Long Term Response Action Audit Report No. 16

Long Term Response Action

Audit Report No. 16

October 16, 2007 through April 22, 2008

Ace Services Site

Colby, Kansas

Prepared forUSEPA Region VII

June 3, 2008

Prepared by.Black and Veatch Special Projects Corp.

EPA Contract Number EP-S7-05-06EPA Task Order No. 0075

BVSPC Project Number 44720

30018001

11111Superfund

Table of Contents

1.0 Introduction ....:. ;...... 1-1

2.0 Observations on General System Operation 2-1

2.1 Well Field '..2-1

2.2 Treatment Plant 2-3

2.3 Resin Quality Issues 2-6

3.0 Sampling and Record Keeping 3-1

4.0 Evaluation of System Performance 4-1

5.0 Action Summary : 5-1

Tables

Table 4-1 Selected Flow and Chromium Concentration Data

Table 4-2 Performance Data Summary

Ace Services Site TC-1 044720.01.49LTRA Audit Report No. 16

1.0 Introduction

As part of Task Order 0075, United States Environmental Protection Agency

(EPA) Contract no. EP-S7-05-06, Black & Veatch Special Projects Corp. (BVSPC) is to

monitor key plant operations and evaluate the plant operator's conformance to specified

requirements for system operation at the Ace Services Site, Ground Water Treatment

System (GWTS) in Colby, Kansas. These evaluations or audits previously occurred on a

quarterly basis, but have been reduced to a semi-annual basis beginning with this audit.

The audits include a site visit to observe the City of Colby operators and obtain key plant

operating data. This report summarizes the findings from the 16th performance audit

conducted April 21 to April 22, 2008. This report covers the period from October 16,

2007, through April 22, 2008. The results from previous audits are summarized in the

following reports:

• Lons Term Response Action Audit Report No. 1, dated November 10, 2003.

• Long Term Response Action Audit Report No. 2, dated March 19, 2004.

• Lons Term Response Action Audit Report No. 3, dated July 2, 2004.

• Long Term Response Action Audit Report No. 4, dated November 19, 2004.

• Low Term Response Action Audit Report No. 5, dated April 22, 2005.

• Lons Term Response Action Audit Report No. 6, dated June 24, 2005.

• Lons Term Response Action Audit Report No. 7, dated August 26, 2005.


• Long Term Response Action Audit Report No. 9, dated March 3, 2006.

• Lons Term Response Action Audit Report No. 10, dated May 24, 2006.

• Long Term Response Action Audit Report No. 11, dated July 28, 2006.


• Lons Term Response Action Audit Report No. 13, dated February 15, 2007.

• Long Term Response Action Audit Report No. 14, dated May 10, 2007

• Lons Term Response Action Audit Report No. 15, dated November 30, 2007.

Ace Services Site 1-1 044720.01.49LIRA Audit Report No. 16

2.0 Observations on General System Operation

The Ace Services GWTS performance audit was performed onsite April 21

through April 22, 2008. BVSPC representative Curt McCoy performed the audit

including review of operation records, GWTS functions, and observation of the City

operators throughout the regular staff hours.

The City staffing of the plant was unchanged from the last several audits. Mr. Jim

Helus with the City of Colby Public Works Department is assigned as the full time

operator for the treatment system. Mr. Helus generally arrives at the treatment plant at

8:00 A.M. and spends the majority of the day tending to the plant and well field systems.

Mr. Helus is occasionally supplemented by other city staff on an as needed basis. A

second operator is at the plant on Wednesdays to assist with the extra work associated

with collecting, preparing, and shipping the weekly sample splits for off-site laboratory

analysis. Mr. Helus is responsible for system operation Monday through Friday.

Weekend staffing is provided by various other members of the Colby Public Works

Department; however, Mr. Helus remains on-call for plant alarms 7 days a week. Mr.

Helus responds to all off-hours alarms in a timely manner.

The assignment of a single primary operator continues to result in good follow-

through on maintenance, supplies inventory, record keeping, and problem resolution.

The plant, office, storage, and lab areas were clean and very well organized. The

operating staff continues to express positive attitudes regarding the facility and their jobs.

Mr. Helus remains particularly well engaged in his job as plant operator and his skill

levels regarding the more complex plant subsystems continues to improve. Mr. Helus, as

well as other plant staff, routinely call BVSPC for advice and assistance as needed.

2.1 Well Field

A reduced scheme sampling round including the extraction wells, monitoring

wells, and residential wells was conducted from April 21 through April 23, 2008. A

complete analysis of the groundwater extraction system performance and chromium

plume status will be conducted on an annual basis only. An abbreviated evaluation of the

April 2008 sampling round results is presented in a technical memorandum. The

Ace Services Site 2 - 1 " 044720.01.49LIRA Audit Report No. 16

complete analysis will be presented in the Long Term Response Action, Cleanup Status

Report Number JO which will be prepared after the semi-annual sampling round

conducted in October 2008.

A granular activated carbon (GAC) treatment system installed by Kansas

Department of Health and Environment (KDHE) to remove the 1,2-dichloroethane (1,2-

DCA) and other volatile organic compounds (VOCs) from the well water prior to

entering the GWTS was started on August 24, 2004.

As the remediation of the chromium plume continues, various extraction wells are

taken offline to extend resin life and reduce operating cost. Individual well flows at the

end of the 16th audit period were as follows:

Original CurrentWell Design flow Actual flow

EX-li 35 gpm 70 gpmEX-ld 40 gpm 0 gpm (well off to prevent migration)EX-2s 25 gpm 0 gpm (well off-low water)EX-2i 100 gpm 100 gpmEX-2d 100 gpm 0 gpm (well off to prevent migration)EX-3s 25 gpm 0 gpmEX-3i 50 gpm 50 gpmEX-3d 75 gpm 0 gpm (off for low chromium)EX-4s 25 gpm 0 gpm (well off-low water)EX-4i/d 100 gpm 100 gpmEX-5s 25 gpm 0 gpm (off for low chromium)EX-5i/d 100 gpm 125 gpmPWS-8 125 gpm 125 gpm

Total flow from the wells as of April 22, 2007, was 570 gpm. This rate is slightly

elevated from the rate of 545 gpm at the end of the 15th audit period. BVSPC

recommended in the Long Term Response Action, Cleanup Status Report Number 9,

dated November 30, 2007, that the pumping rate at EX-5i/d be increased to 125 gpm to

capture a recently detected slug of contamination in the area of that extraction well. The

new pumping rate was initiated on December 14, 2007, after approved by the EPA in a

conference call on December 10, 2007.


2.2 Treatment Plant

A review of sampling records shows that at the beginning of the 16th audit period,

the hexavalent chromium concentration in the composite groundwater entering the

Groundwater Treatment Plant (GWTP) was below the analysis method limit of detection

of 15 ug/L, due to a recent change of carbon at the GAC plant. Once the carbon reached

a point of equilibrium the influent reached a maximum level of 136 ug/L chromium. The

influent chromium level maintained a fairly constant level and was found to be 106 ug/L

at the end of the 16th audit period.

Problems and anomalies noted regarding operation of the well field during the

16th audit period are described below:

1. Loss of power to extraction well 4i/d overnight on December 9, 2007,

caused the influent tank to drain down to 12% by the time the plant

operator arrived in the morning. Power was reestablished to the well and

the plant was turned on and returned to equilibrium within 2 hours.

2. Power was lost again to extraction well nests 4 and 5 on December 13,

2007. Wells 4i/d and 5i/d were started once again within a couple of

hours and the plant was returned to equilibrium. The power loss was due

to problems with the service provider and not due to communication errors

within the plant system.

3. The effluent tank ultrasonic level transmitter froze for the first and only

time during the winter on the evening of January 21, 2008, causing theplant to shut down. By 10:45 A.M. the following morning, the transmitter

had thawed and the plant was started.

4. Power was lost to extraction well nests 1, 2, 3, and at PWS-8 on February

1, 2008. This power loss caused the GWTP to shut down briefly, but was

up and running again in a couple of hours.

5. Power was lost to all wells on the evening of March 13, 2008, which

caused the plant to shut down. The plant was restarted and running again

within an hour.

Ace Services Site 2-3 044720.01.49LTRA Audit Report No. 16

The GWTP ran essentially continuously throughout the 16th audit period (except

during the brief periods of power loss with the well field described above). These power

failures were due to losses with the service provider during inclement winter weather.

Only once during the winter period did a tank level transmitter freeze overnight, but was

thawed naturally and back in operation the following morning. The GWTS was operated

at a nominal capacity of about 545 gpm through December 14, 2007, when the BVSPC

recommendation of increasing flow at EX-5i/d was implemented. Table 4-1 provides a

day-by-day accounting of total plant flow throughout the 16th audit period.

As noted in previous audit reports, the GAC system does not appear to have had

any significant impact on the GWTS with the exception of occasional clogging of the bag

filters with carbon fines (particularly when the GAC beds are backwashed or a new one is

brought on line) and elimination of the hexavalent chromium loading to the GWTP for

several days when a fresh carbon bed is brought on-line. Two fresh carbon beds were

brought on-line during the 16th audit period.

There were no major issues noted during the 16th audit period involving the ion

exchange resin. The final resolution of the water hammer problem described in the 10th

audit report continued to perform throughout the 16th audit period. No water hammer

was experienced.

Overall, the GWTP treated approximately 154.902 million gallons during the 16th

audit period averaging about 819,587 gallons per day (gpd).

Milestones for resin management activities were as follows:

TRAIN A:

October 16, 2007 - Beginning of 16th audit period. Bed Al is lead, A2

is lag (Train A has been in this configuration since September 12,

2007).

January 3, 2008 - Beds advanced to put A2 in lead and A3 in lag.

January 22, 2008 -New resin placed in bed Al and backwashed.

April 22, 2008 - End of 16th audit period. Bed A2 is in lead and A3 is

lag. Bed Al has fresh resin and is ready for operation.


TRAIN B;

- October 16, 2008 - Beginning of 16th audit period. Bed Bl is lead, B2

is lag (Train B has been in this configuration since September 12,

2007).

- January 3, 2008 - Beds advanced to put B2 in lead and B3 in lag.

- January 23, 2008 - New resin placed in bed Bl and backwashed.

- April 3, 2008 - Resin strainers cleaned in Beds B2 & B3.

- April 22, 2008 - End of 16th audit period. Bed B2 is in lead and B3 is

lag. Bed Bl has fresh resin and is ready for operation.

The status of the GWTS at the end of the 16th audit period included operation of

treatment trains with Beds A2 and B2 in lead service and Beds A3 and B3 in lag service.

Stand-by Beds Al and Bl had fresh resin. As can be seen in Table 4-1, the trains were

being operated at the same rates near the beginning of the 16th audit period. Train A was

being operated at about 400 gpm with Train B running about 400 gpm. Problems and

anomalies regarding plant operation that were noted or corrected during the 16th audit

period are described below:

1. Plant communication failures and solutions with the well field were

discussed in the previous well field section of the audit report.

2. October 29, 2007, the observation was made that EX-li was showing "0"

feet of water within the well, yet the well was continuing to pump. This

indicated that the level probe had failed in the well, therefore a new level

probe was ordered. The new probe was installed by Woofter Pump &

Well on November 26, 2007. The water level is now reading correctly at

the plant operating computer.

Overall no significant issues arose and were needed to be resolved during the 16th

audit period. Operator follow-through to address, diagnose, and solve plant issues was

excellent during the 16th audit period and should be commended.


2.3 Resin Quality Issues

Section 2.3 of the 7th through 10th audit reports summarized significant water

quality incidents related to poor resin quality as well as the ultimate resolution for these

problems. Resin performance observed in subsequent audit periods have verified that all

of the significant problems have been resolved and resin performance from the current

supplier has considerably improved.


3.0 Sampling and Record Keeping

As part of the audit, the in-plant records kept by the City operators were reviewed

for completeness and conformity to requirements. The sample collection and analysis

methods are also observed. During the review, emphasis was placed on water flow and

chromium concentration data that are critical to evaluation of treatment system

performance. The daily records were well organized in notebooks kept at the plant. The

daily records were organized by month and date and were complete and easy to access.

The City operators have continued to enter the flow meter totalizer readings and sample

analysis results into Excel® spreadsheets to facilitate trend tracking and quick data

retrieval. The sample record sheets include free chlorine results when the discharge to

the city water system is active as well as total chromium results of the morning influent

sample.

The operators have continued to fill out a GAC system log sheet each day. This

log sheet records critical flow and pressure data for the KDHE GAC system.

The City operating staff has done an excellent job with the sampling and record

keeping requirements during the 16th audit period. Any significant irregularities that

were noted in the audit and subsequent review of records are described below:

1. Incomplete records regarding system problems: No issues were noted

with the plant operator's recordkeeping. BVSPC will continue to take

the initiative to gather all data regarding major incidents and generate

simple technical memorandums for the record to assist in future

problem solutions.

2. Incomplete records at GWTP: A review during the 16th audit indicated

that all required records are now on-file at the GWTP.

There have been no significant changes regarding plant sampling and record

keeping during the 16th audit period. In an effort to reduce the quantity of plant records

being copied for BVSPC records in hardcopy format, the plant operator was asked to

cease hard copy preparation of the daily records and laboratory analysis. The plant logs

will continue to be maintained in their current format. In the future, documents are to be


scanned using the plant copier and placed into a daily electronic file. Lab records are

also to be scanned when received and placed into the daily electronic files. The daily

electronic files are to be forwarded to BVSPC on a monthly basis in an electronic format

for inclusion into the BVSPC filing system.


4.0 Evaluation of System Performance

The GAC system constructed by KDHE was started on August 24, 2004 (during

the fourth audit period). Data was closely monitored during the 16th audit period to

determine if there were any significant impacts on the GWTS as a result of the GAC

system being on line. The only day-to-day impacts noted were the occasional loading of

carbon fines on the bag filters and the additional head pressure required of the extraction

pumps to push through the GAC beds. Also, when a new GAC bed is first placed on line

it will remove the hexavalent chromium for several days. There were two new GAC beds

brought on line during the 16' audit period.

The ability to capture and control the chromium plume in the groundwater is

periodically assessed via sampling and groundwater elevation measurement. These data

are analyzed and the findings summarized in semi-annual Cleanup Status Reports. The

most recent report (Cleanup Status Technical Memorandum, dated June 4, 2008)

indicates that the extraction wells are providing good plume containment and capture.

Selected flow and sampling data from October 16, 2007, through April 22, 2008,

are presented in Table 4-1. Table 4-1 also shows the amount of hexavalent chromium

removed by the treatment system. As shown in Table 4-1, the concentration of

hexavalent chromium in the raw water entering the treatment system during the 16th audit

period began at about 59 ug/L in late October 2007, and fluctuated somewhat during the

16th audit period due to changes in well pumping schemes, ending at about 106 ug/L in

mid-April 2008.

The data show that the system treated 154.9 million gallons from October 16,

2007, through April 22, 2008. A total of 45.39 kilograms (kg) (100.06 pounds) of

chromium were removed during this period. Two beds of ion exchange resin (Beds Al

and Bl) were exhausted during this period as shown in Table 4-1.

The relative performance data from the previous periods are shown in Table 4-2

along with the data for the exhausted Beds from this audit period. Please note that this

table does not show the total water treated for the period, only the total gallons for the

exhausted beds are shown for the audit period. Data from the early periods are shown as

an average per 600 cubic foot bed of resin.


The chromium holding capacity of the resin is expected to diminish with

diminishing influent hexavalent chromium concentrations due to the lower equilibrium.

More gallons of water are treated with the same 600 cubic feet of resin but at diminishing

resin holding capacity. As the hexavalent chromium concentration drops, a point is

eventually reached where the gallons treated by a given amount of resin will no longer

increase. This is due to the presence of other anions in the influent water that take up

resin exchange capacity. Previous performance audits analyzed the relationship between

the gallons of water treated by a vessel of resin and the influent chromium concentration.

Current observations indicate that once the average chromium concentration drops below

100 u.g/L, each 600 cubic foot treatment vessel may have reached its maximum

chromium holding capacity.

Increases (10%) over the 16th audit period have occurred in the resin prices due

to transportation costs. The total resin cost including transportation and disposal for the

16th audit period was 0.163 cents per gallon, which is up from the 15th period total of

0.144 cents per gallon. This is also up from 0.156 cents per gallon from the 13th and 14th

audit period, and comparable to 0.164 cents per gallon from the 11th and 12lh audit

periods. This increase in resin price no longer enables one to see reduced costs as the

resin approaches peak ion exchange capacity. Should resin prices stabilize at the current

costs, the assumption can be made that future treatment costs for resin will be

approximately 0.165 cents per gallon of water treated. BVSPC does not have access to

sufficient data to determine the total cost per gallon to treat the extracted groundwater

including labor and plant utilities.


Table 4-1Selected Flow and Chromium Concentration Data

Ace Services Site

Date

16-Oct-07171819202122232425262728293031

Hexavalent ChromiumAt sample location SC-1Hach unit

(ug/L)

Totals for Month

ContinentalLabs (ug/L)

00000000

5959595959595994

TRAIN AGallonsTreatedX1000

420348433372427411395409364399409390397415383372

6344

ChromiumRemoved

(kg)0.0000.0000.0000.0000.0000.0000.0000.0000.0810.0890.0910.0870.0890.0930.0860.1320.748

TRAIN BGallonsTreatedx 1000

420348433372427412395406364399409391398416383373

6346

ChromiumRemoved

(kg)0.0000.0000.0000.0000.0000.0000.0000.0000.0810.0890.0910.0870.0890.0930.0860.1330.749

RemarksGAC plant changed vessels 10-01-07

Beds A1 and B1 lead

Ace Services SiteLIRA Audit Report No. 16 4-3 044720.01.49


Ace Services Site

Date

1-Nov-0723456789101112131415161718192021222324252627282930


(ug/L)

Totals for Month


949494949494

122122122122122122122128128128128128128117117117117117117117117116116116


431370409421381386397403399431396377402404397405417397392396404394388399402404389375403417

11166

ChromiumRemoved

(kg)0.1530.1320.1460.1500.1360.1370.1830.1860.1840.1990.1830.1740.1860.1960.1920.1960.2020.1920.1900.1750.1790.1750.1720.1770.1780.1790.1720.1650.1770.1834.891

TRAIN BGallonsTreatedx lOOO

431370407419381385396403400432394377403402397406417397392396404393387398401403389375402416

11155

ChromiumRemoved

(kg)0.1530.132

. 0.1450.1490.1360.1370.1830.1860.1850.2000.1820.1740.1860.1950.1920.1970.2020.1920.1900.1750.1790.1740.1710.1760.1780.1790.1720.1650.1770.1834.886

Remarks

GAC plant changed vessels 1 1-28-07



Ace Services Site

Date

1-Dec-072345678910111213141516171819202122232425262728293031


(ug/L)

Totals for Month


116116116116111111111111111111111136136136136136136136106106106106106106106868686868686

TRAIN AGallonsTreatedx lOOO

402409447358406445392437438385438440439449494473460463453559546527572582476516482575532467478

14540

ChromiumRemoved

(kg)0.1770.1800.1960.1570.1710.1870.1650.1840.1840.1620.1840.2270.2260.2310.2540.2440.2370.2380.1820.2240.2190.2120.2300.2340.1910.1680.1570.1870.1730.1520.1566.088


401408446357406385369385368328363359358342379353346348339330307269248257358382292301289350359

10782

ChromiumRemoved

(kg)0.1760.1790.1960.1570.1710.1620.1550.1620.1550.1380.1530.1850.1840.1760.1950.1820.1780.1790.1360.1320.1230.1080.1000.1030.1440.1240.0950.0980.0940.1140.1174.571

Remarks

Brief loss of power in wellfield - 1.5 hrs.

Brief loss of power in wellfield - 1 .5 hrs.



Ace Services Site

Date

1-Jan-082345678910111213141516171819202122232425262728293031


(ug/L)

Totals for Month


86101101101101101101101

00000000000000

494949494949495656

TRAIN AGallonsTreatedx lOOO

588530435386430424417416413418420445417407411398456409422410395229397439431413407434421406396

13020

ChromiumRemoved

(kg)0.1920.2030.1660.1480.1640.1620.1590.1590.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0740.0810.0800.0770.0760.0810.0780.0860.0841.509


329271412385429423416416413418420445416407412398457408422410396228336435432414408434419406395

12410

ChromiumRemoved

(kg)0.1070.1040.1580.1470.1640.1620.1590.1590.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0620.0810.0800.0770.0760.0810.0780.0860.0841.303

Remarks

Beds A2 and B2 lead

GAC plant changed vessels 1-09-08

Effluent tank level meter frozen 8 PM.Effluent tank level meter thawed 1 1 AM.

Ace Services SiteLTRA Audit Report No. 16 4-6 044720.01.49


Ace Services Site

Date

1-Feb-08234567891011121314151617181920212223242526272829


(ug/L)

Totals for Month


5656565656868686868686865151515151515196969696969696939393


452410420381369362361362389389326346

.347381358359353375354342383371365363349307282388292

10536

ChromiumRemoved

(kg)0.0960.0870.0890.0810.0780.1180.1180.1180.1270.1270.1060.1130.0670.0740.0690.0690.0680.0720.0680.1240.1390.1350.1330.1320.1270.1120.0990.1370.-1032.408

TRAIN BGallonsTreatedX1000

452412419413456479478481516514436455460506475476469501469453509493485484464521505516538

13835

ChromiumRemoved

(kg)0.0960.0870.0890.0880.0970.1560.1560.1570.1680.1670.1420.1480.0890.0980.0920.0920.0910.0970.0910.1650.1850.1790.1760.1760.1690.1890.1780.1820.1893.080

RemarksBrief loss of power in wellfield - 2 hrs.



Ace Services Site

Date

1-Mar-082345678910111213141516171819202122232425262728293030


(ug/L)

Totals for Month


9393939380808080808080

108108108108108108108111111111111111111111110110110110110110

TRAIN AGallonsTreatedxlOOO

313362

. 362293293320369331370366336382423420424423397420403439427421425437373424450426404428445

12106

ChromiumRemoved

(kg)0.1100.1270.1270.1030.0890.0970.1120.1000.1120.1110.1020.1560.1730.1720.1730.1730.1620.1720.1690.1850.1790.1770.1790.1840.1570.1770.1870.1770.1680.1780.1853.445

TRAIN BGallonsTreatedxlOOO

549477482494546555491438491487448508430420424423398420403440427421425438372425449427404427445

13984

ChromiumRemoved

(kg)0.1930.1680.1700.1740.1650.1680.1490.1330.1490.1480.1360.2080.1760.1720.1730.1730.1630.1720.1690.1850.1790.1770.1790.1840.1560.1770.1870.1780.1680.1780.1854.062

Remarks

Brief loss of power in wellfield - 1 hr.

Ace Services SiteLTRA Audit Report No 16 4-8 044720.01.49


Ace Services Site

Date

1-Apr-082345678910111213141516171819202122


(ug/L)

Totals for Month


110112112112112112112112106106106106106106106106106106106106106106

TRAIN AGallonsTreatedxlOOO

423400444461433423431418406447475471493495487465490518507491428403

10009

ChromiumRemoved

(kg)0.1760.1700.1880.1960.1840.1790.1830.1770.1630.1790.1910.1890.1980.1990.1950.1870.1970.2080.2040.1970.1720.1624.093

TRAIN BGallonsTreatedxlOOO

423401444381432422430416405443377372364363358341360380372361423401

8669

ChromiumRemoved

(kg)

0.1760.1700.1880.1620.1830.1790.1820.1760.1630.1780.1510.1490.1460.1460.1440.1370.1450.1530.1490.1450.1700.1613.553

Remarks

End of 16th Audit period


Table 4-2Performance Data Summary

Ace Services Site

Exhausted Resin Bed

A1

B1

A2

B2

A3

B3

Total Flow

Chromium Removed

Perform. Test

20.50 MG

121.40gr/cf

20.50 MG

121.40gr/cf

-

-

-

-

-

-

-

-

41.00MG

145.68 Kg

Audit PeriodNo. 1

-

-

-

-

28.49 MG"

93.60 gr/cf

25.76 MG

93.60 gr/cf.

-

-

-

-

54.25 MG

112.32 Kg

Audit PeriodNo. 2

34.70 MG

49.80 gr/cf

-

-

-

-

-

-

-

-

30.70 MG

52.55 gr/cf

65.40 MG

61.41 Kg

Audit PeriodNo. 3

-

-

31.10MG

41. 05 gr/cf

33.42 MG

42.68 gr/cf

-

-

-

-

-

-

64.52 MG

50.24 Kg

Audit PeriodNo. 4

-

-

-

-

-.

-

31.10MG

34.28 gr/cf

31.10MG

71. 35 gr/cf

33.90 MG

29.53 gr/cf

96.10 MG

81. 10 Kg

Audit PeriodNo. 5

25.72 MG

75. 10 gr/cf

25.35 MG

88. 18 gr/cf

40.37 MG

90.81 gr/cf

30.71 MG

73.06 gr/cf

-

-

-

-

122.15 MG

196.29 Kg

Audit PeriodNo. 6

-

-

_

-

-

-

-

-

32.04 MG

57.67 gr/cf

35.08 MG

63.87 gr/cf

67.12 MG

72.92 Kg

Audit PeriodNo. 7

27.74 MG

36.14 gr/cf

26.75 MG

34.86 gr/cf

30.13MG

42.62 gr/cf

30.11 MG

42.54 gr/cf

-

-

-

-

1 14.73 MG

93.70 Kg

Audit PeriodNo. 8

-

-

-

-

_

-

-

-

29.44 MG

41.61 gr/cf

29.11 MG

41. 14 gr/cf

58.55 MG

49.65 Kg

Audit PeriodNo. 9

30.78 MG

36.38 gr/cf

29.52 MG

34.50 gr/cf

29.75 MG

28.08 gr/cf

29.67 MG

27.98 gr/cf

-

-

-

-

11 9.72 MG

76.16 Kg

Audit PeriodNo. 10

-

-

-

-

-

-

-

-

38.20 MG

45.72 gr/cf

38.32 MG

45.87 gr/cf

76.52 MG

45.80 Kg

Audit PeriodNo. 11

40.66 MG

35.93 gr/cf

38.52 MG

34. 10 gr/cf

-

-

-

-

-

-

-

-

79.18 MG

42.02 Kg

Audit PeriodNo. 12

-i

-

-

40.12 MG:30.90 gr/cf

40.01 MG

30.80 gr/cfi

~ ~iJ

i~i

1i

80.13 MG

37.02 Kg

Audit PeriodNo. 13

_

-

_

-

-

-

-

-

44.17MG

3 1.00 gr/cf

39.94 MG

30.20 gr/cf

84.11 MG

36.72 Kg

Audit PeriodNo. 14

40.19 MG

25.08 gr/cf

44.13 MG

27.77 gr/cf

-

_

-

--

-

-

-

_

84.32 MG

31.71 Kg

Audit PeriodNo. 15

-

-

-

-

46.79 MG

32.64 gr/cf

46.19MG

32. 13 gr/cf

50.28 MG

24.35 gr/cf

48.99 MG

23.40 gr/cf

192.25 MG

67.51 Kg

Audit PeriodNo. 16

46.53 MG

27.53 gr/cf

42.23 MG

24.67 gr/cf

-

-

-

-

-

--

-

-

88.76 MG

31 .32 Kg

MG = Million Gallons

gr/cf = grams of chromium per cubic foot of resin.

Total Water Treated to Date since GWTP Startup : 1488.81 Million Gallons

Total Hexavalent Chromium Removed to Date since GWTP Startup: 1231.56 Kg

5.0 Action Summary

The following is a list of recommended actions or changes to improve system

operation or record keeping procedures based on observations made during the 16th audit.

This list also includes any needed equipment repairs or adjustments identified during this

audit. Further details can be found in the body of this audit report. It is noted that the

action items listed have been carried over from the 15th audit period and all were resolved

prior to the 16th audit.

1. Recalibrate and/or repair the Train B raw water influent flow meter

FIT-10201. There are several meters throughout the plant which enable

the operator to monitor flow rates without using this particular meter.

This ability to monitor flow rates from other meters does not warrant

the expense of having a vendor recalibrate this meter. Therefore, this

issue is considered to be resolved and will not be included in future

audit action summaries.

2. Train A: PDIT-30101 & PDIT-30102 on Vessel T-30100 has

reportedly no reading on the office CPU while the vessel is in

operation. The piping associated with these meters was drained and

rust/sediments were noticed in the discharge water. The meters were

operating correctly after this piping drainage.

3. Piping throughout the GWTP is beginning to rust after months of

condensation during hot summer months. The bag filter housing is also

rusting. The bag filter and piping will need to be prepped and painted

during the colder winter months while the condensation on the piping is

minimal. All interior piping/filter housings were painted during the

low winter condensation periods and greatly improved the appearance

of the plant.

4. The flange bolts on the Influent and Effluent manway covers are

rusting with rust streaks running down the light colored paint. These

bolts need to be prepped and painted when cooler ambient temperatures

permit. The first coat of paint has been applied to these flange bolts


and will require an additional coat as ambient weather conditions

permit.

Ace Services Site 5-2 044720.01.49LTRA Audit Report No. 16

Documents

Long Term Response Action Audit Report No. 16