II III 1101 IIIIIIIIIIII I. Alk. Internal Letter. wilt Rockwell International. HDMSe BNA

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1 HDMSe nternal Letter AXW 15 July 1992 No :. Alk wilt Rockwell nternational TO : (Name. Organ,ral,on. n!ernala Cdress FROM :,Name. O,,ancat,cn, internal Address. ~nc = J. T. Nagamatsu S. R. Lafflam Rocketdyne-Canoga Rocketdyne-Plummer 597, 055-AA24.543, 055-JA suo;ect:environmental Protection Activity Repor t PROBLEMS - Nothing of significance to report. ACHEVEMENTS - Nothing of significance to report. NFORMATON B/886 - Several areas surrounding the Sodium Disposal Facility were sampled to obtain background levels for chemicals and radioactivity in soils. Buried objects in the western area are being excavated from noncontaminated areas. SSFL Ground Water Programs - Comments on the nterim Well Construction Proposal were received from the NASA/MSFC technical coordinator and the ETEC program manager. The document will be finalized for the DOE approval loop upon transmittal of NASA and Rocketdyne comments to GWRC. At ETEC's request, Environmental provided ETEC personnel with a tour of potential sites for the Area V interim extraction wells. Various options for well and tank placement were explored. RD-34A, downgradient of RMDF (Area V), showed 61 ppb TCE from the sample taken 8 June 1992 during the quarterly round. Previous results, since August 1991, ranged from ppb TCE. The off-site wells at the western borders (OS-1,2,3,4,5, and OS- 21) continue to remain clean. OS-8 and OS-10, wells directly north of SSFL, are also clean. Per a DOE request, the "Draft Comprehensive State Ground Water Protection Program Guidance" from EPA was reviewed and comment provided. EPA would give deferential authority to the State, and the State would set the RCRA priority which might differ from the DOE's national priorities. Additionally, a certification program for drillers, pump installers, and test samplers would be required. Discussions are continuing with GWRC concerning the regulatory requirements for the 1993 SSFL Ground Water Monitoring Schedule that is to be compiled by 1 October Current plans call for decreasing the number of wells monitored but increasing the analytes measured to insure full compliance with both the Federal regulations and the State code prescribed in Title 22. The offsite well monitoring will be impacted (and upscaled) due t o BNA

2 HDMSe results from the on -going Multi - Media Sampling Program that spanned the northern off-site border of the SSFL. Corrective Action Order (CAO ) - Environmental met with members of the DTSC on 9 July 1992 to discuss the health based risk assessment activities for the CAO. A " scaled down" risk assessment will be conducted prior to the RF. Environmental will review the assessment guidance document and provide comments to the DTSC by the end of July. Freon 22 Waste - Staff began investigating the disposal of approximately 200 gallons of Freon 22 refrigerant gas originating from a refrigeration system removal at the Canoga facility. Attempts will be made to recover the compressed gas for reuse in another refrigeration system before declaring the material a waste. Aerosol Profile - An inventory of aerosol containers to be disposed via the Ensco facility have been supplied to the disposal facility. Ensco has asked that only preapproved aeroso l containers be shipped to the disposal facility. New types of aerosol containers may be added to the profile at Rocketdyne's discretion. This profile will provide Rocketdyne with the option to reduce lab packing services by allowing in-house packaging of this waste. ndustrial Wastewater Sampling - Routine monthly industrial wastewater sampling was conducted at four locations at Canoga, as required by L. A. City Bureau of Sanitation. Stormwater Program Modification - A notice of proposed modification was received from the RWQCB. Permit modification was in response to a 4 / 92 final federal ruling, and essentially eliminates requirement to sample stormwater. Staff is awaiting issuance of permit ( s) from RWQCB with the final requirements. Submission of Revised Part A Application for RMDF - A revised Part A application for RMDF was submitted to DOE for review and signature last Thursday. Revisions to the existing Part A permit are needed to allow for the storage and treatment of soils containing mixed wastes at RMDF which will be generated from the remediation project at the Old Sodium Burn Facility. DOE signed the. application and forwarded it to EPA for processing by early next week. SSFL Area V Ground Water Program - The R/ A and VOC analytical data from the B / 059 French drain water was reviewed. There were no elevated levels of radionuclides and chemicals. The water will be discharged to the storm drain. BNA

3 HDMSe The May Monthly Report on SSFL Ground Water Assessment was completed for ETEC. Canoga Ground Water - The latest analytical results for water samples collected from the extraction wells have been received. 1,1,1-TCA and 1,1-DCE concentrations have shown elevated levels in extraction well E-5. t appears that the respective plumes are migrating away from extraction wells E-3 and E-04 and toward E-5 and possibly E-6. On 7 July 1992, a pressure gage located in the hydrogen peroxide feed line failed. This resulted in a loss of 100 gallons of peroxide into the secondary containment berm. The peroxide was diluted and pumped into the collection tank at the W treatment system. The spill was not reportable. Risk Management and Prevention Program (RMPP) Canoga Facility - Environmental and Facilities staff members and the consultant continue to work on the development of the RMPP - the current task being the modeling of vapor dispersions. The official draf t report will be submitted for internal review by 17 July Rule Work continues for evaluating replacements for acetone and PA used as a shop-aide and other noncompliant operations. A Manufacturing control policy is in the process of being written with ME&T and MTS to phase out noncompliant and unnecessary uses. Tooling - A chemical inventory was performed in B/029 to determine rule compliance. B/037 TCA Containing 1-4 Dioxane - Twenty-five drums containing trichloroethane with 1-4 Dioxane were deemed unacceptable for use and were identified for waste disposal and solvent reclamation. HazMat Elimination Team : Monthly Solvent Reduction Report - Since program inception in October 1989, Rocketdyne has posted a 64.0% reduction of trichloroethane and a 96.4% reduction of Freon 113, from the baselines, as compared to targeted goals of 31.2% and 68. 8% respectively. These goals reflect the accelerated phaseout requested by President Bush. Chemical Tracking System (CTS) - The initial entry of new MSDSs is almost complete ; subsequent receivals will be entered after a duplication check is performed. Additional FOCUS reports are being identified for end users, and an inquiry screen for "product by name" is almost ready for initial user checkout. Missing environmental data are being filled in on Health & Safety MSDSs ; one volume out of the 30 total volumes has been completed. Chemical storage locations at DeSoto were identified and device numbers were assigned for the Chemical Tracking System. BNA

4 HDMSe ! CR+6 Elimination - The fourth meeting was held regarding reduction and elimination of chromated materials. Members of the Turbopump O/E in conjunction with ME& T will submit a change request to find a non - chromated primer. The next meeting is scheduled for 23 July Rockwell Power Systems ( RPS) - Albuquerque / Bernalillo County - Additional information has been requested from RPS in order to better define their processes and the products used. Thi s information will be provided to the Bernalillo County Air Pollution Control District for their review ( although it is still not expected that permits will be required). Rocket Engine Test Air Toxics Source Testing - Several meetings were held with the Aerothermodynamics group to determine the accuracy of the plume volumetric flow rate used by ABB Environmental to calculate air toxic emission factors. They will be working this issue over the next few weeks. Process Safety Management (PSM,SSFL - Federal OSHA ' s final rule on PSM is partially in effect as of 26 May t has been determined that SSFL is extensively affected by this new rule. The PSM requirements are very similar to those of California's RMPP ; however, OSHA has developed its own list of highl y hazardous chemicals requiring PSM. This new rule deals specifically with the protection of the employees by preventing and minimizing the consequences of highly hazardous chemical accidents. The California RMPP deals with the protection of the public. Hazardous Materials nventory ( SSFL ) - The managers for the various facilities at SSFL were requested to provide the current inventory for hazardous materials handled in their areas. The existing inventory will be updated and submitted to the Ventura County Fire Department. Asbestos - Baker Pacific removed approximately 1000 square feet of asbestos -containing floor tile and mastic from SSFL B/300B. The project was completed over the weekend in order not to impact routine operations. Wall surfacing material from SSFL B / 003 was sampled and found to contain asbestos. Former Nevada Field Laboratory - Twenty samples were retrieved from Area B. The samples are currently being analyzed for asbestos. n addition, four 55-gallon containers were filled by Disposal Control Services with asbestos - containing debris from a land owner ' s property. After completion of the job, the landowner inspected the area and appeared satisfied with the completed work. Environmental Auditing Program - Monthly AB 2588, Rule 109 daily logs were received, reviewed for compliance and filed. BNA

5 HDMSe SCAOMD Source Testing Fee Request - An invoice was received from SCAQMD on 13 July requesting payment of $ in source testing evaluation fees incurred during installation of low-nox burners in various boilers at Canoga pursuant to Rule The accompanying District letter noted that the fees were due on 6 July and that permits would be suspended unless payment was received prior to that date. The District was contacted and agreed that the letter was in error and a 30 - day extension was granted. S. R. Lafflam Director Environmental Protection BNA