BLACK & VEATCH6601 College BlvdOverland Park KS 66211

Tel (913)4582900

USEPA Region VIIAce Services Site

Mr Bob StewartUSEPA Region VU901 N 5th StreetKansas City Kansas 66101

fi Veatch

RECEIVED

NOV 12 2003 BVSPC Project 46132BVSPC File F 1 2

November 10 2003

Subject tPA Contract No 68 W5 0004W A No 075 KARA 07GEFirst Audit Report

Dear Mr Stewart

Enclosed are two copies of the report summarizing the first audit of the City of Colby s operation of theACE Services GWTS Peryour request 1 am sending one copy directly to Mr Dan Gravatt at KDHE andone copy to Mr Gerry Bieker at the City of Colby

Please feel free to call me at (913) 458 6506 if you have anv questions or need additional information

Sincerely

BLACK & VEATCH SPECIAL PROJECTS CORP

Ken WyattProject Engineer

KWW

cc D Gravatt (KDHE)G BiekerG Felkner

40115798

Long Term Response ActionAudit Report #1

Ace Services SiteColby, Kansas

Prepared forUSEPA Region VII

November 10 200j

Prepared bjBlack and Veatch Special Proiects Corp

EPA Contract Number 68 W5 0004LPA Work Assignment Number 075 RARA 07GE

BVSPC Project Number 46132

Table of Contents

1 0 Introduction 1 1

2 0 Observations on General System Operation 2 1

2 1 Well Field 2 I2 2 Treatment Plum 2 2

3 0 Sampling and Record Keeping 3 1

40 Evaluation of System Performance 41

50 Action Summary 51

Ace Services Sitt TC1 46132149LTRA Audit Repontfl

1 0 Introduction

As part of Task 9, Work Assignment 075-RARA 07GE Black & Veatch SpecialProjects Corp (BVSPC) is to monitor key plant operations and evaluate the plantoperator s conformance to specified requirements for svstem operation Theseevaluations or audits are to occur on a quarterly basis The audits include a site visit toobserve the City of Colby operators and obtain key plant operating data This reportsummarizes the findings from the first such audit conducted on October 7 through 9,2003

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2 0 Observations on General System Operation

BVSPC representatives ai rived at the ground water treatment plant (GWTP) ataround 7 00 a m each morning and did not leave the plant until between 5 00 and 6 00p m each evening This allowed observation of the city operators throughout the regularstaff hours The City is staffing the plant from about 8 00 a m to approximately 4 00p m each day Generally onlv one operator is present though other City personnel comeand go during the day It was observed that frequently two opeiators are present duringthe morning sample collection and analysis round The level of staffing seemed adequateas long as there were no complications with the well or plant systems The plant operatorwas away from the plant for lunch each day leaving the plant and office vacant Theresponse to alarms during hours that the plant was not staffed was reasonably timely aslong as the auto dialer was set to dial out that particular condition High influent tanklevel needs to be added to the auto dialer

The plant office and lab areas appeared clean and well kept The operating staffexpressed positive attitudes regarding the facility and their jobs and seemed genuinelyinterested in the success of the extraction and treatment systems

Specific details of svstem operation and record keeping including problems notedduring the audit are provided below

2 1 Well FieldAll the extraction wells were operating with the exception of EX 2s and EX-3i

Well EX 2s has not been operated since the beginning of the performance test in late

June due to insufficient water in the well It was noted that this well could be operatedperiodically at 8 to 10 gpm Well EX 3i was down due to a problem with the well pumpThis pump was pulled out of the well on October 8 and was found to have a failedcoupling between the pump and motor The pump/motor assembly was sent back to thevendor for repairs on October 9 All others wells were operating at design flow ratesTotal flow from the extraction system was approximately 750 gpm A review of the flowrecords and logged flow trends in the PLC revealed that the total flow from the well fieldhad averaged 770 01 more gpm since the beginning of operation by the city

Ace Services Silt. 2 1 46132149LTRA Audn Report MI

A review of sampling records, indicate that the concentration of hexavalentchromium m the composite ground water had dropped to less than 0 5 milligrams per liter(mg/1) by early October The chrome load to the treatment process averaged only 0 51mg/1 from August 12 through October 2 (see Table 4 1) It appears that the areas ofhighest chiome concentration in the aquifei are being quickly removed and/or that theextraction wells capture zones are extending beyond the plume

2 2 Treatment PlantThe treatment plant was operating throughout the audit period and operating

records indicate that operation had been essentially continuous with the exception of ashut down due to a storm related power outage The lighting strike that was believed tohave caused the outage also caused a voltage surge in the PLC system which createdsome abnormal conditions on re start Ovei all the plant treated an average of just morethan 1 1 million gallons of water per day each day since operation by the city began onAugust 12 2003 The lead vessel on Train B saturated and the Train B beds advanced

for the first time on September 29 Train A was advanced 3 days later on October 2 Noresin had been delivered to the site by the time of the audit so both trains had exhaustedresin in the stand by beds

A few problems and anomalies were noted regarding plant operation during theaudit These are described belou

BVSPC noted that the pressure drop acioss the resin trap for bed A 1 wasgrossly excessive The PLC display showed a pressure drop of 15 0 psi withno fluctuation The City operators did not realize that the PLC display rangemaximum is 15 0 so that a steady reading of 15 0 indicates that the actualpressure drop is higher The local display on the pressure transmitter headshowed an actual pressure differential of more than 35 psi This extremelyhigh pressure drop was limiting flow through the train and generatingexcessive pressure in the lead and lag beds BVSPC demonstrated the properprocedure for draining bed A 1 to allow removal and cleaning of the cloggedresin trap The trap was removed and cleaned on Octobei 9

Permission was granted by KDHE Bureau of Water to discharge the treatmentplant effluent to the drinking water svstem on or about October 6 WhenBVSPC drrwed at the unattended plant at 7 00 a m the morning of October 8

Ace Sen ices Sue 2 2 46132149LIRA Audit Report H\

we found that the effluent tank high alarm was annunciating and the tank levelwas nearly to the point of tripping the high high alarm, which shuts down thetreatment plant No one from the city had responded to the alarm BVSPCopened valve CV 4 to discharge water to the creek and clear the tank alarmbefore a shutdown occurred A brief investigation revealed that the PLC wasdisplaying the icon which indicates that the City was requesting water Thisrequest switches the automatic controls to open CV 5 for discharge to the citysystem rather than CV 4 for discharge to the creek The operators had leftvalve CV 5 in computer manual closed which prevents the PLC fromopening the valve As a result the control system was left with no possibledischarge option The override on CV 5 was a fortunate circumstance sincethe chlorine system had not been started The City Operators hadunintentionally caused the request for water to the City system whichappeared around midnight as the City water tower regulation controls soughtto fill the tower The chlorine system was subsequently started later on themorning of October 8 and discharge to the City drinking water system began

When the Chlorine system was started on the morning of October 8, thechlorine leak alarm annunciated in the chlorine shed The fitting at the top ofthe rear chlorine bottle was found to be leaking This bottle was closedleaving the system to operate with only one bottle In addition the automaticchlorine feed controller would not function It appeared that the controllerhad been damaged in the lightening strike that caused the earlier poweroutage The chlorine alarm panel had also been affected by the strike, butrequired onlv reprogramming to return to normal function The feedcontroller was placed into manual mode and adjusted so that the desired 0 5ppm chlorine residual was achieved so water could be discharged to the Citysystem The chlorine system supplier was contacted regarding repair orreplacement of the controller

Ace Services Site 23 46132149LTRA Audit Reports I

3 0 Sampling and Record Keeping

The in plant iccords kept by the City opeiators were reviewed for completenessand conformity to requirements During the review emphasis was placed on water flowand chromium concentration data that are critical to evaluation of treatment systemperformance The dailv records were well organized in a notebooks kept at the plantThe daily records were organized by date and put in essentially the same format as wasused for the treatment system performance test A few deficiencies and problems werenoted in the records These were pointed out to the City operators so that they couldcorrect their procedures These problems are described below

The differential pressure data recorded on the Ion Exchange Vessel Log wasrecorded incorrectly The operators misunderstood the PLC display, whichshows the pressure differential for both the ion exchange bed and the outletresin trap The operators were subtracting one from the other and recordingthat result even if the result was a negative number The differential pressuredata recorded by the City operators up until this audit are misleading and mustbe disregarded

The results recorded on the record forms for in plant analyzed hexavalentchromium samples are incorrect and misleading The City operators areroutinely diluting the sample 1 to 1 with distilled water so that the Hach andHarma instrument readings are Vi of the actual sample concentration Theoperators are then writing the instrument readings (not the actual sampleconcentration) m the plant records notebook Although this dilution isgenerally noted in the lab notebook, the form with the daily plant records hasthe instrument reading written in but often no mention of it being a dilutedsample The result of this is that anyone looking at the sample records wouldconclude that the chrome concentration was one half of the actual level Thecorrect procedure is to record the instrument reading and details regarding anydilution of the sample in the lab notebook and enter the actual sampleconcentration on the record form

Very few oft site lab analysis recoids were available at the plant There wasnot sufficient data available to evaluate how well in plant analysis comparedwith off site analysis It is critical to be able to verify the accuracy of the inplant sample analysis with matching off site analysis results The off site lab

Ace Service Sue 3 1 46132149LIRA Audit Report #1

results were not bound into the plant records notebook along with the in plantresults as they should have been

There was no sample drawn for laboratory analysis when the lead beds weredeemed to have reached breakthrough sufficient to warrant being taken out ofservice A sample from the lead bed effluent should be sent for off-siteanalvsis of hexavalent chromium concentration just before the beds areadvanced to accurately quantify breakthrough

Ace Services Site 3 2 46132 149LTRA Audit Report)? I

4 0 Evaluation of System Performance

Except for the issues noted in section 2 1 above regarding wells EX 2s and 3i theextraction performed perfectly Wells did not cycle and no significant problems werenoted

Selected flow and sampling data from the beginning of long term operation onAugust 12 through October 2 2003 are presented in Table 4-1 As shown in Table 4 1,the concentration of hexavalent chromium in the raw water entering the treatment systemhas dropped to under 0 5 mg/1 The influent concentration averaged 0 51 mg/1 for thefirst 52 days of operation The data show a continuation of the trend of falling chromiumconcentrations noted during the 35 day final performance test It appears that thedegradation in chromium concentrations may be slowing as the composite influent levelsfall below 0 5 mg/1

The data shows that the lead bed in tram B treated 25,764 681 gallons over 48days before it was exhausted The lead bed on train A treated 28,485 339 gallons over 51days The bed life achieved during these first 51 days is consistent with the resinperformance observed during the treatment performance test In total the two lead bedsremoved 231 Ibs of chrome from 54 million gallons of water During the performancetest the two lead beds removed 300 Ibs of chrome from 41 million gallons of water Theresin holding capacity achieved during the first 51 days of operation was 93 6 grams ofchrome per cubic foot of resin verses 121 4 for the performance test The somewhatlower holding capacity is expected due to the diffeient equilibrium driven by the lowerconcentration in the raw water

Ion exchange is often used as a polishing process in water treatment because it isvery cost efficient compared to other treatment technologies at low contaminant

concentrations The relatively low concentration of hexavalent chromium now seen in thecomposite groundwater is an ideal application for ion exchange The total resin costincluding transportation and disposal was 0 166 cents per gallon for the first 51 days of

operation This is a significant reduction from 0 210 cents per gallon from theperformance test and demonstrates the excellent efficiency of the ion exchange process inthis application There is not sufficient data at this time to compute the total cost per

Ace Services Sin. 4 1 46132LIRA Audit Report #1

gallon to treat the extracted ground water including labor and plant utilities however it is

anticipated that these cost will be a relatively small part of the total

Ace Sen ices Sue 42 46132149LTRA Audit Reports I

TABLE 4-1SELECTED FLOW AND CHROME CONCENTRATION DATA

Date

8 128 138 148 158 168 178 188 198 208 218 228 238 248 258 268 278 288 298 308 319 19 29 39 49 59 69 79 89 99 109 119 129 139 149 159 169 179 189 199 209 219 229 239 249 259 269 279 289 299 30

10 110 2

Avg =

Hex Chromeat SC 2 per

Odyessy mg/l

1 40066058062062

058060042052052048044074051054056058058056056052052056060056046048040052048050052052050054052044042046046048048048046054056048048048050

051

Total Chromeat SC 9 per

Continental Labs

ND(<01mg/l)

ND(<01mg/IJ

ND(<01mg/l)

ND(<01mg/l)

ND(<01mg/l)

NO (< 01 mg/l)

ND(<01mg/l)

FM 2total gallons

22 787 000

74 779 900

79451 100

Train AFM3A

total gallons

1 332 695

10000000

10000000

9818034

Train BFM3B

total gallons

1 332 700

10000000

10 000 000

7 097 481

Remarks

Begin LTRA operation

No odyessy data

FM 3B rolled over to zeroFM 3A rolled over to zero

FM 3A & 3B rolled to zero

Tram B beds advanced

Tram A beds advanced

5 0 Action Summary

The following is a listing of the recommended changes in the City operators plantoperating or record keeping procedures based on observations made during this auditThis is a summary listing This listing also includes anv equipment repairs oradjustments deemed needed from the audit Further details can be found in the body ofthis audit report

1 Well FX 2s should be periodically operated (at least weekly) at 8 to 10 gpmfor a few hours

2 Record both the resin trap and resin bed pressure drops separately andcorrectly PLC readings should be verified at the local transmitter head

3 Any resin trap showing a pressure drop m excess on 10 psi should be

immediately cleaned4 The chlorine feed controller should be replaced or repaired and operated in

automatic mode to allow for flow paced delivery of chlorine to the water

5 The leak at the head of the rear chlorine bottle should be repaired6 High alarms in both the influent and effluent storage tanks should trigger the

auto dialer

7 The results of samples analyzed in plant for hexavalent chromium should berecorded in the sample record form as actual sample concentrations not

instrument readings for diluted samples Dilution details should be recorded

in the lab notebook8 The results from off site laboratory analysis of samples should be kept in the

plant records notebook along side the matching in plant sample results tofacilitate data comparison

9 The Operators should always check for agreement between the results off siteand m plant sample analysis immediatel) when off site results becomeavailable

10 A sample should be collected for off-site laboratory analysis at the outlet of a

saturated lead bed just before the bed is lemoved from service to quantify thehexavalent chromium breakthrough

Ace Services Site 5 1 461 j2 149LTRA Audit Report#l