SECOND EXPLANATION OF SIGNIFICANT DIFFERENCES
MIDDLETOWN AIRFIELD SUPERFUND SITE
DAUPHIN COUNTY, PENNSYLVANIA
I. INTRODUCTION
Site Name and Location
Site Name: Middletown Airfield Superfund Site (Site)
Site Location: Lower Swatara Township, Dauphin County, Pennsylvania
Lead and Support Agencies
Lead Agency: U.S. Environmental Protection Agency, Region 3 (EPA)
Support Agency: Pennsylvania Department of Environmental Protection (PADEP)
II. STATEMENT OF PURPOSE
EPA is issuing this Second Explanation of Significant Differences (ESD) for the Site, in
accordance with Section 117(c) of the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980, (CERCLA), as amended, 42 U.S.C. § 9617(c), and 40 C.F.R.
§ 300.435(c)(2)(i) of the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). Section 117(c) of CERCLA and 40 C.F.R. § 300.435(c)(2) of the NCP require that EPA
either issue an ESD when modifications to the selected remedy are necessary, and such
modifications significantly change, but do not fundamentally alter, the remedy selected in a
Record of Decision (ROD) with respect to scope, performance, or cost, or issue a ROD
amendment if such changes fundamentally alter the remedy selected. This ESD presents a
modification that significantly changes but does not fundamentally alter the remedy selected and,
therefore, a ROD amendment is not required.
Purpose of the ESD
This Second ESD modifies the Selected Remedy by changing the treatment system from the
existing air stripper water treatment system to a Granular Activated Carbon (GAC) water
treatment system. This upgrade is to treat the groundwater for non-site related contaminants to
standards set forth by the PADEP Safe Drinking Water Program (SDWP). The system upgrade,
financed by the current owner and operator, will still be protective of and effectively treat site-
related contamination. The basis for this Second ESD is discussed in detail in Section III, below.
EPA issued three RODs for the Site dated December 30, 1987, December 17, 1990, and
September 17, 1996, as well as an ESD on April 23, 1992. The culmination of these RODs and
ESD in regard to a final remedy are explained in more detail in Section III.
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This Second ESD will be incorporated into the Administrative Record maintained for the Site, as
required by the NCP at 40 C.F.R. § 300.825(a)(2). The Administrative Record, which contains
documents forming the basis for this decision, is located in the information repository at the EPA
Region III offices in Philadelphia, Pennsylvania; the Middletown Public Library; and online at
https://www.epa.eov/siiperfimd/middletownairfield.
III. SUMMARY OF I II I SITE HISTORY, CONTAMINATION AND SELECTED
REMEDY
Site Background
The Site is located at the Harrisburg International Airport (HIA) in Lower Swatara Township,
Dauphin County, Pennsylvania. The Site is bordered by the Susquehanna River to the south, the
Pennsylvania Turnpike to the north, and residential and commercial areas to the east and west.
Pennsylvania Route 230 runs through the approximate center of the Site from east to west, as
shown in Figure 1 - Site Location Map (Figure 1). In addition to the HIA, a private warehouse
company, Penn State University (PSU), and the Middletown School District use portions of the
Site.
Site History
The U.S. Army and U.S. Air Force (USAF) used the Site as a military facility from 1898 to
1966. The Site was initially operated by the Army as a basic training camp in 1898 during the
Spanish-American War. In 1917, the Army Signal Corps established the Aviation General Depot
at the Site, consisting of warehouses and garages. Flight operations began in 1918. The depot
was renamed the Middletown Air Intermediate Depot in 1921 and the airfield
portion of the Site was renamed Olmstead Field in 1923. During World War II, the Site
was utilized for overhauling aircraft, including paint stripping, repainting, and engine
repair/replacement. In 1947, Olmstead Field was renamed Olmstead Air Force Base to
coincide with the designation of the USAF as a branch of the Department of Defense. The Site
was operated as the Olmstead Air Force Base until closing in 1966.
In 1971, the Pennsylvania Department of Transportation (PennDOT) took over ownership and
operation of the airfield and related buildings at the Site as a commercial airport, the HIA.
Ownership of the HIA was then transferred from the Commonwealth of Pennsylvania to the
Susquehanna Area Regional Airport Authority (SARAA) in January 1998 and SARAA is the
current owner and operator of HIA. The remainder of the Site is currently owned by a private
warehouse company, PSU, and the Middletown School District.
In March 1983, the Pennsylvania Department of Environmental Resources (PADER, now known
as PADEP) detected trichloroethylene (TCE) in 6 of the 10 groundwater production wells
supplying drinking water to HIA, and the wells were subsequently taken out of service. Primarily
due to contamination of the groundwater, EPA proposed the Site to the National Priorities List
(NPL) on October 1, 1984, and formally added it to the NPL on June 1, 1986.
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In 2014, SARAA identified per- and polyfluoroalkyl substances (PFAS) in multiple groundwater
production wells, including HIA-13, which is specifically identified in EPA's ROD as
instrumental for the selected remedy, and shut off the PFAS contaminated wells from the system.
Subsequently, SARAA tested the effectiveness of GAC treatment on PFAS in water, which was
found to be effective and was documented in a report titled "Final Report for Susquehanna Area
Regional Airport Authority ("SARAA Report"), Ground water Well #9, Granular Activated
Carbon Pilot Test, February 28, 2017" (Appendix A). The SARAA Report provides a summary
of production wells at HIA that have been contaminated with PFAS and indicates the use of
firefighting foam (a known source of PFAS) at the HIA firehouse as the potential source of
contamination.
Based on the SARAA Report, and on EPA's evaluation of former fire training areas at the Site as
potential sources of PFAS contamination, documented in EPA's 2017 Five Year Review, EPA
has concluded that HIA operations are the likely source of PFAS contamination, and not the
historical military-related waste disposal areas that were addressed by the selected remedy in the
Superfund RODs and ESD. Further, PFAS in groundwater is being addressed under a permit
issued to SARAA by the PADEP SDWP. Therefore, although PFAS contamination is located in
the HIA wells and EPA is modifying its remedy to provide for TCE treatment by GAC under the
PADEP permit, EPA does not intend to pursue a CERCLA response action to address PFAS
contamination in groundwater at the Site.
Current Use
The Site consists of approximately 500 acres. Currently, HIA, as well as associated commercial
and industrial facilities, use approximately 182 acres of the Site. The Harrisburg campus of PSU
uses approximately 218 acres that include administrative and housing facilities. Commercial
warehouses and industrial facilities are located on the remaining 93 acres. The Middletown
School District owns and operates approximately 7 acres to store equipment and has a vehicle
maintenance facility located in one of the former warehouses. The Middletown Borough also
uses part of the property for a woody waste recycling facility.
The majority of Lower Swatara Township, in which the Site is located, is served by public water
and sewer. Residents in Middletown Borough, located to the northeast of the Site, are required
by a borough ordinance to connect to public water that relies on deep bedrock groundwater as its
source. The source of drinking water for the HIA is groundwater which is extracted by a series of
15 production wells, which can be turned on independently depending on need. Several of the 15
production wells have been taken offline due to the discovery of PFAS, summarized in the
SARAA Report. Groundwater extracted from the other wells is currently treated by air stripping
in accordance with EPA's remedy, which will change to treatment by GAC in accordance with
this ESD and PADEP's permit to SARAA. The provision of drinking water to the HIA is
regulated by the PADEP SDWP.
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Selected Remedy
EPA issued three RODs for the Site on December 30, 1987, December 17, 1990, and September
17, 1996, as well as an ESD on April 23, 1992, that collectively consist of the following remedial
components:
• Extraction and treatment of TCE contaminated groundwater within the industrial area via
air stripping for the following purposes:
o Attainment of maximum contaminant levels (MCLs) pursuant to the federal Safe
Drinking Water Act prior to distribution and use for industrial, commercial, and
residential drinking water purposes at HIA;
o Restoration of groundwater to meet MCLs throughout the aquifer at the Site; and
o Containment of the potential discharge of contaminants to the Susquehanna River.
• Institutional controls restricting groundwater use at the HIA and within Middletown
Borough;
• Institutional controls requiring soil sampling and analysis during excavations at the HIA
and PSU parcel;
o PADEP approval is necessary prior to onsite use/disposal of excavated soils.
• Institutional controls requiring groundwater, surface water, and sediment monitoring to
monitor the performance of the groundwater extraction and treatment system and any
future modifications to the system.
In the 1987 ROD, EPA identified both air stripper water treatment systems and GAC water
treatment systems as remedial alternatives. Both remedial alternatives were deemed to provide a
high level of assurance of water supply, meet all regulatory requirements with proven
technology, and have no unavoidable significant adverse effects. Air stripping was ultimately
selected by EPA over GAC treatment due to the higher costs of GAC compared to air stripping.
To implement the remedy, on April 15, 1988, an Interagency Agreement was signed between
EPA, USAF, and PennDOT to implement the remedy selected in the 1987 ROD. On September
1, 1993, an Administrative Order on Consent (AOC) was signed between EPA and the USAF to
implement the remedy selected in the 1990 ROD, as modified by the 1992 ESD. On April 16,
1997, PADEP and PennDOT entered into a Memorandum of Understanding (MOU) to
implement the remedy selected in the 1996 ROD and continue operation of the groundwater
treatment system at HIA in accordance with the 1987 ROD. On December 31, 1997, PADEP,
PennDOT, and SARAA entered into a Consent Order and Agreement (COA) transferring the
responsibilities set forth in the MOU from PennDOT to SARAA. Therefore, SARAA currently
has the responsibility of implementing the remedy, including all the components listed above.
The remedy was constructed and it achieved cleanup goals. EPA documented construction
completion for the Site on September 18, 1996 with the Final Closeout Report (FCOR). EPA
deleted the Site from the NPL on July 10, 1997.
IV. DESCRIPTION OF SIGNIFICANT DIFFERENCES AND THE BASIS FOR
SECOND ESD
This Second ESD documents the upgrade of the existing air stripper water treatment system to a
GAC water treatment system. This system upgrade is not required by EPA, and instead is an
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upgrade by SARAA performed to meet the standards of the PADEP SDWP for non-site related
contaminants, demonstrated by the SARAA Report (Appendix A). This upgrade to the treatment
facility will maintain and improve the groundwater cleanup capabilities and SARAA is
completing and financing this system upgrade.
The contamination consists of PFAS including perfluorooctanesulfonic acid (PFOS) and
perfluorooctanoic acid (PFOA), which SARAA identified in 2014 in groundwater wells above
levels allowed by the PADEP SDWP. EPA has determined that PFAS contamination is likely
associated with operations at the HIA, such as fire training areas, and not the waste disposal
areas associated with the Middletown Airfield Superfund Site. By upgrading the water treatment
system to provide treatment by GAC, SARAA is addressing PFOS and PFOA contamination as
required by the PADEP SDWP permit issued on October 28, 2021 (Appendix B).
EPA notes that the production well HIA-13 is one of the 15 production wells and has not
operated since 2014, when it was determined to be contaminated with PFAS by SARAA.
SARAA informed EPA during a March 22, 2022, site visit that SARAA was currently working
with PADEP to improve the groundwater treatment system to address PFAS. SARAA further
informed EPA that the improvements are expected to be completed during the next Five-Year
Review period (2022-2027) and upon completion, SARAA will resume operation of HIA-13 as
the production well for contaminated groundwater consistent with EPA's remedial decision and
the PADEP permit.
SARAA has stated to EPA that it will follow the PADEP permit, as well as new and emergent
SDWP regulations as they arise.
The groundwater treatment system is being changed by SARAA from air stripping to GAC and
will continue to treat the primary contaminant of concern, TCE, in groundwater, while also
treating non-site related PFAS. The remedy will remain protective of human health and the
environment and the change does not fundamentally alter the final remedy components discussed
in Section III. Further, the upgraded system does not fundamentally alter the overall cleanup
approach.
V. AFFIRMATION OF STATUTORY DETERMINATIONS
EPA has determined that the modification to the Selected Remedy as described in this Second
ESD complies with the statutory requirements of CERCLA Section 121, 42 U.S.C. § 9621. EPA
believes that the Selected Remedy, as further modified by this Second ESD, remains protective
of human health and the environment, complies with Federal and State requirements that are
applicable or relevant and appropriate to this remedial action, and is cost effective.
VI. COMMUNITY INVOLVEMENT
As required by the NCP, EPA will publish a notice of availability and a brief description of this
Second ESD following its signing. In accordance with Section 117(d) of CERCLA and the NCP
40 C.F.R. § 300.825(a), this Second ESD and supporting information will become part of the
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Site's Administrative Record, which is available for review online at
https://www.epa.gov/superfund/middletownairfield and at the following locations:
U.S. Environmental Protection Agency Region III
Four Penn Center
1600 John F. Kennedy Boulevard
Philadelphia, PA 19103-2852
Middletown Public Library
20 N. Catherine Street
Middletown, PA 17057
VII. SUPPORT AGENCY REVIEW
In accordance with 40 C.F.R. § 300.435(c)(2), EPA consulted with PADEP on the modifications
to the Selected Remedy in this Second ESD. EPA received a letter dated September 20, 2023
from PADEP that concurs with the Selected Remedy as further modified by this Second ESD.
This letter of concurrence can be found in the Administrative Record.
VIII. CONCLUSION
This Second ESD modifies the Selected Remedy by changing the treatment system from the
existing air stripper water treatment system to a GAC water treatment system. This upgrade is to
treat the groundwater for non-site related contaminants to standards set by the PADEP SDWP.
The treatment upgrade will also effectively treat site-related contamination.
Approved by:
PAUL
LEONARD
Digitally signed by PAUL
LEONARD
Date: 2023.09.22 14:57:17
-04'00'
Paul Leonard, Director
Superfiind and Emergency Management Division
6
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Figures -
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s © 2012 Google/ |
ISD A FatmSe rvi ce Agen'&
Approximate
Site Location
Middletown Airfield
Superfund Site
Figure 1
Site Location Map
US EPA
REGION III
1650 Arch Street
Philadelphia, Pennsylvania 19103
United States
Environmental Protectior
Agency
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Commercial
Warehousing
Middletown
Borough
School
District
Pennsylvania
State
University
Harrisburg
International
Airport
Middletown Airfield
Superfund Site
Figure 2
Current Site Uses
US EPA
REGION III
1650 Arch Street
Philadelphia, Pennsylvania 19103
United States
Environmental Protectior
Agency
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Appendix A -
Final Report for Susquehanna Area Regional
Airport Authority ("SARAA Report"), Ground
water Well #9, Granular Activated Carbon Pilot
Test, February 28, 2017
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Final Report
FOR
Susquehanna Area Regional
Airport Authority
Groundwater Well #9
Granular Activated Carbon Pilot Test
February 28, 2017
Prepared by;
GLACE ASSOCIATES, INC.
3705 Trindle Road
Camp Hill, PA 17011
Phone: 717-731-1579
Fax: 717-731-1348
www.glaceeng.com
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Revision Sheet
Revision Sheet
Kclosisc No.
Ditlc
ki^ision Description
1
2/28/2017
Initial Issue of Report
Test Plan
2017-02-28, saraa pilot testfinal report
Page i
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TEST REPORT
TABLE OF CONTENTS
Page #
ACRONYMS AND ABBREVIATIONS Hi
1.0 MANAGEMENT SUMMARY. 1
2.0 INTRODUCTION AND BACKGROUND 6
2.1 Introduction 7
2.2 Background 8
2.3 Source Well PFC Data 11
2.4 Technical References 16
2.5 Pilot Test Organization 16
2.6 Pilot Test DEP and Analytical Laboratory Contacts 17
3.0 TESTDESCIPTIONAND OPERATIONAL SUMMARY. 18
3.1 Test Objectives 19
3.2 Pilot System Description 19
3.3 Test Equipment 21
3.3 Test Description 21
3.4 Operational Summary 23
4.0 GRANULAR ACTIVATED CARBON ADSORPTION TEST RESULTS 28
5.0 GAC ADSORPTION TEST SUMMARY. 32
6.0 BASIS OF DESIGN FOR HIA WATER SUPPLY SYSTEM. 36
7.0 GROUNDWATER PUMPING TEST RESULTS. 42
8.0 PUMPING TEST SUMMARY 57
ATTACHMENT 1- CONCEPTUAL GAC SYSTEM DESIGN BASIS 59
aTTACHMENT2 - WELL 9 TRANSMISSIVITY CALCULATION 67
Test Report Page ii
2017-02-28, saraa pilot test final report
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ACRONYMS AND ABBREVIATIONS
The following is a list of the acronyms and abbreviations used in this document and the meaning of each.
HIA - Harrisburg International Airport
GAC - Granular Activated Carbon
MDL - Method Detection Limit
MOU - Memorandum of Understanding
LOQ - Limit of Quantification
PFC - Perflourinated Compound
PFOA - Perfluorooctanoic Acid
PFOS - Perfluorooctanoic Sulfonate
PFHA - Perfluoroheptanoic Acid
PFNA - Perfluorononanoic Acid
PFBS - Perfluorobutane-sulfonic Acid
PFHS - Perfluorohexane-sulfonic Acid
POC - Point of Contact
RDL - Reporting Detection Limits
SARAA - Susquehanna Area Regional Airport Authority
VOC - Volatile Organic Compound
WTP - HIA Site-wide Water Treatment Plant
Test Report Page iii
2017-02-28, saraa pilot testfinal report
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1.0 MANAGEMENT SUMMARY
1.0 MANAGEMENT SUMMARY
PAGE 1
SARAA PILOT TEST REPORT
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1.0 MANAGEMENT SUMMARY
1.0 MANAGEMENT SUMMARY
The purpose and intent of the pilot test was as follows:
1. Pumping test for Well #9 to assess impact on controlling PFC migration in adjacent
wells.
2. Comparison of two types of granular activated carbon at an operating source well
contaminated with PFCs to assess removal capability and cost effectiveness.
3. Develop site specific design criteria for long term use of granular activated carbon for
source water treatment at the HIA water treatment plant.
The pilot test was conducted using two identical treatment trains to test two types of GAC. Each train
was configured in lead - lag test GAC treatment unit arrangement to ensure the discharge to the sewer
was consistently free on any PFC or VOC compounds. This was successfully achieved during the entire
duration of the test.
In reviewing the groundwater level and water quality data from the source wells tested, the pumping of
Well 9 did have an influence on the adjacent source wells, particularly Well 6. This impact is illustrated
in the graphs shown in Section 7 for Wells 6, 11 and 12 by the rebound in groundwater level when the
test is stopped. Since the level transducers were not in operation before the test was started, the overall
impact could not be fully investigated but the test data did indicate these wells were influenced during the
test. However, the data also indicate that this influence did not have a noticeable impact on controlling
the concentrations of PFCs at the site as shown by the appearance and persistence of PFCs in wells both
within and beyond the influence of the test well during the test.
Well #9 Pumping Impacts
—Well #12 —Well #6 —Well #11
The presence of PFCs over the site may be due to a number of factors including their mobility in the
groundwater and that all sources of PFCs both from onsite and offsite activities have not been fully
identified. These factors would indicate that the most efficient approach for future operation of the HIA
water supply system would be to control the low-level PFCs treatment in the groundwater using GAC at
PAGE 2
Ill 1.1 PILOT TEST REPORT
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1.0 MANAGEMENT SUMMARY
the existing centrally located system Water Treatment Plant as opposed to independent systems located at
each respective recovery well head.
Another consideration favoring a centrally located GAC system is that presently EPA has only established
Health Advisory limits for PFOS and PFOA. Additional or lower allowable concentrations for all of the
identified PFCs could be established by EPA in the future and GAC has been shown to be an effective
treatment for them.
The second objective of the test was to compare two GAC types, coal based GAC and coconut based
GAC, for applicability of treatment and long term operating costs at HIA. The results indicate that both
GACs tested performed better in overall adsorption capacity than the literature referenced to estimate
capacity at the time the test plan was developed. The estimated GAC life used in the test plan
development assumed a utilization rate of 0.01114 mg of PFOS adsorbed per gram of GAC. The test
results indicated that the site specific rate for overall PFC adsorption was significantly greater for both
GAC types tested. It should be noted that PFOS was used as the indicator compound since it was present
at the highest concentrations at the site, had an established HAL and was the first compound to break
through the GAC lead test units.
Based on the test results and the lower unit cost of the coconut based GAC, ($1.65 /lb for the virgin
coconut based product versus $1.83/lb for the virgin coal based product), the test indicates that the basis
of design should initially utilize a system incorporating the coconut based GAC for implementation at
HIA. The prices used for comparison are the actual costs of the GACs used for the pilot test. Since bulk
purchase of GAC for full scale units may vary, any GAC treatment system implemented at HIA should be
capable of utilizing either type to provide flexibility to switch should changes occur in the GAC market or
technology.
The third objective was to utilize the results to develop a facility WTP basis of design for the
implementation of GAC treatment at HIA.
Beyond removing PFCs in the source water, a full scale GAC system at HIA must also account for
conditions imposed on HIA by the Memorandum of Understanding (MOU) signed April 16, 1997 by the
Department of Environmental Protection to address VOC contamination at the site. This VOC
contamination was addressed by PADEP in Records of Decision (ROD) from 1987, 1990 and a 1992
Explanation of Differences (ESD) resulting in the 1997 MOU.
The system must also comply with all applicable PADEP and EPA drinking water regulations which
include the capability to remove VOC contamination that may be present at the site to below drinking
water standards. Presently, the only source water well that has demonstrated the presence of VOCs
consistently is Well #13. Since the facility is required by the MOU to continue to pump source water
wells, the inclusion of Well 13 in future pumping schemes has been assumed as a base case for the WTP
GAC system basis of design. VOCs in the source water are presently controlled using an air stripper
which is not effective for the removal of PFCs. The proposed WTP upgrade for the control of PFCs as
contained in this report is also a demonstrated technology for the removal of the VOCs present at the site
to below drinking water standards. It is therefore entirely feasible that the air stripper operation could be
suspended and the water treated entirely using GAC. Whether this approach is pursued for permitting
with PADEP will depend on the cost of VOC treatment by air stripping followed by polishing with GAC
filtration for PFC removal as compared to the cost of treating both VOCs and PFCs in a combined GAC
filtration system.
The WTP GAC system basis of design also assumes that the pumping of Well 13 would not exceed 25%
of the total daily withdrawal for treatment at the WTP as was done prior to 2014 when the PFCs were first
PAGE 3
SARAA PILOT TEST REPORT
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1.0 MANAGEMENT SUMMARY
identified. This maximum percentage of Well 13 source water used for total facility water demand is
limited since cis-l,2-dichloroethenemay becomes the limiting factor in GAC change-out frequency when
the concentrations in the influent exceed approximately 1 ug/L. The cis-l,2-dichloroethene concentration
used in the basis of design was based on 2014 concentrations in Well 13 resulting in a WTP combined
influent concentration of cis-l,2-dichloroethene equal to 1.95 ug/L. At this concentration and the
recorded concentrations of PFCs during the test, cis-l,2-dichloroethene becomes the controlling
contaminant in the GAC change out frequency.
A conceptual system upgrade to include GAC treatment for PFCs described in this report is based on
removing one of the air strippers for installation of the GAC system. The final system configuration will
be assessed and determined during the preliminary and final design phases of the plant upgrade.
The following is a summary comparison of two potential water demand conditions for the WTP GAC
system. The first condition is based on a water demand from 2013 which included the inter-connection
with the United Water System. The average water demand was 0.515 MGD for this condition. The
second condition is based on the water demand from the 3rd quarter of 2016 which represents current
demand without the inter-connection with the United Water System. The average water demand was
0.248 MGD for this condition
The GAC system would consist of a lead unit and a lag unit, each holding 20,000 lbs of GAC. When any
of the PFC compounds of concern is detected in the effluent of the lead unit above 0.040 ug/L, a carbon
change will be scheduled thereby ensuring that the water pumped to the distribution system is always free
of any of the compounds of concern.
For this comparison both conditions were based on a single lead - lag unit configuration, actual plant
design would likely use a dual Lead - Lag arrangement for operational flexibility and redundancy.
However, the annualized GAC cost would be representative regardless of the unit size or whether a single
or dual arrangement is implemented.
Lead Unit Lag Unit
Intermediate Sampling
Point
The System Treatment Performance for Both Water Demand Conditions is based on the following
influent conditions and lead unit breakthrough concentrations; (Refer to Section 6 for additional details)
PAGE 4
Ill 1.1 PILOT TEST REPORT
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1.0 MANAGEMENT SUMMARY
Design
Design
GAC
Design
GAC
Influent
Breakthru
Cone.
Effluent
Effluent
Lead Unit
Lag Unit
CO
C1
PFC s
ug/L
0.60282
0.040
WD
Chlorabenzene
mg/L
0.00826
0.0005
ND
1,2-Dichlorobenzene
mg/L
0.00000
0.0005
ND
1,4-Dichlorobenzene
mg/L
0.00000
0.0005
ND
cis-1,2-Dichioroethene
mg/L
0.00195
0.0005
ND
Trichioroethene
mg/L
0.00076
0.0005
ND
PH
SU
8.3
8.5
8.5
Hardness
mg/L
200
NA
NA
NOTE: ALL COSTS ARE APPROXIMATE ESTLMATLONS USED FOR COMPARLSON ONLY
Cost of replacement GAC = $1.65 per pound (Pilot Unit Test Cost)
Mobilization and Removal Charge for Spent GAC = $0.85 per pound (Pilot Unit Cost for GAC Removal)
Condition 1
Water Demand (MGD) 0.515 MGD
Daily Source Well Pumping (hours per day) 12 hrs/day
GAC System Flow Rate (gpm) 715 gpm
Lead Unit GAC Charge (lbs) 20,000 lbs
GAC Change-Out Interval (Days) 145 days
Carbon replacement and disposal Cost per change-out $50,000 per change-out
Annualized Carbon Change-out Cost $ 126,000 per year
Condition 2
Water Demand (MGD) 0.248 MGD
Daily Source Well Pumping (hours per day) 12 hrs/day
GAC System Flow Rate (gpm) 345 gpm
Lead Unit GAC Charge (lbs) 20,000 lbs
GAC Change-Out Interval (Days) 300 days
Carbon replacement and disposal Cost per change-out $50,000 per change-out
Annualized Carbon Change-out Cost $61,000 per year
Please note that a safety factor of 50% was incorporated into the GAC utilization estimate. The change
out interval is being driven the inlet concentration of cis-l,2-dichloroethene of 1.95 tig/L. If this
concentration drops below 1 tig/L, the PFC concentration will control the change out interval and the
resulting annualized cost will be as follows:
Alternate Condition 1 (Based on PFC change-out Frequency)
GAC Change-Out Frequency (Days) 288 days
Annualized Carbon Change-out Cost $65,000 per year
Alternate Condition 2 (Based on PFC change-out Frequency)
GAC Change-Out Frequency (Days) 598 days
Annualized Carbon Change-out Cost $31,000 per year
PAGE 5
IK. 1.1 PILOT TEST REPORT
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2.0 INTRODUCTION AND BACKGROUND
2.0 INTRODUCTION AND BACKGROUND
PAGE 6
SARAA PILOT TEST REPORT
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2.0 INTRODUCTION AND BACKGROUND
2.0 INTRODUCTION AND BACKGROUND
2.1 Introduction
In the 2nd quarter of 2014, investigations overseen by EPA for the presence of Perflourinated Compounds
(PFCs) in drinking water across the United States, not presently regulated by EPA, determined that one of
these compounds, Perfluorooctane Sulfonic Acid (PFOS), was found in the United Water Supply System
at the interconnection with the Harrisburg International Airport water supply. The Health Advisory Limit
(HAL) for PFOS at that time was 0.2 ug/L. As a result of this finding, the interconnection between HIA
and United water was discontinued until additional investigations and actions could be taken to ensure
that these compounds are controlled below the established HALs.
In response, HIA issued a public notice as directed by PADEP to address this condition. Additionally and
in cooperation with PADEP, HIA took the following actions;
• Shut down Well #13 which was suspected as the source of the PFCs at that time
• Shifted groundwater supply to other active wells
• Flushed the entire water distribution system
• Tested groundwater supply wells for presence of PFCs
• Tested water distribution system for presence of PFCs
• Upon receiving results of groundwater supply well testing, shut down Wells #9 and #6 in addition
to Well #13
• Shifted all groundwater supply to Wells #4 and #12
• Began investigation of the source of the PFC contamination and treatment options to remove
them from water supply system and bring the system back online in normal operating mode
• Results of water supply testing for PFCs after the system flushing indicated the absence of these
compounds using Wells #4 and #12 as the source of supply at that time
The investigation and subsequent report for the control of PFOS in the drinking water at HIA was
finalized and submitted to DEP in late 2014. As a result emergency response actions were developed
including a sampling and analysis monitoring plan conducted by HIA and specific point of use treatment
actions were developed to address any future excursions of water quality above the HAL for PFOS and
PFOA in the HIA Drinking water system.
Additionally, HIA initiated an investigation of the use of granular activated carbon for application at HIA
to resume normal source water pumping operations suspended due to the presence of PFCs in the primary
source water supply wells used onsite.
HIAs key objective for the investigation of treatment options was to determine the most cost effective
means to provide quality water in a reliable manner to address and return the system to normal operation
including the interconnection with United Water. Based on the work conducted to date, the addition of
activated carbon filtration as a polishing system is recommended to provide HIA with a treatment system
that is capability of meeting the water quality requirements consistently and which can be installed and
operated effectively in the existing plant.
However, since the use of activated carbon on PFC removal was a relatively new application at the time,
it was recommended during meeting with PADEP and EPA that a small, portable well head pilot
treatment system be installed and operated to obtain necessary site specific operating parameters to design
a full scale treatment plant upgrade.
PAGE 7
SARAA PILOT TEST REPORT
-------
2.0 INTRODUCTION AND BACKGROUND
The purpose and intent of the pilot test was as follows:
• Pumping test for Well #9 to assess impact on controlling PFC migration in adjacent wells.
• Comparison of two types of granular activated carbon at an operating source well contaminated
with PFCs to access contaminates removal capability and cost effectiveness.
• Develop site specific design criteria for long term use of granular activated carbon for source
water treatment at the HIA water treatment plant.
The pilot test for the treatment of PFC contaminated groundwater with granular activated carbon filters
from Well #9 was started on July 18, 2016 and operated continuously until October 17, 2016 when
pumping was terminated. Samples from Well #9, Well #6 and Well #12 were monitored after the pilot
test pumping was discontinued to monitor for rebound.
The source of the PFC contamination onsite has not be verified but prior to the test it was suspected that
the use of firefighting foam at the airport that contained these compounds in concentrations ranging from
0.5% to 2.0% was a potential source.
In May 2016 the EPA revised the HAL for PFOS and PFOA to 70 ppt from the previous levels of 200
ppt. As a result, the laboratory test procedures were modified and the detection level for these
compounds was lowered below the previous HAL level of 200 ppt. This resulted in historic data that had
previously indicated Non Detect levels of these compounds possibly having concentrations above the new
HAL Limit when compared to present data. This change in detection level is noted in the data but historic
data prior to May 2016 indicating Non Detect levels of PFCs in some of the sample locations may not be
effectively assessed against the data collected after May 2016.
2.2 Background
A potential source of the PFC contamination onsite was the use of firefighting foam at the airport that
contained these compounds in concentrations ranging from 0.5% to 2.0%, depending on the manufacturer
and type of foam used. The foam was used primarily for firefighting equipment operational testing, in
accordance with FAA requirements. An analysis of the use of PFC firefighting foam for this potential
source was undertaken.
The analysis indicated that firefighting foams containing PFCs were bought and used at the airport site
starting approximately in 1975 according to purchasing records. These purchases have continued to date
with unused drums of this foam presently onsite. Current operational procedures have been put in place
to collect the foam in container when testing equipment operations. The only uncontrolled use of this
foam would occur in the event of an actual firefighting event.
Approximately, 6,500 gallons of foam containing PFCs has been purchased since 1975, of that amount
approximately 660 gallons remains onsite unused.
Based on assumptions concerning the composition of the various products purchased, this volume of
foam would contain approximately between 168 to 932 pounds of total PFCs (see the Appendix for
additional details). It is not possible to distinguish the individual PFC compounds, specifically PFOS or
PFOA the two compounds that presently have established HALs, from the manufacturer information
provided. Also, some manufacturer data does not list specific PFC composition ranges since they list
PAGE 8
SARAA PILOT TEST REPORT
-------
2.0 INTRODUCTION AND BACKGROUND
them as proprietary information. For these cases an assumed range of concentration based on similar
products was used in the analysis.
Present site data indicate that contamination may be centered in the area of the Fire House and Well #9
(see "Harrisburg International Airport Water Wells" located at the end of this section for source well
locations). Based on the sampling event for PFCs conducted starting in June of 2014, PFCs were
measured in wells #6, #9 and #13 above the health advisory limits in effect at the time of the sampling.
The available data indicates a total mass of documented PFC actually used on site for firefighting
purposes may be between 140 and 845 pounds. Since the groundwater wells have been pumping since
approximately 1990 when the treatment plant was installed, a portion of this mass of PFCs has likely been
removed through this pumping. It is not possible to determine how much remains in the subsurface since
it is highly miscible and mobile in groundwater.
The use of carbon in the pilot treatment system was based on a review of applicable treatment
technologies and EPA published data indicating that activated carbon treatment is a viable technology for
the removal of PFCs in water treatment facilities and is compatible with the site specific conditions and
operating requirements. The applicability of activated carbon adsorption to address PFC contamination
was also discussed during our meetings with DEP and EPA and is described by EPA Fact Sheet 505-F-
11-002 May 2012 in the Appendix).
During a meeting in 2014 EPA discussed that a water treatment plant in Minnesota was using carbon
filtration on their water supply effectively, however no confirmatory information or publically accessible
reports on this system were identified or were able to be obtained to assess the applicability at HIA for a
similar treatment approach.
Other than activated carbon, both powdered (PAC) and granular (GAC), there have been studies that have
indicated the potential for treatment using coagulation and precipitation, reverse osmosis and ion
exchange. These technologies were reviewed and determined to be cost prohibitive for application at
HIA. Some research data indicates other adsorption media have had some success in removing PFCs but
do not have the extent of application experience in water treatment as does PAC and GAC. For purposes
of the control and treatment plan, GAC was selected for further investigation over PAC since it is less
difficult and costly to install and operate than PAC at HIA.
The primary concern in the application of GAC for removal of PFCs in low concentrations is the
adsorption capacity for these compounds. The adsorption capacity impacts the carbon change out
frequency, size of the carbon filtration system and resulting capital and operating costs. Since little
information was available on actual operating systems removing PFCs from groundwater using GAC in
2014 and, in general, GAC adsorption capacity can be impacted by site specific conditions, a well head
pilot test was plan was developed and submitted to DEP in August 2015 for review and final PADEP
approval for the test was received on July 12, 2016.
In accordance with the approved August 2015 Pilot Test Plan, a well head test was implemented at Well
#9, the well with the highest concentrations of PFCs found in the June 2014 sampling event. The flow
rates proposed for the test were to exceed what would be a typical annual flow consistent with historic
withdrawals to assess both the impact on adjacent source wells and to obtain relevant operational data on
the use of GAC as a treatment technology.
PAGE 9
SARAA PILOT TEST REPORT
-------
2.0 INTRODUCTION AND BACKGROUND
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PAGE 10
SAR4A PILOT TEST REPORT
-------
2.0 INTRODUCTION AND BACKGROUND
2.3 Source Well PFC Data
LABORATORY BACKGROUND INFORMATION
The testing for PFCs in drinking water supplies was started nationwide in 2014 based on a PFOS HAL of
0.2 ug/L and a PFOA HAL of 0.4 ug/L. The samples initially collected were analyzed using Method 537
by ALS laboratories based on the following Reporting Detection Limits;
Laboratory Limits - Starting June 2014 to August 2016
PFOS
PFOA
PFNA
PFHXS
PFHPA
PFBS
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
RDL
0.0385
0.0192
0.0192
0.0288
0.0096
0.0865
In May of 2016 the EPA revised HALs were lowered for PFOS and PFOA to 0.070 ug/L. The revised
HAL also reduced the limit for the total concentration of both compounds to 0.070 ug/L. A modified 537
analytical method Rev. 1.1 was developed by EPA used for the analysis of PFCs based on the revised
HALs. This new method was used for reporting PFCs at HIA starting in August of 2016. The revised
method reporting and quantification limits for the data presented starting in August 2016 are as follows;
Laboratory Limits - Starting August 2016
PFOS
PFOA
PFNA
PFHXS
PFHPA
PFBS
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
MDL
0.005
0.001
0.001
0.004
0.001
0.004
LOQ
0.010
0.002
0.002
0.010
0.002
0.010
QUARTERLY SOURCE WATER SUMMARY
The following graphs summarize the quarterly average concentration of PFOS and PFOA in the source
wells from 2014 to present. The information in the attached graphs includes the contaminant
concentrations, the average monthly withdrawal from the well in Million Gallons and the HAL for PFOS
and PFOA.
PAGE 11
SARAA PILOT TEST REPORT
-------
2.0 INTRODUCTION AND BACKGROUND
- Monthly Withdrawal
(Avg. MG)
o
s
WELL #1 QUARTERLY SUMMARY PFOS and PFOA
-*¦—Perfluorooctanesulfonic acid PFOS HAL — -ir- - Perfluorooctanoic acid PFOA HAL —~—Monthly Withdrawal
PFOS PFOA (Avg. MG)
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WELL #2 QUARTERLY SUM MARY PFOS and PFOA
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PFOS
0.45
PFOS HAL
- - Perfluorooctanoic acid
PFOA
PFOA HAL
0.60
PAGE 12
SAR4A PILOT TEST REPORT
-------
2.0 INTRODUCTION AND BACKGROUND
- - Perfiuorooctanesulfonic acid
PFQS
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WELL #4 QUARTERLY SUMMARY PFOS and PFOA
PFOS HAL - -a- - Perfluofooctanoic acid PFOA HAL
PFOA
Monthly Withdrawal
(Avg. MG)
WELL #6 QUARTERLY SUMMARY PFOS and PFOA
Perfluorooctanesulfonicaeid PFOS HAL - - Perfluorooctanoic acid PFOA HAL —Monthly Withdrawal
PFOS PFOA ( Avg, MG)
8
>. 0.2000
0.0000
0.4500
PAGE 13
SAR4A PILOT TEST REPORT
-------
2.0 INTRODUCTION AND BACKGROUND
WELL #9 QUARTERLY SUMMARY PFOS and PFOA
- «- - Perfiuorooctanesulfonic acid PFOS HAL - - Perfluorooctanoic acid PFOA HAL —•—Monthly Withdrawal
PFOS PFOA (Avg. MG)
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-------
2.0 INTRODUCTION AND BACKGROUND
WELL #12 QUARTERLY SUMMARY PFOS and PFOA
—Perfluorooctanesufforiic acid PFOS HAL Perfluorooctanoicacid PFOA HAL —~—Monthly Withdrawal
PFOS PFOA (Avg. MGD)
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-------
2.0 INTRODUCTION AND BACKGROUND
2.4 Technical References
The following is a partial list of the references that were used in preparation of this document.
• "Sorption ofperfluorinated compounds from contaminated water to activated carbon " Journal of
Soils Sediments (2010) 10:179-185, DOI 10.1007/sl 1368-009-0172-z. Mona C. Hansen; Marion
H. Borresen; Martin Schlabach; Gerard Cornelissen
• "Engineering and Design - ADSORPTION DESIGN GUIDE"; Department of the Army, U.S.
Army Corps of Engineers; Design Guide No. 1110-1-2; March 2001
2.5 Pilot Test Organization
The following is a list of the organizational contact (POCs) for the pilot test for informational purposes.
SARAA - (Owner)
Dave Spaulding - Deputy Director for Engineering and Planning
717-948-3900
dspaulding@saraa.org
Scott Snoke - Utility Program Manager
717-948-3900 extension #4608
Scott.snoke@saraa.org
Jessica Silcox - Environmental Program Manager
717-948-3900 extension #4607
Glace Associates, Inc. - (Engineering Consultant to SARAA)
Thomas Galatro - Project Manager
717-731-1579 (office)
717-944-1144 (cell)
tomg@glaceeng.com
Kevin Jacobs - H&S / Permitting Manager
717-731-1579 (office)
ke vin@glaceeng. com
Advantage Engineers - (Hydrogeologist Consultant to SARAA)
Patrick R. Cummings, P.G., LSRP - Sr. Project Manager/Hydrogeologist
856-231-0800 (o) ext. 240
215-870-1706 (m)
PCummings@advantageengineers.com
PAGE 16
SARAA PILOT TEST REPORT
-------
2.0 INTRODUCTION AND BACKGROUND
2.6 Pilot Test DEP and Analytical Laboratory Contacts
The following is a list of organizations that require coordination during planning, permitting and testing.
PADEP
Jay E. Patel, P.E.
Environmental Engineer Manager
Clean Water Program
717-705-4803
Thomas J. Filip III, P.E.
Environmental Engineer
Safe Drinking Water Program
717-705-4941
J. Pascal Kwedza
Permits Section
Clean Water Program
717-705-4815
Analytical Laboratories used in Test Program
ALS Global
Amy K. Borden
Project Coordinator
ALS Life Sciences Division / Environmental
24 Dogwood Lane
Middletown, PA 17057
717-944-5541 x3131
Eurofins Lancaster Laboratories Environmental, LLC
Jeremy Young
Senior Account Manager
2425 New Holland Pike
Lancaster, PA 17601
717-693-5814
i eremvY oung@,eurofinsU S .com
PAGE 17
SARAA PILOT TEST REPORT
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3.0 Test Description and Operational Summary
3.0 TEST DESCIPTION AND OPERATIONAL SUMMARY
Page 18
-------
3.0 Test Description and Operational Summary
3.0 TEST DESCRIPTION AND OPERATIONAL SUMMARY
3.1 Test Objectives
• Well #9 Pumping Impact on Adjacent Wells
Well #9 was pumped at higher than historic rates to determine if pumping the well would mitigate
movement of PFCs in the groundwater toward Well #12.
• Site Specific Carbon Utilization Rate
Determination of the site specific Carbon Utilization Rate for PFCs to supplement existing data
on carbon adsorption of PFCs. This utilization data will be used for the design of treatment
system approaches utilizing GAC to address the PFCs found in the groundwater at HIA
• Comparison of GAC Types on PFC Treatment and Operating Cost
Site specific carbon utilization rates for both coal and coconut based GAC to determine the most
cost effective media for use at HIA. Virgin coal based GAC has been used for the treatment of
PFCs at a similar site located in Warminster, PA. Virgin coconut based GAC is less expensive
per pound than the coal based material but does not have the same extent of operational data for
PFC removal available to assess a reliable utilization rate for the design of a full scale system.
• Site Specific Design Basis Criteria
The data from the above 3 objectives along with the pilot system operating parameters will be
used for the design of treatment system approaches utilizing GAC to address the PFCs found in
the groundwater at HIA.
3.2 Pilot System Description
The pilot system test consisted of equipment and controls to transfer groundwater from the existing Well
House #9 using a new submersible well pump with a variable speed control. The groundwater was
pumped and the flow rate monitored and controlled through two parallel carbon adsorption units. The
first, GAC #1A, utilized a virgin coal based GAC for treatment of PFCs. The second, GAC #2A, utilized
a virgin coconut based GAC for treatment of PFCs. Both units discharged to polishing carbon filters
containing the same carbon as the lead vessels before being discharged to industrial storm water Outfall
#5. The following Figure 1 depicts the flow scheme of the pilot system.
Water flow from Well #9 was monitored by an influent flow meter (FM1) prior to being split between the
two parallel carbon adsorption treatment trains. The total influent flow from Well #9 was controlled by
adjusting the speed of the submersible pump and by adjusting the flow control valve (VI). The flow
meter included an instantaneous flow rate indicator and a flow totalizer. Both instantaneous flow rate and
totalized flow were recorded daily. Following the influent flow meter and control valve, influent water
was sampled using Sample Point A.
The influent pressure to each train was monitored by dial pressure gauges (PI1 and PI4). These pressure
gauges were monitored and recorded daily.
Valves V2 and V3 were opened 100% and influent well water was then split between GAC 1A (coal
based GAC unit) and GAC 2A (coconut based GAC unit), the lead GAC units for both treatment trains.
Page 19
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3.0 Test Description and Operational Summary
As treated water was discharge from the two lead units, pressures were monitored and recorded daily
from each using dial pressure gauges (PI2 and PI5). Treated effluent from these lead units was also
sampled using Sample Points B and C.
FIG. 1 ¦ PILOT TEST SYSTEM PROCESS FLOW DIAGRAM
Effluent from the lead units (GAC 1A and GAC 2A) then flowed to the lag units for each train, GAC IB
and GAC 2B respectively.
Following treatment through the lag units, treated water flowed out of GAC IB and GAC 2B. The flow
rates through each treatment trains was controlled by control valves CV4 and CV5 and instantaneous flow
rate and totalized flow monitored and recorded daily using flow meters FM2 and FM3. Effluent pressure
was monitored and recorded daily using dial pressure gauges PI 3 and PI6. Discharge from each lag unit
was sampled using Sample Points E and F.
Once per month a total discharge sample was taken from Sample Point D for use in a Discharge
Monitoring Report submitted to DEP in compliance with a temporary discharge permit.
Page 20
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3.0 Test Description and Operational Summary
3.3 Test Equipment
The following is a list of the equipment used for the pilot system;
Unit
Description / Comments
Well Pump
Well Pump, Manufacturer : Grundfos 230s200-6 Submersible 20HP VFD
Max. Flow 220 gpm Design Head 225 Ft TDH
GAC #1
Model# TIGGCP-5000
GAC: TIGG 5D 1240 virgin coal based carbon - 5,000 lbs. charge
GAC #2
Model# TIGG CP-5000
GAC: TIGG 5DC 1240 virgin coconut based carbon - 5,000 lbs. charge
FM #1, #2 and #3
Blue-White F-1000 Series Paddlewheel Flow Meter
GAC #3
Model# TIGG CP-5000
GAC: TIGG 5D 1240 virgin coal based carbon - 5,000 lbs. charge
GAC #4
Model# TIGG CP-5000
GAC: TIGG 5DC 1240 virgin coconut based carbon - 5,000 lbs. charge
3.3 Test Description
Prior to the start of the test, the existing well level sensors and the Well #9 pump were inspected and
tested. This inspection and testing of the existing Well #9 well pump determined that due to the age of
the pump and long period of inactivity, it would not be able to meet the requirements of the test and future
pumping needs. The inspection also indicated that some of the existing well level sensors and monitoring
system were not operable and would not be able provide adequate data to meet the objectives of the test.
The Well #9 pump was removed and replaced by a new submersible pump with a variable speed drive to
provide the same pumping characteristics of the existing pump.
The level sensors in all the wells were all inspected and their operation verified. The level sensor in Well
#9 was replaced along with the pumps as described. For the test, data loggers were added to the level
controls for Wells #6, #9, #11, #12 and #13.
The 4 individual carbon columns were rental units from a TIGG, LLC a carbon system supplier. The
carbon columns were filled with the specified carbon prior to shipment to the site by TIGG, LLC. The
influent and effluent manifolds with the valves, sample taps, flow meters and pressure indicators were
also prefabricated by TIGG, LLC and shipped to the site with the carbon columns.
When the carbon columns and piping manifolds arrived onsite they were unloaded and the system
installed by Eichelbergers, Inc.
Pre-Test Carbon Wetting. Air Purging and Initial System Start-Up
After the pilot system was installed, the Well #9 pump was used to fill and purged air from the carbon
vessels. Once the units were filled and purged of air they were allowed to stand and wet the carbon as
directed by the carbon manufacturers.
After the units were prepared for operation, the well pump was started up and the air purging valves on
the units remained opened until all air was released from all system piping and the carbon units. After the
Page 21
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3.0 Test Description and Operational Summary
air was purged, the purge valves were closed and the control valves for GAC units #1A and #2A adjusted
until the desired system flow was achieved per the operating plan.
Pilot Test GAC Operation
Step Draw-Down Pump Test;
Procedures for the pumping test steps were as follows:
1. Record the rest water level in Wells.
2. Obtain initial water quality parameters from Wells, dissolved oxygen (DO), pH, oxidation-
reduction potential (ORP), conductivity, temperature, and turbidity.
3. Set the pump at the first discharge rate.
4. Monitor water levels in wells utilizing pressure transducers.
5. Monitor of water quality parameters from Wells for each step of the drawn-down test.
6. Collect samples for PFC analysis from Wells.
7. Monitor discharge rate of the pump
8. After the pump step is complete (24 hours), adjust the pumping rate to the next step.
9. Repeat procedures until last step has been completed.
GAC Utilization Test:
After the completion of the step draw down test, the system flow rate was set for the carbon
utilization test. The flow rate chosen for the Well #9 pilot carbon utilization test was based on the
step down test results and the capacity of the well pump. The Well #9 flow rate setting used for
the test was 180 gpm.
During this phase of the test the effluent from both lead columns was monitored to ensure there
was no breakthrough of PFCs above the HAL to the lag columns before the end of the 90 day test
was complete.
Page 22
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3.0 Test Description and Operational Summary
3.4 Operational Summary
The following is a summary of the Pilot System Operating Schedule for the test that was conducted in the
field;
Test
Phase
Test Day
(Date)
Well #9 Avg.
Flow (gpm)*
GAC 1 Avg.
Flow (gpm)*
GAC 2 Avg. Flow
(gpm)*
Step Test
1 (7/18/2016)
82
-
-
Step Test
2 (7/19/2016)
48
30
28
Step Test
3 (7/20/2016)
104
53
55
Step Test
4 (7/21/2016)
157
87
79
Step Test
5 (7/22/2016)
261
129
148
Step Test
6 (7/23/2016)
233
136
112
Step Test
7 (7/24/2016)
231
125
119
Operating
8 (7/25/2016)
Thru
92
(10/17/2016)
181.3
96.2
94.5
* Flow rates are averages based on manual flow totalizer readings averaged over the time between
readings. Over the course of the test the readings were within 95% accuracy between the test totals for
Well 9 and the sum of GAC 1 and GAC 2.
The following is the Well and GAC Treatment System Sampling Schedule for the test that was conducted
in the field;
Test
Phase
Test Day (Date)
PFC Samples Taken
VOC Samples Taken
Baseline
-3 (7/15/2016)
Wells 6,9,12
Wells 6, 9
Step Test
1 (7/18/2016)
Wells 6,12 GACPts.
A
Step Test
4 (7/21/2016)
Wells 6,12 GACPts.
A
Operat
nq
8 (7/25/2016)
Wells 6,12, GAC Pts.
A,B,E,C,F,D
Wells 6, 9, 12 GAC Pts.: D
Operat
nq
22 (8/8/2016)
Wells 6,12, GAC Pts.
A,B,E,C,F,D
Wells 6, 12 GAC Pts.: A,E,F,D
Operat
ng
36 (8/22/2016)
Wells 6,12 GACPts.
A,B,E,C,F
Operat
ng
43 (8/29/2016)
Wells 12 GAC Pts.: A,B,C
Operat
ng
47 (9/2/2016)
Wells GAC Pts.: A,B,C
Operat
nq
51 (9/6/2016)
GAC Pts.: A,B,E,F,D
Operat
nq
53 (9/8/2016)
Wells GAC Pts.: A,B,C
Operat
ng
57 (9/12/2016)
Wells 6, 12 GAC Pts.: A,B,C
Operat
ng
60 (9/15/2016)
Wells GAC Pts.
A,B,C
Operat
ng
64 (9/19/2016)
Wells GAC Pts.
A,B,E,C
Operat
nq
67 (9/22/2016)
Wells GAC Pts.
B,C
Operat
nq
71 (9/26/2016)
Wells GAC Pts.
A,B,E,C
Operat
nq
74 (9/29/2016)
Wells 12 GAC Pts.: A,B,C
Operat
nq
78 (10/3/2016)
Wells GAC Pts.: A,B,E,C,D
Operat
nq
88 (10/13/2016)
Wells 6,12 GAC Pts.: A,B,E,C,F
Operat
nq
92 (10/17/2016)
Wells 6,12 GAC Pts.: A,B,E,C,F,D
Post Test
102 (10/27/2016)
Wells 6, 9,12
Wells 6,12 GAC Pts.: A
Post Test
109 (11/3/2016)
Wells 6, 9,12
Wells 6,12 GAC Pts.: A
* Well 9 samples and GAC Point A samples are from the same source. During the test samples were
identified as Point A, before and after the test the samples are identified as Well 9.
Page 23
-------
3.0 Test Description and Operational Summary
The following graphs summarize the results of the pilot test operation for PFC concentration in the source
wells during the pilot test.
PILOT TEST SOURCE WELL PFC CONCENTRATION SUMMARY
The following graphs summary the concentrations of PFCs in Wells #6, #9 and #12 during the pilot test
pump and treat testing of Well #9.
Well #6 PFC CONCENTRATIONS DURING PILOT TEST
-PFOS
-PFHPA
-PFOA
PFBS
-PFNA
-Well #9 Flow
-PFHXS
S
u
0.00
0.270
1 *]
\
PFOS/PFOA HAL = C
.070 u
g/L
0.261
1
3.220
3.220
1
I
1
HH
a ¦
y
H
5
K
s
Q£
200 a
E
50
to
vD
kD
iC
V,
tJ
tJ
ti
9
o
o
o
N
(S
Page 24
-------
3.0 Test Description and Operational Summary
WELL #6 TOTAL PFC CONCENTRATION
RAINFALL - WELL #9 TEST FLOW
0,20
- TOTAL PFCs
-Rainfall
-PFOS Plus PFOA
-Daily Flow
0,6977
\
D.567
N.
D.524^
0.3106
\
i
.248
0.239
i /
i /
• /
V
!
ii /
i
1 »
%
*
•1
. ! i
» ,
/V'
i\
i i
/--V \.J
I
V
v ¦ ¦
a
H
"5 |
cf> %
to «fi
4 H W p
3 3
5 3 3*
1 10 A IS
p oe w da
S 3 !
U> W t0 U> t
a. & 'fit. jab- i
X X £ J1 <
A A A 4. 2
l£ U» i
i 9
J <
ID
i
8
73
7
6,5
r a
b (fj
2
5.5
0
5 s
4.5 £
$
4 i
3-5
wt
01
3 -g
c
2.5 =
42
2 I
cc
1,5
1
0.5
0
WELL #9 PFC CONCENTRATIONS DURING PILOT TEST
-~-PFOS PFOA —»-PFNA -K-PFHXS
—4—PFHPA —PFBS Well #9 Flow
Page 25
-------
3.0 Test Description and Operational Summary
WELL #9 TOTAL PFC CONCENTRATION
RAINFALL - WELL #9 TEST FLOW
-•-TOTAL PFCs
-—--Rainfall
-PFOS Plus PFOA
-Daily Flow
Page 26
-------
3.0 Test Description and Operational Summary
WELL #12 TOTAL PFC CONCENTRATION
RAINFALL - WELL #9 TEST FLOW
—TOTAL PFCs
-•Rainfall
0.08
M
Q.
a
0.05
0.04
0.02
0.01
0.00
-PFOS Plus PFOA
-Daily Flow
0 078
0.062
0.041
J.049
0
034 ^
l/
D.025
1 » /
1 * /
1 I
IP1 / /
111 / J
/l
1
1
I
i
i
\
.. .±.
11 //
^ j|l //
1
!
is
?. -
*"
/ta'l
,,v-
A
M
Jit/
L..
\ j ! *i
11
Jl L
• *
Ay
• ^
4.5 O
3.5 ju
Page 27
-------
4.0 Granular Activated Carbon Adsorption Test Results
4.0 GRANULAR ACTIVATED CARBON ADSORPTION TEST RESULTS
Page 28
-------
4.0 Granular Activated Carbon Adsorption Test Results
4.0 GRANULAR ACTIVATED CARBON ADSORPTION TEST RESULTS
Charts in the previous section summarize the Granular Activated Carbon Adsorption Test influent
concentrations from Well #9 for all analyzed PFCs. As shown in the charts for Well #9, the pre-test
concentrations were non-detect due to the length of time the well was not pumped. Upon the start of the
pump test phase, the concentrations increased to more than twice the concentrations that were observed in
the well when the PFCs were first observed in 2014. These high concentrations continued for
approximately 30 days before they eventually leveled off to the original 2014 concentrations.
Upon completion of the test and shut of Well #9 pumping, the PFC concentrations dropped significantly,
but remained above the new HAL for approximately 30 days after the conclusion of the test. No
additional data was available after the November 3, 2016 sampling event at the time of the writing for this
report.
The Well #9 influent PFC concentrations as shown in charts resulted in a test mass loading to the GAC
columns significantly greater than the original loading assumptions contained in the test protocol.
During the test VOCs in Well #9 were sampled along with the PFC sampling. The VOC sampling of the
Well #9 influent resulted in only 1 sample, taken on September 9, 2016, indicating a detectable VOC
concentration for Trichloroethylene at 0.52 ug/L. Subsequent samples for VOCs in the influent of Well
#9 were non-detectable for all tested compounds including Trichloroethylene.
Upon completion of the test and discontinuance of pumping from Well #9, a single sample after the test
was complete indicated a concentration of 1.2 ug/L of Toluene on October 27, 2016 but again, subsequent
samples were non-detect in Well #9 for all VOCs including Toluene.
AT NO TIME DURING THE TEST WERE PFCS OR VOCS DETECTED IN THE SEWER
DISCHARGE ABOVE NON-DETECTION CONCENTRATIONS.
The following charts show the performance of the lead columns of each test train (coal and coconut).
This data was used to assess the adsorption capacity of the two types of carbon for development of the
basis of design for a facility upgrade to carbon treatment at the Water Treatment Plant.
The graph entitled "Pilot System Lead Column PFOS + PFOA Effluent Concentrations" shows the two
PFCs with EPA established HAL (PFCs of Concern) in the effluent of each of the lead GAC columns in
relation to the test flow. The lead column effluents were sampled before the flow was sent to the
polishing or lag columns for final treatment before discharge. This ensured that at no time were PFCs
above HAL were discharged to the storm sewer since the time lag between sampling and laboratory
reporting was typically 3 weeks. As the results show, the lead or test columns discharges also never
exceeded the HAL indicating the polishing columns were never loaded above HAL during the entire test
duration.
The second graph entitled "Pilot System Lead Column PFOS + PFOA Performance" shows the same
effluent data for the lead column effluents but in relation to the influent concentrations of PFOS plus
PFOA.
The third graph entitled "Pilot System Lead Column Total PFC Performance" show the lead column
effluent for Total PFC concentrations in relation to the total PFC influent concentrations.
Page 29
-------
4.0 Granular Activated Carbon Adsorption Test Results
PILOT SYSTEM LEAD COLUMNS PFOS + PFOA EFFLUENT CONCENTRATIONS
3 0,07 HAL
E 0.04
3
<
o
-•-GAC 1A (Coal) Effluent Sample Pt. B
—GAC 1 Flow gpm
-x-GAC 2A (Coconunt) Effluent Sample Pt. C
——GAC 2 Flow gpm
PFOS + PFOA HAL = 0.070 ug/L
PILOT SYSTEM LEAD COLUMNS PFOS PLUS PFOA PERFORMANCE
-GAC 1A (Coal) Effluent Sample Pt. 8
-Pilot System Influent - PFOS Plus PFOA
-GAC 2A (Coconunt) Effluent Sample PC, C
5.00 8
Page 30
-------
4.0 Granular Activated Carbon Adsorption Test Results
PILOT SYSTEM LEAD COLUMNS TOTAL PFC PERFORMANCE
—X—GAC 1A (Coal) Effluent Sample Pt. B * GAC 2A (Coconunt) Effluent Sample Pt. C
—•— Pilot System Influent - Toial PFC
0.20
6.000 =
1
Page 31
-------
GAC ADSORPTION TEST SUMMARY
Page 32
-------
5.0 GAC Adsorption Test Summary
5.0 GAC ADSORPTION TEST SUMMARY
In the pilot test plan development a number of assumptions were used based on the limited technical data
available on the removal of PFCs using GAC. The following table illustrates the test design basis with
the results of the test for the key parameters associated with GAC performance for the removal of PFCs.
TEST DESIGN BASIS
ACTUAL TEST DATA
Flow
GAC #1A (Coal)
GAC #2A (Coconut)
50 gpm
50 gpm
95.5 gpm (avg.)
93.8 gpm (avg.)
Test Duration
90 days
92 days
Carbon Charge
GAC #1A Coal
GAC #2A (Coconut)
5,000 lbs
5,000 lbs
5,000 lbs
5,000 lbs
Average Mass Loading Rate - Total PFCs
GAC #1A Coal
GAC #2A (Coconut)
0.001797 lbs/day
0.001797 lbs/day
0.00629 lbs/day
0.00615 lbs/day
Est. time to PFOS Initial Breakthrough Limit
0.040 ug/L Note 1
GAC #1A Coal
GAC #2A (Coconut)
31 days
31 days
to j Note 2
78 days
^ m j Note 3
> 92 days
Total PFCs to PFOS Breakthrough Limit
GAC #1A Coal
GAC #2A (Coconut)
0.0557 lbs
0.0557 lbs
0.4776 lbs
> 0.5231 lbs
Carbon Utilization (mg PFC/gr GAC)
GAC #1A Coal
GAC #2A (Coconut)
0.011138 mg/gram
0.011138 mg/gram
0.0955 mg/gram
> 0.1046 mg/gram
Note 1 - This breakthrough concentration is based on the RDL for PFOS (0.040 ug/L) at the time of the
Test Protocol Preparation. Since this breakthrough concentration is below the present HAL
(57% of the current HAL)for PFOS and PFOA, it is a realistic target to base the determination
that the carbon bed has been exhausted for the adsorption of PFCs and a GAC change out is
required..
Note 2 - The combined total of PFOS and PFOA concentration in the effluent from GAC #1A coal
exceeded 0.040 ug/L on day 71, the concentration of PFOS alone did not exceed 0.040 ug/L until
after day 78 and before day 88 of the test.
Note 3 - The combined total of PFOS plus PFOA in the effluent from GAC #2A coconut never exceeded
0.016 ug/L for the entire test duration. The concentration of PFOS never exceeded 0.013 ug/L
for the entire 92 days of the test.
The test data indicates a higher mass loading was achieved during the pilot test than the technical
literature estimated and as presented in the test plan. This will result in lower frequency of carbon
replacement in the development of a basis of design for a facility wide carbon treatment system.
The theorectical equilibrium constant used for PFOS in the development of the test protocol was 0.01726
mg PFOS / gr GAC utilized based on technical literature available at the time the protocol was developed.
There were two specific references used; (refer to test protocol submitted in 2014 for additional details)
1. Hansen/Borresen 2010 (J Soils Sediments -2010)
Page 33
-------
5.0 GAC Adsorption Test Summary
2. USEPA Drinking Water Treatability Database Perflnorooctane Sulfonate GAC Isotherm
Note: In the development of the theoretical equilibrium concentration (qe)0 as determined by the
Freundlich adsorption expression EPA values for K ranged from 5.1 to 50.9, the use of 2.73 for K from
the Hansen/Borresen study resulted in more conservative estimate and was used in the test protocol
estimate for time to breakthrough. Additionally, the test protocol assumed that PFOS and PFOA would
be the predominate PFCs present and would account for the total PFC loading.
Equilibrium Concentration (qe)0
(qe)o = KCj " qe = Quantity of adsorbate per unit of adsorbant (mg/'g)
(= Equilibrium concentration of adsorbate in solution (mg/'L)
K and n = Freundlich adsorption isotherm constants for a given
adsorbate at a given temperature
Based on the above reference material and the assumptions made for the constant values of K and n the
theoretical equilibrium used for the test protocol for breakthrough of PFOS was 0.01726 mg PFOS / gr
GAC utilized.
The wide range of theoretical carbon utilization rates resulting from variations in the theoretical derived
equilibrium concentration and other potential groundwater conditions resulted in the need to develop site
specific data to provide a realistic estimate of the operational parameters for the implementation of a GAC
treatment system at HIA to address PFC removal.
The following summarizes the development of the site specific equilibrium constants from the test data
for the development of a facility basis of design. Since other PFCs besides PFOS and PFOA were present
at significant concentrations in the test system influent, the site specific equilibrium concentrations
developed were based on the total PFC loading as sampled during the test which should be more
indicative of actual conditions for a full scale system.
Lead UnitCoal Based GAC #1A
Avg. PFC Inlet Concen. =
Total PFC Inlet Mass Loading Rate =
Total PFCs to Breakthrough at 0.04 ug/L =
Carbon Vessel Charge =
PFC Loading to Breakthru / lb GAC =
Equilibrium Concentration (qe)o =
0.005900 mg/L
5.900 ug/L
0.00629 lbs/day at design flow rate & concentration
0.4776 lbs total PFCs
5,000 lbs
0.0000955 lbs PFC/lb GAC utilized (74 days actual loading)
0.0955205 mg PFC/gr GAC utilized
12,578.830 gallons treated during test
10,781,866 gallons treated to Breakthru
The test results indicated an increase in the equilibrium concentration for the coal based carbon GAC of
4.5 times greater than the theorectical equilibrium concentration used in the test protocol.
Page 34
-------
5.0 GAC Adsorption Test Sum man
The coconut based GAC did not reach the breakthrough concentration 0.040 ug/L during the duration of
the test and a direct comparision of breakthrough loading between the two types of GAC could not be
done using the field test data.
The following is the analysis of the GAC estimated breakthrough loading had the test continued until
breakthrough to 0.040 ug/L for the coconut based GAC.
Lead Unit Coconut Based GAC #2A
Avg. PFC Inlet Concen. =
Total PFC Inlet Mass Loading Rate =
Total PFCs to Breakthrough at 0.04 ug/L =
Total Test PFC Loading =
Est. Days to Breakthru to 0.04 ug/L =
Est. PFC loading to Breakthru to 0.04 ug/L =
Est. Additional PFCs removed =
Carbon Vessel Charge =
Low Range PFC Loading to Breakthru / lb GAC =
Low Equilibrium Concentration (qeh =
High Range PFC Loading to Breakthru / lb GAC =
High Equilibrium Concentration (qe},D =
0.00b900 mg/L
5.900 ug/L
0.00615 lbs/day at design flow rate & concentration
Breakthru concentration not reached during test
0.5231116 lbs total PFCs
110 days (based on exptrapolation past day 92)
0.6338882 lbs PFCs fusing avg loading rate past day 92)
0.1107766 lbs
5,000 lbs
0.0001046 lbs PFC/lb GAC utilized
0.1046223 mg PFC/grGAC utilized
0.0001268 lbs PFC/lb GAC utilized
0.1267776 mg PFC/gr GAC utilized
12,409,879 gallons treated during test
13,758,779 Est. gallons treated To Breakthru
(92 days actual loading)
(110 est. loading)
The test results indicated an increase in the equilibrium concentration for the coconut based carbon GAC
of 6.3 times greater than the theorectical equilibrium concentration used in the test protocol.
Page 35
-------
6.0 Basis of Design for 111A Water Supply System
6.0 BASIS OF DESIGN FOR HIA WATER SUPPLY SYSTEM
Page 36
-------
6.0 Basis of Design for 111A Water Supply System
6.0 BASIS OF DESIGN FOR HIA WATER SUPPLY SYSTEM
The following basis of design was developed using the characteristics of the source water PFC
concentration from the second quarter of 2014 and the pilot test and the source water concentration for
VOCs and withdrawal rates from the fourth quarter 2013. This data was used since this was considered
representative of the last time the source wells were pumped without adjustment to control the
concentration of PFCs in the finished water and is the most recent VOC and PFC data available for the
source wells.
Note 1
Weil Number
Monthly Avg. Withdrawl 2nd
Qtr. 2014
% ofTotal Flow
Total PFCs
Benzene
Carbon Tetrachloride
Chlorobenzene
CD
£Z
CD
N
C
CD
jZi
O
o
¦C
o
b
CN
1,4-Dichlorobenzene
1,2-Dichloroethane
1,1-Dichloroethene
CD
cz
CD
.c
"CD
o
o
sz
o
b
CN_
tn
o
trans-1,2-Dichloroethene
1,2-Dichloropropane
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
Total Xylenes
1,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Vinyl Chloride
MG
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
1
0
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
0
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
0
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9
1.43
11%
3.7031
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11
0
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12
8.59
64%
0.175
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
3.4
25%
0.381
32.6
7.7
3.0
"ota I
13.42
Projected Flow and Concentration
Flow
MGD
1
0.000
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0.000
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
0.000
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
0.000
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9
0.055
11%
3.7031
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11
0.000
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12
0.330
64%
0.175
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
0.130
25%
0.381
0
0
32.6
0
0
0
0
7.7
0
0
0
0
0
0
0
0
0
0
0
3.0
0
"ota I
0.515
Flow Weighted Concentration
0.602S | 0 | 0 18.261 0 | 0 | 0 | 0 |1.95| 0|0|0|0|0|0|0|0|0|0|0 |0.76| 0
Note 2
Note 1 Based on average 2015 Pilot Test Concentrations
Note 2 Based on 2013/2014 Concentrations
Note 3 Based on 2013/2014 Concentrations
Based on the evaluation of the 2013 and 2014 data on source water as shown above, the design influent
and effluent for a WTP carbon adsorption system to replace the air strippers was developed. The
conceptual system would be a lead - lag arranged GAC system to treat source water at a maximum flow
rate of 715 gpm which is equivalent to pumping 0.515 MGD for 12 hours per day. If a higher treatment
flow rate is required either by increased water demand or a requirement to reduce source water well
pumping time to less than 12 hours per day, a second GAC lead - lag treatment train would be required.
The breakthrough effluent concentrations listed in the table below used for GAC system operation are
based on a conservative estimate for providing sufficient time to; first receive analytical results from the
laboratory and second to schedule a carbon change out. Since the system will be operated in a lead - lag
arrangement the water quality delivered to the water distribution system will always be free of any the
contaminants of concern since the lag column would be providing contaminant removal during the
interval between when the breakthrough concentration was reached and the GAC changed out of the lead
column.
Page 37
-------
6.0 Basis of Design for HIA Water Supply System
Design
Influent
Cone.
MCL
Effluent
Limits
Design
GAC
Breakthru
Effluent
Design
GAC
Effluent
CO
Lead Unit
C1
Lag Unit
PFCs
ug/L
0.60282
0.070
0.040
ND
Chlorobenzene
mg/L
0.00826
0.100
0.0005
ND
1,2-Dichlorobenzene
mg/L
0.00000
0.600
0.0005
ND
1,4-Dichlorobenzene
mg/L
0.00000
0.300
0.0005
ND
cis-1,2-Dichloroethene
mg/L
0.00195
0.070
0.0005
ND
Trichloroethene
mg/L
0.00076
0.005
0.0005
ND
PH
SU
8.3
6-9
8.5
8.5
Hardness
mg/L
200
NA
NA
NA
Based on this influent characterization and the breakthrough concentrations used to indicate GAC change
out, the WTP system carbon utilization was calculated for a WTP GAC system as shown below using the
results from the pilot test for the site specific equilibrium constant for total PFCs and the design basis for
GAC treatment of VOC contaminated water as contained in the USACE Design Guide 1110-1-2 (2001).
Please refer to the Test Plan for additional detail on the USACE Design Guide procedures used for VOC
treatment.
Carbon Utilization Rates - based on Low Equilibrium Concentration from Pilot Test for Coconut Based GAC
PFCs
(qefo
0.1046223
mg PFC/gr GAC utilized
as developed during pilot test
Carbon Usage Rate (CURi
CUR(g/L) =(C0-C1) 1 (qe)o
CURpFC
0.0053795
0.0000449
Ssftc/Lj^o -llsred
1S gac/S al HS3 =irerea
VOCs
Carbon Usage Rate (CUR)
CUR (g/L) =(C0-C1)/ (qe)j
(qek.
CUR
(mg/g)
(Qgac/Ltoo -iBeraa)
(IbSGAc'aalHIO FJItsrsd)
Chlorobenzene
3.269915
0.00237
0.0000198
1.2-Dichlorobenzene
14.640785
0.00000
0
1,4-Dichlorobenzene
3.3986095
0.00000
0
cis-1,2-Dichloroethene
0.1353859
0.01072
8.943E-05
Trichloroethene
0.2514893
0.00103
0.0000086
(qefo developed based on the following reference (see test protocol for additional information)
USACE Design Guide 1110-1-2 (2001)
Page 38
-------
6.0 Basis of Design for IIIA Water Supply System
Based on the above Carbon Utilization design basis, the bed life for a single GAC carbon column was
estimated as follows;
Basis of Design for GAC Application at the WTP -
Pre 2014 Withdrawal Rate
Treatment System
TreatmentTrains Used =
1
Lead/Lag
Flow Rate perTreatmentTrain =
715
gpm
Carbon Selection:
Secfic
Avg.
P
Surface
Particle
Apparent
Abrasion
Iodine #
Area
Size
Density
Number
Type mg/g
m2/g
^m
g/cc
TIGG 5DC1241 NSF Coconut 1100
1200
0.48
85
Carbon Vessel Selection
Carbon Vessel Capacity =
20000
lbs
10
ft. Diameter
9.33
ft. Bed Height
732
cf carbon
Design Flow Rate =
715
gpm
1.593850837
cfs
Hydraulic Loading Rate =
0.063754033
gpm/sf
Maximum Vessel Flow Rate =
750
gpm
1.671
cfs
0.06684
gpm/sf
Bed Volume =
233.25
cu. Ft.
MinimumBed Life per Train
(lbsGAC.i'galH20 Fittsrea!
Bed Life
Safety
Adjusted
Gallons
Days
Factor
CUR
Treated
Operation
Total PFCs
1.5
0.0000673
2.97E+08
288
Chlorobenzene
1.5
2.97033E-05
6.73E+08
654
1,2-Dichloro benzene
1.5
0
1,4-Dichlorobenzene
1.5
0
cis-1.2-Dichloroethene
1.5
0.00013414
1.49E+08
145
Trichloroethene
1.5
1.29441E-05
1.55E+09
1500
days
Breakthru at
145
Basis of Design for GAC Application at the WTP -
3rd Qtr 2016 Withdrawal Rate
Page 39
-------
6.0 Basis of Design for HIA Water Supply System
Basis of Design for GAC Application at the WTP - 3rd Qtr 2016 Withdrawal Rate
Flow Rate
WTP Production
Treatment Goal
The following is a summary ofWTP influent concentrations of PFCs andVOCs
and a projected WTP influent characterization based on a flow weighted avg. of contaminants
Well #9 concentrations are based on the average concentration during the pilot test. This was greater
than the 2014 concentration and therefore was used in the basis of design
The 2nd quarter of 20014 was the last time source well pumping was not adjusted to control PFC concentrations
and this used for withdrawal distribution from each of the source for the flow weighted average concentration
calculation.
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-------
6.0 Basis of Design for IIIA Water Supply System
Treatment System
TreatmentTrains Used =
1
Lead/Lag
Flow Rate per Treatment Train =
345
gpm
Carbon Selection:
Secfic
Avg.
P
Surface
Particle
Apparent
Abrasion
Iodine #
Area
Size
Density
Number
Type mg/g
m2/g
Mm
g/cc
TIGG 5DC 1241 NSF Coconut 1100
1200
0.48
85
Carbon Vessel Selection
Carbon Vessel Capacity =
20000
lbs
10
ft. Diameter
9.33
ft. Bed Height
732
cf carbon
Design Flow Rate =
345
gpm
0.768620072
cfs
Hydraulic Loading Rate =
0.030744803
gpm/sf
Maximum Vessel Flow Rate =
750
gpm
1.671
cfs
0.06684
gpm/sf
Bed Volume =
233.25
cu. Ft.
MinimumBed Life per Train
(I bSeAD'Q OIH2Q Fl fer&s)
Bed Life
Safety
Adjusted
Gallons
Days
Factor
CUR
Treated
Operation
Total PFCs
1.5
0.0000673
2.97E+08
598
Chlorobenzene
1.5
2.97033E-05
6.73E+08
1355
1,2-Dichlorobenzene
1.5
0
1,4-Dichlorobenzene
1.5
0
cis-1,2-Dichloroethene
1.5
0.00013414
1.49E+08
300
Trichloroethene
1.5
1.29441E-05
1.55E+09
3110
Breakthru at
300
days
Page 41
-------
GROUNDWATER PUMPING TEST RESULTS
Page 42
-------
7.0 Pumping Test Results
7.0
GROUNDWATER PUMPING TEST RESULTS
An evaluation groundwater flow, Well 9 capture zone, and potential for control of PFC concentrations in
site groundwater was conducted through a multi-stage pumping test. The initial phase included a step-
drawdown test to determine the optimal discharge rate for Well 9 during the PFC treatment system
operation. The second phase included a constant rate pumping test to support determination of
breakthrough for the GAC system, as well as evaluate potential impact of Well 9 pumping on Wells 6, 11,
12, and 13.
Step-drawdown pumping test results are presented on the following graph.
Harrisburg International Airport
Middletown, Pennsylvania
Well #9
Pumping Test
Step-Drawdown
A total of six different pumping rates were utilized during each step in the first phase pumping test. Each
step involved increasing the discharge rate based on Well 9 water level response and to stress the aquifer
without pumping the well dry. Results of the step-drawdown indicate the maximum discharge rate of 236
GPM that was achieved during the test greatly exceeded the Well 9 capacity. Drawdown observed during
the step test reached equilibrium while still maintaining sufficient water column above pump intake at
180 GPM. Therefore, the 180 GPM rate was chose for the constant rate pumping test and pilot treatment
system discharge rate.
Water levels in pumping well 9, and observation wells 6, 11, 12, and 13 were continuously monitored on
five minute intervals to determine if Well 9 pumping would be sufficient to control PFC concentrations in
Page 43
-------
7.0 Pumping Test Results
groundwater beneath the site, and also support determination of pilot treatment system breakthrough time.
As noted in the paragraph above, a constant rate of 180 GPM was chosen based on the results of the step-
drawdown test. Results of the constant rate pumping test are presented on the following graphs for Wells
6, 9, 11, 12, and 13 and show 24 hour daily average summaries of the source well water levels as
compared to the Well 9 pilot test pump flow rate, rainfall and river stage as recorded at Harrisburg
International Airport.
WELL #6 GROUND WATER ELEVATIONS
Well #6 -¦••-Rainfall Well 9 Flow gprn River Stage
Page 44
-------
7.0 Pumping Test Results
WELL U9 GROUND WATER ELEVATIONS
Well #9 -¦•"Rainfall Well 9 Flow gpm — River Stage
WELL #11 GROUND WATER ELEVATIONS
-Well #11Rainfall Well 9 Flow gpm —- River Stage
6
~V~^
3
.. .1 11 ! 1 "i 1 > I i • !! '
H/
H
i! • •
Jif?
mj'mm
i I £
= i a
£ * >
5 oc
Page 45
-------
7.0 Pumping Test Results
299.00
298.00
294.00
293.00
292.00
7/9/16 0:00 7/29/160:00 8/18/16 0:00 9/7/16 0:00 9/27/160:00 10/17/16 0:00 11/6/160:00
300.00
WELL #12 GROUND WATER ELEVATIONS
-Well ##12 --•--Rainfall Well 9 Flowgpm — River Stage
220.00
210.00
180.00
170.00
7/9/2016
WELL #13 GROUND WATER ELEVATIONS
Well #13--•--Rainfall Well 9 Flow gpm —<—River Stage
7/29/2016 8/18/2016 9/7/2016 9/27/2016 10/17/2016
11/6/2016
Page 46
-------
7.0 Pumping Test Results
The most significant drawdown induced by Well 9 pumping was observed in Well 12, with a drawdown
of +/- 4 feet, followed by Well 6, with a drawdown of +/- 3 feet. While rebound was observed in Well 13
water levels, no discernable change in drawdown was observed between the background monitoring water
level and both step-drawdown and constant rate pumping test water level. As can be seen in the graphs
the groundwater wells closest to Well 9 were the most impacted by the pilot test withdrawal rate.
Also evident on the groundwater level graphs was a gradual downturn in groundwater levels in each
observation well, with exception to Well 13. This may be related to the effect of Well 9 pumping, which,
as indicated by the data, indicate a significant amount of water being removed from storage. In addition,
the sustainable pumping rate, as determined during the step-drawdown test, in Well 9 was not sufficient to
overcome the volume of water in storage and induce significant drawdown in observation wells to reduce
PFC concentrations in those wells.
Groundwater geochemical readings were collected daily during the step-drawdown pumping test and
weekly during the constant rate pumping test to evaluate if changes were observed induced by Well 9
pumping. Groundwater geochemical parameter readings were collected following completion of sampling
at each proposed well sampling location. A Horiba U-22 multi-parameter water quality meter was
utilized to collect field indicator parameters. The groundwater geochemical parameters included dissolved
oxygen (DO), turbidity, oxidation-reduction potential (ORP), pH, specific conductivity and temperature.
PILOT TEST SOURCE WELL WATER QUALITY DATA SUMMARY
The following Tables for Pumping Well 9 effluent and pilot treatment system influent and effluent
display changes in groundwater chemistry during both the step-drawdown test and the constant rate
pumping test. The most notable changes over the course of both pumping test phases was the drop in
conductivity, ORP, and dissolved oxygen in Well 9 effluent. This indicates Well 9 pumping began to pull
groundwater from different regions of the bedrock aquifer that contain differing geochemical conditions
The following Tables for Wells 6, 9, 11, 12, and 13 are summaries of the source well water and pilot test
system water quality data as recorded at Harrisburg International Airport.
Page 47
-------
7.0
Pumping Test Results
Date
Time
Well 6
Test
Day
PH
SU
ORP
mV
Cond.
US/cm
Turb.
NTU
D.O.
mg/L
Temp.
°C
Baseline
T
12-JUI-16
Baseline
W
13-JUJ-16
6.82
160
1.01
34.2
3,73
17.8
Rump Test
1
M
18-Jul-16
10:10
7.06
141
1.03
22.9
3.85
19.2
PumpTest
2
T
19-JUI-16
9:28
7.37
126
0.99
26.3
1.02
19.8
PumpTest
3
W
20-Jul-16
9:23
6.8
158
1.04
19.2
4.85
18.7
PumpTest
4
Th
21-JUI-16
10:20
6.49
174
1.03
12.9
4.16
20.8
PumpTest
5
F
22-Ju 1-16
10:03
6.83
175
1.03
11
3.61
18
Operating
S
M
25-Jul-16
9:41
6.93
189
1
10.7
3.88
19.3
Operating
12
F
29-JUI-16
9:18
6.95
141
1
5.9
3.14
17.6
Operating
15
M
l-Aug-16
9:26
6.89
181
1.03
17.8
3.97
18.5
Operating
22
M
8-Aug-16
11:10
7.1
110
1.09
13.4
4.12
19.8
Operating
29
M
15-Aug-16
9:18
7.01
75
1.13
24.3
3.86
19.3
Operating
36
M
22-Aug-16
9:09
7.36
152
0.9
30.9
3.08
19.4
Operating
43
M
29-Aug-16
9:00
7.2
105
1.27
23.6
3.88
19.7
Operating
51
T
6-Sep-16
9:40
6.79
33
1.03
18.4
3.08
18.5
Operating
57
M
12-Sep-16
9:14
7.02
122
0.999
25.2
3.48
18.5
Operating
&4
M
19-Sep-16
953
7.23
132
0.972
27.8
3.89
18.4
Operating
70
S
25-Sep-16
9:14
7.16
101
0.9
10.4
3.52
17.21
Operating
78
M
3-Oct-16
9:09
7.51
291
0.94
23.35
3.4
23.24
Operating
86
T
ll-Oct-16
8:15
7.62
159
0.999
29.43
3.36
16.51
Operating
92
M
17-Oct-16
9:30
7.66
175
0.999
16.4
3.63
17.56
Date
Time
Well 9 - System Influent Sample Pt. A
Test
Day
PH
SU
ORP
mV
Cond.
US/cm
Turb.
NTU
D.O.
mg/L
Temp.
°C
Baseline
T
12-Jul-16
Baseline
W
13-Jul-16
7.33
168
0.957
20.8
3.12
17.2
PumpTest
1
M
18-Jul-16
10:10
7.21
173
1.22
19.6
4.1
16.9
PumpTest
2
T
19-JUI-16
9:28
7.3
248
1.18
10.3
3.54
16.4
PumpTest
3
W
20-Jui-16
9:23
6.81
320
1.17
4.9
3.06
15.6
PumpTest
4
Th
21-JUI-16
10:20
7.16
290
1.1
8.2
3.05
16.6
PumpTest
5
F
22-Ju 1-16
10:03
7.2
267
1.1
12.9
3.25
16.7
Operating
3
M
25-Ju)-16
9:41
7.34
268
1.1
4.7
2.75
16.6
Operating
12
F
29-JU1-16
9:18
7.32
269
1.09
4.4
2.39
16.1
Operating
15
M
l-Aug-16
9:26
7.38
268
1.09
5.5
2.45
15.9
Operating
22
M
B-Aug-16
11:10
6.96
196
1.13
4.8
2.24
15.3
Operating
29
M
15-Aug-16
9:18
7.27
129
1.17
7.8
3.88
16.3
Operating
36
M
22-Aug-16
9:09
7.48
195
1
15.3
1.42
16.65
Operating
43
M
29-Aug-16
9.-00
73
145
1.18
14.4
3.28
15.8
Operating
51
T
6-Sep-16
9:40
6.49
89
1.16
13.1
1.06
14.8
Operating
57
M
12-5ep-16
9:14
7.02
148
0.95
16.8
2.66
16.4
Operating
64
M
19-Sep-16
9:53
7.42
142
0.96
17.3
1.88
16.92
Operating
70
S
25-Sep-16
9:14
7.35
148
0.99
5.5
1.46
14.5
Operating
78
M
3-Oct-16
9:09
7.65
180
0.99
28.6
0.82
14.75
Operating
86
T
ll-Oct-16
8:15
7.81
203
0.99
27.6
0.73
14.22
Operating
92
M
17-Oct-16
9:30
7.78
210
0.999
31.2
1.21
14.52
Page 48
-------
7.0 Pumping Test Results
Date
Time
Well 11
Test
Day
PH
5U
ORP
mV
Cond.
US/cm
Turb.
NTU
D.O.
mg/L
Temp.
°C
Baseline
T
12-jui-ie
Baseline
W
13-JUI-16
7.13
74
1.12
34.2
2.17
15.3
Pump Test
1
M
1B-Jul-16
10:10
7.08
164
1.02
10.5
3.59
17.8
Pump Test
2
T
19-JUI-16
9:28
6.8
185
1.11
3.7
3.09
15.6
Pump Test
3
W
20-Jul-16
9:23
7
167
1.12
7.5
2.36
17
PumpTest
4
Th
2i-Jui-i6
10:20
7.02
172
1.08
7.1
2.93
17.6
Pump Test
5
F
22-Jul-16
10:03
7.03
195
1.2
11.8
2.07
15.8
Operating
8
M
25-JUI-16
9:41
7.06
194
1.2
14.3
1.93
17
Operating
12
F
29-JUI-16
9:18
7.1
188
1.21
5.9
1.87
14.6
Operating
15
M
l-Aug-16
9:26
7.05
191
1.15
6.6
1.85
15,4
Operating
22
M
S-Aug-16
11:10
6.91
11
1.16
6.4
2.77
16.7
Operating
29
M
15-Aug-16
9:18
6.88
92
1.16
22.3
2.96
16.4
Operating
36
M
22-Aug-16
9:09
7.22
109
1.01
26.3
0.79
17.24
Operating
43
M
29-Aug-16
9:00
7.35
105
1.24
18.4
3.28
16.2
Operating
51
T
6-5ep-16
9:40
6.67
65
1.17
9.9
2.4
15.3
Operating
57
M
12-Sep~16
9:14
7.13
99
0.97
16.3
2.74
16.65
Operating
64
M
19-5ep-16
9:53
7.43
95
0.99
17.1
2.35
15.6
Operating
70
S
25-Sep-16
9:14
7.11
79
1.01
10.8
2.53
15.17
Operating
78
M
3-Oct-16
9:09
7.66
210
0.99
16.9
3.14
16.22
Operating
86
T
ll-Oct-16
8:15
7.72
172
0.97
21.4
3.06
14.71
Operating
92
M
17-Oct-16
9:30
7.54
172
1.01
28
2.42
14.96
Date
Time
Well 12
Test
Day
pH
SU
ORP
mV
Cond.
|iS/cm
Turb.
NTU
D.O.
mg/L
Temp.
°C
Baseline
T
12-Jul-16
Baseline
W
13-Jul-16
6.72
211
0.946
3.2
3.12
14.8
PumpTest
1
M
18-Jul-16
10:10
7.03
136
0.935
2,8
4.26
17.1
PumpTest
2
T
19-Jul-16
9:28
6.25
244
0.939
2.3
3.62
15.9
PumpTest
3
W
20-Jul-16
9:23
6.74
214
0.972
4.2
4.35
17
PumpTest
4
Th
21-Jul-16
10:20
7.04
238
0.913
4.1
3.39
15.8
PumpTest
5
F
22-Ju 1-16
10:03
6.83
2.09
0.94
6.5
4.21
16
Operating
8
M
25-Jul-16
9:41
6.92
214
0.94
4.2
3.52
17.2
Operating
12
F
29-Ju!-16
9:18
6,86
200
0.94
4.4
3.05
16.6
Operating
15
M
l-Aug-16
9:26
6.89
209
0.94
5.3
3.16
15,8
Operating
22
M
8-Aug-16
11:10
6.82
150
1.01
4.21
3.3
16.4
Operating
29
M
15-Aug-16
9:18
6.96
140
1.03
7.8
3.61
16.9
Operating
36
M
22-Aug-16
9:09
7.43
254
0.9
42.2
2.47
17.3
Operating
43
M
29-Aug-16
9:00
7.16
158
0.983
14.3
2.7
16.9
Operating
51
T
6-Sep-16
9:40
6.46
121
0.97
11.8
3.38
15.3
Operating
57
M
12-Sep-16
9:14
6.88
253
0.9
17.4
3.58
17.09
Operating
64
M
19-Sep-16
953
6.92
137
0.99
12.9
3.68
15.6
Operating
70
S
25-5ep-16
9:14
6.67
292
0.989
8.2
3,54
15.04
Operating
78
M
3-Oct-16
9:09
7.38
292
0.996
6.84
287
16.54
Operating
86
T
ll-Oct-16
8:15
7.26
311
0.987
10.97
2.37
15.18
Operating
92
M
17-Oct-16
9:30
7.58
322
0.994
17.7
2.98
15.04
Page 49
-------
7.0 Pumping Test Results
Date
Time
Well 13
Test
PH
ORP
Cond.
Turb.
D.O.
Temp.
Day
SU
mV
liS/cm
NTU
mg/L
°C
Baseline
T
12-Jul-16
Baseline
W
13-JUI-16
6.87
172
0.622
5.5
3.28
15.1
PumpTest
1
M
lS-Jul-16
10:10
7.91
116
0.569
23.4
1.03
17.1
Pump Test
2
T
19-Jul-16
9:28
7.45
165
0.498
30.6
4.4
16.6
PumpTest
3
W
20-JUI-16
9:23
7.48
162
0.524
16.8
4.83
17.5
PumpTest
4
Th
21-Jul-16
10:20
7.54
153
0.516
34.5
5.42
16.9
PumpTest
5
F
22-Jul-16
10:03
7.51
160
0.526
18.8
5.74
16.1
Operating
8
M
25-JUI-16
9:41
7.69
162
0.499
10.3
5.89
17.3
Operating
12
F
29-Jul-16
9:18
7.54
135
0.607
34
6.4
14.6
Operating
15
M
l-Aug-16
9:26
7.59
139
0.546
29.2
4.83
14.9
Operating
22
M
S-Aug-16
11:10
7.34
110
0.62
32.4
5.8
16.8
Operating
29
M
15-Aug-16
9:18
7.24
125
0.66
37.3
6.2
17.8
Operating
36
M
22-Aug-16
9:09
7.69
87
0.657
43,7
4.03
17.5
Operating
43
M
29-Aug-16
9:00
7.34
68
0.648
37.6
5.83
16.6
Operating
51
T
6-Sep-16
9:40
7.38
77
0.637
24.8
5.59
15.7
Operating
57
M
12-5ep-16
9:14
7.42
75
0.612
26.9
4.73
16.3
Operating
64
M
19-Sep-16
953
7.59
84
0.651
25.1
4.91
15.5
Operating
70
S
25-Sep-16
9:14
7.38
79
0.632
29.3
4.27
15.36
Operating
78
M
3-Oct-16
9:09
7.83
105
0.628
26.7
4.93
15.06
Operating
86
T
ll-Oct-16
8:15
8.05
146
0.614
33.8
3.82
14.2
Operating
92
M
17-Oct-16
9:30
7.89
117
0.656
35
4.27
15.2
Date
Time
GAC IB (Coal) Effluent Sample Pt. E
Test
pH
ORP
Cond.
Turb.
D.O.
Temp.
Day
SU
mV
|iS/cm
NTU
mg/L
OC
Baseline
T
12-JUI-16
Baseline
W
13-JUI-16
PumpTest
1
M
18-Jul-16
10:10
PumpTest
2
T
19-Jul-16
9:28
PumpTest
3
W
20-JUI-16
9:23
7.32
129
1.13
5.8
0.2
16.5
PumpTest
4
Th
21-Jul-16
10:20
7.44
262
1.09
5.9
0.67
16.6
PumpTest
5
F
22-Jul-16
10:03
7.28
165
1.09
6.8
1.03
16.1
Operating
8
M
25-Jul-16
9:41
7.16
253
1.08
4.7
0.98
16.1
Operating
12
F
29-JUI-16
9:18
7.25
174
1.07
4.4
0.53
16.2
Operating
15
M
l-Aug-16
9:26
7.22
170
1.07
5.1
1.31
15.9
Operating
22
M
8-Aug-16
11:10
7.25
197
1.15
4.9
0.81
17.5
Operating
29
M
15-AUS-16
9:18
7.12
139
1.16
7.9
1.02
16.1
Operating
36
M
22-Aug-16
9:09
7.26
200
1.01
17.3
0.66
15.6
Operating
43
M
29-Aug-16
9:00
7.33
162
1.16
12.4
1.3
155
Operating
51
T
6-Sep-16
9:40
6.8
147
1.15
7.1
2.2
16.4
Operating
57
M
12-Sep-16
9:14
7.21
158
0.97
11.3
1.8
15
Operating
64
M
19-Sep-16
953
7.03
145
0.97
11.4
1.92
15.44
Operating
70
S
25-Sep-16
9:14
7.23
150
0.99
3.3
1.05
14.27
Operating
78
M
3-Oct-16
9:09
7.39
193
1
5.1
1.58
14.5
Operating
86
T
ll-Oct-16
8:15
7.54
207
1
27.5
1.6
13.95
Operating
92
M
17-Oct-16
9:30
7.77
228
0.96
30.2
1.78
15.23
Page 50
-------
7.0 Pumping Test Results
Date
Time
GAC2B
Coconut) Effluent Sample Pt. F
Test
Day
PH
SU
ORP
mV
Cond.
|i5/cm
Turb.
NTU
D.O.
mg/L
Temp.
OC
Baseline
T
12-Jul-16
Baseline
W
13-Jul-16
PumpTest
1
M
18-JUI-16
10:10
Pump Test
2
T
19-Jul-16
9:28
PumpTest
3
W
20-Jul-16
9:23
7.32
129
1.13
5.8
0.2
16.5
PumpTest
4
Th
21-JUI-16
10:20
7.31
283
1.09
6.1
1.99
16.2
PumpTest
5
F
22-Jul-16
10:03
7.31
182
1.08
7.7
1.61
16
Operating
5
M
25-Jul-16
9:41
7.21
261
1.08
5
1.21
16.1
Operating
12
F
29-JUI-16
9:18
7.21
169
1.07
4.8
1.01
16.2
Operating
15
M
l-Aug-16
9:26
7.17
160
1.07
5.3
0.8
16.1
Operating
22
M
8-Aug-16
11:10
7.11
198
1.15
5.5
0.8
16.4
Operating
29
M
15-Aug-16
9:18
7.1
135
1.16
4.66
1.43
15.9
Operating
56
M
22-Aug-16
9:09
7.29
196
1.02
20.3
0.94
15.7
Operating
43
M
29-Aug-16
9:00
7.34
151
1.17
13
2.03
15.7
Operating
51
T
6-Sep-16
9:40
6.89
136
1.14
4.5
2.97
16.2
Operating
57
M
12-Sep-16
9:14
7.23
152
0.96
12.3
2.45
15.56
Operating
64
M
19-Sep-16
953
7.43
159
0.98
14.3
2.54
15.52
Operating
70
S
25-Sep-16
9:14
7.25
147
0.97
3.8
0.47
14.29
Operating
78
M
3-Oct-16
9:09
7.42
182
1
5.1
1.57
14.5
Operating
86
T
ll-Oct-16
8:15
7.65
204
1
29.6
1.43
13.92
Operating
92
M
17-Oct-16
9:30
7.83
197
1
27.4
1.88
16.21
Geochemical conditions in observation wells were also monitored during each of the two pumping test
phases. Graphs presenting geochemical trends for each observation well are included below.
Page 51
-------
7.0 Pumping Test Results
Groundwater Geochemistry - Conductivity
All Wells
Well 9 Pumping Test
J=
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if;
270
• Well 6
• Well 9
• Well 11 250
• Well 12
• Well 13
230
Well 9 GW Elevation
2 per. Mov. Avg. (Well 6)
2 per. Mov. Avg. (Well 9) 2io
2 per. Mov. Avg. (Well 11)
2 per. Mov. Avg. (Well 12)
2 per. Mov. Avg. (Well 13) 190
50 per. Mov. Avg. (Well 9 GW Elevation)
170
29-Jul-16 18-Aug-16
7-Sep-16 27-Sep-16 17-Oct-16 6-Nov-16 26-Nov-16 16-Dec-16
Time (Date)
Page 52
-------
7.0 Pumping Test Results
g 205
a.
cc
O
155
Groundwater Geochemistry - ORP
All Wells
Well 9 Pumping Test
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• Well 6
• Well 9
• Well 11
• Well 12
• Well 13
Well 9 GW Elevation
2 per. Mov. Avg. (Well 6)
2 per. Mov. Avg. (Well 9)
2 per. Mov. Avg. (Well 11)
2 per. Mov. Avg. (Well 12)
2 per. Mov. Avg. (Well 13)
50 per. Mov. Avg. (Well 9 GW Elevation)
9-Jul-16 29-Jul-16 18-Aug-16 7-Sep-16 27-Sep-16 17-Oct-16 6-Nov-16 26-Nov-16 16-Dec-16
Time (Date)
Page 53
-------
7.0 Pumping Test Results
Groundwater Geochemistry - Dissolved Oxygen
All Wells
Well 9 Pumping Test
0.5
19-Jun-16
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• Well 9
• Well 11
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Well 9 GW Elevation
2 per. Mov. Avg. (Well 6)
2 per. Mov. Avg. (Well 9)
2 per. Mov. Avg. (Well 11)
2 per. Mov. Avg. (Well 12)
2 per. Mov. Avg. (Well 13)
50 per. Mov. Avg. (Well 9 GW Elevation)
9-Jul-16 29-Jul-16 18-Aug-16 7-Sep-16 27-Sep-16 17-Oct-16 6-Nov-16 26-Nov-16 16-Dec-16
Time (Date)
Page 54
-------
7.0 Pumping Test Results
14
19-Jun
Groundwater Geochemistry - Temperature
All Wells
Well 9 Pumping Test
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• Well 9
• Well 11
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Well 9 GW Elevation
2 per. Mov. Avg. (Well 6)
2 per. Mov. Avg. (Well 9)
2 per. Mov. Avg. (Well 11)
2 per. Mov. Avg. (Well 12)
....... 2 per. Mov. Avg. (Well 13)
....... 50 per. Mov. Avg. (Well 9 GW Elevation)
16 9-Jul-16 29-Jul-16 18-Aug-16 7-Sep-16 27-Sep-16 17-Oct-16
Time (Date)
6-Nov-16 26-Nov-16 16-Dec-16
Page 55
-------
7.0 Pumping Test Results
Groundwater Geochemistry - Turbidity
All Wells
Well 9 Pumping Test
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250 2 per. Mov. Avg. (Well 6)
2 per. Mov. Avg. (Well 9)
2 per. Mov. Avg. (Well 11)
2 per. Mov. Avg. (Well 12)
2 per. Mov. Avg. (Well 13)
200 50 per. Mov. Avg. (Well 9 GW Elevevation)
19-Jun-16 9-Jul-16 29-Jul-16 18-Aug-16 7-Sep-16 27-Sep-16 17-Oct-16 6-Nov-16 26-Nov-16 16-Dec-16
Time (Date)
Graphs provided above indicate some changes to geochemical conditions within the aquifer were
observed during the pumping test, especially with respect to ORP and pH. In conjunction with the
changes seen in groundwater elevation for each observation well during Well 9 pumping, the changes in
geochemical conditions also are key to understanding Well 9 capture zone and the potential for Well 9
pumping to control the PFC plume.
WELL 9 TRANSMISSIVITY CALCUATION
The transmissivity of the bedrock aquifer within the Well 9 capture zone was determined through
utilization of Aqtesolve. The calculated transmissivity for Well 9 as determined during recovery
following completion of the constant rate pumping test is 47.95 feet squared per minute (ft2/min). The
back-up data for this calculation is presented in the attachments to this report.
Page 56
-------
8.0 Pumping Test Summary
8.0 PUMPING TEST SUMMARY
Page 57
-------
8.0 Pumping Test Summary
SUMMARY OF PUMPING TEST FINDINGS
A two phase pumping test was completed as part of the pilot study and included both step-drawdown and
constant rate pumping tests. Groundwater elevation was collected on five minute intervals during the
entire pilot study. Groundwater geochemical data were collected daily during the step-drawdown test and
weekly during the constant rate test. Results of the data collected during each phase of the pilot study
pumping test are summarized below:
• Minimal drawdown was observed in each observation well (Well 6, 11, 12, and 13) resulting
from Well 9 pumping, with a maximum drawdown observed in Wells 6 and 12;
• A review of groundwater geochemical parameters, especially ORP and pH, collected during each
phase of the pumping test indicate observation wells included in the study are within the Well 9
capture zone; and,
• Groundwater elevation and calculated transmissivity data from Well 9 collected during the
constant rate pumping test indicate the specific capacity of the well was not sufficient to
overcome recharge to the well from storage and induce a high enough draw-down in observations
wells to control PFC concentrations in groundwater.
Page 58
-------
Attachment 1
ATTACHMENT 1 - CONCEPTUAL GAC SYSTEM DESIGN BASIS
Page 59
-------
Attachment 1
Subject:
Project ft:
Designs^:
Checked:
approved:
CJcceAsuwiatirs. Inc.
37iX 7>*«fc Smo '.aT Ht PA
¦Ha1 7Y7-731-14Ti3 Fit 717-73M30
HIA PF05 P IC'" Test
LGAC Test ResLt Evaluation
-*501
T . G -3lat'0
Date: a'16'2317
Date:
Page
or 1S
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Pilot T 65: ^eault Analysis - Baa la 3-f Design Tor Full Seals System
Lead Unit Coal B ased GAC #1A
Avg. RFC infet Careen. -
Total PFC ln;et Mass Loading Rata -
Tote I PFCi to Btfestethnsugh at D.M ug/L =
CariKsn Vessel Chares -
PFC Lauding lu Brcukshru / lb GAC =
Equlltnrltn Concentration (¦Lit"
Lead Unit Coconut Baawf GAC £24
A«f. PFC InetConcen. -
Tolal PFClciet Mass Loadrvg Rate -
Total PFCi toirtijUJlrough art D.W ujy'L =
Total Test PFC Loaning -
Est. Days ta BreakCirulD 0.B4 ugfl. -
Est PFC loading to Brealcttru id 0.04 ugrt. -
Est Adfftonal PFCs renoved -
Carson Vessel Charge -
Low r:,! '1^:! PFC Liudir^; III Eredfethfu / lb GAC =
Low Eqjll&rturn Concentration (q,^ -
High Range PFC Loading to Brejkshru / lb GAC =
Hi-gli Equlltarlian Concentration fq.'^ -
:?j days actual loading:
0.005900 mg'L
5.900 ug,'L
~.~0629 Ite'day at design flow rate £ concentration
D.477S ICS tolal PFCs
S.DOO Its
D.DQDD955 lite PFC/lb GAC uliliietd
0.09552051 ms PFC/gr GAC utilised
12,573,830 gilais treated during test
10,73 l.SBE ga Ions treated tc- Ereadtin.
D.005900 mg'L
5.9CO ug.'L
0.0E615 ibS'da/ at design row rate & eoreentratlon
areakmrt,1 concentrated id: reached during test
0.523111E3 ItSS total PFCS
110 dare foased or explraK atlon aastday §2)
0.5338E321 lbs PFCs fusing avq loaffng rata oast day 92'i
0.11077653 lbs
5,000 Its
0.0001046 Ibi PFC/lb GAC utillted
0.1(^62213 rrg PFC/gr GAC utiliied
0.0001263 Iba PFC/lb GAC utiliied
0.126777E4 mg PFC/gr GAC utiliied
12,409,879 gaftons treated durtng test
13,753,779 Est. gallons teated To Breattmu
;92 days sotual loading:
(110 est. loading)
East Ca ;.i at f r:--- ciict *esji:s - ccts a:ici t: Tecfr :a .teratu'e
:q.;>o -KC.",n
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for r? jansraor.
Page 60
-------
Attachment 1
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Subject HIA PFQS Pis: Test
LGAC res: Rest.-:t Evaluation
Project *:
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Checked:
Approvad:
474-15C1
T. Galatro
Date: 2/16.'2il17
~ate:
Paga 10 of 15
Basis of Design far GAC Application at the WTP - Pre 2Q14 Withdrawal Rate
Flow Hare
VVTP arcduSlon
l5B,P0C',Q0P"1ga ors punped In 2013
Avg. Dally Fl&» -
Avg. FlDwrate -
515.D5S.4-& ga Ions aer say
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rnearmenr Gaa/
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antra projected WTP nrueitcfaracterlzaCQd based an a flow weighted avg. of cortamlrarr.s
Wei *= concentrations are based on the average concentration dutng the pilot test. This was greater
than the 2014 corcentra:lon and therefore was used in Pie basis of design
me 2nd quarter of 2DD14 was the last time soiree well pumping was not adjusted to control PFC conoertratons
ana ftiis usee for withdrawal ssfflbutJan frorr each of tne soiixe tor tie flow weighted average concentraBon
calculation.
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Page 61
-------
Attachment 1
Subject:
HIA PFOS PUol Test
LGAC Tes: Result Evaluation
Tjir
Project #;
474-1SC1
Dsaignes:
T. Gaiafo
Date: 2i'16'2017
37C6 TrtiOe fioart Caflp HTfV
Checked:
Date:
T*" 7f 7-721-1£7S Fair ?17-73M3t3
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Page
11 or is
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irfTue-nt
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RFGs
(q.!b
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as developed during p-ilol test
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Page 62
-------
Attachment 1
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Project if;
474-15D1
Dealgna-df:
T. Galata
Date: 2!116/2017
snoe 7t™*- soaa; at j»bi
Cheeked:
Date:
1W 7T7-73T-T57U FaJC 7T7-7JM34S
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Page
12 Of 16
rnwrrjism Sysiem
Leas. ¦ _ag
Treatnent Trains Used -
1
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1200
D.43
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£C'K<]
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9.33
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732
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1.671
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5ed Lffe
Safety
FaeSw
i.i ts-i c'galHio ni»fxijl
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CUR Treated
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1.5
'10000673
2.97E+08
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a
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145
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says
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145
Page 63
-------
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approvad:
474-15D1
T. Gaiat'o
Date: g16'2ai7
Date:
Paga 13 oT 15
Basis of Design for GAC Application at the VfTP - 3rd Qtr 2018 Withdrawal Rate
Flow Ram
WTP PrudiKSlon
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Page 64
-------
Attachment 1
E 5?
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Subject:
HIA PFOS P IK Test
LGAC T es: Result E >31 lottos
,iS5S3»»
Project 4:
Designed:
474-1501
T. GalSfc'O
Date:
2i'i &20 17
3T£ TttKfc ffcwi Carep .tKfia
Checked:
Date:
lit 7f7-7J1-1£?9 Fate 7T7-73M3W
Approval:
Page
14 Of 15
Design
Influent
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Design
GAC
Breakttiru
Eruent
Design
GAC
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co
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0.60232
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0.6CO
O.COC5
ND
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o.ocs
acoos
ND
OH su
S.3
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Page 65
-------
Attachment 1
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Subject:
HIA PFOS P ID1 Test
lgac Tea p.eELt Evaluation
Project it:
Dsalgnea::
4-1 3- . OL 1
T. Galatro
Date: 2/16/2017
snx "n* rdm cwm mf*
Checked:
Date:
Til* 7f 7-73T-1S7B Fax: ?T?-72f-13M
Approved:
Page
15 ot 15
rrearmepr Syxrwn
Lean • Lag
Trealnert Trains- Used -
1
Flew Rate pe-' Taea-.ment yah -
345
gpm
CartKHi Sefecnwij
SecTc
Avg.
P
Sirface
Particle
Apparent
ASsra&or
lodheF
A?ea
Size
Densiiy
Nirrser
Type mg/g
m3^g
pm
3'oe
TIGG 5DC 1241 NSF Coconut 11 DO
1200
C.43
35
Csrt»p t/s-sse/1 SeJecaon
Caton Vessel Casasity -
2 rata
As
10
it Diane:e*
9.33
it Bes hetg?it
732
cf carEon
Des^n Flow Rate -
345
gpm
a.763620372
CIS
Hydraulic Loan ng Rate -
0.D307443D3
gpr.'Br
Maxnurn Vessel Flow Sate -
75C
gpnr
1.671
c?s
C .366-34
gpr.'sr
E-ad Volume -
233.25
OU. Ft
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(I fr®3AiJgalMK Fllmd]
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Safety
AdJEted
Gal Kins
Days
Fsafflf
CUR
Treated
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1.5
0.0000573
2.97E+08
69E
CNcrotenzene
1.5
2.97D33E-05
6.73E+08
1355
1,2-Dlctto-ot
-------
Attachment 2
ATTACHMENT 2 - WELL 9 TRANSMISSIVITY CALCULATION
Page 67
-------
Attachment 2
60.
48.
E- 36.
4—1
CT
E
s
I 24.
12.
~I I 1 1 I 1 1 I I I Mil 1 1 I I I llll 1 1 I I I III
3 I 'I I I I I I I I I llll | II
1. 13. 1 DO. 10*00. 1.0E+4 1.0E+5
Adjusted Time (min)
i ml
Data Set: O'iweIl9.aqt
Oate: 02/20/17
WELL TEST ANALYSIS
Time: 09:49:54
PROJECT INFORMATION
Company: Advantagje
Client: SARAA
Project 1400588-02
Location: Middl-e'.own, PA
Test Well: vVell :¦
Test Date: 7/18/16
AQJIFER DATA
Saturated Thickness: 4QC. ft
Aniso;ropy Ratio (Kz/Kr): JL
WELL DATA
Pumping Wells
Well Name
X [fO
Y (ft'i
Well 9
40.19657
-76.762.B8e
Observation Wells
Well Name
X (ft)
Y fftl
° Well 9
40.19657
-76.76286f
Aquifer Model: Confined
T =47.05 ft2/min
SOLUTION
Solution Meshod: C ccc-^'-Jaccb
S = 6.744E-88
Page 68
-------
Appendix B -
PADEP SDWP Permit
-------
Pennsylvania
DEPARTMENT OF ENVIRONMENTAL
3 PROTECTION
October 28, 2021
Scott W. Snoke, Utility Program Manager
Susquehanna Area Regional Airport Authority
One Terminal Drive, Suite 300
Middletown, PA 17057-5048
Re: Public Water Supply
Permit No. 2221501
PWS ID No. 7220044
APS ID No. 1033643
Auth ID No. 1345490
Granular Activated Carbon Upgrade Project
Lower Swatara Township, Dauphin County
Dear Scott Snoke:
Issuance of the enclosed construction permit is authorized in accordance with the provisions of
the laws of the Commonwealth. Our office should be notified at least 30 days prior to the
completion of construction so that an inspection can take place. The proposed facilities
may not be placed into service until you obtain a separate public water system operation
permit from the Department.
The most up-to-date regulations for Public Water Supplies, which we believe are self-
explanatory, can be found at the following web address:
Please have your authorized representative and supervising engineer complete the enclosed
Certificate of Construction/Modification Form and submit it to our office when requesting our
inspection. Please make provisions to comply with certification before construction begins.
Any person aggrieved by this action may appeal the action to the Environmental Hearing Board
(Board) pursuant to Section 4 of the Environmental Hearing Board Act, 35 P.S. § 7514, and the
Administrative Agency Law, 2 Pa.C.S. Chapter 5A. The Board's address is:
TDD users may contact the Environmental Hearing Board through the Pennsylvania Relay
Service, 800.654.5984.
Appeals must be filed with the Board within 30 days of receipt of notice of this action unless the
appropriate statute provides a different time. This paragraph does not, in and of itself, create any
Safe Drinking Water
Southcentral Regional Office | 909 Elmerton Avenue | Harrisburg, PA 17110-8200 | 717.705.4708 | F 717.705.4930
www.dep.pa.gov
http://www.pacode.com/secure/data/025/chapterl09/chaplQ9toc.html
Environmental Hearing Board
Rachel Carson State Office Building, Second Floor
400 Market Street
PO Box 8457
Harrisburg, PA 17105-8457
-------
Scott Snoke, Utility Program Manager - 2 -
Susquehanna Area Regional Airport Authority
October 28, 2021
right of appeal beyond that permitted by applicable statutes and decisional law.
A Notice of Appeal form and the Board's rules of practice and procedure may be obtained online
at http://ehb.courtapps.com or by contacting the Secretary to the Board at 717.787.3483. The
Notice of Appeal form and the Board's rules are also available in braille and on audiotape from the
Secretary to the Board.
IMPORTANT LEGAL RIGHTS ARE AT STAKE. YOU SHOULD SHOW THIS DOCUMENT
TO A LAWYER AT ONCE. IF YOU CANNOT AFFORD A LAWYER, YOU MAY QUALIFY
FOR FREE PRO BONO REPRESENTATION. CALL THE SECRETARY TO THE BOARD
AT 717.787.3483 FOR MORE INFORMATION. YOU DO NOT NEED A LAWYER TO FILE
A NOTICE OF APPEAL WITH THE BOARD.
IF YOU WANT TO CHALLENGE THIS ACTION, YOUR APPEAL MUST BE FILED
WITH AND RECEIVED BY THE BOARD WITHIN 30 DAYS OF RECEIPT OF NOTICE
OF THIS ACTION
If you have any questions, please contact Wade Cope, P.E. at 717.705.4771 or wcope@pa.gov.
Sincerely,
feaefcA 7%. TKattucci
Joseph M. Mattucci
Program Manager
Safe Drinking Water Program
Enclosures
cc: Max Stoner, P.E., Glace Associates, Inc.
-------
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL PROTECTION
BUREAU OF SAFE DRINKING WATER
PUBLIC WATER SUPPLY PERMIT
NO. 2221501
A. PERMITTEE: (Name and Address)
Susquehanna Area Regional Airport Authority
One Terminal Drive, Suite 300
Middletown, PA 17057
C. THIS PERMIT APPROVES FOR: 1. ^ CONSTRUCTION
AS INDICATED BELOW:
Source
Facilities
~
Well(s)
~
Impoundment
~
~
Spring(s)
~
Settling
~
~
Surface Water
ISI
Filtration
~
~
Finished Water
~
Iron and Manganese Treatment
Softening
~
~
Fluoridation
~
~
Distribution Facility
B. PROJECT/PLANT LOCATION
Municipality Lower Swatara Township
County Dauphin County
2. ~ OPERATION OF FACILITIES
Approved Under Construction Permit No.
BVRB
General Corrosion Control ~ Bottled Water System
Corrosion Control for Lead/Copper Q Bulk Water Hauling System
Disinfection Q Vended Water System
Pump Station(s) Q Retail Water Facility
Transmission Lines
Finished Water Storage
Other Well Pump Replacement removal of air stripping system
KNOWN AS: Granular activated carbon upgrade project, well pump replacement, chlorine analyzer replacement,
upgrades to water softener, replace service water pumps, upgrades to the Supervisory PLCs
LIMIT OF AUTHORIZATION
YOU ARE HEREBY AUTHORIZED TO CONSTRUCT OR OPERATE, AS INDICATED ABOVE, PROVIDED THAT FAILURE
TO COMPLY WITH CHAPTER 109, OF THE RULES AND REGULATIONS OF THE DEPARTMENT OF ENVIRONMENTAL
PROTECTION OR THE TERMS OR CONDITIONS OF THIS PERMIT SHALL VOID THE AUTHORITY GIVEN TO THE
PERMITTEE BY THE ISSUANCE OF THE PERMIT.
THE PLANS, SPECIFICATIONS, REPORTS AND SUPPORTING DOCUMENTS SUBMITTED AS PART OF THE PERMIT
APPLICATION BECOME PART OF THE PERMIT.
NO DEVIATIONS FROM APPROVED PLANS OR SPECIFICATIONS AFFECTING THE TREATMENT PROCESS OR
QUALITY OF WATERS SHALL BE MADE WITHOUT WRITTEN APPROVAL FROM THE DEPARTMENT.
THIS PERMIT IS ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL PROTECTION UNDER THE AUTHORITY OF
THE PENNSYLVANIA SAFE DRINKING WATER ACT, THE ACT OF MAY 1, 1984 (P.L. 206, NO. 43). OPERATION SHALL
COMPLY WITH THE PROVISIONS OF CHAPTER 109 ADOPTED UNDER THE AUTHORITY IN SECTIONS 4 AND 6(e) OF
THE PENNSYLVANIA SAFE DRINKING WATER ACT.
THIS PERMIT IS SUBJECT TO THE ATTACHED SPECIAL CONDITIONS: 1 through 13
PERMIT ISSUED DEPARTMENT OF ENVIRONMENTAL PROTECTION
October 28, 2021 "TKattucci
Date By
Joseph M. Mattucci
Title Program Manager
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October 28, 2021
SAFE DRINKING WATER PROGRAM
Susquehanna Area Regional Airport Authority
Public Water Supply Permit No. 2221501
Page 2 Lower Swatara Township
Dauphin County
This permit is issued subject to all Department of Environmental Protection (Department) Rules and
Regulations now in force and the following Special Conditions:
1. Upon completion of construction in accordance with the approved plans and specifications, the
permittee shall submit the Certificate of Construction/Modification to the Department. Certification
shall state that the work was completed in accordance with the approved plans and specifications and
shall be signed by the professional engineer or other person responsible for the work. Certification
shall include that adequate operation and maintenance information for the approved facilities is
available, on site, for use by the public water system's personnel.
2. Prior to issuance of an Operation Permit, the facilities shall be properly disinfected in accordance
with 25 PA Code, Chapter 109.711 of the Safe Drinking Water Regulations and by the American
Water Works Association (AWWA). The facilities shall be tested for coliform bacteria in
accordance with AWWA standards. The samples shall be analyzed by a Department-accredited
laboratory. Copies of the satisfactory microbiological test results shall be submitted with the
Certificate of Construction.
3. Each train of the approved TIGG Model CP20K-10 dual vessel granular activated carbon (GAC)
treatment system shall only be operated in a series (lead/lag) configuration.
4. The Granular Activated Carbon (GAC) system is approved for a maximum flow of 500 gallons per
minute (gpm) per train and a total maximum flow of 1,000 gpm for the entire system.
5. This permit approves the use of TIGG COCL60 virgin coconut-based activated carbon, as
manufactured by TIGG, LLC, for treatment of Perfluorooctanesulfonic acid (PFOS) and
Perfluorooctanoic Acid (PFOA). The Permittee may not use any other GAC or other technology
without the prior consent of the Department.
6. The Permittee shall sample the raw and finished water for concentrations of PFOA and PFOS at least
once every thirty (30) days and be analyzed by a Department accredited laboratory.
7. The permittee shall report to the Department within one (1) hour following discovery or receipt of
any sample result of the finished water which combined concentrations of PFOA and PFOS exceeds
55 ng/L (parts per trillion).
8. The permittee shall conduct performance monitoring for combined concentrations of PFOA and
PFOS at the mid-point sample tap between the lead and lag treatment units at least once every thirty
(30) days. The samples shall be obtained and analyzed by a Department accredited laboratory for
PFOA and PFOS analysis. The accredited laboratory shall report the sample results to the
Department.
When a sample results show break-through (combined concentrations of PFOA and PFOS > 70
ng/L) of the lead treatment unit, the first unit shall be removed from service and the second treatment
unit shall become the lead unit. The treatment unit removed from service must then be refilled with
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SAFE DRINKING WATER PROGRAM
Susquehanna Area Regional Airport Authority
Public Water Supply Permit No. 2221501
October 28, 2021
Page 3 Lower Swatara Township
Dauphin County
virgin media or replaced with a like unit filled with virgin media, and then reinserted into position as
the lag unit.
9. The Permittee shall conduct and document an initial demonstration of capability (IDC) for all
analysts responsible for conducting compliance and/or comparative grab sampling and analysis in
accordance with Section 10 of EPA's Method 334.0.
10. The Permittee shall conduct and document an initial calibration verification for all instruments used
for conducting compliance and/or comparative grab sampling and analysis in accordance with
Section 10 of EPA's Method 334.0.
11. The Permittee shall submit documentation of completion of Special Conditions (9) - (10) to the
Department with the Certificate of Construction.
12. The Department specifically retains the right to modify, add to, or delete any or all of the Special
Conditions attached to this permit. The Department also retains the right to rescind the permit, if, in
its sole determination, operation of the facilities presents a threat to public health or the permittee is
not in compliance with the Special Conditions.
13. The Permittee shall submit a phased construction schedule and timeline with estimated dates of the
start of construction for each phase and subtask at least 60 days prior to the start of construction and
an update at least 14 days prior to the start of Phases 1, 2, and 3 of construction.
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