Internal Letter oi% Rockwell · PDF fileInternal Letter oi%Rockwell International ... Nothing of significance to report. ... modeling study based on essentially the same methodology

Internal Letter oi% Rockwell Internationa lDate: • 8 June 1988 NO:• 88EU-090

TO : ;Name . Organization, fnrerna! Address FROM : Name, Organization, Interne; Address, Phone /

J . H . KellerRocketdyne-SSFL540, 055-T486

S . R . LafflamRocketdyne-SSFL543, 055-T4855705

Subject . • Environmental Control Weekly Activity Repor t

ACHIEVEMENTS - Nothing of significance to report .

PROBLEMS - Nothing of significance to report

INFORMATION

Alfa-Bravo Permit 0232 - The air emissions permit for the Alfa-Bravo teststands was received from the VAPCD after payment of the renewal fee andsubmitttal of the required data logs . The permit is valid for the period from1 January 1988 through 31 December 1988 . A copy of the permit has beentransmitted to the Test staff for proper posting .

B/009 (Canoga) Oven Permits - A group of oven permits (M63255-M63259) werereceived from SCAQMD for the Turbopump Overhaul Center, B/009 . These ovens,four Tenney Engineering and one Thermodynamic Engineering, were inspected by aSCAQMD inspector several months ago . Copies of the permits have beenforwarded to Ralph Hanks for proper posting .

VAPCD Meeting - SCTI Activities - A meeting was held at VAPCD headquarters todiscuss the Kalina cogeneration project and the SCTI H-1 heater high NOxvalue. With an Environmental representative present, ETEC staff presented abriefing on the Kalina project to the Engineering Section . VAPCD stated thatthe auxiliary burner will need a permit and the unit envisioned by Kalinashould be low-NOx, i .e ., 30-40 ppm, (2) the ammonia sparging tank will requirepermitting, and (3) the emergency pressure relief system dumping to theexhaust duct will not require permitting .

Relative to the recent H-i heater high NOx valve, the Engineering section saidthat Rocketdyne should be able to request a change in the permitted conditionsince H-1 was apparently grandfathered and the condition in question simplyreflects a source test that ETEC is willing to redo with a more suitableexcess oxygen level . Another meeting on the subject is planned with the VAPCOEnforcement Section for 7 June 1988 .

Asbestos Abatement Work Status -

B/201 (SSFL ) : NASA approval pendin g

B/409 (SSFL) : Water tank /heat exchanger scheduled for asbestosremoval beginning 17 June and concluding by 24 June .

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8/026 (SSFL) : Removal of 1 foot of asbestos-insulated pipescheduled for 7 June under the original planned removal . Approvalhas been given by VAPCD .

B/104 (DeSoto) : One asbestos-insulated valve within building and90 feet of piping outside building slated for removal .Notification has been made to SCAQMD .

CARE Nickel Plating Survey Submittal - The results of a nickel plating surveyhave been submitted to the California Air Resources Board . The data onelectroplating tanks and control technology were provided by the generatingdepartments . Environmental coordinated the data compilation and combined theresults into a unified submittal .

SSFL Traffic Abatement Plan - A response received from the VAPCD stated thatthe traffic abatement plan submitted for SSFL in March 1988 would be approvedconditionally . Approval predicated on the condition that by the next annualupdate 50 percent of the first shift week day employees must be participantsin the ride -sharing information program , as typified by Commuter Computer .Currently the figure is at 25 percent . A traffic coordinator has recentlybeen hired by Human Resources and will be copied on the approval letter whenreceived .

SCTI Fuel Usage Data Submittal - SCTI fuel usage data for 1986 and 1987 havebeen provided to VAPCD per their request . These data were obtained from fuelpurchase orders . In the future, the actual metered gas flows to specificpermitted SCTI heaters will be available via time plots .

Facility 705 (CTL-III) Iodine Dispersion Modeling - The effort to dispersionmodel the iodine exhaust emissions from the scrubbing tower associated withthe interstage condensers has commenced : ERT (Camarillo ) is performing themodeling study based on essentially the same methodology employed by EMSI forthe chlorine modeling and approved by the VAPCD for this effort . The projectis on the fast track and a draft report is expected in a couple of weeks .

ELV Braze Line , B/001 . Canoga - EMSI has been contacted concerning a programof air sampling in the area of the ELV braze line in 8/001 . A test plan has

been prepared by EMSI and reviewed by Environmental . MSDSs for hazardousmaterials used in the braze operation have been obtained and will be providedto EMSI . Preliminary evaluation of sampling locations, air velocities, andsampling logistics at Canoga will be assessed by EMSI this week .

Torpedo Ejector Cleaning - Canoga - Environmental was requested to review asolvent change in an expoxy stripping operation permitted under SCAQMD Permitto Construct 154762 . The original stripper solution consisting of a methylenechloride, phenol and formic acid solution was to be replaced by Turco W0#1which contains phosphoric acid and 2-butoxy ethanol . Condition 1 of thepermit requires that only non-photochemically reactive solvents can be used inthe system . Turco Products was contacted and assurances were received fromthem that Turco WO#l is non-photochemically reactive . Turco will provide an

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MSDS indicating such . A go-ahead was given to the Rocketdyne project managerto proceed with the chemical changeover subject to approval by Health andSafety .

Hazardous Waste Contracts - Six representatives of Rollins EnvironmentalServices, Inc . (RES) were at SSFL on 6 June to discuss implementation of thenew hazardous waste disposal contract . RES will be providing a monthlyservice to lab pack retrograde and off-spec chemicals for incineration . Thisservice should alleviate the extended accumulation and storage of chemicalsthat serve no useful purpose at Rocketdyne . Rollins Corporate Transportationis researching the possibility of using railcars to transport large volumes ofspecific hazardous wastes (e .g . CTL-III potassium hydroxide) to theirincinerator in Deer Park, Texas .

Hazardous Material Incidents - Written follow-up reports have been submittedto the appropriate regulatory agencies for the May 16 perchloroethylene spillat Canoga and the May 18 MMH spill at APTF .

Hazardous Waste Reports - CA DOHS has granted Rocketdyne a time extensionuntil June 30, 1988 to submit the annual /biennial hazardous waste reports forall seven EPA identification numbers .

Waste Minimization - Chemical analysis data for the CTL-III potassiumhydroxide waste has been submitted to Inspiration Mines in Arizona .Inspiration Mines is a large copper smelter which uses large quantities ofcaustic as part of their process . There is possibility that Rocketdyne may beable to sell /give the hydroxide to Inspiration Mines to use as a chemicalreagent, therefore exempting the solution from hazardous waste regulations andeliminating disposal costs .

Canoga Ground Water Program - The Annual Summary of Results of Ground waterquality Monitoring for 1987 has been completed by Groundwater ResourcesConsultants, Inc . (GRC) and is being distributed for review by the pertinentregulatory agencies . Third quarter sampling for FY1988 will be conducted byGRC during the week of 13 June 1988 . The proposed Phase II InvestigationWorkplan prepared for Montgomery Ward has been reviewed by GRC and commentsregarding the proposal have been submitted to Environmental .

Environmental has been investigating the feasability of installing an in-lineprocess Gas Chromatograph (GC) to monitor treated ground water from theultraviolet hydrogen peroxide (UV/H202) treatment system . The GC wouldcontinuously monitor the effluent quality and if inadequate treatment shouldoccur an automatic shutoff could prevent any discharge of non-complianteffluent to the environment .

In addition, a meeting is scheduled for 27 June 1988 with the South Coast AirQuality Management District (SCAQMD) to discuss air monitoring permits for theUV/H202 system .

Canoga Waste Water Treatment Facility - Environmental is considering thepurchase of a Memtek membrane filter unit to upgrade the existing waste wate r

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treatment plant . Memtek is currently looking into the modifications that willbe necessary at the existing facility to incorporate the unit into thetreatment process . Environmental will evaluate the feasability and benefitsalong with other systems prior to selecting a treatment option .

Training - A field sampling training program for Environmental Unit membersand Plant Services Environmental Technicians is being developed by the ChemLab and Environmental . An exact date for the training has not yet beenselected .

Waste Discharge Requirements for SSFL - Due to the proposed additional flowsgenerated by ground water cleanup systems, current permits governing the wastewater treatment and disposal system are no longer appropriate . Therefore,Environmental is preparing applications to update both the waste dischargerequirements and NPDES permit governing SSFL .

SSFL Surface Impoundment Closure Activities - Rocketdyne received the"Completeness Determination " letter from the Department of Health Services(DHS) on June 1, 1988 . They considered the latest draft Closure Plans to be"administratively complete but technically inadequate " and have givenRocketdyne until June 30, 1988 as the deadline for the submittal of plans thatwould include further soil removal from APTF , STL-IV, ECL, ABSP , Delta, SPA-1and SPA-2 . Only PLF was not mentioned . DHS commented that they wanted "nomore bargaining " and that Rocketdyne should proceed with the directionsprovided so that an approval could be given by August following the publiccomment period ' s termination as of July 1, 1988 . The only other recourse thatDHS has offered is post-closure monitoring of each impoundment with all of itsattendant financial liability for the Corporation .

OHS had stated that EPA had not yet finished its review . When EPA wascontacted it was made clear to Rocketdyne that EPA wanted OHS to establish itsleadership in the closure plans and that EPA had only included their standardstatement that groundwater monitoring requirements were those set forth in thecode of federal regulations , which Rocketdyne is not following nor has itfollowed . 40 CFR 265 Subpart F includes the option for alternative technicalapproaches to the groundwater monitoring if sufficient documentation of anacceptable rationale is provided . Groundwater Resource Consultants, Inc .( GRC) will be writing the text for Rocketdyne by June 22, 1988 .

OHS wants all contaminant levels down to background , ( i .e . zero ) or post-closure monitoring . OHS stated that Rocketdyne could go down to the sandstoneand stop, provided that the walls around the impoundments were clean .

Rocketdyne Environmental , with the advice and counsel of Corporate Legal,intends to seek lessening of the requirements through negotiation with the EPAand DHS administration , particularly with respect to being subject togroundwater monitoring procedures delineated in 40 CFR Part 265, Subpart F,which would include more investigation and more well drilling .

SSFL Groundwater Program - The four stripping tower systems that have beenrestarted are experiencing difficulties . The Delta booster pump is down and

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back in service . Apparently the liquid came from a different source otherthan the tanks (e .g . parts rinsing) . This was not a reportable incident andthere were no injuries .

On 6 June approximately 30 gallons of oil spilled in B/001 when an 0-ringfailed on a pressurized oil line . The Canoga Spill Response Team(Environmental and Plant Services ) responded to the spill . This was not areportable incident and there were no injuries .

On 3 June approximately 3 gallons of trichloroethane spilled from a hoseassociated with the 8/001, 544 process area degreaser . The Spill ResponseTeam mitigated the incident . This was not a reportable incident and therewere no injuries .

On 2 June approximately 10 gallons of potassium hydroxide spilled when adiaphram pump failed during an acid neutralization project at DeSoto B/104 .Rocketdyne environmental contractor ( Disposal Control Service ) was on sitedoing the neutralization and quickly cleaned up the hydroxide . This was not areportable incident and there were no injuries .

On 7 June three 8-foot lengths of pipes taken to Surplus Sales to be scrapped,were found to be wrapped with friable asbestos insulation . Apparently thepiping was sent to Surplus Sales as a result of a renovation project atCanoga-West . There was no release of asbestos to the environment . The pipingwas covered , labeled, and will be disposed of as hazardous waste viaRocketdyne ' s asbestos abatement contractor .

B/886 Burn Pit - Environmental conducted a job walk with DCS to constructberms/ditches and to install culverts at the B/886 Burn Pit in order to divertsurface water from entering the facility and to prevent soils suspended inwater from running off the facility . This is being done in response to theCategory II Surface Water finding stated in the recent DOE EnvironmentalSurvey .

DOE ES7H Long -Range Plan - Environmental met with ETEC personnel on June 2 & 7to discuss the DOE environmental survey . Cost estimates for soil analysis andgroundwater monitoring plans are currently in work by Groundwater ResourcesConsultants . Action items have been assigned to complete a 10 yearEnvironmental Safety and Health ( ES&H) Long-Range Plan which is due back toDOE-SAN by 30 June 1988 . The plan will include a description of all presentand planned ES&H activities with associated costs necessary to rectify .problems at DOE ' s facilities, and to maintain required environment , safety andhealth programs .

/ .7c_S. R . Lafflam , Manage r

Cy r)Environmental Uni t

SRL:sj/0007H

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ENVIRONMENTAL UNIT - WEEKLY ACTIVITY REPORT

DISTRIBUTION

T . W . ButlerM . G . ChavezP . C . G. CoulterM. A . Franci sD . C . HunterJ . A . KucinskasL . E . LukunichJ . Monagha nD . Ploszaj0 . S . RobersonC . J . RozasM . RobertsonJ . UrangaEnvironmental Staff

540, 055-T486031, 055-SS25091, 055-AB57878, 001-D48564, 055-T486014, 055-EA35546, 055-AD06598, 055-SS06540, 055-T483565, 055-L805551, 055-CSO1539, 055-SS12Dallas, 407-200

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another has been ordered ; the Bravo blower pump is not working correctly ; theacid injection systems at Alfa and Canyon need further adjustment to maintainan effluent level of pH 8 .0 - currently they are at 8 .4 and 8 .2, and theEnvironmental technicians are making adjustments in the acid flow .Arrangements have been made to have EMCON Associates (consultants in thestripping tower systems) to come to SSFL to diagnose the problems and assistin solving them . When the systems are running , chemical analysis of theeffluents has indicated that all volatile organic compounds had been removed .

Underground Tank Program - Rocketdyne has received the permits for the removaland installation of the underground tanks in Area II at B/204 and B/207 .

Huntsville Briefing - Environmental management and staff will brief the NASAFacilities organization in Huntsville , Alabama on NASA ' s responsibilities andliabilities for the closure of surface impoundments and groundwate rremediation for Area II at SSFL . The briefing will take place on June 8 and 9 .

Waste Minimization - On June 2 approximately 5000 gallons of 2 . 5% waste KOHwas transported from CTL-III to an empty 6500 gallon tank at DeSoto B/104 .This solution was used to neutralize 250 gallons of 50% hydrochloric acid froma spent bath and a similar quantity of ammonium bifluoride . The reactionproducts of the neutralization will be sewered under permit using the B/104

clarifier . This effort provided an excellent opportunity to minimize

hazardous waste generation , resulting in $30,000 saved in hazardous wastedisposal costs .

SARA - Title III, Section 313 toxic chemical release reporting for both DeSotoand Canota facilities are expected to be completed by June 10th . As yet, thereportable chemicals under 313 are TCA and freon - both of which are used in

excess of 10,000 lbs . at each facility . Release reporting for SSFL will becompleted by June 17th .

Environmental Task Team - On 1 June Environmental, Health & Safety,Manufacturing and Transportation met to discuss problems with chemical use andhandling at Rocketdyne . Issues of concern include improper chemical handlingresulting in hazardous material incidents . Also discussed were thepossibilities of a chemical tracking system to satisfy federal requirementsfor chemical use reporting . Action items include training relative to properstorage, handling, transportation, and use of chemicals throughout thefacility . In addition, a member of Environmental will conduct an audit totrace the flow of chemicals from time of purchase through the time they areused at individual facilities . Unfortunately, a representative fromPurchasing was not available to add vital comments concerning chemicalordering through the chem stores min/max system .

Hazardous Material Incident s

On 6/3/88, a yellowish liquid (pH 9) was observed in the bermed area at L-14,

544 process area . The standing liquid was cleaned up by the Plant ServicesSpill Response Team . There was no release to the sewer . Plant Services leaktested the suspect tanks over the weekend and there was no evidence of cracksor holes . The original solution will be pumped back into the tanks and placed

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