The Soil Vapor Extraction System consists of four primary elements:

The vent field consists of clusters of soil vents (vertically installed perforated pipes) placed underground into the 10 acres of contaminated soils. Each vent cluster includes three to six vents. Soil vents are connected to a common set of collection pipelines (manifolds) which are also placed underground. Collection pipelines carry the vapors to the soil vapor treatment plant.

The soil vapor treatment plant receiSoil Vapor Extraction System the soil vapor collected by the soil vent system. The soil vapor then passes through filters and extraction blowers, and through a common heat exchanger to cool flows. It is then filtered through a granulated activated carbon adsorption system to remove almost all of the VOCs. The treated air (effluent) is measured for VOCs, if the concentration level exceeds 9.8 lbs per day, it is recycled through the blower and granulated activated carbon adsorption system; otherwise it is introduced back into the soil or discharged through a 50-foot exhaust stack.

Lockheed Martin will reinject between 50-70 per cent of treated soil vapor. Based on three-dimensional vapor transport modeling and the physical properties of the subsurface soil at the Plant B-1 site, 100 percent reinjection cannot be achieved. The air reinjection system consists of blowers at the treatment plant, a main injection line leading to the vent field, and an automated valve to control the injection into each branch of the vent field being used for reinjection. The capacity of the injection system is designed to be 4,200 cubic feet per minute (cfm), or 70 percent of the capacity of the Soil Vapor Extraction System. The injection system is capable of drawing air from either the effluent side of the treatment unit or from the atmosphere; however, in steady operations, any reinjection air shall be treated soil vapor. Lockheed Martin plans to operate the reinjection system at a maximum feasible level.

OPERATION AND MAINTENANCE

The Lockheed Martin Soil Vapor Extraction System is located at 1705 Victory Place in Burbank, California. As the Independent Monitor hired by the City, Alton Geoscience will conduct scheduled and unscheduled audits to ensure that the following project system operation specifications are being consistently met:

Air is processed by the treatment plant at a rate between 2,000 and 6,000 standard cubic feet per minute (SCFM) for removal of volatile organic compounds (VOCs). The two independent Soil Vapor Extraction Systems designated as low vacuum and high vacuum will have capacities of 3,600 and 2,400 SCFM respectively. When an activated carbon bed is saturated with VOCs, it shall be automatically taken off line with effluent immediately routed to the second activated carbon bed. The activated carbon bed can also be manually taken off line for routine maintenance.

The amount of VOC vapors emitted is minimized by controlling flow quantities, shortening GAC adsorption times to two hours per day between regeneration cycles (for at least the first six months of operation), diverting effluent flow through a carbon polishing unit if mass concentration of stack discharge flow is too high, and by re-injecting 50 to 70 percent of the gas stream back to the well field.

Processed air is monitored for VOCs before exiting the plant. If total VOCs exceed set point levels, the effluent air is automatically routed through a GAC polishing unit. If effluent still approaches permit limits, vent field extraction rates are automatically reduced. If effluent levels continue to approach exceedence of permit limits with both of the above controls in place, the plant is automatically shut down. At any of these points, the logic controllers are automatically warning the operator and the City of Burbank.

The saturated activated carbon bed is regenerated by heating and stripping with 15 psig steam. VOC-laden steam is condensed to two-phase liquid condensate which is separated into a heavy liquid VOC layer (approximately 1.5 specific gravity) and a lighter water phase. The VOC liquid is stored in a tank temporarily, then it is transported off site. The VOC-saturated water is processed on site through an air stripper. Off gas is routed through the vapor phase filter. Water is passed through an activated carbon polishing beds to a water neutralization unit where pH is adjusted to between 6.5 and 8. The water is subsequently analyzed for VOCs and is discharged to the sewer if within specifications. Water not meeting discharge specifications is stored temporarily then transported off site.

A startup period of 90 days is required to bring the system on line. The components of the system are started, tested, adjusted, and tuned by the contractor and manufacturers to achieve maximum operational efficiency. Full emissions monitoring occurs during the startup period to ensure emission accedences are avoided. Any accedences associated with testing and adjusting equipment are corrected, documented, and reported.

Processed wastewater to be discharged to the sewer include: 2,200 gallons/day of process wastewater from the air stripper; 250 gallons/day boiler blowdown water; 5,000 gallons/day of cooling tower blowdown; 10 gallons/day washdown water from building drains; and 40 gallons/day of domestic wastewater. Reclaimed PCE and TCE solvents produced are stored for removal by a licensed waste hauler or recycler.

As the Independent Monitor, Alton Geoscience will ensure that the following emission controls and shut down procedures are met:

The Soil Vapor Extraction System is controlled and monitored by programmable logic controllers. The controllers monitor and record data and manage automated system shut downs in cases of component malfunctions or emission accedences. The controllers monitor the Soil Vapor Extraction System through temperature, pressure and/or flow sensors throughout the treatment plant. The controllers automatically alter the facility configuration and throughput assuring that the 9.8 pounds per day maximum VOC limit is not exceeded. The carbon cycle time is closely monitored and adjusted (during startup and when major changes are made in the plant feed stream) to maintain the emissions rate of less than 9.8 pounds per day maximum. If the daily emission rate approaches the established limit, the polishing unit is automatically placed on line. If the effluent again approaches the set point, the field extraction rate is reduced. If the established limit is then reached, the facility is automatically shut down. These automatic changes are recorded for system analysis and adjustment. The operations monitoring system has an alarm system located at a City facility with personnel on duty 24 hours per day. The alarm notifies City personnel if emissions exceed 9.8 pounds per day of VOC. A second signal (supplied by Lockheed Martin) indicates a facility shut down. Lockheed Martin provides personnel on standby duty 24 hours per day to ensure manual shut down of the plant within one hour of a breakthrough in the event that the automatic shut down feature fails. Alarm and shutdown occurrences are documented (including reason for alarm or shutdown) and maintained as a public record.

An emergency response plan is submitted to the City which specifies deployment of emergency-response agencies in the event of a spill at the site or in transport. The plan must be reviewed and approved by the Fire Chief prior to project commencement.

Containment berms are constructed around the storage tanks to the satisfaction of the Fire Chief.

EMISSION MONITORING PROCEDURES

As the Independent Monitor, Alton Geoscience will audit measures taken to limit emissions of all VOCs (including PCE and TCE) to a maximum of 9.8 pounds per day. VOC concentrations following treatment are measured on a continuous basis using a continuous emission monitor (CEM). The CEM is established and utilized as follows:
The Independent Monitor will collect and analyze effluent air samples weekly within the first 30 days of operation and will calibrate the emission monitor accordingly.

Lockheed Martin will send the Independent Monitor bi-weekly written reports indicating VOC emissions for each day that month. The Independent Monitor will compare the Lockheed Martin data with its own independent monthly sample and send a bi-weekly written report to the City which states whether or not the system that month has operated within the limit of 9.8 pounds of VOCs per day.

During the first three months of operation, the Independent Monitor will sample emissions once per week for the four contaminants (perchloroethylene, trichloroethylene, vinyl chloride, and carbon tetrachloride). The Independent Monitor will use these samples to perform two health risk assessments (HRAs). Air samples will be taken according to a schedule.

Using these samples, the Independent Monitor will perform the two HRAs to determine whether the one per million risk threshold has been exceeded. For the purpose of this requirement, these HRAs will be a spreadsheet calculation that computes risks for monitored chemicals. This information will be included in the Independent Monitor's bi-weekly report to the City.

In the event that the excess cancer risk calculated by the project life HRA exceeds one in one million based on the analysis of any one monthly or quarterly sample, the sampling frequency will be increased to at least one sample per week for at least one month. The monthly average emission rate of the four contaminants will be calculated from four consecutive weekly samples, one of which will be the sample which triggered the increase in sampling frequency.

A 70-year HRA (in accordance with SCAQMD Rule 1401) will be conducted for informational purposes.

When the monthly average emission rate results in a calculated risk over the project life in excess of one per million, plant operations will be adjusted to ensure that the monthly average emission rate for the next month is far enough below the threshold to entirely compensate for the accedence in the prior month. The monthly written report from the Independent Monitor will state whether or not these adjustments, if needed, have achieved this requirement.

If the operational adjustments cause the expected project life to be extended, the health risk assessments will use the extended project life rather than the 8.5 years currently expected.

If the vinyl chloride limit of 0.14 pounds per day is exceeded in any month, the emissions in the future months must be reduced so that the monthly average for a three- month period which includes the month of violation meets the emission limit.

The Independent Monitor will ensure that proper measures are incorporated into the monitoring process. If the reports from the Independent Monitor indicate a consistent pattern of failure to achieve these projects requirements, the City will take appropriate enforcement action based on violations of conditions of approval of the CUP.

The applicant can modify operational conditions and parameters so long as the Independent Monitor's monitoring operations indicate compliance with target risk calculations and emissions limits for daily VOCs and vinyl chloride.