Rockwell Internal Letter - DTSC - Santa Susana Field … · 2007-08-10 · Rockwell Internal Letter Date: August 24, 1995 No. 95EP203 To: M+n4OWarvan, ... use a Millipore Vacuum Pump

ATTACHMENT VIII-B

Rockwell Internal Lette rDate: August 24, 1995 No. 95EP203

To: M+n4 OWarvan, MhnW AW-)

Those ListedFrom: Am . Muni A00w, PNm y

A. D. NelsonRocketdyne - SSFL

D/543, 055 - T48666178

Subject Groundwater Remediation Facilities Monitoring Pla n

This plan summa rizes the operation and monito ring of the SSFL groundwater extraction andtreatment systems . A copy of this plan will be kept at the hazardous waste yard office and at

the office of the engineer responsible for the groundwater remediation operations . Sectionnumbers refer to sections in the treatment system folder for each unit .

INTRODUCTION :

The purpose of the groundwater reclamation program is twofold : 1) to maintain groundwatergradients to prevent off-site movement of contaminated groundwater, and 2) to extract andtreat degraded groundwater from targeted areas for removal of volatile organic contaminants .The location of the extraction and treatment systems are shown on the map (Figure 1 -Treatment System Location Map) in Section 3 and are designated as follows :

SSFL TREATMENT SYSTEMS

. TREATMENT NAME SSFL AREA

1) Area I Road AST Area I

2) Alfa AST Area I

3) Bravo AST Area II4) Canyon AST Area I

5) Delta AST Area H

6) STL-IV AST Area HI

7) RD-9 Area (UV/H2O2 Batch Unit) Area II

8) WS-5 UVIH2O2 Unit Area I

9) ECL Collection Tank Area III

Treatment facilities are currently in place at all areas except the ECL extraction area .

Treatment systems are air stripping towers (AST) with vapor phase carbon treatment or

ultraviolet light/hydrogen peroxide treatment systems (UV/H202) .

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DESCRIPTION OF TREATMENT SYSTEMS :

A description of each treatment system , associated extraction wells and area , designcontamination level, treatment rates , and effluent points are shown on the GroundwaterTreatment Systems table (See Section 5). A schematic diagram of each well and associatedlithogic log is also provided in Section 5 . Section 4 contains a diagrammatically illustration ofeach treatment system and associated design specifications .

PERMITS : (Compliance)

A Permit To Operate the AST' s has been obtained from the County of Ventura Air PollutionControl District (VCAPCD). A copy of the permit (No. 1344) is located in Section 4 of thisfolder, and shall be posted at each AST.

On 25 May 1990, Part B Applications for the Groundwater Remediation Facilities (EPA ID#'sCA1800090010 and CAD093365435) located in Area II (NASA) and Areas I & III(Rocketdyne ) respectively, were submitted to the California Depa rtment of Health Services(DoHS ) . On 15 November 1990, an Amended Pa rt A were submitted to the DoHS . The PartA Applications were granted approval of the requested interim status on 25 February 1991 .The Depa rtment of Toxic Substances Control (DTSC) issued . a Hazardous Waste Faci lity

Post -Closure Permit effective May 11, 1995 which is the permit to operate the groundwatertreatment units .

MONITORING :

1) Air Flow Rate (Compliance) :

Subject to VCAPCD Permit , item 3 , a mechanical exhaust damper is located in the exhaust of

each AST p rimary tower, at the entrance to the blower. The sett ing of the damper shall be set

during each inspection, subject to Rockwell letter dated November 14, 1990 , referencenumber 90RC14835 (see copy Section 4) . Before making a manometer reading , disconnect

both hoses and adjust the manometer to read zero . Damper setting is determined by the

marked manometer reading at each AST which has been determined by the manufacturers

recommended procedure (see Section 4). The adjusted manometer reading shall be indicatedon the SSFL Air Stripping Tower Daily Inspection Log (Log ) (see Log located in Section 3) .

2) Independent Water Samples (Compliance) :

Subject to VCAPCD Permit, item 5 , an independent certified laboratory analyzes monthly

samples taken of the AST influent, primary tower effluent, and the secondary tower effluent

from each air stripping tower (see table below for sample ports) . Currently, these samples are

taken by Groundwater Resources Consult ants (GRC) and taken to a certified lab for analysis .

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August 24, 199 5

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Results are published in the Monthly Groundwater Monitoring Report . Results shall bemaintained at the office of the engineer for a period of two years and be made available toVCAPCD personnel on request .

INDEPENDENT SAMPLING SCHEDUL E

AST SAMPLE PORT SAMPL ING SCHEDULE

ALFA AT1-I, AT1-E, AT2-E MONTHLYAREA I RD AIRI-I, AIR1-E, AIR2-E MONTHLYBRAVO BT13-I, BT1-E*, BT3-E*, BT2-E*, BT4-E* MONTHLYCANYON CT1-I, CTI-E, CT2-E MONTHLYDELTA DTI-I, DTI -E, DT2-E MONTHLYSTL-IV STL1-I, STL1-E, STL2-E MONTHLY

* Note : Only one set of towers may be operating . Sample only from operating towers .

3) AST Air Stack Monitoring (Compliance) :

Subject to VCAPCD Permit, item 6, tests shall be conducted once per week of operation forROC at the exhaust of each carbon adsorption system and at the exhaust of each secondary

tower. Tests shall be conducted by the approved analyzer (Foxboro Century OVA 128Portable Organic Vapor Analyzer) . Operation of the OVA shall be per manufactures

Instruction Booklet 611-132 dated December 1985 .

Sample collection and analysis shall be as follows :

a) A ll air measurement shall be made by using a Tedlar (or similar air sampling bag)sample bag . For each analysis, the bag shall be filled with the subject air, thenexpressed, and refilled . Use one bag for "zero air" and effluent, and a second bag for"100" (i .e . setting the high end of scale) and influent air if taken .

b) Calibrate OVA using 0 ppm ROC as meth ane calibration gas and 95 to 100 ppmROC as methane calibration gas . Set zero point using 0 ppm calibration gas, and thehigh end using the percent of calibration gas used (usually 95 to 100 ppm) . Set theOVA to read the actual calibration gas used. Make a background reading of air,noting the reading at the top of the Log . Zero-out the background reading by setting

the instrument indicator to "0" . This subtracts the background from all subsequent

readings .

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c) Collect sample of air from the carbon canister effluent manifold . For the secondarytower, use a Millipore Vacuum Pump connected to the air sampling port connected toa PVC pipe running to the top of the tower . The pump shall be run for a minimum of5 minutes before a sample is taken .

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

4) AST Water Samples (Rockwell Noteworthy Practice) :

A Rockwell technician shall collect a system influent VOC water sample in the middle of eachmonth (see table of sample po rts below) . The technician shall take system effluent watersamples for VOC 's in the middle of each month of AST operation (see table below) .Analytical results shall be kept in Sections 1 for system influent and Section 2 for systemeffluent .

ROCKETDYNE SAMPLING SCHEDULE

AST/UV UNIT SAMPLE PORT SAMPLING SCHEDULE

ALFA AT 1-I MONTHLYALFA AT2-E MONTHLYAREAIRD AIR1-I MONTHLYAREAIR D AIR2-E MONTHLYBRAVO BT13-I MONTHLYBRAVO BT2-E and/or BT4-E MONTHLYCANYON CT1-I MONTHLYCANYON CT2-E MONTHLYDELTA DTI-1 MONTHLY

DELTA DT2-E MONTHLYSTL-IV STL1-I MONTHLYSTL-IV STL2-E MONTHLY

WS-5/UV W54 MONTHLYWS-5/UV W5-E MONTHLYUVBATCH T-1,2 MONTHLY

UV/BATCH T-3,4 MONTHLY (From RD-9 only),AFTER TREATMENT (If"Batch"from other areas)

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5) UV/H2O2 Water Samples (Rockwell Noteworthy Practice) :

0 Well WS-5

A Rockwell technician shall take VOC water samples- of system influent (monthly) at po rtW5-I, and a system effluent (monthly) from port W5-E in the middle of each month asindicated in the table above .

a UV/BATCH (When Operational)

A Rockwell technician shall take water samples of the system influent at tank po rts T-1,or T-2 in the middle of each month . After treatment, samples of the treated water shall betaken from tank po rts T -3 or T-4. When treatment is consistantly from RD-9 andassociated wells, sample monthly ; when "batches" are treated , sample after treatment.Sample analytical results for each batch will be filed in the UV/Batch unit folder.

6) Sampling and Testing Methodology :

Samples, including trip blanks shall be collected , labeled, and transported per the Site-WideSampling and Analysis Plan , 8640M-225, dated May 3 , 1995 and/or site specific Samplingand Analysis Plan for Areas I and III (8640M -258 dated June 5, 1995 ) or for Area II (8640M-236 dated June 5, 1995 ) . Laboratory analyzing the samples shall adhere to EPA methodprocedures including approp riate quality control and quality assessment protocol . Analyticalrequirements for precision, accuracy, holding times and detection limits sha ll be followedaccording to method protocol as dictated by State of California certification and specified inthe Laborato ry QA manual and the Sampling and Analysis Plan . Typically, throwaway glovesshall be worn while taking samples . Samples shall be taken from the effluent (leastcontaminated) to the influent (most contaminated ) to reduce contamination of the effluent

samples at each site . Place each VOC sample in a cooler with ice immediately after fi lling .All samples shall be transported under chain -of-custody to the SSFL Chem Lab and logged in .

7) Results :

Results of all samp ling analysis sha ll be filed in the folder labeled for each treatment system .Copies of the analysis shall be kept in the engineers office and at the SSFL Hazardous WasteYard office .

8) Log (Compliance) :

Daily inspection logs of the treatment systems must be completed every normal working day

(Monday through Friday, excluding holidays and weekends) . All copies of the logs shall be

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maintained and be made available to agency personnel on request . Copies of the logs shall bemaintained at the Hazardous Waste Yard office, and at the office of the engineer .

• Air Stripping Towers Log s

The SSFL Air Stripping Tower Daily Inspection Log (see copy located in Section 3) shallbe completed by a Rockwell technician every normal working day. Items that must be

filled out on a daily basis include :

General : Time, Tower Check List, Tower Meter (Flow Rate, Totalizer)AIR: Manometer Reading onl ySHMP/C12: All (if used)OBSERVATIONS : As requiredREPAIRS : As require d

All other item shall be completed on a weekly basis, or as noted .

At Delta, the Delta Tower Filter Operation Record shall be filled in whenever the filtersare backwashed . Follow directions in folder located on the control panel at the DeltaTower.

a UV/H2O2 Systems Logs

The SSFL UV/H,O, Treatment Systems Daily Inspection Lost (see copy located in

Section 3 ) shall be completed by a Rockwell technici an every normal working day(Monday through Friday) . A ll items must be completed , if applicable, every day. TheSSFL Ultraviolet Light/Hydrogen Peroxide Treatment System Monthly Log (for the

UV/Batch) and OPERATION LOG - WELL SITE 5 (for Well WS-5) shall be completedevery day of operation .

• Hazardous Waste Tank Daily Inspection Checklis t

The Hazardous Waste Tank Daily Inspection Checklist form (see copy located in Section

3) shall be filled out daily (Monday through Friday) for the UV/Batch Tanks (TI and T2),for the peroxide tanks at WS-5 and the UV batch unit, ECL and STL-IV collection tanks .

9) SHMP Samples From AST's :

If SHMP is used, a sample of the AST effluent shall be taken quarterly or during startup if theunit has been down and operating conditions may have ch anged .

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OPERATION AND MAINTENANCE :

Operation and maintenance of the AST's will be conducted using the OPERATION ANDMAINTENANCE MANUAL FOR GROUNDWATER TREATMENT SYSTEM, asassembled by Emcon Associates, dated July 1987, and updated on January 1989 .

Operation and maintenance of the UV/H2O2 treatment systems will be conducted using the

perox -pure Operating and Maintenance Manual, dated 2/22/90 for the Batch Unit in Area

II, and the perox -pure Systems Operation and Maintenance Manual , dated 10/12/90 for

the unit at Well WS-5, Area I .

All maintenance activities and associated corrective actions shall be recorded on the Daily

Inspection Log for the appropriate unit (see Log above) .

A. D. Nelson, Manager

cc: GROUNDWATER REMEDIATION OPERATIONS PLAN (Rocketdyne, NASA)Rocketdyne Environmental Technician sSSFL Treatment System Sample and Analysis BindersManager of Environmentral Protectio nManager of Remediation

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