12/2009 5/13/2009 5/13/2009 5/13/2009 1545 1705 100 1015 1230 1630 1630 1630 1645 1645 1645 85 100 1900 58 33 2750 --<2.0 3030 --<2.0 4.1 4.1 760 4.5 2.9 1100 5.7 <5.0 1220 8.3 4.7 12 13 1600 13 11 2220 21 12.1 2800 29.6 17.1 ND ND 680 ND ND 1160 <1.0 <5.0 1300 5.3 <1.0340230ND390440<100.0 79 399 90.1 7 367 ND ND 87 ND ND 104 <1.0 <5.0 121 1.4 <1.0 ND ND 1800 ND ND 3290 42.7 <5.0 4180 70.1 <1.0NDND340NDND5923.2 <5.0 672 4.1 1.2 ND ND 3300 ND ND 4680 30.4 <5.0 5640 71.3 <1.0 ND ND 14 ND ND <20.0 <1.0 <5.0 20.8 <1.0 <1.0 ND ND 150 ND ND 201 <1.0 <5.0 233 2.8 <1.0 ND ND 370 ND ND 654 <1.0 <5.0 733 2.3 <1.0 ----------6.5 --0.091 7.1 --0.12 ----------7.4 --ND 7.4 --ND Footnotes: ug/L - micrograms per Liter mg/L - Milligrams per Liter ND - Non Detect Table 2 2014 Full Scale System Testing Results Seaboard Group High Point, North Carolina Page 1 of 2 Sample ID AOP INF AOP 8%AOP 16%AOP 24%PWDR-1 INF AOP 0%AOP INF AOP 0%AOP 8%AOP 8% TiO2 INF HEAT AOP TiO2 - 2Hr Date 9/29/2014 9/29/2014 9/29/2014 9/29/2014 9/29/2014 9/29/2014 10/2/2014 10/2/2014 10/2/2014 10/2/2014 Time 1215 1300 1330 1400 1315 1445 1030 1030 1115 1130 1,4-Dioxane ug/L 3170 D 1170 D 1420 D 1210 D 3260 D 1280 D 2970 D 997 D 62.6 D 480 D 2840 D 572 D 1,1,1-Trichloroethane ug/L ND ND 0.42 J ND 2900 D ND ND ND ND ND 1,1-Dichloroethane ug/L 5.2 5.0 3.8 2.9 2300 D 1.7 0.72 J 0.72 J 0.67 J 0.70 J 1,1-Dichloroethene ug/L ND ND ND ND 1700 D ND ND ND ND ND Acetone ug/L 14 230 220 230 ND 220 6.7 230 370 260 Benzene ug/L 0.41 J ND ND ND 160 D ND ND ND ND ND Chlorobenzene ug/L 51 0.87 J 0.79 J 0.56 J 7100 D 0.44 J 11 ND ND 1.4 Chloroethane ug/L ND ND ND ND 2100 D ND ND ND ND ND Cis-1,2-Dichloroethene ug/L 30 2.4 2.2 1.7 5400 D ND 3.8 ND ND ND Tetrachloroethene ug/L ND ND ND ND ND ND ND ND ND ND Toluene ug/L 0.72 J 0.90 J 0.72 J 0.74 J 330 D 0.62 J ND 0.42 J ND ND Vinyl Chloride ug/L ND ND ND ND 960 D ND ND ND ND ND Parameter Table 2 2014 Full Scale System Testing Results Seaboard Group High Point, North Carolina Page 2 of 2 Sample ID Date Time 1,4-Dioxane ug/L 1,1,1-Trichloroethane ug/L 1,1-Dichloroethane ug/L 1,1-Dichloroethene ug/L Acetone ug/L Benzene ug/L Chlorobenzene ug/L Chloroethane ug/L Cis-1,2-Dichloroethene ug/L Tetrachloroethene ug/L Toluene ug/L Vinyl Chloride ug/L Parameter AOP INF AOP 8-4 AOP 8-3 AOP 16-3 AOP 16-4 AOP 16-4 Ti02 AOP 16-3 Ti02 AOP 8-3 Ti02 AOP 8-4 Ti02 10/9/2014 10/9/2014 10/9/2014 10/9/2014 10/9/2014 10/9/2014 10/9/2014 10/9/2014 10/9/2014 1340 1400 1415 1435 1500 1545 1610 1625 1640 3060 D 124 D 110 D 15.8 ND 417 D 405 D 387 D 423 D ND ND ND ND ND ND ND ND ND 7.6 5.7 2.5 D 3.0 JD ND 1.8 1.6 JD 2.4 JD 2.9 D ND ND ND ND ND ND ND ND ND 8.3 340 390 D 420 D 390 D 400 300 D 270 D 290 D ND ND ND ND ND ND ND ND ND 84 ND ND ND ND 4.9 4.2 D 5.7 D 6.2 D ND ND ND ND ND ND ND ND ND 39 ND ND ND ND 1.6 2.1 D 2.4 JD 3.2 D ND ND ND ND ND ND ND ND ND 1.0 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND Table 3 2014 Full Scale System Reaction Rate Constants Seaboard GroupHigh Point, North Carolina Page 1 of 1 Run H2O2 Concentration(mg/L)pH(SU)Flow Rate (gpm) Power (KW)Power / Flow(kW/Lpm)1,4 Dioxane Influent (ppb)1,4 Dioxane Effluent (ppb)Percent Removal (%) Calculated 1,4 Dioxane Rate Constant (Lpm/kW) AOP 8%27 5 35 240 1.81 1170 63%0.55 AOP 16%54 5 35 240 1.81 1420 55%0.44 AOP 24%81 5 35 240 1.81 1210 62%0.53 AOP 0%0 5 35 240 1.81 1280 60%0.50 AOP 0%0 5 35 240 1.81 997 66%0.60 AOP 8%27 5 35 240 1.81 62.6 98%1.93 AOP 8% - TiO2 27 5 35 240 1.81 481 84%1.00 AOP TIO2 - 2Hr 0 5 35 240 1.81 572 81%0.91 AOP 8-4 27 4 35 240 1.81 124 96%1.77 AOP 8-3 27 3 35 240 1.81 110 96%1.83 AOP 16-3 54 3 35 240 1.81 15.8 99%2.90 AOP 16-4 54 4 35 240 1.81 2 100%4.04 AOP 16-4 TiO2 54 4 35 240 1.81 417 86%1.10 AOP 16-3 TiO2 54 3 35 240 1.81 405 87%1.11 AOP 8-3 TiO2 27 3 35 240 1.81 387 87%1.14 AOP 8-4 TiO2 27 4 35 240 1.81 423 86%1.09 Design June 1, 2009 NA NA 50 145 0.77 3000 3 100%9.00 Design April 28, 2010 NA NA 50 245 1.30 3000 3 100%5.33 Footnotes: Tests perfromed by, designed by and data provided by Jamestown Engineering kW/Lpm - Kilowatts per Liters per Minute gpm - Gallons per Minute ppb - Parts per Billion KW - Kilowatt % - Percent 3060 3060 3060 3060 3170 2970 Table 4 Influent Water Quality Data Seaboard Group II High Point, North Carolina Page 1 of 1 Parameter Method Units Raw Influent 1 Photo-Cat Influent 2 Chemicals of Concern - 1,4-Dioxane 1,4-Dioxane 8260C ug/L 3,300 2,800 Chemicals of Concern - Volatile Organic Compounds 1,1,1-Trichloroethane 8260B ug/L 2,000 2.5 1,1-Dichloroethane 8260B ug/L 1,900 11 1,1-Dichloroethene 8260B ug/L 1,400 0.62 Acetone 8260B ug/L 1,000 38 Benzene 8260B ug/L 110 0.72 Chlorobenzene 8260B ug/L 5,600 73 Chloroethane 8260B ug/L 1,600 2.4 cis-1,2-Dichloroethene 8260B ug/L 5,000 52 Tetrachloroethene 8260B ug/L 17 0.17 Toluene 8260B ug/L 220 1.2 Vinyl chloride 8260B ug/L 1,700 0.67 General Water Quality Parameters Calcium 6010D mg/L 154 203 Magnesium 6010D mg/L 67.5 69.3 Iron 6010D mg/L 7.25 0.58 Manganese 6010D mg/L 5.69 4.22 Potassium 6010D mg/L 9.33 14 Sodium 6010D mg/L 59.5 73.8 Bicarbonate (as CaCO3)4500 mg/L 640 14 pH (SU)4500 mg/L 6.4 2.9 Total Alkalinity as CaCO3 310.2 mg/L 640 14 Hardness 2340B mg/L 660 790 Calcium Hardness 2340B mg/L 390 510 Magnesium Hardness 2340B mg/L 280 280 Bromide 300.0 mg/L 2.1 - 10 3 7.5 - 14 Chloride 300.0 mg/L 190 400 Sulfate as SO4 300 mg/L 9.3 57 Nitrate as N 353.2 mg/L 0.025 0.025 Nitrite as N 354.2 mg/L 0.017 0.017 Nitrate/Nitrite as N 355.2 mg/L 0.041 0.041 Total Dissolved Solids 2540C mg/L 960 1,800 Total Suspended Solids 2540D mg/L 16 2.5 Chemical Oxygen Demand 5220D mg/L 120 99 Total Organic Carbon 5310B mg/L 22 21 Footnotes: 1 Sample ID "TEST 0 INF 80116" - collected on 8-01-2016, influent water made up of groundwater and leachate, estimated to be 80-90% groundwater and 10-20% leachate 2 Sample ID "Test 0 PC INF 80116" - collected after pre-treatment system and directly prior to the Purifics Phot-Cat Unit 3 There was an initial influent sample with a bromide detection of 2.1 mg/L, additional bromide data was collecting indicating that the well PWDR-1 was 6.0 mg/L and the leachate was 10.0 mg/L. This range in bromide concentrations is reflected here. 4 This is the range of bromide concentrations observed from seven Photo-Cat influent bromide samples collected during the test. mg/L - milligrams per Liter Table 5 Photo-Cat Testing Plan Seaboard GroupHigh Point, North Carolina Page 1 of 2 Test ID Run ID Flow Rate (gpm)pH Chemical Additive Chemical Dose (mg/L)TiO2 kW Sample ID 8/1/2016 Test 0 INF NA NA NA NA NA NA Test 0 INF PC 080116 Run A 40 4.2 N NA N 240 Test 0 Run A Eff 080116 Run B 40 4.2 N NA N 120 Test 0 Run B Eff 080116 Run C 30 4.2 N NA N 120 Test 0 Run C Eff 080116 8/2/2016 Test 1 INF NA NA NA NA NA NA Test 1 INF PC 080216 Run A 40 4.2 N NA Y 240 Test 1 Run A Eff 080216 Run B 40 4.2 N NA Y 120 Test 1 Run B Eff 080216 Run C 30 4.2 N NA Y 120 Test 1 Run C Eff 080216 Test 2 INF NA NA NA NA NA NA Test 2 INF PC 080216 Run A 40 4.2 ADX 100 Y 240 Test 2 Run A Eff 080216 Run B 40 4.2 ADX 100 Y 120 Test 2 Run B Eff 080216 Run C 30 4.2 ADX 100 Y 120 Test 2 Run C Eff 080216 Test 3 INF NA NA NA NA NA NA Test 3 INF PC 080216 Run A 30 4.2 ADX 60 Y 120 Test 3 Run A Eff 080216 Run B 40 4.2 ADX 60 Y 120 Test 3 Run B Eff 080216 Run C 40 4.2 ADX 60 Y 240 Test 3 Run C Eff 080216 8/3/2016 Test 4 INF NA NA NA NA NA NA Test 4 INF PC 080316 Run A 40 4.2 ADX 100 N 240 Test 4 Run A Eff 080316 Run B 40 4.2 ADX 100 N 120 Test 4 Run B Eff 080316 Run C 30 4.2 ADX 100 N 120 Test 4 Run C Eff 080316 Test 5 INF NA NA NA NA NA NA Test 5 INF PC 080316 Run A 30 4.2 H2O2 150 N 120 Test 5 Run A Eff 080316 Run B 40 4.2 H2O2 150 N 120 Test 5 Run B Eff 080316 Run C 40 4.2 H2O2 150 N 240 Test 5 Run C Eff 080316 Test 6 INF NA NA NA NA NA NA Test 6 INF PC 080316 Run A 40 4.2 H2O2 200 N 240 Test 6 Run A Eff 080316 Run B 40 4.2 H2O2 200 N 120 Test 6 Run B Eff 080316 Run C 30 4.2 H2O2 200 N 120 Test 6 Run C Eff 080316 Test 7 INF NA NA NA NA NA NA Test 7 INF PC 080316 Run A 30 4.2 H2O2 150 Y (P25)120 Test 7 Run A Eff 080316 Run B 40 4.2 H2O2 150 Y (P25)120 Test 7 Run B Eff 080316 Run C 40 4.2 H2O2 150 Y (P25)240 Test 7 Run C Eff 080316 Footnotes on Page 2. Table 5 Photo-Cat Testing Plan Seaboard GroupHigh Point, North Carolina Page 2 of 2 Test ID Run ID Flow Rate (gpm)pH Chemical Additive Chemical Dose (mg/L)TiO2 kW Sample ID Test 8 INF NA NA NA NA NA NA Test 8 INF PC 080316 Run A 40 4.2 ADX 100 Y (P25)240 Test 8 Run A Eff 080316 Run B 40 4.2 ADX 100 Y (P25)120 Test 8 Run B Eff 080316 Run C 30 4.2 ADX 100 Y (P25)120 Test 8 Run C Eff 080316 Footnotes: 4. 12% by weight premixed ADX solution concentration. 5. 30% H2O2 solution concentration 6. Chemical doses are provided as pure chemical concentration. gpm - gallons per minute mg/L - milligrams per Liter TiO2 - Titanium Dioxide Kw - Kilowatts NA - not applicable H2O2 - Hydrogen Peroxide 1. Influent groundwater concentration shall be approximately 80% extracted groundwater and 20% landfill leachate. Table 6 Advanced Oxidation Process (AOP) Testing Results Seaboard Group High Point, North Carolina Page 1 of 5 Parameter TEST 0 INF 80116 AS EFF 80116 TEST 0 PC INF 80116 TEST 0 RUN A EFF 80116 TEST 0 RUN B EFF 80116 TEST 0 RUN B EFF 80116 Test 1 PC INF 080216 Test 1 Run A EFF 080216 Test 1 Run B EFF 080216 Test 1 Run C EFF 080216 8260C (µg/L) 1,4-Dioxane 3300 2900 2800 1400 1800 1700 3000 1200 1600 1300 8260B (µg/L) 1,1,1-Trichloroethane 2000 5.5 2.5 4.6 5.8 4.2 13 7.5 7.7 5.1 1,1-Dichloroethane 1900 29 11 26 28 23 40 31 28 24 1,1-Dichloroethene 1400 1.2 0.62 0.21 0.21 0.21 4.2 0.21 0.21 0.21 Acetone 1000 15 38 220 150 180 14 240 150 200 Benzene 110 1.7 0.72 1.2 0.87 1.1 2.2 0.92 0.41 0.65 Chlorobenzene 5600 180 73 13 24 17 180 4.3 18 12 Chloroethane 1600 5.4 2.4 6.8 5.8 5.3 12 9.8 7.9 5.5 cis-1,2-Dichloroethene 5000 130 52 18 32 20 160 9.4 26 16 Tetrachloroethene 17 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.17 Toluene 220 2.6 1.2 2.9 1.9 2.8 3.4 1.8 0.96 1.2 Vinyl chloride 1700 1.1 0.67 1.0 0.51 0.81 4.6 0.66 0.32 0.32 6010D (mgL) Iron 7.25 0.146 0.576 ------0.25 ------ Manganese 5.69 2.37 4.22 ------2.41 ------ 300.0 (mg/L) Bromide 2.1 9.6 7.5 ------12 ------ Chloride 190 410 400 ------400 ------ Footnotes on Page 5. Table 6 Advanced Oxidation Process (AOP) Testing Results Seaboard Group High Point, North Carolina Page 2 of 5 Parameter 8260C (µg/L) 1,4-Dioxane 8260B (µg/L) 1,1,1-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethene Acetone Benzene Chlorobenzene Chloroethane cis-1,2-Dichloroethene Tetrachloroethene Toluene Vinyl chloride 6010D (mgL) Iron Manganese 300.0 (mg/L) Bromide Chloride Test 2 PC INF 080216 Test 2 Run A EFF 080216 Test 2 Run B EFF 080216 Test 2 Run C EFF 080216 Test 3 PC INF 080216 Test 3 Run A EFF 080216 Test 3 Run B EFF 080216 Test 3 Run C EFF 080216 2900 1100 1400 1300 2700 1200 1400 720 9.7 6.3 7.2 5.2 5.5 3.8 3.3 1.5 31 26 29 25 24 20 16 10 2.8 0.21 0.21 0.21 1.5 0.21 0.21 0.21 16 240 160 190 14 200 130 230 1.6 0.58 0.40 0.49 1.4 0.47 0.15 0.15 150 4.9 17 11 140 8.4 13 0.91 8.6 8.9 7.8 5.5 5.2 4.3 3.4 3.1 120 8.6 23 15 110 12 17 2.5 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.17 2.5 1.2 0.86 0.97 2.2 1.2 0.64 0.74 2.9 0.81 0.32 0.32 1.5 0.32 0.32 0.32 0.21 ------0.26 ------ 2.24 ------2.28 ------ 14 ------13 ------ 370 ------390 ------ Footnotes on Page 5. Table 6 Advanced Oxidation Process (AOP) Testing Results Seaboard Group High Point, North Carolina Page 3 of 5 Parameter 8260C (µg/L) 1,4-Dioxane 8260B (µg/L) 1,1,1-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethene Acetone Benzene Chlorobenzene Chloroethane cis-1,2-Dichloroethene Tetrachloroethene Toluene Vinyl chloride 6010D (mgL) Iron Manganese 300.0 (mg/L) Bromide Chloride Test 4 PC INF 080316 Test 4 Run A Eff 080316 Test 4 Run B Eff 080316 Test 4 Run C Eff 080316 Test 5 PC INF 080316 Test 5 Run A Eff 080316 Test 5 Run B Eff 080316 Test 5 Run C Eff 080316 2800 1000 1200 920 2600 1.2 1600 940 5.8 5.2 6.5 4.0 2.9 2.2 2.5 1.4 21 22 22 17 12 6.1 10 7.6 1.6 0.21 0.21 0.21 0.78 0.21 0.21 0.21 14 220 180 220 10 340 150 230 0.97 0.62 0.15 0.15 0.64 0.15 0.15 0.15 95 1.6 6.3 2.3 74 0.17 6.1 0.48 5.4 8.3 6.2 4.0 3.0 0.23 2.1 3.2 86 5.1 14 6.8 53 0.15 10 1.9 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.17 1.7 1.3 0.14 0.14 0.96 0.14 0.50 1.0 1.9 0.44 0.32 0.32 0.84 0.32 0.32 0.32 0.18 ------0.22 ------ 2.29 ------2.31 ------ 12 ------12 ------ 380 ------380 ------ Footnotes on Page 5. Table 6 Advanced Oxidation Process (AOP) Testing Results Seaboard Group High Point, North Carolina Page 4 of 5 Parameter 8260C (µg/L) 1,4-Dioxane 8260B (µg/L) 1,1,1-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethene Acetone Benzene Chlorobenzene Chloroethane cis-1,2-Dichloroethene Tetrachloroethene Toluene Vinyl chloride 6010D (mgL) Iron Manganese 300.0 (mg/L) Bromide Chloride Test 6 PC INF 080316 Test 6 Run A Eff 080316 Test 6 Run B Eff 080316 Test 6 Run C Eff 080316 Test 7 PC INF 080316 Test 7 Run A EFF 080316 Test 7 Run B EFF 080316 Test 7 Run C EFF 080316 2500 900 1500 1300 2600 570 1200 670 1.7 0.75 1.2 1.4 1.2 1.0 0.57 0.84 8.3 7.6 8.8 9.7 9.7 7.5 4.8 6.6 0.21 0.21 0.21 0.21 0.21 0.21 0.21 0.21 20 240 140 180 12 210 170 270 0.52 0.15 0.15 0.15 0.64 0.15 0.15 0.15 64 0.57 7.1 4.2 77 2.7 4.1 2.1 0.23 2.4 0.23 1.4 1.5 1.4 0.23 1.8 40 2.2 9.9 7.3 50 3.7 4.5 2.4 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.76 1.0 0.47 0.76 0.87 0.70 0.43 0.59 0.32 0.32 0.32 0.32 0.32 0.32 0.32 0.32 0.20 ------0.20 ------ 2.19 ------2.31 ------ 13 -------------- 360 -------------- Footnotes on Page 5. Table 6 Advanced Oxidation Process (AOP) Testing Results Seaboard Group High Point, North Carolina Page 5 of 5 Parameter 8260C (µg/L) 1,4-Dioxane 8260B (µg/L) 1,1,1-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethene Acetone Benzene Chlorobenzene Chloroethane cis-1,2-Dichloroethene Tetrachloroethene Toluene Vinyl chloride 6010D (mgL) Iron Manganese 300.0 (mg/L) Bromide Chloride Test 8 PC INF 080316 Test 8 Run A EFF 080316 Test 8 Run B EFF 080316 Test 8 Run C EFF 080316 PWDR-1 081616 Leachate 081616 Lime Slurry 081616 Ferric Chloride 081616 2600 580 920 630 -------- 2.2 3.4 4.8 4.6 -------- 12 15 20 18 -------- 0.21 0.21 0.21 0.21 -------- 27 280 220 260 -------- 0.57 0.15 0.15 0.15 -------- 81 2.5 6.9 2.4 -------- 2.2 3.8 4.5 4.4 -------- 48 3.7 11 4.5 -------- 0.17 0.17 0.17 0.17 -------- 0.14 0.14 0.14 0.14 -------- 0.32 0.32 0.32 0.32 -------- 0.18 -------------- 2.17 -------------- --------6.0 10 0.05 U 2.5 U ---------------- Footnotes: µg/L - Micrograms per liter mg/L - Milligrams per liter U - The analyte was analyzed for but not detected to the level shown Table 7 Advanced Oxidation Process (AOP) Reaction Rate Constants Seaboard Group High Point, North Carolina Page 1 of 1 Run Flow Rate1 (gpm) Power (KW) Power / Flow (kW/Lpm) 1,4 Dioxane Influent (ppb) 1,4 Dioxane Effluent (ppb) Percent Removal (%) Calculated 1,4 Dioxane Rate Constant (Lpm/kW) Modeled 1,4 Dioxane Rate Constant (Lpm/kW) Coefficient of Determination (R2) 1,4-dioxane target (ppb) Power Required to meet target at 50 gpm2 (KW) Test 0 Run A 41 240 1.55 1200 57%0.55 Test 0 Run B 41 120 0.77 1800 36%0.57 Test 0 Run C 31 120 1.02 1700 39%0.49 Test 1 Run A 42 240 1.51 1200 60%0.61 Test 1 Run B 43 120 0.74 1600 47%0.85 Test 1 Run C 32 120 0.99 1300 57%0.84 Test 2 Run A 41 240 1.55 1100 62%0.63 Test 2 Run B 40 120 0.79 1400 52%0.92 Test 2 Run C 31 120 1.02 1300 55%0.78 Test 3 Run A 32 120 0.99 1200 56%0.82 Test 3 Run B 42 120 0.76 1400 48%0.87 Test 3 Run C 40 240 1.59 720 73%0.83 Test 4 Run A 39 240 1.63 1000 64%0.63 Test 4 Run B 41 120 0.77 1200 57%1.09 Test 4 Run C 30 120 1.06 920 67%1.05 Test 5 Run A 30 120 1.06 2 100%6.78 Test 5 Run B 39 120 0.81 1600 38%0.60 Test 5 Run C 37 240 1.72 940 64%0.59 Test 6 Run A 39 240 1.63 900 64%0.63 Test 6 Run B 40 120 0.79 1500 40%0.64 Test 6 Run C 33 120 0.96 1300 48%0.68 Test 7 Run A 29 120 1.09 570 78%1.39 Test 7 Run B 39 120 0.81 1200 54%0.95 Test 7 Run C 38 240 1.67 670 74%0.81 Test 8 Run A 41 240 1.55 580 78%0.97 Test 8 Run B 41 120 0.77 920 65%1.34 Test 8 Run C 29 120 1.09 630 76%1.29 Design June 1, 2009 50 145 0.77 3000 3 100%9.00 145 Design April 28, 2010 50 245 1.30 3000 3 100%5.33 245 Footnotes: 1 - Flow rates for respective Test Runs are those at the time of effluent sample collection. 2 - Power requirement calculations utilize modeled first order rate constant. kW/Lpm - Kilowatts per Liters per Minute gpm - Gallons per Minute ppb - Parts per Billion KW - Kilowatt % - Percent *- Modeled Rate constant and R2 values not including Test 5 Run A effluent data. ** - Modeled Rate constant and R2 values including Test 5 Run A effluent data. 2500 2600 2600 1253 3 3 0.63 0.99 2800 3000 2900 2700 2800 2600 0.83 0.99 0.67 0.79 0.59 * / 1.29 **1.0 * / 0.07 ** 0.54 0.99 1.00 3 1306 2030 1549 1929 2167 / 991 2018 1437 3 3 3 23943 3 3 3 0.91 0.64 0.93 NA NA 0.89 0.82 1.02 0.93 FIGURES Clarifier Aeration Tank Bag FiltersSettlingTankAir StripperDual Media Filters Equalizatio n Tank Cartridge Filters (1 micron) Photo-Cat Sample Port #1 Acid Ferric chloride ADX or H2O2 Sodium Hydroxide Sample Port #3Sample Port #2 Sample Port #4 Figure 1. Process Flow Diagram Effluent Tank and Pump Lime Figure 2. Test 0 and Test 1 AOP Performance Decay Curves y = 2806.5e-0.537x R² = 0.9904 0 500 1000 1500 2000 2500 3000 0 0.5 1 1.5 2 1, 4 -Di o x a n e (p p b ) Power / Flow (kW/lpm) Test 0 080116 UV only 1,4-dioxane Expon. (1,4-dioxane) y = 2758.8e-0.631x R² = 0.9149 0 500 1000 1500 2000 2500 3000 3500 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 1 080216 UV + FG TiO2 1,4-dioxane Expon. (1,4-dioxane) Figure 3. Test 2 and Test 3 AOP Performance Decay Curves y = 2661.6e-0.641x R² = 0.9261 0 500 1000 1500 2000 2500 3000 3500 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 2 080216 UV + FG TiO2 + 60mg/L ADX 1,4-dioxane Expon. (1,4-dioxane) y = 2683.9e-0.829x R² = 0.999 0 500 1000 1500 2000 2500 3000 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 3 080216 UV + FG TiO2 + 100mg/L ADX 1,4-dioxane Expon. (1,4-dioxane) Figure 4. Test 4 and Test 6 AOP Performance Decay Curves y = 2369.6e-0.671x R² = 0.7926 0 500 1000 1500 2000 2500 3000 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 4 080316 UV + 100mg/L ADX 1,4-dioxane Expon. (1,4-dioxane) y = 2460.2e-0.631x R² = 0.9968 0 500 1000 1500 2000 2500 3000 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 6 080316 UV + 200mg/L H2O2 1,4-dioxane Expon. (1,4-dioxane) Figure 5. Test 5 AOP Performance Decay Curves Note: Test 5 Run A data point not included for the calculation of the decay curve shown. Note: Test 5 Run A data point included for the calculation of the decay curve shown. y = 2597.4e-0.593x R² = 1 0 500 1000 1500 2000 2500 3000 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 5 080316 UV + 150mg/L H2O2 1,4-dioxane Expon. (1,4-dioxane) y = 947.49e-1.292x R² = 0.0743 0 500 1000 1500 2000 2500 3000 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 5 080316 UV + 150mg/L H2O2 1,4-dioxane Expon. (1,4-dioxane) Figure 6. Test 7 and Test 8 AOP Performance Decay Curves y = 2321.1e-0.892x R² = 0.8151 0 500 1000 1500 2000 2500 3000 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 7 080316 UV + P25 TiO2 + 150mg/L H2O2 1,4-dioxane Expon. (1,4-dioxane) y = 2307.2e-1.018x R² = 0.9274 0 500 1000 1500 2000 2500 3000 0 0.5 1 1.5 2 1, 4 -di o x a n e (p p b ) Power / flow (kW/lpm) Test 8 080316 UV + P25 TiO2 + 100mg/L ADX 1,4-dioxane Expon. (1,4-dioxane) APPENDIX A Curriculum Vitae – John Perella PERSONNEL RESUME 1 JOHN F PERELLA PRINCIPAL ENVIRONMENTAL ENGINEER Mr. Perella has 17 years of experience in the environmental profession. Currently, his primary roles include serving as senior technical engineer and to provide technical support/review for environmental remediation projects. Mr. Perella has been involved in all phases of groundwater and soil remediation projects including remedial action planning and strategic development, treatment process development, detailed engineering design, plant construction, plant operations, and site closures. Mr. Perella has developed expertise in designing, constructing, and operating aboveground treatment systems associated with 1,4-dioxane and in-situ thermal remediation projects. Remediation experience also includes the design and implementation of in-situ remediation techniques including air sparging, soil vapor extraction, in- situ thermal heating, and enhancement of subsurface conditions to promote biological degradation of contaminants (for example, enhanced reductive dechlorination for chlorinated organic compounds). Mr. Perella has been a key presenter for the Arcadis Technical Knowledge and Innovation (TKI) Knowledge Transfer Series for Engineered Treatment Systems presenting specifically on Advance Oxidation Processes (AOPs) and the treatment of 1,4-dioxane. Project Experience In-Situ Thermal Heating and Groundwater Pump and Treat Systems – Chlorinated Solvent Site Tampa, Florida Engineer of Record for chlorinated solvent site, responsible for design, construction management, operations and maintenance (O&M) management, and training of O&M personnel for a 50 gpm surficial, 550 gpm Floridan aquifer pump-and-treat system and 900 scfm / 30 gpm dual phase extraction (DPE) system utilizing 3-phase electric resistive heating (ERH) for the treatment of source areas. ERH system installed in phases in two source areas both with elevated concentrations of chlorinated solvents and 1,4-dioxane. ERH systems utilized approximately 30 electrodes in each source area installed approximately 2 feet from the base of the clay confining layer. The aboveground treatment system utilized air stripping, advanced oxidation process (AOP) utilizing the Calgon Carbon RayOx system with hydrogen peroxide injection, and carbon adsorption to remove contaminates from the water and vapor. EDUCATION BS, Environmental Engineer, North Carolina State University at Raleigh, 1997 YEARS OF EXPERIENCE Total – 17 years With ARCADIS – 10 years PROFESSIONAL REGISTRATIONS Professional Engineer - FL CORE SKILLS 1.Engineered TreatmentSystems2.Remediation Engineering3.Operations and Maintenance4.Site Assessment PROFESSIONAL ASSOCIATIONS National Society of Professional Engineers (NSPE) CERTIFICATIONS OSHA 40 hour HAZWOPER OSHA 8 hour Site Supervisor PERSONNEL RESUME - John F Perella Project Experience Continued 2 Groundwater Pump and Treat System – Chlorinated Solvent Site Bradenton, Florida Senior Process Engineer for chlorinated solvent site, responsible for design, construction oversight and operation, maintenance and management for the Interim Remedial Action (IRA) system. Groundwater contaminated with chlorinated solvents and 1,4-dioxane. Extraction system consists of 10 groundwater extraction wells producing 30 gpm. Treatment system consists of iron removal pretreatment, an advance oxidation process (AOP) utilizing the Purifics ES Photo-Cat and granular activated carbon (GAC) for effluent polishing. Treated effluent discharged to the local POTW. Responsible for Remedial Action Plan (RAP) and preliminary full scale system design, consisting of over 70 extraction wells producing approximately 200 gpm. Full scale treatment system consists of iron and aluminium removal pretreatment, media and ultra-filtration, AOP treatment, GAC polishing, reverse osmosis for a portion of the treated effluent to be discharged to offsite infiltration galleries, onsite injection of treated effluent and discharge of effluent to offsite POTW. Water Treatment System for Thermal Project – Chlorinated Solvent Site St. Petersburg, Florida Senior Process Engineer for the design and implementation of an 80 gallon per minute groundwater treatment system to support an in-situ thermal desorption remediation project to reduce chlorinated solvents and 1,4-dioxane. Responsibilities included coordination of overall project activities including local permitting and general contractor support of the project and managing the water system design team that included process, electrical, mechanical, and structural aspects. The system incorporates a synthetic media system as the primary water treatment method with other processes designed to reduce iron. The system has been operating successfully since August 2012 and is operating as designed. Interim Chlorinated Plume and 1,4-Dioxane System– Chlorinated Solvent Site St. Petersburg, Florida Senior Process Engineer for an interim water treatment system that included advanced oxidation process as the primary treatment technique to remove chlorinated compounds and 1,4-dioxane. The system utilized HiPOx APT AOP system for treatment of 1,4-dioxane. The system also included various process steps to remove iron. The 32 gallon per minute treatment system has been operating successfully for over four years. Advanced Oxidation Pilot Test– Chlorinated Solvent Site St. Petersburg, Florida Senior Process Engineer for the design and implementation of a 32 gallon per minute pilot groundwater extraction and treatment system. The pilot system includes iron removal processes and a side-by-side evaluation of two advanced oxidation process units. The site is impacted with chlorinated volatile organic compounds and 1,4-dioxane. The system has been operating consistently with > 90 percent uptime and has achieved the treatment goals. Groundwater Pump and Treat System – Chlorinated Solvent Site Sarasota, Florida Senior Process Engineer for chlorinated solvent site, responsible for the design, construction oversight and groundwater treatment system operation and maintenance management for the groundwater extraction and treatment system. Groundwater contaminated with chlorinated solvents, 1,4-dioxane and arsenic. System utilizes a 15-foot-deep and 140-foot-long groundwater extraction trench designed to limit the movement of contaminated groundwater PERSONNEL RESUME - John F Perella Project Experience Continued 3 offsite. The construction of the extraction trench utilized a single pass horizontal trencher. The horizontal trencher eliminated the need for any dewatering during the construction of the extraction trench. The treatment system consists of an advanced oxidation process utilizing the Calgon Ray/Ox system with hydrogen peroxide injection, air stripping, and activated alumina adsorption. System flow rate is approximately 40 gpm and treated groundwater is discharged onsite utilizing approximately 600 feet of infiltration gallery, during high water events excess water is discharge to NPDES permitted surface water outfall. Groundwater Pump and Treat and Air Sparge and Soil Vapor Extraction Systems – Chlorinated Solvent Site Orlando, Florida Engineer of Record for chlorinated solvent site, responsible for the design, construction oversight and groundwater treatment system operation and maintenance management for the groundwater extraction and treatment system and air sparge and soil vapor extraction (AS/SVE) system. Groundwater contaminated with chlorinated solvents. Groundwater extraction system consists of 7 extraction wells producing approximately 30 gpm. Treatment of groundwater consists of air stripping and pH adjustment with discharge of treated water to the POTW. AS/SVE system consists of 40 AS wells and 5 SVE trenches. AS/SVE system is designed as a barrier wall system to protect surface water from groundwater daylighting. Groundwater Pump and Treat Systems – Chlorinated Solvent Site Jacksonville, Florida Engineer of Record for chlorinated solvent site, responsible for the design, construction oversight and groundwater treatment system operation and maintenance management for the groundwater extraction and treatment system. Groundwater contaminated with chlorinated solvents. Groundwater extraction system consists of 6 extraction wells producing approximately 30 gpm. Treatment of groundwater consists of air stripping utilizing a turbo stripper fluidized bed air stripper with discharge of treated water to the POTW. Groundwater Pump and Treat Systems – Explosives Site Milan, Tennessee Senior Process Engineer for the Milan Army Ammunitions Plant, responsible for the operations and maintenance management of two groundwater pump and treat systems and design and implementation of extraction and conveyance systems expansion. Both treatment systems operate at approximately 1200 gpm each. Responsible for the design and implementation of 6 new extraction wells and approximately 5-miles of HDPE pipeline. Average flow rate for extraction wells is approximately 200 gpm each. Treatment process consists of iron and manganese removal pretreatment by pH adjustment and sand filtration and granular activated carbon (GAC) for the removal of explosives. Treated effluent is discharged to surface water via NPDES permit. In-Situ Thermal Heating – Chlorinated Solvent Site Orlando, Florida Engineer of Record for chlorinated solvent site, responsible for design, construction management, operations and maintenance (O&M) management, and training of O&M personnel for a 1200 scfm / 30 gpm multi-phase extraction (MPE) system utilizing 3-phase electric resistive heating (ERH) for the treatment of source area. ERH system utilized 93 electrodes and 44 extraction wells in the source area. The aboveground treatment system utilized air stripping and Liquid Phase granular activated carbon (GAC) for treatment of liquids, while vapors were treated through a regenerative Vapor Phase GAC system. PERSONNEL RESUME - John F Perella Project Experience Continued 4 Groundwater Pump and Treat System – Chloride Site Odessa, Texas Senior Process Engineer for chloride site, responsible for design for the modification to an existing groundwater treatment system. Modifications include the installation of additional extraction and injection wells to cover an area greater than 4 miles. Treatment system includes electro-dialysis reversal (EDR) and reverse osmosis for the removal of chlorides. Treated water will be returned to the aquifer as to limit impacts of remediation on the aquifer. Brine concentrate is discharged to a deep aquifer injection well. Total system flow rate approximately 300 gpm. Free Product Recovery – Petroleum Terminal Nassau, Bahamas Project Engineer for petroleum terminal, responsible for design, construction oversight and groundwater treatment system operation and maintenance management for a free product recovery system. Recovery system consists of 5 recovery wells located in a petroleum storage tank farm. Recovered free product is pumped to an onsite holding tank and removed from the site by an asphalt manufacturer at no cost to the client. Approximately 20,000 gallons of free product has been removed since the installation of the recovery system. Petroleum Impacted Soils Excavation – Petroleum Site Ocklawaha, Florida Project Engineer for petroleum site, conducted site assessment and remediation activities under the Florida Department of Environmental Protection (FDEP) petroleum preapproval program. Responsibilities included design and construction oversight of a 5,300-ton petroleum-contaminated soil excavation. Groundwater Pump and Treat, AS/SVE, Ex-Situ Soil Remediation and Excavation – Solvent Site Lakeland, Florida Project Engineer for solvent site, responsible for groundwater and soil remediation system operations and maintenance management for a 20 gpm surficial aquifer pump and treat system as well as an AS/SVE system with 300 scfm and 500 scfm flow rates, respectively. Responsible for design and construction oversight of a 4,000 cubic yard ex-situ biopile construction project and design and construction oversight of a 5,000 cubic yard contaminated soil excavation. The excavation required the installation of approximately 200 feet of sheet piling. Dewatering requirement for the excavation was approximately 30 gpm of contaminated groundwater, which was treated with the onsite treatment system and discharged to the existing infiltration galleries. Low Temperature Thermal Desorption – Pesticide Site Tampa, Florida Project Engineer for pesticide site, responsible for design and implementation of a cooling water pumping system during operations of a low-temperature thermal desorption unit for soil remediation. Olga Water Treatment Plant (WTP) ImprovementsFort Myers, Florida Project Engineer, evaluated Miex® DOC resin, ferric sulfate, and aluminium sulfate for removal of dissolved organic carbon (DOC) and color in surface water utilized by the WTP. Determined theoretical softening requirements utilizing both lime and soda ash as well as evaluating the possible effects of organics coagulation prior to softening. Authored applicable portions of the basis of design report. PERSONNEL RESUME - John F Perella Project Experience Continued 5 Boca Ceiga Pump Station Improvements St. Petersburg, Florida Project Engineer, designed pump station upgrades for wastewater collection system in which force main pressures were to increase, in some cases by 100 percent. Sized pumps, designed piping and valve configurations, and developed construction plans for nine county-owned and two privately owned pump stations. Design flow rates for the pump stations ranged from 125 gpm to 1,000 gpm. Selected Publications Bourke M., T.L. Champlin, J. Perella, C. Topham, and J. Blattman. 2002. “Use of a Magnetic Ion Exchange Resin to Improve DBP Precursor Removal and Reduce Coagulant Usage at Lee County’s Olga WTP.” In Proceedings to the 2002 Florida Section of the American Water Works Association Annual Conference. Tarpon Springs, Florida. APPENDIX B Field Data APPENDIX C Laboratory Analytical Reports