Startup Report For Interim Measures No. 3 Groundwater Treatment System

Startup Report forInterim Measures No. 3Groundwater Treatment SystemWaste Discharge RequirementsOrder No. R7-2004-0103PG&E Topock Compressor StationNeedles, CaliforniaPrepared forCalifornia Regional Water Quality Control BoardColorado River Basin Regionon behalf ofPacific Gas and Electric CompanyAugust 12, 2005155 Grand Avenue, Suite 1000Oakland, CA 94612

Startup Report forInterim Measures No. 3 Groundwater Treatment SystemWaste Discharge Requirements Order No. R7-2004-0103PG&E Topock Compressor StationNeedles, CaliforniaPrepared forCalifornia Regional Water Quality Control Board, Colorado River Basin Regionon behalf ofPacific Gas and Electric CompanyAugust 12, 2005BAO\052230006

ContentsAcronyms and Abbreviations. ii1.0 Introduction.12.0 Sampling Locations .13.0 Description of Startup Activities .24.0 Treated Effluent Management .35.0 Sampling and Analytical Procedures .36.0 Analytical Results .47.0 Completion of Startup Phase .68.0 Certification .7Tables123456Sampling Station Descriptions .1Startup Log .2First Day Influent Parameter Stability.3Comparison of Effluent Monitoring Results with WDR Effluent Limitations .4Influent, Effluent, and Reverse Osmosis Concentrate Monitoring Results.5Combined Effluent and Reverse Osmosis Concentrate Monitoring Results .6AppendixAAnalytical ReportsBAO\052230006i

Acronyms and AbbreviationsCRBRWQCBColorado River Basin Regional Water Quality Controlgpmgallons per minutePG&EPacific Gas and Electric CompanyUSEPAU.S. Environmental Protection AgencyWDRWaste Discharge RequirementsBAO\052230006ii

1.0 IntroductionWaste Discharge Requirements (WDR), Order No. R7-2004-0103, issued by the ColoradoRiver Basin Regional Water Quality Control Board (CRBRWQCB), authorizes Pacific Gasand Electric Company (PG&E) to extract, treat, and re-inject groundwater into injectionwells located on San Bernardino County Assessor’s Parcel No. 650-151-06. The Monitoringand Reporting Program under Order No. R7-2004-0103 requires a three-day startup test ofthe groundwater remediation system and preparation of a startup report. PG&E performedthe CRBRWQCB-required startup test of the groundwater remediation system betweenJuly 25 and July 28, 2005. This report presents the startup test results, as required by theMonitoring and Reporting Program.2.0 Sampling LocationsThe startup test required collecting and analyzing samples of the remediation systeminfluent, effluent, and reverse osmosis concentrate. The sampling stations are described inTable 1.TABLE 1Sampling Station DescriptionsStartup Report for Interim Measures No. 3 Groundwater Treatment SystemSample StationLocationGroundwater Treatment System InfluentStation is sample tap on pipe into T-100.Groundwater Treatment System EffluentStation is sample tap on pipe upstream of T-700.Groundwater Treatment System ReverseOsmosis Concentrate MonitoringStation is sample tap on pipe to T-701.PG&E’s letter to the CRBRWQCB Executive Officer dated June 29, 2005 described theinfluent, effluent, and reverse osmosis sampling station locations within the remediationsystem. Samples of influent and reverse osmosis concentrate were collected from thelocations described in the June 29, 2005 letter.As described in PG&E’s letter to the CRBRWQCB Executive Officer dated July 28, 2005, thegroundwater treatment system effluent sampling station used for the startup test differedfrom the effluent sampling station proposed in the June 29, 2005 letter in that startupeffluent samples were collected upstream of the Treated Water Tank (T-700), rather thandownstream of the tank. The need for an alternate effluent sampling station for the startuptesting only was caused by the temporary re-routing of reverse osmosis concentrate (brine)into the treated water tank while waste profiling was being performed.As described in PG&E’s letter to the CRBRWQCB Executive Officer dated July 28, 2005,startup effluent samples from the alternate effluent sampling station were collected ascomposite samples over a 40-minute period to capture variability in effluent conductivity.This sampling approach is representative of the normal treatment system effluent and meetsBAO\0522300061

STARTUP REPORT FOR INTERIM MEASURES NO. 3 GROUNDWATER TREATMENT SYSTEMthe requirements of WDR Provision 25. The sampling station proposed in the June 29, 2005letter will be used as the effluent sampling station for future compliance monitoring.Although not representative of either effluent or reverse osmosis concentrate individuallyduring the startup testing (because of temporary re-routing of reverse osmosis concentrateinto the treated water tank during the startup period), PG&E collected a sample of combinedtreated effluent and reverse osmosis concentrate at Sampling Station B identified in theJune 29, 2005 letter. Results for these samples are presented, along with the analytical resultsof the required influent, effluent, and reverse osmosis concentrate samples, in Section 6.0. Asstated above, this sample location will be the monitoring location for treatment systemeffluent for future compliance monitoring.3.0 Description of Startup ActivitiesThe date, time, and flow rate for activities performed during startup are presented inTable 2. The startup test began at 8:00 a.m. on Monday July 25, 2005. During startup testing,treated effluent was combined with reverse osmosis concentrate and transferred to tanks atthe MW-20 bench for offsite disposal. A log of startup activities is provided in Table 2.TABLE 2Startup LogStartup Report for Interim Measures No. 3 Groundwater Treatment SystemEventDate/TimeInfluent Flow Rate(gpm) aStartup initiationJuly 25, 20058:00 a.m.70 gpmThree extraction well volumes treatedJuly 25, 20058:09 a.m.70 gpmFirst of three consecutive readings for pH, specific conductivity,and temperatureJuly 25, 20058.00 a.m.70 gpmSecond of three consecutive readings for pH, specificconductivity, and temperatureJuly 25, 20059:00 a.m.70 gpmThird of three consecutive readings for pH, specific conductivity,and temperatureJuly 25, 200510:00 a.m.70 gpmJuly 25, 200511:00 to 11:35 a.m.70 gpmJuly 27, 20055:09 p.m.70 gpmJuly 27, 20058:30 to 9:30 a.m.70 gpmThird day sample analytical results for pH, total chromium, andhexavalent chromium communicated to the CRBRWQCBJuly 28, 20056:10 p.m.70 gpmDischarge to injection wells initiatedJuly 31, 20052:00 p.m.70 gpmFirst day samples collectedFirst day sample analytical results for pH, total chromium, andhexavalent chromium communicated to the CRBRWQCBThird day samples collectedaTable shows typical flow rate. Influent flow rate varied between 68 and 72 gpm.BAO\0522300062

STARTUP REPORT FOR INTERIM MEASURES NO. 3 GROUNDWATER TREATMENT SYSTEMSystem stability was demonstrated on the first day of the startup test by running the systemuntil at least three well volumes had been extracted and until three consecutive influentreadings taken at least one hour apart for pH, specific conductivity, and temperature werewithin 5 percent of each other. With the treatment system operating at 70 gallons per minute(gpm), three well volumes (equivalent to 600 gallons) were extracted by 8:09 a.m. Hourlydata for pH, specific conductivity, and temperature collected on the first day of the startuptest are presented in Table 3. All parameter values were within 5 percent, meeting thestartup criteria specified in Subsection 2a of the Treatment System Startup Phase andStartup Reporting section of the Monitoring and Reporting Program.TABLE 3Day 1 Influent Parameter StabilityStartup Report for Interim Measures No. 3 Groundwater Treatment SystempH(standard units)Specific ees centigrade)7/25/20058:00 a.m.6.9610,63027.57/25/20059:00 a.m.7.0110,67027.87/25/200510:00 a.m.6.9810,79028.1Date/TimeAfter three well volumes were pumped and influent groundwater stability wasdemonstrated, the Day 1 remediation system influent, effluent, and reverse osmosisconcentrate samples were collected. The system influent, effluent, and reverse osmosisconcentrate were again sampled on Day 3 of the startup test. The dates and times ofsampling are presented in Table 2.4.0 Treated Effluent ManagementPG&E transferred treated groundwater generated during the startup test period to storagetanks at the MW-20 bench for offsite transport and disposal at a permitted disposal facility.Subsurface injection was initiated at 2:00 p.m. on July 31, 2005, after analytical results fromthe Day 1 and Day 3 samples demonstrated that effluent quality complied with WDReffluent limitations, as summarized in Section 6.0.5.0 Sampling and Analytical ProceduresAll samples were collected at the designated sampling locations from sample taps directlyinto containers provided by Truesdail Laboratories, Inc. The exception was the effluentsample (Location SC-702). At this location, the sample was collected from a sample tap intoa 5-gallon bucket. The flow was controlled so that 2 to 4 gallons of liquid were compositedover a 40-minute period. The 40-minute sample collection period was chosen in response toBAO\0522300063

STARTUP REPORT FOR INTERIM MEASURES NO. 3 GROUNDWATER TREATMENT SYSTEMobserved effluent specific conductivity variability observed at this location, so that thesample would be representative of the treated effluent.Sample containers were labeled and packaged according to standard sampling procedures.The samples were stored in a cooler at 4 Celsius and transported to Truesdail LaboratoriesInc. via a courier service under chain-of-custody documentation. Truesdail Laboratories,Inc. is certified by the California Department of Health Services (Certification #1237) underthe State of California’s Environmental Laboratory Accreditation Program. All analyseswere performed in accordance with the latest edition of the “Guidelines Establishing TestProcedures for Analysis of Pollutants” (40 CFR Part 136), promulgated by the U.S.Environmental Protection Agency (USEPA). Analytical reports, including chain-of-custodydocumentation, are presented in Appendix A.The analytical method selected for total chromium had a method detection limit of 1.0 partsper billion as required by the Monitoring and Reporting Program. The analytical methodselected for hexavalent chromium had a method detection limit of 0.2 parts per billion, asrequired by the Monitoring and Reporting Program.6.0 Analytical ResultsReports prepared by the certified analytical laboratory are presented in Appendix A.Effluent sample analytical results for pH, total chromium, and hexavalent chromium arecompared to WDR effluent limitations in Table 4. All effluent sample results comply withthe WDR effluent limitations.TABLE 4Comparison of Effluent Monitoring Results with WDR Effluent LimitationsStartup Report for Interim Measures No. 3 Groundwater Treatment SystemUnitsDay 1 SampleResultsDay 3 SampleResultsEffluent LimitStandard Units8.037.976.5-8.4Total Chromiumµg/L1.51.850Hexavalent Chromiumµg/L0.400.4116ParameterpHµg/L micrograms per literMonitoring results for influent, effluent, and reverse osmosis concentrate samples for allrequired monitoring parameters are presented in Table 5. As described in Section 2.0, PG&Ealso collected samples of combined treated effluent and reverse osmosis concentrate thatwere not required by the Monitoring and Reporting Program. Results for these samples arepresented in Table 6.BAO\0522300064