Internal LetterIFT41

Rockwell Internationa l

TO: N,7' C FRO M

J . H. Keller S. R . LafflamRocketdyne-SSFL Rocketdyne-SSFL540, 055-JAlO 543, 055-JA1 6

392-530 1

Subject

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SSFL Ground Water -The State DOHS notified Rocketdyne that the variancerequest for the ground water stripping towers has been denied . The permittingprocess could take in excess of 1-2 years . The decision whether or not toturn off the SSFL remediation system is being considered .

ACHIEVEMENTS Nothing of significance to report .

SSFL Environmental Monitoring Report - The mailing list and distribution forthe SSFL Environmental Monitoring Report has been updated .

VAPCD Inspection -SSFL A VAPCD inspector and the Enforcement Managerconducted a routine semi-annual inspection of SSFL on 15 November . PermitNumbers 0226 (Areas I & II), 0241 (COCA), 0240 (STL-4, PLF,and ECL) and 0232(Alfa/Bravo) were examined . Although no violations were issued during theinspection, the District decided subsequent to the visit to issue an NOV torepair the Area II gas pump retractor . (The NOV has not yet been received .)Plant Services has been directed to repair the hose retractor . The visitorsalso commented several times about Rule 74 .6 (cleaning/degreasing) andprovided useful graphics pertinent to it .

Rocketdyne Environmental Program White Paper - A white paper on theEnvironmental Program at Rocketdyne was prepared per request of the VicePresident, Marketing Development . The Environmental Program addresse s

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industrial wastewater, ground water , air emissions including asbestos, andhazardous waste disposal . The white paper describes the general design toensure full compliance with all federal , state , and local environmenta lregulations .

COCA Test Facility White Paper - A white paper that addresses compliance withair emission , wastewater and hazardous waste regulations at the COCA testfacility was prepared at the request of Facilities Advanced Programs , ProjectEngineering . The paper describes current permits that would be associate dwith COCA activities .

SCAQMD Rule 1169 - A non-resettable totalizing ampere-hour meter, pursuant toSCAQMO Rule 1169, hasbeen ordered and is scheduled for installation on tank544-13 by 8 December 1989 . CE Environmental is scheduled to begin sourcetesting of chromium emissions from the process tank on 12 December . Theplastic balls to be used in the test program have been ordered by 0/544personnel per discussion with Facilities and Plant Operations , Manufacturing .

Air Stripping Towers Permitting (SSFL) -A letter was mailed 15 November tothe VAPCDcontaining a check for $850 for permit processing fees in connectionwith the issuance of Permit to Operate #1344 . A draft copy of the P/O hadbeen revised and was included in the submittal .

Permit #0232 Renewal - The VAPCD permit for Alfa/Bravo, permit #0232, is duefor renewal . A letter from the District requesting payment of $42,545 .40 by14 January 1990 has been received . A draft copy of the permit was enclosedand will be formally distributed by Environmental to the affected parties fo rreview and comment .

NPDESReport - The October report was submitted todeadline . No exceedances were reported .

the RWQCB by the prescribed

Flow Meters Installation - SSFL - The Isco flowmeters were installed atPerimeter Pond and R2A pond and are now in working order. A programming erro rduring discharge from PP resulted in an inaccurate total flow readout ,however, the correct value will b e calculated from other available data .

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SCAQMD Rule 109 - As a result of the 9 November variance meeting with the AQMDHearing Board , the following information is being compiled by Environmental :1) a complete list that identifies all materials in use at Rocketdyne whichare regulated under Rule 109 ; 2) a list of all VOC/vapor pressure data thatare available for each material ; and 3 ) the origin of the value . Theinformation will be sent to Corporate Environmental - Seal Beach where arepresentative will be assembling similar data from other Rockwell divisions .After assembly of all information , the material list will be submitted to theSCAQMD by Monday, 4 December 1989 .

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SCAQMD Rule 1113 Proposed Amendments Environmental attended the AQMD publicworkshop on proposed new amendments to Rule 1113, Architectural Coatings . Theproposed new amendments were drafted as the result of adoption by the StateAir Resources Board of a suggested control measure ( SCM) in May 1989 .Although the proposed new amendments closely parallel the SCM, two exceptionsare noted below :

The rule lowers the VOC limit for lacquer to 500 gm/l, instead680 gm/l, as the first change increment .

Prohibition of the sale of the products is effective concurrently with th eeffective date of the limit instead of in three years .

The AQMD is reviewing the public comments and a new draft will bedistributed . The impact of the new amendments to Rocketdyne operations isbeing assessed .

PM10 Monitoring - SSFL - Environmental and the contractor visited the twoproposed site locations at SSFL where PM1O ambient monitoring equipment is tobe installed . The contractor has agreed to a mid-December startup dateprovided equipment availability .

VAPCD Rule 74 .2 - Environmental attended a work shop in Ventura given by theVAPCD to receive comments regarding proposed amendments to Rule 74 .2,Architectural Coatings . There are 33 new or revised definitions, new VOClimits for 19 specialty coatings, elimination of five specialty coating limitsthrough consolidation with other categories, and the addition of eight andelimination of one administrative requirement . Representatives from paintmanufacturers , including the Southern California Paint and CoatingAssociation , were in attendance . All agreed that lowering the VOC contentdoes not solve the emission problem as the lower VOC paints and coatings arenot as good and thus require repainting much more often that required by theolder high VOC paints . Other issues included the cost of disposal of non-compliance paints and coatings and the grace period for their replacement andthe possible elimination of metallic-pigmented coatings and quick dry sealers .

Westlake Steam Boiler, B/018 - Environmental has been in contact withmanagement at the Westlake facility (D1564) regarding requisite informationfor permitting the Thermo-Pak steam boiler at that facility . The permitapplication has been stalled for some time due to insufficient specificationdata on the boiler . The forthcoming data will allow submittal of theapplication to the VAPCD .

AB3205 Facilities Design has contacted Environmental to review two projects :1) to demolish and reconstruct a garage for forklifts and light duty truck ssouthwest of B/436 at SSFLand 2) to remodel the B/301restroom at SSFLfo r

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handicap access . The review relates to the VAPCD questionnaire pursuant toAB3205 that requires an applicant for a certificate of occupancy provideinformation indicating whether aVAPCD permit is required .

Training - Environmental conducted a hazardous waste handling course forpersonnel in 0/546 and two new environmental technicians on 20 November .

Area 11 Environmental Funding - Environmental prepared cost estimatesjustifying expenses requested forFY1990 Area IT environmental expenditures .The estimates were submitted to the program office .

Surplus Cylinders - Environmental received definite verbal commitment from theUSAF Astronautics Laboratory ( AFAL ) to acceptthe surplus compound A, chlorinetrifluoride, and fluoride propellants . Rocketdyne will ship the pressurecylinders to theAFAL following written confirmation of which cylinders arerequired . There are over 100 cylinders which the Air Force has a use for .This transaction will save Rocketdyne significant disposal and liability costs .

Open Burning - A 25-R was prepared to allow El Dorado Engineering to continueinvestigation of three explosive waste disposal alternatives includingcontinuation of open burning on-site, contained open burning in a chamberon-site, and off-site disposal .

SSFL Air Stripping Towers - Area I Road air stripping tower has bee nchlorinated and is ready to start operation . The power supply to wellRD-2 isnot operational dueto overload controls . Department 031 is working tocorrect this and it should be operational by l December 1989 . All other airstripping towers are operating without problems .

Water Over-Supply - With all air stripping towers in an operational mode, andCo-gen off-line, there now is an over-supply of water being pumped at SSFL .The result is that tanks at central storage are overflowing . The run-off iscausing some erosion near well WS -6 near the Alfa air stripping tower .Environmental is investigating the feasibility of discharging the effluentfrom some of the air stripping towers directly to the storage ponds, ratherthan pumping the effluent water into the distribution system . Thedistribution system has been installed with a "call" system from centralstorage which would automatically start pumping effluent water to the storagetanks if the water is required .

UV-Peroxidation System - The UV -Peroxidationsystem was tested for the firsttime on 13 November 1989 using contaminated water from well WS-9 whichsupplies the Bravo air stripping tower . Tests were conducted using 4, 8, and12 lamps to determine treatment requirements . Analysis of treated water hasshown that using 4 lamps allows some residual TCE (2 .8 ppb) to remain, butbelow action levels . The use of 8 and 12 lamps removes all VOA ' s . ECL wellsand tanks are now installed and operational . A test of the system wasconducted with the contractor, Project Engineering and Environmental . Waterfrom the ECL facility will receive treatment as soon as the Chem Lab is gearedup to analyze the constituents in the water .

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Water System Tour - Environmental took the new D1 031 water supervisor on a twohour tour of theSSFL water and sewage treatment systems to describe theenvironmental operational requirements at SSFL .

SSFL Ground Water Program - The Alfa, Bravo, Canyon, and Delta systems areoperational and Rocketdyne is treating over 500,000 gallons ofTCE-contaminated water daily . These air stripping tower systems will remainon during the Thanksgiving holidays . Environmental ' s goal is to get the AreaI Road system on line next week and then combine its compliance testing (forthe permit to operate from VAPCD ) with that of Bravo during January 1990 .

The SSFL Chem Lab has been requested to prepare a go/no go analysis for 15 ofover 70 compounds comprising the base neutral compounds array so that the ECLwater could be remediated at the Batch Facility ( using UV light/H202treatment) in December 1989 . If the Lab can meet the schedule, Environmentalwould be able to assess the batch reaction times and power requirements tohandle the ECL water at the system prior to any release into the SSFL reclaimlines .

The two-hour briefing that was presented to the DOE auditors on the SSFLground water program on 16 November 1989 was well received . Their plansinclude returning toRocketdyne with a laptop computer to enter all theEnvironmental data they believe necessary to provide DOE with the database toevaluate future remediation activities . They agreed to provide Environmentalwith a copy of that information following its generation .

Radiation Health & Safety was supplied with the non-public water sources thatprovide water to the SSFL toilet facilities for purposes of radon analysis .Radon is one of the 18 daughter products of the naturally-occurring uraniumthat was geologically deposited in Ventura County and is believed to be atSSFL . Environmental declared operational five air-stripping tower systems,one UV /H202 system , and one pumping well along Area I Road (WS-5 )

providing a total of 775 GPM, of which only about 80 GPM are utilized in thelavatories .

Envi ronmental provided the updated ground water monitoring schedule to the EPAon 8 November 1989 .

The Department of Health Services (OHS) requested that Environmental providethem with a mylar base map and an aerial of the SSFL facility . Arrangementswere made to have GRC provide them with the base map directly . Environmentalgave DHS the address and phone number for contacting Pacific Western AerialSurveys to purchase the aerials themselves .

Environmental has provided the DOE auditors with all of the individualchemical analysis and radiological reports (not the summaries ) for Area IVduring the three day period of 20 -22 November 1989 when they entered the datavia their laptop computer utilized on-site . They say that DOE management hasrequested that they directly access all of the reports in order to avoidtranscription errors for the generation of their database on SSFL's Area IV .Environmental requested that GRC photocopy all of the Area IV original reportsand send them to circumvent this process within the next reporting period .

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DOE/Area IV Activities -- The DOE site specific plan for ETEC which includesthe five year Environmental Restoration and Waste Management Plan has beenreleased to the legislators , regulators and local citizen groups fo rcomments . Comnentors have been asked to provide newer or more accuratetechnical data which would enhance the plan . A meeting was held withEnvironmental , ETEC and DOE/SAN members on 21 November 1989 to review thisplan prior to the 1 December submittal . Comments are due to the DOE/SANoffice by 1 December 1989 and toDOE/HQ by 15 December 1989 . Final sitespecific plans are expected to be released by DOE/HQ in early January 1990 .

Environmental attended a readiness review on 13 November 1989 for the T/059shield disc removal from the vacuum vessel . This is the second ofthree stepof the T/059 remediation project. No action from Environmental will b erequired .

Environmental is providing input to ETEC on the Environmental Protectio nImplementation Plan (EPIP ) required by DOE /HQ and DOE /SAN . This planaddresses all aspects of the environmental programs (air, water, hazardouswaste ) related to ETEC . Requests to DOE for follow-up reports or data will besubmitted as needed upon review of the EPIP .

As part of the new open attitude displayed by the current DOE regime and itscontractors , ETEC will conduct an environmental audit geared towards award feecriteria and general environmental protection program directives .Environmental will provide the necessary information where applicable . Thi saudit will commence during the week of 27 November 1969 .

Asbestos - SSFL- The non-friable asbestos floor tile project at T/009, Are aIV has been completed .

The 80 linear feet of asbestos containing material on electrical conduit atthe COCA test stand was removed by Latch-On Insulation Inc . A notification toVAPCD was not required because the insulation itself was not cut nor removed .The material has been packaged and will be properly disposed of .

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New Process Facility - Environmental attended the weekly process facilitymeeting held to discuss design requirements . Environmental was informed thatDowney's requirements call for a chem film bath to be included in the newfacility which includes potassium ferrous cyanide . Rocketdyne does not havethe capability to treat cyanide wastes . Environmental requested Downeycollect samples from their existing rinse tanks after the largest part theyhave is processed in the them film tank, along with determining theconcentration of cyanide in the them film tank itself, to determine if thecyanide concentration will be below Rocketdyne discharge levels . Downey wil lprovide the information to Rocketdyne as soon as it is available .

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Underground Tanks (SSFL) - The Environmenta l Unit is currently preparing anSSFL Underground Tank Status Report per request of the Ventura CountyEnvironmental Health Department ( VCEHD) . The request was a response to theinspection by the VCEHD on 28 September 1989 .

Hazardous Waste Management (SSFL )

on 15 November , 15 drums of hazardous waste was transported to Oil andSolvent Process Company (OSLO) in Azusa, California for recycling .

On 21 November , 62 drums of hazardous waste was transported to RollinsEnvironmental Services( RES) in Deer Park, Texas for incineration .

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On 11 November , approximately 20,000 pounds of electroplating wastewatertreatment filter cake was transported to USPCI in Clive, Utah forstabilization and subsequent landfill . The Environmental Unit iscurrently profiling the filter cake into a metal recovery facility inTexas to reclaim the metals (copper , nickel , chromium , iron) .

Hazardous Material Remediation - On 29 November , approximately 2 gallons ofperch i oroethylene spilled from a drum at the chemical storage yard when itslipped from the drum dolly and ruptured . Approximately 1/2 gallon wasreleased to the concrete . The material in the drum was repackaged and thespill was not reportable .

Support to Area IV Activities - Arrangements have been made with GroundwaterResources Consultants, Inc .(GRC) for them to provide the draft of the Area IVreport on 22 November 1989 . The lengthy delays have been due to the slowreceival of radiological data . Agreement was made that as soon as onecomplete round of sampling results was available, SRC would transmit the dataimmediately ; however, the labs have been telling them that early December 1989would be the soonest the results would be available .

The data Environmental has collected up to present shows that the off-sit ewells bordering the northwest slope of Area IV (05-1, 2, 3, 4 . and 5) have notshown any presence of volatile organic compounds and have no radioactivit ythat is above the maximum permissible limits .

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JOB SHOPPERS - Alan Nelson

S . R . Lafflam, Manage rEnvironmental Unit

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ENVIRONMENTAL UNIT - WEEKLY ACTIVITY REPOR T

T . W. Butler 540, 055-JA1 2M . G . Chavez 031, 055-SS25P . C . Coulter 091, 055-AB57G . Gaylord 622, 055-TO38D . C . Gibbs 638 , 055-HB1 3J . V. Horwatt 874, 001- B03

. Hunter 564 , 055-JA1 8J . A . Kucinskas 014, 055-EA35R . H . Lancet 638, 055-HA02K . H . Lynch 541, 055-SS1 3L . E . Lukunich 546, 055-AD06J . Monaghan 598, 055-SS06D . Ploszaj 540, 055-JA1 4R . Reisenweber 870, 001 -110, SG05G. M . Richards 574, 055-AB0 50 . S . Roberson 565, 055-LB05C . J . Rozas 551 , 055-CBO TM . Robertson 539 , 055-SS1 2M . C . Shoemaker 539, 055-AC1 0E . J . Wooster 564, 055-BA7 5D . J . Zweng 622 055-TO38Environmental Staff

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