--- - Department of Toxic Substances Control. Maziar Movassaghi Acting Director 8800 Cal Center Drive Sacramento, California

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1 Unda S, Adams Acting Secretary for Environmental Protection Department of Toxic Substances Control Maziar Movassaghi Acting Director 8800 Cal Center Drive Sacramento, California ~...,-.....,.,.-"...,.. Edmund G. Brown Jr. Governor January 6, 2011 Mr. Arthur J. Lenox Environmental Remediation The Boeing Company 5800 Woolsey Canyon Road Canoga Park, California REVIEW OF CLOSURE PLANS FOR INACTIVE GROUNDWATER TREATMENT. UNITS AT SANTA SUSANA FIELD LABORATORY Dear Mr. Lenox: The Department of Toxic Substances Control (DTSC) reviewed the various closure plans for eight inactive groundwater treatment units at the Santa Susana Field Laboratory and enclosed are DTSC's review comments. A draft version of the comments was provided to you via on October 21,2010, and the closure plans were discussed in a conference calion October 29, DTSC understands that the closure plans are being revised and will be submitted to DTSC as a permit modification. If you have any questions concerning the review comments, please contact Mr. Paul Ruffin via at pruffin@dtsc.ca.gov or by phone at (916) Sincerely, - /I original signed by /I /. / Mark Malinowski, P.G. Performance Manager Team Enclosure: Plans Comments cc: See next page

2 Mr. Arthur J. Lenox January 6, 2011 Page 2 cc: via Allen Elliott National Aeronautics and Space Administration George C. Marshall Space Flight Center Allen.elliott@nasa.gov Randy Ueshiro NASA Program and SSFL Remediation The Boeing Company Randal.y.ueshiro@boeing.com Michael R. Lispi, REA, CPEA Vice President Haley & Aldrich, Inc. mlispi@haleyaldrich.com Rizgar Ghazi, P.E. Unit Chief, Engineering and Special Projects Office Department of Toxic Substances Control rghazi@dtsc.ca.gov Paul Ruffin, P.E. Engineering and Special Projects Office Department of Toxic Substances Control Pruffin@dtsc.ca.gov

3 Linda S, Adams Acting Secretary for Environmental Protection " I -:~ -- - Department of Toxic Substances Control Maziar Movassaghi Acting Director 8800 Cal Center Drive Sacramento, California Edmund G. Brown Jr. Governor MEMORANDUM TO: VIA: FROM : Mark Malinowski, P.G. Performance Manager Team - - }. Perry Myers, P.E. III original signed by II Senior Hazardous S-ubst~es EngIneer Engineering and Special Projects Office P I R ff P E -II original signed by II au u In,.. \ Hazardous Substances Engineer Engineering and Special Projects Office DATE : SUBJECT: REVIEW OF GROUNDWATER TREATMENT UNIT CLOSURE PLANS, SANTA SUSANA FIELD LABORATORY, CANOGA PARK, CALIFORNIA, EPA 10. NOS. CAD AND CA The Boeing Company (Boeing) and the National Aeronautics and Space Administration (NASA) submitted closure notifications for inactive groundwater treatment units (GWTUs) to the Department of Toxic Substances Control (DTSC) on March 8, 2010, and March 15, 2010, respectively. In separate letters on the same dates, Boeing and NASA submitted permit modification notifications (Class 1*, with prior approval) to revise the closure plans for the GWTUs. OTSC issued a response to Boeing's closure and permit modification notifications on April 26, DTSC participated in a conference call with Boeing and NASA on June 23, 2010, to discuss the process for closing the inactive GWTUs. As part of that process, I have reviewed the following documents and my comments are listed below in the comments section. A. Hazardous Waste Facility Post-Closure Permit,, Areas I and Ill, Permit Number PC-94/ , Modification Number MOD SC A, EPA ld. No. CAD , Attachment A, Permit Conditions, Revised January 5,2010. [Boeing PC Permit]

4 Page 2 B. Hazardous Waste Facility Post-Closure Permit,, Area II, Permit Number PC-94/ , Modification Number MOD SC B, EPA Id. No. CA , Attachment A, Permit Cond ltions, Revised January 5, [NASA PC Permit] C. Groundwater Remediation Operation Plan, Rocketdyne Site (Areas I and III),, Revision 3, October 11,2000, Section XIII Closure. [GROP Areas I and III Closure Plan] D. Groundwater Remediation Operation Plan, NASA Site (Area II), Santa Susana Field Laboratory, Revision 3, October 11, 2000, Section XIII Closure. [GROP Area II Closure Plan] E. Closure Plan for Area I and Area III Groundwater Treatment Units, April [Areas I and III GTU Closure Plan] F. Closure Plan for Area II Groundwater Treatment Units, April [Area II GTU Closure Plan] G. Closure Plan for the WS-05 Hazardous Waste Treatment Unit, December [WS-05 Closure Plan] H. Closure Plan for the Delta Hazardous Waste Treatment Unit, December [Delta Closure Plan} The Boeing PC Permit authorizes five (5) GWTUs identified by location as Alfa, Area I Road, Canyon, STL-IV and WS-05. The NASA PC Permit authorizes three (3) GWTUs identified by location as Delta, Bravo, and RD-09. Six of the GWTUs use air stripping towers (ASTs): Alfa, Area I Road, Canyon, STL-IV, Delta, and Bravo. Two of the GWTUs use ultra-violet/peroxidation (UV/HzOz) treatment: WS-05 and RD-09. The current closure plan for the Boeing GWTUs is the GROP Areas I and III Closure Plan approved in the Boeing PC Permit. Similarly, the current closure plan for the NASA GWTUs is the GROP Area II Closure Plan approved in the NASA PC Permit. The Boeing and NASA permit modification notifications in March 2010 proposed to replace the GROP closure plans with the WS-05 Closure Plan, Delta Closure Plan, Areas I and III GTU Closure Plan, and Area II GTU Closure Plan. These four plans had been submitted as part of permit applications or permit modifications, but DTSC has not completed approval actions on the permits or modifications. The proposed closure plans for the six AST and the two UV/HzOz GWTUs are similar. The exterior of the GWTUs and their containment pads are decontaminated by steam cleaning or pressure washing, except for the sensitive electrical system areas of the

5 Page 3 UV/H GWTUs. The interior of the treatment equipment is rinsed by recirculating the effluent from the operating treatment equipment through the system. This rinse water is analyzed and compared to performance standards to determine if the decontamination was successful. Concrete core samples are collected from the containment pads. Soil samples are collected from under the containment pads at several depths at the locations of the concrete core samples. The GWTUs are dismantled and demolished with the material and waste disposal options selected based on the results of analyses. The results of the soils sample analyses are used to determine if risk-based closure standards have been achieved or if a release has occurred that warrants further investigation and amendment of the closure plan. General Comments: 1. The March 2010 permit modification notifications were submitted for Class 1* modifications. The classification of permit modifications are listed in Appendix I to California Code of Regulations, title 22, division 4.5, chapter 20 and additional requirements are provided in California Code of Regulations, title 22, section , subsection (d) (22 CCR (d)). If the proposed closure plan changes are not explicitly listed in Appendix I, Boeing and NASA may request a determination of the classification pursuant to 22 CCR (d). 2. Submittal of closure plans from the 2006 permit applications and 2007 permit modifications may be confusing to the public. I recommend that the revised closure plans for the Boeing and NASA PC Permit modifications should either be direct replacements for the closure plans in the "Groundwater Remediation Operation Plan" or stand alone documents with a current date. 3. The closure plans must cover all of the tank system, including the associated ancillary equipment, from the hazardous waste point of generation through the treatment tanks to a point of disposal onsite, or to a point of shipment for disposal offsite. The GWTU closure plans do not include the piping from the groundwater extraction wells to the treatment units and any effluent piping. 4. Surface samples must be taken to confirm that equipment and structures have not been or are no longer contaminated with hazardous constituents. Rinse water sampling alone is not recommended for measuring decontamination of tanks, since it is not conclusive evidence that hazardous constituents have been removed. However, rinse water from components such as pumps, piping, and filters, where wipe sample locations are inaccessible, may be used to determine if the decontamination process has met performance standards. Wipe samples are applicable to smooth and impervious solid surfaces. Chip sampling is recommended for porous surfaces, such as uncoated concrete, asphalt and wood.

6 Santa Susana Field laboratory Page 4 5. The closure plans propose recirculating rinse water in operational treatment units. Considering the time these units have been idle. there may be difficulties restoring them to operational status. It may be more straightforward to dismantle the treatment units and decontaminate the parts. 6. The maximum inventory evaluations are incorrect. The maximum inventory would be if the Gwru was abandoned with the entire tank system capacity containing waste, including any reagent chemicals and generator accumulation areas. OTSC recognizes that this hypothetical maximum inventory, which is primarily used for the closure cost estimate, may not match the actual condition of the unit prior to closure. The summaries of anticipated quantities of wastes that will be generated during closure activities are incomplete and inadequate. 7. The closure plans do not specifically address removal and analysis of sediments/ sludges from tanks/sumps or removal of the AST packing. 8. The closure plans discuss moving sodium hexametaphosphate and hydrogen peroxide that remains at the time closure activities are initiated to the active treatment units (Delta and WS-05) where it will be used. What is the inventory of sodium hexametaphosphate and hydrogen peroxide at the GWTUs? 9. The proposed soil sample locations, under the central portions of the containment slabs, are probably the least likely locations to discover a release. Add sample locations along the perimeter of the containment, at or near sumps, and at any identified cracks through the containment. Alternatively, collect soil samples after the containment pads have been removed. 10. Soil samples for VOCs analysis should be collected using methods that minimize soil disturbance and are consistent with EPA Method Use of hand trowels and hand augers may not be appropriate. Specific Comments : Boeing PC Permit 11. Page 4 lists the groundwater treatment facilities in Areas I and III. The list includes the Eel Collection Unit in Area III. Is the ECl Collection Unit the same as the ECL Collection System discussed in the description of the STl-IV Air Stripping System on page 5? Does Boeing intend to close the ECl Collection Unit at the same time as the five GWTUs in Areas I and III?

7 Page 5 Areas I and III GTU Closure Plan 12. Section 4., Hazardous Waste Constituents, lists waste codes that applied or may have potentially applied to the waste stream treated in the GWTUs, but does not list chemical compounds (except trichloroethylene and hydrazine). Section 4 is referenced in Section 8 as constituents for analysis and in Section 10 as a list of analytes for the performance standard. It is not clear how the list of waste codes in Section 4 will function in closure plan Sections 8 and Section 5.2, page 15, 3rd bullet, refers to carbon canisters associated with the Bravo treatment unit, which is in Area II. 14. Section It is not clear why flushing treated effluent through the system is "after the equipment exteriors and the concrete slab have been decontaminated." This may be a "carry over" from earlier closure plans which treated the exterior and concrete slab rinse water in the treatment system. 15. Section 8. Please explain how the analytical methods list in Table 3 is adequate for hazardous waste characterization. 16. Section 8.1. The numbers of external and internal rinse water samples are not specified in the text. Table 4, Closure Cost Estimate, section 1.2.1, indicates 5 samples per treatment unit, but the cost estimate column "Amount or Number" indicates 4 samples per unit. The discrepancy should be corrected. This number of samples may not be sufficient if multiple efforts are required to adequately decontaminate the external or internal treatment unit surfaces. 17. Section 9.1. It is not clear why the analyses specified for soil samples are different between the first and second paragraphs. 18. Section Decontamination of the treatment unit is considered successful if the rinse water circulating in the operating treatment unit is not a hazardous waste. This is clearly not an appropriate performance standard for decontamination of surfaces. See General Comment Section This section clarifies that for the primary performance standard soil samples will be analyzed for the organic compounds under the hazardous waste codes, identified in Section 4, for which the treatment unit was permitted to treat. Only the waste codes F001, F002, and F005 listed in Section 4 have identified organic hazardous constituents. Waste codes 211 and 213 list some chemical compounds as examples for the waste description, but a complete list of hazardous constituents is not provided. It is not clear why "non-detect" is identified as a Primary Performance Standard if a health risk assessment will be

8 Page 6 applied to any detected organic constituent. The soil analyses and performance standards are only discussed for organic constituents. There are no performance standards for inorganic constituents. 20. Section 10.3 proposes a risk assessment for organic constituents in soil and an iterative process of removal and subsequent risk assessments until the risk endpoints are within an acceptable range. The description of this closure by removal process is wholly inadequate. 21. Section 11, Closure Cost Estimate. The cost estimates are incomplete and inadequate. Provide a revised cost estimate. DTSC typically uses CostPro or RACER cost estimating programs to evaluate closure cost estimates. However, because the implementation of closure is imminent. a detailed closure cost estimate comparable to CostPro or RACER is not essential. 22. The sections for Closure Cost Estimate and Financial Responsibility are both numbered "11." 23. Table 1, Maximum Inventory, indicates 15,000 gallons of decontamination rinse water per unit. However, Table 4. Closure Cost Estimate, line 1.2.2, indicates only 1 unit with 15,000 gallons of rinse water, instead of 4 units. The text in the tables should be reconciled and corrected as necessary. 24. Table 4, Closure Cost Estimate, line J indicated 5 samples per treatment unit, but costs are only provided for 4 samples per unit. Line 2.1 specifies $75.00/hour. but has a unit cost of $ (see line 3.1 for example of specifying 2 $75/hour/person). Line 3.2 provides for only 18 samples of soil and concrete per unit. which provides three samples at each of six locations. So either the concrete core sample or the 24"-30" depth soil sample is not included in the cost estimate. In section 4.0 the values in the Estimated Cost column are incorrect and the correct values are shown in a column at the wrong location. The Cost Estimate should be revised as necessary to accurately reflect the anticipated costs. Area II GTU Closure Plan 25. The Executive Summary, Introduction, first bullet, says there are 2 sets of four air stripping towers (ASTs) at the Bravo Test Area. There are 2 sets of two ASTs for a total of four ASTs. 26. Section 4., Hazardous Waste Constituents. lists waste codes that applied or may have potentially applied to the waste stream treated in the GWTUs, but does not list chemical compounds (except trichloroethylene and hydrazine). Section 4 is

9 Page 7 referenced in Section 8 as constituents for analysis and in Section 10 as a list of analytes for the performance standard. It is not clear how the list of waste codes in Section 4 will function in closure plan Sections 8 and Sections and It is not clear why flushing treated effluent through the system is "after the equipment exteriors and the concrete slab have been decontaminated." This may be a "carry over" from a prior closure plan which treated the exterior and concrete slab rinse water in the treatment system. 28. Section indicates that after the decontamination of the RD-09 treatment unit interior is completed, the carbon canisters will be disconnected and removed from the treatment unit. Carbon canisters are not listed in the description of the RD-09 UV/Peroxidation Unit in Section Section This section clarifies that for the primary performance standard soil samples will be analyzed for the organic compounds under the hazardous waste codes, identified in Section 4, for which the treatment unit was permitted to treat. Only the waste codes F001, F002, and F005 listed in Section 4 have identified organic hazardous constituents. Waste codes 211 and 213 list some chemical compounds as examples for the waste description, but a complete list of hazardous constituents is not provided. It is not clear why "non-detect" is identified as a Primary Performance Standard if a health risk assessment will be applied to any detected organic constituent. The soil analyses and performance standards are only discussed for organic constituents. There are no performance standards for inorganic constituents. 30. Section 10.3 proposes a risk assessment for organic constituents in soil and an iterative process of removal and subsequent risk assessments until the risk endpoints are within an acceptable range. The description of this closure by removal process is wholly inadequate. WS-05 Closure Plan 31. The Closure Plan is inadequate and should be updated. 32. Section 2. The closure plan must include any influent/effluent tanks. 33. Section 3.2., Hazardous Waste Constituents, lists waste codes that applied or may have potentially applied to the waste stream treated in the GWTU I but does not list chemical compounds (except TEC, cis 1,2-DCE, trans 1.2-DCE and hydrazine). Section 3 is referenced in Section 9 for organic compounds to be analyzed for the performance standard. It is not clear how the list of waste codes in Section 3 will function in closure plan Section 9.

10 Page Section 6.3. The decontamination of the equipment interiors consists of continuously flushing treated effluent through the system for a minimum of two hours. There are no sampling, analysis, or performance standards described for the decontamination. 35. Section 6.5. The management and disposal of rinse water treated in the treatment unit is not described. 36. Section 9. This section states that soil samples will be analyzed for the organic compounds under the hazardous waste codes, identified in Section 3, for which the treatment unit was permitted to treat. Only the waste codes F001, F002, and F005 listed in Section 3 have identified organic hazardous constituents. Waste codes 211 and 213 list some chemical compounds as examples for the waste description, but a complete list of hazardous constituents is not provided. clear why "non-detect" is identified as a Primary Performance Standard if a health risk assessment will be applied to any detected organic constituent. The soil analyses and performance standards are only discussed for organic constituents. There are no performance standards for inorganic constituents. 37. Section 9 proposes a risk assessment for organic constituents in soil and an iterative process of removal and subsequent risk assessments until the risk endpoints are within an acceptable range. The description of this closure by removal process is wholly inadequate. It is not 38. Section 10, Closure Cost Estimate. The cost estimates are incomplete and inadequate. Provide a revised cost estimate. DTSC typically uses CostPro or RACER cost estimating programs to evaluate closure cost estimates. However, because the implementation of closure is imminent, a detailed closure cost estimate comparable to CostPro or RACER is not essential. Delta Closure Plan 39. The Closure Plan is inadequate and should be updated. 40. Section 6.3. The decontamination of the equipment interiors consists of continuously flushing treated effluent through the system for a minimum of two hours. There are no sampling, analysis, or performance standards described for the decontamination. 41. Section 6.5. The management and disposal of rinse water treated in the treatment unit is not described.

11 Page Section 9. This section states that soil samples will be analyzed for the organic compounds under the hazardous waste codes, identified in Section 3, for which the treatment unit was permitted to treat. Only the waste codes F001, F002, and FOOS listed in Section 3 have identified organic hazardous constituents. Waste codes 211 and 213 list some chemical compounds as examples for the waste description, but a complete list of hazardous constituents is not provided. It is not clear why "non-detect" is identified as a Primary Performance Standard if a health risk assessment will be applied to any detected organic constituent. The soil analyses and performance standards are only discussed for organic constituents. There are no performance standards for inorganic constituents. 43. Section 9 proposes a risk assessment for organic constituents in soil and an iterative process of removal and subsequent risk assessments until the risk endpoints are within an acceptable range. The description of this closure by removal process is wholly inadequate.