Internal Letter 01% Rockwell international

'23 April 1993 No:93EP-18 0Date .

• 10- (N,nre, O, a, dat;an , Intern/ Addms) F ROW IName . Ortwi (,On. lnte .,ut Addess . Ph~ )

Those Listed X. D . NelsonRocketdyne-SSFLD7543 , 055-T486586-617 8

•

sut,iect :Groundwater Remediation Facilities Monitoring Pla n

This plan summarizes the operation and monitoring of the SSFLgroundwater extraction/treatment systems . A copy of this planwill be kept at the hazardous waste yard office and at the officeof the Environmental Field Operations Manager . Section numbersrefer to sections in the treatment system folder for each unit .

The purpose of the groundwater reclamation program is twofold : 1)to maintain groundwater gradients to prevent off-site movement ofcontaminated groundwater , and 2 ) to extract and treat degradedgroundwater from targeted areas for removal of volatile organiccontaminants . The location of the extraction /treatment systemsare shown on the map (Figure 1 - Treatment System Location Map)in Section 3 and are designated as follows :

1) Area I Road AST2) Alfa AST3) Bravo AST4) Canyon AST5) Delta AST6) STL-IV AST and Collection Tank7) RD-9 Area (UV/Ho2 Batch Unit)

t 28) WS-5 UV/H O Unit9) ECL Collection Tank

Treatment facilities are currently in place at all areas exceptthe ECL extraction area . Treatment systems are air strippingtowers (AST) with vapor phase carbon treatment or ultravioletlight/hydrogen peroxide treatment systems (UV/H202) .

DESCRIPTION OF TREATMENT SYSTEMS :

A description of each treatment system , associated extractionwells and area , design contamination level, treatment rates, andeffluent points are shown on the Groundwater Treatment Systemstable (See Section 5) . A schematic diagram of each well andassociated lithogic log is also provided in Section 5) . section4 contains a diagrammatically illustration of each treatmentsystem and associated design specifications .

PERMITS : ( Compliance )

A Permit To Operate the AST's has been obtained from the Countyof Ventura Air Pollution Control District ( VCAPCD) .A copy of the permit ( No . 1344 ) is located in Section 3 of thisfolder, and is posted at each AST .

mss'NELSON

CONFIDENTIAL - UNDER PROTECTIVE ORDER, UnitedStates District Cou rt for the Central District of California

No . CV 97-1554

tRSS-60-1432

BNA 114825

HDMSe00359020

93EP-18023 April 1993Page 2

On 25 May 1990 , Part B Applications for the GroundwaterRemediation Facilities (EPA ID# 's CA1800090010 and CAD093365435)located in Area II (NASA ) and Areas I & III (Rocketdyne)respectively , were submitted to the California Department ofHealth Services ( Dolls ) . On 15 November 1990, an Amended Part Awere submitted to the DoHS . The Part A Applications were grantedapproval of the requested interim status on 25 February 1991 .

(6)z 0 40 ,• zip* ,

1) Air Flow Rate (Compliance) :

Subject to VCAPCD Permit, item 3, a mechanical exhaust damper islocated in the exhaust of each AST primary tower , at the entranceto the blower . The setting of the damper shall be set duringeach inspection . Damper setting is determined by the markedmanometer reading at each AST which has been determined by themanufacturers recommended procedure ( see Section 4) . Theadjusted manometer reading shall be indicated on the SSFL AirStripping Tower Daily Inspection Log (Log ) (see Log located inSection 3) .

2) Independent Water Samples (Compliance) :

. Subject to VCAPCD Permit , item 5 , an independent certifiedlaboratory analyzes monthly samples-taken of the AST influent,primary tower effluent , and the secondary tower effluent fromeach air stripping tower (see table below for sample ports) .Currently , these samples are taken by Groundwater ResourcesConsultants ( GRC) and taken to a certified lab for analysis .Results are published in the Monthly Groundwater MonitoringReport. Results shall be maintained at the office of theEnvironmental Field Operations Manager for a period of two yearsand be made available to VCAPCD personnel on request .

SAMPLING SCHEDULE

ASS SAMPLE PORT SAMPLING SCHEDULEALFA AT1-I, AT1-E , AT2-E MONTHLYAREA I RD AIR1-I , AIR1 -E, AIR2 -E MONTHLYBRAVO BT13-I , BT1-E , BT3-E , BT2-E , BT4-E MONTHLYCANYON CT1-I , CT1-E , CT2-E MONTHLYDELTA DT1-I, DTI-E , DT2-E MONTHLYSTL-IV STL1-I, STL1-E , STL2 -E MONTHLY

3) AST Air Stack Monitoring ( Compliance) :

Subject to VCAPCD Permit , item 6 , tests shall be conducted onceper week of operation for ROC at the exhaust of each carbonadsorption system and at the exhaust of each secondary tower .Tests shall be conducted by the approved analyzer ( FoxboroCentury OVA128 Portable Organic Vapor Analyzer ) . Operation of theOVA shall be per manufactures Instruction Booklet 611-132 datedDecember 1985 .

NELSON RSS-60-1433

CONFIDENTIAL - UNDER PROTECTIVE ORDER, UnitedStates District Court for the Central District of Californi a

No. CV 97-1554 BNA 11482 6

HDMSe00359021

93EP-18023 April 1993Page 3

• Sample collection and analysis shall be as follows:

a) All air measurement shall be made by using aKevlar sample bag . For each analysis , the bag shall befilled with the subject air, then expressed, andrefilled .

b) Calibrate OVA using 95 ppm ROC as methanecalibration gas . Set zero point using 0 ppm calibrationgas . Make a background reading of air, noting thereading at the top of the Log. Zero-out the backgroundreading by setting the instrument indicator to "0" .

C) Collect sample of air from the carbon canistereffluent manifold . For the secondary tower, use aMillipore Vacuum Pump connected to the air samplingport connected to a PVC pipe running to the top of thetower . The pump shall be run for a minimum of 5minutes before a sample is taken .

d) Analyze samples of air collected in the Kevlarbags and write results on the Log .

4) AST Water Samples (Rockwell Noteworthy Practice) :

• A Rockwell technician shall collect .- a system influent VOC watersample in the second week of each month ( see table of sampleports below ) . A Rockwell technician shall take system effluentwater samples for VOC's in the second week of each month ofoperating AST's (see table below ) . Analytical results shall bekept in Sections 1 for system influent and Section 2 for systemeffluent .

SAMPLING SCHEDULE

ALFAALFAAREA I RDAREA I RDBRAVOBRAVOCANYONCANYONDELTA

DELTA. STL-IV

STL-IVWS-5/WWS-5/UVUV /BATCHUV /BATCH

NELSON

SAMPLE PORTAT1-I

AT2-EAIR1-I

AIR2-EDT13-IBT2-E,BT4-ECT1-ICT2-EDT1-IDT2-ESTL1-I

STL2-EW5-IW5-ET-1,2T-3,4

SAMPLING SCHEDULEMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYMONTHLYAFTER TREATMENT

RSS-60-143 4

CONFIDENTIAL - UNDER PROTECTIVE ORDER, United

States DistrictCourt for the Centra laDistrict of California

BNA 114827

HDMSe00359022

93EP-18023 April 1993Page 4

05) UV/H202 Water Samples (Rockwell Noteworthy Practice) :

Well WS-5A Rockwell technician shall take VOC water samples of systeminfluent (monthly) at port W5-I, and a system effluent (monthly)from port W5-E in the second week of each month as indicated inthe table above .

UV/BATCH (When operational )A Rockwell technician shall take water samples of the systeminfluent at tank ports T-1, and T-2 in the second week of eachmonth or upon transfer of water to the holding tanks . Aftertreatment, samples of the treated water shall be taken from tankports T-3 and T-4 . Sample analytical results for each batch willbe filed in the UV/Batch unit folder .

6) Sampling and Testing Methodology :

samples, including trip blanks shall be collected, labeled, andtransported per Groundwater Sampling and Analysis Plan, 8640M-113, dated February 26 1991 . Laboratory analyzing the samplesshall adhere to EPA method procedures including appropriatequality control and quality assessment protocol. Analyticalrequirements for precision, accuracy, holding times and detectionlimits shall be followed according to method protocol as dictatedby State of California certification and specified in theLaboratory QA manual .

7) Results :

Results of all sampling analysis shall be filed in the folderlabeled for each treatment system. Copies of the analysis shallbe kept at the SSFL Hazardous Waste Yard office .

8) Log (Compliance) :

Daily inspection logs of the treatment systems must be completedevery normal working day . All copies of the logs shall bemaintained and be made available to agency personnel on request .Copies of the logs shall be maintained at the Hazardous WasteYard office , and at the office of the SSFL Industrial WasteManager .

Air Stripping Towers LogsThe SSFL Air Stripping Tower Daily Inspection Loa (see copylocated in Section 3 ) shall be completed by a Rockwell technicianevery normal working day . Items that must be filled out on adaily basis include :

• Water: Meter ( Flow Rate , totalizer)SHMP : All (if used )AIR : ManometerEQUIP : Al lOBSERVATIONS : As requiredREPAIRS : As required

NELSON

CONFIDENTIAL - UNDER PROTECTIVE ORDER , United

States District Cou rt for the Central District of CaliforniaNo . CV 97-1554

RSS-60-1435

BNA 114828

HDMSe00359023

93EP-18023 April 1993Page 5

•All other item shall be completed on a weekly basis , except VOASample Taken , which is completed as required .

At Delta , the Delta Tower Filter Operation Record shall be filledin whenever the filters are baekwashed . Follow directions infolder located on the control pannel at the Delta Tower .

UV/H 0 Systems LogsThe ISh W/H Q Treatment Systems Daily Inspection Loa (see copylocated in Sekt' on 3 ) shall be completed by a Rockwell technicianevery normal working day (Monday thru Friday ) . All items must becompleted , if applicable , every day .

Hazardous Waste Tank Daily Inspection Checklis tThe Hazardous Waste Tank Daily Inspection Checklist form (seecopy located in Section 3) shall be filled out daily (Monday thruFriday ) for the ECL and 8TL-IV collection tanks . The SSFLUltraviolet Light /Hvdroaen Peroxide Treatment System Monthly Loashall be completed every day of operation .

operation and maintenance of the AST's will be conducted usingthe OPERATION AND JO1INTRNANCL MANUAL FOR GROUNDWATER TREATXENTSYSTEM , as assembled by Emcon Associates, dated July 1987, andupdated on January 1989 .

Operation and maintenance of the UV/H 0 treatment systems willbe conducted using the perox-pure Opeiaiiag and MaintenanceManual, dated 2/22/90 for the Batch Unit in Area 11, and theperox-pure systems operation and Maintenance Manual, dated10/12/90 for the unit at Well WS-5, Area I .

All maintenance activities will be recorded on the DailyInspection Log for the appropriate unit ( see Log above) .

A . D . Nelson , ManagerIndustrial Waste - SSFL

0

NELSON RSS-60-1436CONFIDENTIAL - UNDER PROTECTIVE ORDER , United

States District Cou rt for the Central District of CaliforniaNo . CV 97-1554

BNA 114829

HDMSe00359024