H EA v 9 8°y ATT11C N m i T - Santa Susana Field Laboratory · National Aeronautic & Space Administration / The Boeing Company Santa Susana Field Laboratory, Area II Simi Hills,

H EA - v 9 8°yATT11C N m i T

California Environmental Protection AgencyDepartment of Toxic Substances Contro l

HAZARDOUS WASTE FACILITYPOST-CLOSURE PERMIT

Facility Name :

National Aeronautic & Space Administration/ The Boeing Company

Santa Susana Field Laboratory, Area IISimi Hills, Ventura County, CA 9306 5

Owner Name :

National Aeronautic & Space Administration

Santa Susana Field LaboratorySimi Hills, Ventura County, California

Operator Name :

The Boeing CompanyRocketdyne Propulsion and Power

Santa Susana Field Laboratory

Simi Hills, Ventura County, California

Permit Number : PC-94/95-3-03

Facility EPA ID Number : CA1 800 090 01 0

Effective Date of Permit : May 11, 1995

Expiration Date of Permit : May 11, 2005

Date Modified : November 9, 200 1

Modification Number: MOD-SC3-110901- B

Pursuant to Section 66270 .42, Title 22, Division 4 .5, California Code of Regulations, the Hazardous WasteFacility Permit issued April 7, 1995, effective May 11, 1995, is hereby modified to address modifications tothe operation, sampling and inspection of the groundwater remediation facilities . Ten pages of the

June 30, 2000 Revised Permit are affected by this modification . Revised pages, labeled as "Revised

November 9, 2001" are hereby incorporated into the approved Permit, replacing the original pages . The

revised permit consists of 1L pages (Attachment A) plus Attachments B through J .

Joseu, P.r, ChiefSouthern California Permi tt ing BranchDepartment of Toxic Substances Contro l

Date :

ARCHIVE COPY

HDMSP00118567

California Environmental Protection AgencyDepartment of Toxic Substances Control

HAZARDOUS WASTE FACILITYPOST -CLOSURE PERMIT

Facility Name :

National Aeronautic & Space Administration/ The Boeing Company

Santa Susana Field Laboratory, Area IISimi Hills , Ventura County, CA 93065

Owner Name :

National Aeronautic & Space AdministrationSanta Susana Field LaboratorySimi Hills , Ventura County, California

Operator Name:

The Boeing CompanyRocketdyne Propulsion and PowerSanta Susana Field LaboratorySimi Hills, Ventura County, California

Permit Number: PC-94/95-3-0 3

Facility EPA ID Number : CA1 800 090 01 0

Effective Date of Permit : May 11, 1995

Expiration Date of Permit : May 11, 2005

Date Modified : November 9, 200 1

Modification Number : MOD-SC3-110901-B

Pursuant to Section 66270 . 42, Title 22, Division 4 .5, California Code of Regulations , the Hazardous Waste

Facility Permit issued April 7, 1995, effective May 11, 1995 , is hereby modified to address modifications to

the operation , sampling and inspection of the groundwater remediation facilities . Ten pages of the

June 30, 2000 Revised Permit are affected by this modification . Revised pages , labeled as "Revised

November 9, 2001 " are hereby incorporated into the approved Permit , replacing the original pages . The

revised permit consists of 1L pages (Attachment A) plus Attachments B through J .

Jose u, P.E, ChiefSou}hem California Permi tting BranchDepartment of Toxic Substances Control

Date :

HDMSP00118568

HAZARDOUS WASTE FACILITY POST-CLOSURE PERMITNASA / Boeing, Santa Susana Field Laboratory, Area IIPC-94/95-3-03 / MOD-SC3-1109010-B / CA180009001 0

TABLE OF CONTENT S

ATTACHMENT A

I. DESCRIPTION OF THE FACILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

A. OWNER, OPERATIONS , AND LOCATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1 . Facility Site Histo ry/Ownership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12. Extraction and Monitoring Wells . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33. Interim Measure Groundwater Remediation System . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

4 . Soil Remediation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4b

B.

C .

COMPLIANCE WITH CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) . . . . . . 5

PERMIT MODIFICATION HISTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

II .

Figure1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Figure 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

CONDITIONS APPLICABLE TO ALL PERMITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

A . REFERENCES AND TERMINOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

B . EFFECT OF PERMIT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

C . REQUIREMENT TO SUBMIT INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

D . CONSENT TO ENTRY BY DEPARTMENT REPRESENTATIVES . . . . . . . . . . . . . . . . . . . . . 9

E . STANDARD CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

F . LAND DISPOSAL RESTRICTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0

G. PERMIT ACTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0

H . NEED TO HALT OR REDUCE ACTIVITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0

I . SEVERABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0

J . PERMIT EXPIRATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0

K . 24-HOUR REPORTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1

L . NOTICE OF PLANNED PHYSICAL CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1

i

HDMSP00118569

NASA/Boeing, SSFL, Area I IHazardous Waste Facility Post-Closure PermitPC-94195-3-03 / MOD-SC3- 110901-B / CA1800090010

Revised November 9, 200 1

M. OPERATIONS AT NIGHT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1

N . PART B PERMIT APPLICATION (OPERATION PLAN) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1

0 . GENERAL RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2

1 . Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2

2 . Transfer of the Permit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2

3 . Operation and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 34 . Monitoring and Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 3

5 . Submittal of Requested Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 4

6 . Hazardous Waste List . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 47 . Anticipated Noncompliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 48 . Noncompliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 4

9 . Incomplete and/or Incorrect Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 4

P . SIGNATORY REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 5

III. SPECIAL CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

A. SECURITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

B . GENERAL INSPECTION REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

C . PERSONNEL TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

D. PREPAREDNESS AND PREVENTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 7

1 . Required Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 172. Testing and Maintenance of Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 173 . Arrangements with Local Authorities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 7

E. CONTINGENCY PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11~

1 . Implementation of Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 t'

2. Copies of Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 !+

3 . Amendments to Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12+

4. Emergency Coordinator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 t~

F. RECORD KEEPING AND REPORTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 r

G. MANIFEST REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 t~

H. GENERATORS REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

I. SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTE . . . . . . . . . . . . . . . 19

J. PROHIBITION OF DISPOSAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

K. ANALYSIS OF WASTES GENERATED DURING POST-CLOSURE . . . . . . . . . . . . . . . . . . 1 9

ii

HDMSP00118570

NASA/Boeing , SSFL, Area I IHazardous Waste Facility Post -Closure PermitPC-94/95-3-03 / MOD-SC3- 110901-B / CA1800090010


IV. POST -CLOSURE CARE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

A. POST-CLOSURE ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

B. UNIT IDENTIFICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

C. POST-CLOSURE PROCEDURE AND USE OF PROPERTY . . . . . . . . . . . . . . . . . . . . . . . . . 21

D. AMENDMENT TO POST-CLOSURE PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

E. NOTICES AND CERTIFICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

F. POST-CLOSURE PLAN MODIFICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

G. CERTIFICATION OF COMPLETION OF POST-CLOSURE . . . . . . . . . . . . . . . . . . . . . . . . . 24

V. GROUNDWATER MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

A. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

B . COMPLIANCE WITH GROUNDWATER CORRECTIVE ACTION . . . . . . . . . . . . . . . . . . . 25

C. WASTE MANAGEMENT AREA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

D. GROUNDWATER PROTECTION STANDARD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

1 . Point of Compliance - Groundwater Monitoring Wells . . . . . . . . . . . . . . . . . . . . . . . . . 26

Table 1 : Point of Compliance Wells . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

2. Background Wells . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Table 2 : Water Quality Monitoring Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

3 . Constituents of Concern . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Table 3 : Constituents of Concern . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

4. Concentration Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

E. COMPLIANCE PERIOD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

F. APPENDIX IX MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

G. GENERAL WATER QUALITY MONITORING AND SYSTEM REQUIREMENTS . . . . . . 35

1 . General Groundwater Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

2. Sampling Analysis Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

3. Well Abandonment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

4. Assignment of Wells in the Groundwater Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

H. DETECTION MONITORING PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

1 . EVALUATION MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

iii

HDMSP00118571

NASA/Boeing, SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3- 110901-B / CA1800090010


J. STATISTICAL PROCEDURE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

K. RECORDKEEPING AND REPORTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Table 4 : Background Monitoring Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

Table 5 : Expanded List of Monitoring Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

Table 6 : Reduced List of Monitoring Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

VI. TANKS AND APPURTENANT EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

A. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

B. PERMITTED AND PROHIBITED WASTE IDENTIFICATION . . . . . . . . . . . . . . . . . . . . . . . 45

C. SECONDARY CONTAINMENT AND INTEGRITY ASSESSMENTS . . . . . . . . . . . . . . . . . 45

D. OPERATING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

E. RESPONSE TO LEAKS OR SPILLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

F. INSPECTION SCHEDULES AND PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

G. RECORD-KEEPING AND REPORTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

H. CLOSURE AND POST-CLOSURE CARE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

I. MAXIMUM STORAGE TIME AND LABEL REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . 48

J. CONTAMINATED CONTAINER REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

K. SPECIAL TANK PROVISIONS FOR IGNITABLE OR REACTIVE WASTE . . . . . . . . . . . . 49

L. SPECIAL TANK PROVISIONS FOR INCOMPATIBLE WASTE . . . . . . . . . . . . . . . . . . . . . . 49

Table 7: Tanks/Containers, Containment Volumes/Capacity, Area II . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 0

VII. CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS . . . . . . . . . . . . . . . . . . 51

A. AUTHORITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

B . STATEMENT OF PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

C . DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

D. SUMMARY OF CORRECTIVE ACTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

Table 8 : Solid Waste Management Units, Areas I , II, III , IV and Buffer Zone . . . . . . . . . . . . . 54

iv

HDMSP00118572

NASA/Boeing , SSFL, Area I IHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-110901-B / CA1800090010


E. PROJECT COORDINATOR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

F. WORK TO BE PERFORMED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 8

1 . Inte rim Measures (IM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

2. Potential or Immediate Threats/Newly Identified Releases /Newly Identified SWMUs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

3. RCRA Facility Investigation (RFI) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 594. Corrective Measures Study (CMS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 615. California Environmental Quality Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 626. Corrective Measures Implementation (CMI) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

G. DEPARTMENT APPROVAL/REPORTING/PROPOSED CONTRACTOR/ADDITIONALWORK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

1 . Department Approval . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

2. Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

3. Proposed Contractor/Consultant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

4. Additional Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

H. QUALITY ASSURANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

I. SAMPLING/ACCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

1 . Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

2. Access . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

J. RECORD PRESERVATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

K. DISPUTE RESOLUTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

L. MODIFICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

M. FACILITY SUBMITTED SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69

VIII . COMPLIANCE SCHEDULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

A. REPORTING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

B . SUMMARY OF COMPLIANCE SCHEDULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

v

HDMSP00118573

NASA/Boeing, SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-110901-B / CA180009001 0

ATTACHMENT S

ATTACHMENT A :ATTACHMENT B :

ATTACHMENT C :ATTACHMENT D :ATTACHMENT E :ATTACHMENT F :ATTACHMENT G :ATTACHMENT H :ATTACHMENT I :ATTACHMENT J :


PERMIT CONDITIONSEXCERPT FROM "STATISTICAL ANALYSIS OF GROUNDWATER MONITORING

DATA AT RCRA FACILITIES" AND ADDENDUMSCOPE OF WORK FOR INTERIM MEASURES IMPLEMENTATIONSCOPE OF WORK FOR A RCRA FACILITY INVESTIGATIONSCOPE OF WORK FOR A CORRECTIVE MEASURES STUDYSCOPE OF WORK FOR A HEALTH AND SAFETY PLANSCOPE OF WORK FOR A PUBLIC INVOLVEMENT PLANSCOPE OF WORK FOR CORRECTIVE MEASURES IMPLEMENTATIONSCOPE OF WORK FOR PROGRESS REPORT SPERMIT MODIFICATION HISTORY

vi

HDMSP00118574

ATTACHMENT A

PERMIT CONDITION S

HAZARDOUS WASTE FACILITY POST-CLOSURE PERMIT

National Aeronautic & Space Administration /The Boeing Company

Santa Susana Field Laborato ry, Area I I

Permit Number : PC-94/95-3-03Modification Number : MOD-SC3-110901-B

EPA I.D. Number: CA1800090010

NASA/Boeing, SSFL, Area I IHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 1800090010

PART I

DESCRIPTION OF FACILITY

A. OWNER, OPERATIONS, AND LOCATION

Revised June 30, 2000

Attachment A - Page

In 1995, National Aeronautic & Space Administration (NASA) as the Facility owner and RockwellInternational Corporation as the Facility Operator applied to the California Department of Toxic SubstancesControl (Department) for a hazardous waste facility post-closure permit to operate hazardous wastegroundwater extraction, treatment and monitoring systems at the NASA/Rockwell Site, as well asmaintenance of caps at closed surface impoundments . After issuance of the post-closure permit in 1995,Rockwell International Corporation, Rocketdyne Division was purchased by The Boeing Company tobecome a wholly owned subsidiary renamed as Boeing North American . As of January 1, 2000, the nameof this Permit was updated to The Boeing Company, Rocketdyne Propulsion and Power . Documentsindicating the operator of this facility may be under Rockwell International Corporation, RocketdyneDivision, Boeing North American Inc ., The Boeing Company, or Rocketdyne Propulsion & Power . NASA

was and currently is the owner of the facility. NASA/Boeing is hereinafter referred to as the Owner and/or

Operator .

The Facility is located in the Simi Hills in Ventura County, California . The Simi Hills are bordered on theeast by the San Fernando Valley and to the north by the Simi Valley . The site is located about 8 miles southof the San Fernando Valley Freeway (Hwy-118) and about 10 miles north of the Ventura Freeway (US-101)(Figure 1) .

1 . Facility Site History/Ownership

The Santa Susana Field Laboratory (SSFL) was established in 1947 and is located in eastern VenturaCounty . The site is located on the western edge of the San Fernando Valley, south of Simi Valley .and near the communities of Santa Susana Knolls, Bell Canyon, and Lakeside Park . As of the year2000, SSFL comprises approximately 2850 acres and is divided into four administrative areas --Area I, Area II, Area III, and Area IV -- and two buffer zone . The Boeing-Rocketdyne facilityincludes Areas I and III totaling 791 acres, plus a contiguous buffer zone of 1143 acres to the southand a contiguous buffer zone of 182 acres to the north. This facility is owned and operated by TheBoeing Company, Rocketdyne Propulsion and Power . Area II, consisting of 404 acres along with42 acres in Area I, is owned by NASA and operated by Boeing-Rocketdyne . Area IV is owned by

Boeing-Rocketdyne and consists of 290 acres . The Department of Energy owns facilities on a 90-acre site within Area IV. This 90 acres are undergoing restoration and consist mainly offacilities/structures built and owned by the Department of Energy and operated by Rocketdyne .

In the early 1980s , trichloroethylene (TCE) was identified in the groundwater at the site du ring aninvestigation of the on site water supply wells . As a result of this discovery, numerousinvestigations have been conducted to assess the presence of volatile organic compounds (VO('s)

in groundwater beneath the site . As a result of the September 1990 Groundwater MonitoringEvaluation (CME) conducted by the Department , Rocketdyne is currently implementing aDepartment-approved Site Characterization program. The Site Characterization program is intendedto provide a better understanding of the complex fracture-dominated groundwater system at SSFL .About 200 monito ring wells have been constructed to assess groundwater contamination .

HDMSP00118576

NASA/Boeing , SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA1800090010


Attachment A - P age 2

In the mid-1980s, the respective owners and/or operators discontinued the use of nine surfaceimpoundments (SIs) in Areas I, II, and III of SSFL . The surface impoundments had been used forcontainment purposes for the activities related to the testing of rocket engines and engine

components . The impoundments received rinse water that may have contained traces of fuels,oxidizers, or solvents .

The impoundments have been undergoing the formal RCRA closure process since 1985 .

The respective owner and/or operators are required to conduct post-closure care because the ninesurface impoundments could not be clean-closed due to groundwater contamination . There are four

SIs in Area II and five SIs in Areas I and III . The four SIs in Area II area covered by this permit .

The five SIs in Areas I and III are covered in a separate permit."

Soil site characterization is provided in the "Interim Final RCRA Facility Assessment Report forRockwell International Corporation, Rocketdyne Division," dated July 10, 1991 and the CurrentConditions Report and Draft RCRA Facility Investigation Workplan Area II and Area I LOX Plant,SSFL, Parts 1 and 2 dated October 1993 .

The Owner and/or Operator has performed several remediation activities related to the SIs includingclosure, soil remediation, and groundwater extraction and treatment . Additional ongoing siteinvestigation includes characterization of the nature and extent of chemicals in the groundwater andsoil at the site .

The four RCRA surface impoundments in Area II (see Figure 2) for which this Post-Closure Permithas been issued are :

a. ALFA Bravo Skim Pond, (ABSP)

b. Storable Propellants Area Pond 1, (SPA-1)

c. Storable Propellants Area Pond 2 , (SPA-2)

d. Delta Area Pond, (Delta)

The five RCRA surface impoundments in Area I and III that are addressed under a separate permitare Advanced Propulsion Test Facility 1 (APTF-1 ), Advanced Propulsion Test Facility 2 (APTF-2),

Systems Test Laboratory 1 (STL-IV-1), Systems Test Laboratory 2 (STL-IV-2), and Engineering

Chemistry Laboratory Pond (ECL) ."

Scone : Conditions of this Permit apply to the maintenance of the surface impoundments' caps,groundwater extraction, monitoring and treatment systems described herein, and any hazardouswastes associated with these activities . Specific requirements addressing releases from solid waste

management units are in Section VII of this Permit .

HDMSP00118577

NASA/Boeing, SSFL , Area IIHazardous Waste Facility Post- Closure PermitPC-94/95-3-03 / MOD-SC3- 110901-B / CA] 80009001 0

2. Extraction and Monitoring Wells


Attachment A - Page 3

In 1995, the site -wide groundwater ex traction and monitoring systems drew from 30 wells and asingle french drain/sump at ECL in Area III . In addition , a total of approximately 210 onsite wells,off-site wells and springs are currently being sampled to assess groundwater conditions at the site .Under the conditions of this Permit, Boeing-Rocketdyne will be specifically sampling 6 background,19 detection , 7 points of compliance , 35 monitoring points, and 28 interim corrective measureswells . The number of wells in each category will vary under specific circumstances spelled out inth is Permit as data is evaluated and as additional wells are installed .

3 . Interim Measure Groundwater Remediation System

Groundwater is extracted and treated using both air stripping and UV/peroxide treatment systems .A brief desc ription is provided in the following section and a detailed desc ription of both systemsis in the "Groundwater Remediation Operation Plan" submi tted by Rocketdyne and incorporated inthis Permit by reference .

Water from the extraction wells is pumped to either a flow equalization tank or directly to the airstripping towers. Un treated water is pumped from the flow equalization t ank and passed throughan air stripping unit or the UV/peroxide treatment unit, from which treated groundwater meetingdischarge requirements is either pumped directly into the SSFL water distribution pipeline ordischarged to one of the site reclaimed water system ponds .

Exhaust from the air stripping towers is directed through vapor phase granular activated carboncanisters and the treated air is released to the atmosphere meeting air discharge regulation. Thetreated air discharge is regulated by the Ventura County Air Pollution Control District .

The ul traviolet light/peroxidation (UV/peroxide) treatment process uses high intensity ul travioletlamps in combination with an oxidation process which facilitates the rapid breakdown of the organicmolecules present in the process groundwater . When the UV/peroxide treatment is completed,hydrocarbons are converted to water and non -hazardous constituents . There are no air emissionsnor waste by-products from the UV/peroxide treatment .

In 1985 , the Owner and/or Operator operated three groundwater treatment systems in Area II . Thesesystems extracted groundwater from six extraction wells using submersible pumps .

In 2001 , the RD -9 UV/Peroxide system was deactivated and placed on standby status . The extractedgroundater was rerouted to the Bravo air stripping system without reducing the number of extractionwells . Future situations may arise that could require routing the ex tracted groundwater back to theRD-9 system .

The Area II Post-Closure Permit includes the operation of extraction wells, monitoring wells andthree permitted groundwater treatment systems (see Figure 2) . The groundwater treatment systemsare described below and detailed in the Area H Groundwater Remediation Operation Plan . Systemvolumes and capacity are summarized in Table 7 of this Permit (Attachment A, Part VI) .

HDMSP00118578

NASA/Boeing , SSFL, Areas I IHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-110901-B / CA180009001 0

Groundwater Treatment Facilities in Area II :

Name Location

Bravo AST Area II - Bravo AreaDelta AST Area II- Delta AreaRD-9 UV/Peroxide Area II - Area II Road


Attachment A - Page 4 a

BRAVO AIR STRIPPING SYSTEM (RD-4, WS-9) :The Bravo Air Stripping system is located near the center of Area II . Two extraction wells feed into

the Bravo system -- RD-4 and WS-9 . The Bravo system treats the extracted groundwater with twoair stripping towers in series . The Bravo system has an operating capacity of 75 gallons per minute

(gpm) . The tower exhaust goes through activated carbon before releasing into the atmosphere . Thetreated groundwater effluent is discharged to a surface channel which flows to the Silvernale onsiteretention pond . Releases from Silvernale pass through Outfall 002, a NPDES Permit monitoringpoint, before continuing offsite down the Bell Canyon drainage .

In 2001, RD-9 UV/Peroxidation system was deactivated and placed on standby status while its threeextraction wells were added to the Bravo Air Stripping system's two extraction wells for a total offive extraction wells feeding into the Bravo system (ES-21, ES-22, RD-4, RD-9, and WS-9) . As

conditions are reevaluated, the RD-9 UV/Peroxidation System may be reactivated and the respectiveextraction wells routed back to the RD-9 System .

In 2001 , conce rns were raised over possible semi -volatile compounds (SVOCs) present in theextracted groundwater leading into the Bravo system . Activated carbon was installed to further treatthe water (polish) a fter the second Bravo tower and adsorb any SVOCs present . Meanwhile , Boeingbegan a year- long monthly sampling of the influent to the first Bravo tower to detect the presenceor absence of SVOCs . The carbon must remain if SVOCs are detected , but may be removed if noSVOCs are detected . The carbon may also be reinstalled if SVOCs are detected in the area of theex traction wells feeding into the Bravo Air Stripping system .

DELTA AIR STRIPPING SYSTEM (WS-9A, HAR-7) :The Delta Air Stripping system is located southern portion of Area II . Two extraction wells feed

into the Delta system -- WS-9 and HAR-7 . The Delta system treats the extracted groundwater with

two air stripping towers in series . The Delta system has an operating capacity of 175 gpm. The

tower exhaust goes through activated carbon before releasing into the atmosphere . The treated

groundwater effluent is discharged to a surface channel which flows to the R-2 Pond (onsite

retention pond) . Releases from the R-2 Pond pass through Outfall 002, a NPDES Permit monitoring

point, before continuing offsite down the Bell Canyon drainage .

AREA II RD-9 UV/PEROXIDATION SYSTEM (ES-21, ES-22, RD-9 )The RD-9 UV/Peroxidation system is located in the northern portion of Area II . Three extractionwells feed into the RD-9 system -- ES-21, ES-22, and RD-9 . In addition, two nearby storage tankscontaining extracted groundwater from other sources and may be used to feed the RD-9 system inbatches . Groundwater is treated at RD-9 using a combination of ultraviolet light (UV) and hydrogen

peroxide (H20) . The RD-9 system is operated in batches and has an operating capacity of two 5,000gallon batches per day at 120 gpm . The treated groundwater effluent is discharged to two nearby

storage tanks .

HDMSP00118579

NASA/Boeing, SSFL, Areas IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3- 110901-B / CA1800090010


Attachment A - Page 4b

In 2001, the RD-9 UV/Peroxidation System was deactivated and placed on standby status . The threeextraction wells were rerouted and added to the Bravo Air Stripping System . As conditions arereevaluated, the RD-9 UV/Peroxidation System may be reactivated and the respective extractionswells routed back to the RD-9 System .

The total groundwater volume treated through the eight treatment systems in Areas I, II, and III,between 1987 and March 1994, is approximately 705 .5 million gallons . During 1993, the totaltreatment capacity of the eight operational treatment systems at the Facility was approximately 950gallons per minute (gpm) . Each extraction/treatment system withdraws contaminated groundwaterfrom one or more nearby pumping wells . The treatment capacity in terms of groundwater pumpage,and the classification of pumping and observation wells for each constructed extraction/treatmentsystem, are presented in Table C-1 of the Annual Groundwater Monitoring Report, Santa SusanaField Laboratory, 1993 and dated February 23, 1994 .

4 . Soil Remediation

In 1985 NASA/Rockwell submi tted a closure plan for four surface impoundments in Area II to theDepartment for review and approval . The Department approved the closure pl an with modificationson September 1988 . The closure plan included soil sampling and closure related activities .

A workplan for additional ve rification sampling of soils at the former surface impoundments wasapproved by the Department and was implemented in 1993 .

Further investigation of residual soil contamination due to NASA and/or Boeing's solid wastemanagement units (SWMUs) is being addressed in a separate and concurrent Corrective ActionProgram (see Attachment A, Part VII of this Permit) .

As part of the Corrective Action process, the Department has reviewed a RCRA FacilityInvestigation (RFI) Workplan prepared by NASA and/or Rockwell's consultant . The RFI Workplanis intended to characterize the magnitude of soil contamination problems from SWMUs (includingregulated surface impoundments) at the SSFL . After contaminated areas are characterized, NASAand/or Boeing must perform a Corrective Measures Study to examine the feasibility of alternativecleanup approaches at contaminated areas .

Based on the Corrective Measures Study , the Department will select appropriate CorrectiveMeasures for implementation . A permit modification to add the requirement to perform the selectedCorrective Measures will be proposed and will be subject to public review and comment and toCEQA .

The Department has reviewed the Groundwater Remediation - Operations Plan,Rocketdyne Site Area II - Santa Susana Field Laboratory, Revision 1, June 25, 1991 (text and figurevolumes) and the Revised Area II Surface Impoundment Post-Closure Plan, Santa Susana FieldLaboratory, submitted in January 1993.

HDMSP00118580

NASA/Boeing, SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CAI 800090010



This permit authorizes the following :

► Continued operation of the groundwater extraction and monitoring systems .

► Corrective action for identified releases of hazardous waste or hazardous constituents from

solid waste management units .

► Further characterization of groundwater contamination .

► Monitoring and evaluation of effectiveness of the groundwater cleanup measures and

modification of present remediation measures, if necessary .

► Maintenance of four surface impoundments caps and surface water diversion structures .

B. COMPLIANCE WITH i IFORNIA ENVIRONMENTAL QU LITY ACT (CEQA )

The Department has prepared a negative declaration in accordance with the California EnvironmentalQuality Act (Public Resources Code, Section 21000, et . seq .) and the State guidelines . The Department has

determined that this particular project will not have a significant deleterious effect on the environment . The

negative declaration was adopted on April 7, 1995 .

C. PERMIT MODIFI CATION HISTORY

Modification to this Permit or the Operations Plan identified in Part II .N .1 of this Permit are allowed as per

22 CCR Sections 66270.41 or 66271 . 42. All modifications made to this Permit and/or Operation Plan arelisted and described in Attachment J to this Permit .

HDMSP00118581

ROCKWELL INTERNATIONAL CORPORATIONROCKETDYNE DIVISIONSANTA SUSANA FIELD LABORATORY

W0.

00

Erbes Rd

23 1ConejoCree k

Freeway

00

Thousanda U Oaks Blvd

THOUSAND OAKS

Kanan Rd

101 Ventura Freeway

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WestlakeBlvd

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118 Freeway

SIMI VALLEY

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BrandeisCamp &

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Lindero Cyn Rd

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NOTE: MAP NOT TO SCAL E

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Susana Pass

Plummer StSanta Susana Par k

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Woolseycny Rd Roscoe Blvd

Bell Cyn Rd

4Bell Canyo n

Las VirgenesRd

EST HILLSValley

Circle Blv d

Van Owen St

Victo ry Blvd

WOODLANDHILLS n

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ROCKWELL INTERNATIONAL CORPORATIONROCKETDYNE DIVISIO NSANTA SUSANA FIELD LABORATORY

■

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0 AREA II I

I.

AREA IV

0

0 AREA II

BUFFER ZONE

0

0

GROUNDWATER RECLAMATION SYSTEM COMPONENTS

PROPERTY SCALEBOUNDARY (Approximate )

0

as0 2400

AREA I

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LEGEND

0FORMER LOCATIONS OF RCRASURFACE IMPOUNDMENT

o GROUNDWATERCOLLECTION / TREATMENT

NASA/Boeing , SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CAI 800090010

PART II

CONDITIONS APPLICABLE TO ALL PERMITS

A. REFERENCES AND TERMINOLOGY



1 . Division 4.5, Environmental Health Standards for the Management of Hazardous Waste of Title 22,California Code of Regulations (CCR) is referred to as "Title 22" in this Permit . Each section in

"Title 22" is cited as 22 CCR [section number] .

2 . Chapters 6.5 through 6 .98 of Division 20 of the California Health and Safety Code are referred toas the "Health and Safety Code" in this Permit .

3 . For purposes of this Permit, terms used herein shall have the same meaning as those in the "Healthand Safety Code" or "Title 22" unless this permit specifically provides otherwise . Where terms are

not defined in the statutes, the regulations, or this Permit, such terms shall be defined by a standarddictionary reference or the generally accepted scientific or industrial meaning of the term .

B. EFFECT OF PERMIT

The Owner and/or Operator shall comply with the provisions of the "Health and Safety Code"(H&SC) and "Title 22," unless otherwise specially provided in this Permit. The issuance of thisPermit by the Department does not release the Owner and/or Operator from any liability or dutyimposed by federal or state statutes and regulations or local ordinances, except the obligation toobtain this Permit. In particular, the Owner and/or Operator shall obtain the required permits issuedby other governmental agencies, at the federal, state and local levels under the applicable land useplanning, zoning, hazardous waste, air quality, water quality, and solid waste management laws forthe construction and operation of the Facility . If there is overlap, the most protective and/orstringent requirement, as determined by the Department, shall apply .

2. Issuance of this Permit by the Department does not prevent the Department from adopting oramending regulations, issuing administrative orders, or obtaining judicial orders which imposerequirements which are in addition to, or more stringent than, those in existence at the time thisPermit was issued, and does not prevent the enforcement of these requirements against the Owner

and/or Operator of the Facility. The Owner and/or Operator shall comply with any such additionalor more stringent requirements in addition to the requirements and conditions specified in thepermit .

3. Issuance of this Permit does not convey property rights or any sort of exclusive privilege, nor doesit authorize any injury to persons or property or any invasion of other private rights .

4. The Owner and/or Operator are permitted to operate the groundwater extraction, treatment andmonitoring systems in accordance with the conditions of this Permit . The Owner and/or Operatorshall perform the hazardous waste management activity authorized by this Permit in accordance withplans and specifications approved by the Department . The Owner and/or Operator shall not conductany hazardous waste management activities prohibited by this Permit . Any other hazardous wastemanagement activities not addressed in this Permit are prohibited, unless otherwise specificallyprovided in the California Hazardous Waste Control Law ("Health and Safety Code") andregulations adopted thereunder.

HDMSP00118584

NASA/Boeing, SSFL, Area II

Hazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA1800090010



C. REQUIREMENT TO SUBMIT INFORMATION

Unless otherwise specifically stated elsewhere in this Permit, the "Health and Safety Code," or the"Title 22", the Owner and/or Operator shall furnish to the Department, within a reasonable time, not toexceed 30 days unless a time extension is approved by the Department, any relevant information which theDepartment may request to determine whether cause exists for modifying, revoking and reissuing, orterminating this Permit, or to determine compliance with this Permit . A copy of any information, report,submittal or notice required by this Permit shall be submitted to :

Department of Toxic Substances Contro lAttn: Chief, Southern California Permitting Branch1011 North Grandview AvenueGlendale, California 9120 1

D. CONSENT TO ENTRY BY DEPARTMENT REPRESENTATIVE S

The Owner and/or Operator, by accepting this Permit, consent to entry, consistent with SSFL securityrequirements, by any authorized representative with appropriate identification from the Department, the StateWater Resources Control Board, the Regional Water Quality Control Board, or the local health officer at anyreasonable hour of the day in order to carry out the purposes of the Hazardous Waste Control Law (Healthand Safety Code Section 25100 etseq.) including but not limited to the activities listed in 22 CCR

66270.30(I) .

The Department reserves the right to challenge the permittee 's assertion of the need for security or to seeklegal relief for any denial of access to the Facility .

E. STANDARD CONDITION S

1 . The Owner and/or Operator shall comply with 22 CCR 66264 .197, 66264.552 and 66270 .40(b) .

2. The Owner and/or Operator shall comply with the general Facility standards contained in Title 22,

Chapter 14, Article 2 .

3 . The Owner and/or Operator shall comply with preparedness and prevention requirements contained

in Title 22, Chapter 14, Article 3 .

4. The Owner and/or Operator shall comply with the contingency plan and emergency proceduresrequirements contained in Title 22, Chapter 14, Article 4 .

5 . The Owner and/or Operator shall comply with the manifest system , recordkeeping and repo rt ing

requirements contained in Title 22, Article 5, Chapter 14, and Section 66270.30(l)(1)-(9) .

HDMSP00118585

NASA/Boeing, SSFL, Area I fHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 1800090010

Revised June 30, 200 0

Attachment A - Page 1 0

6. The Owner and/or Operator shall comply with the closure and post-closure requirements, ifapplicable , contained in Title 22, Chapter 14, Article 7 .

F. LAND DISPOSAL RESTRICTIONS

1 . The Owner and/or Operator shall comply with applicable provisions of the land disposal restrictions

as found in Title 22, Division 4.5, Chapter 18 .

2. The Owner and/or Operator shall retain on-site, until completion of post-closure of the Facility, acopy of all notices, certifications, demonstrations, waste analyses data, and other documentationrelated to the management of all wastes (for on-site or off-site treatment, storage or disposal) subjectto land disposal restrictions .

3. The Owner and/or Operator shall retain on-site a waste analysis plan describing how and whenwastes or treatment residues will be tested to comply with the land disposal restriction regulations .

G . PER MIT ACTIONS

This Permit may be modified, revoked and reissued, or terminated for cause . The filing of a request by theOwner and/or Operator for a permit modification, revocation and reissuance, or termination or a notificationof anticipated noncompliance or planned changes (except as provided in 22 CCR 66270 .42), does not stay

any permit condition. Except as provided in 22 CCR 66270 .42, a new facility permit condition shall becomeeffective on the date specified in the Department's written notice of approval of the permit modification,pursuant to 22 CCR 66270 .42 and/or 66271 .14 .

H . NEED TO HALT OR REDUCE ACTIVITY

It shall not be a defense for the Owner and/or Operator in an enforcement action that it would have beennecessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this

Permit .

1 . SF. . ABILITY

The provisions of this Permit are severable, and if any provision of this Permit, or the application of anyprovision of this Permit to any circumstance is held invalid, the application of such provision to othercircumstances and the remainder of this Permit shall not be affected thereby . [22 CCR 66271 .15(a)]

J . PF. MIT EXPIRATION

In accordance with 22 CCR 66270.51, this Permit and all conditions therein will remain in effect beyond thepermit expiration or termination date, until the effective date of a new permit, if the Owner and/or Operatorhas submitted a timely, complete application (both Part A and Part B) for a new permit and, through no faultof the Owner and/or Operator, the Department has not issued a new permit . In accordance with 22 CCR

66270.10(h), a timely and complete application for a new permit must be submitted at least one-hundred andeighty (180) calendar days before this Permit expires, unless permission for a later date is granted in writing

by the Department .

HDMSP00118586

NASA/Boeing, SSFL, Area IIHazardous Waste Facility Post-Closure Permi tPC-94/95-3-03 / MOD-SC3-063999 110901 -13 / CAI 80009001 0

K. 24-HOUR REPORTING

z 126WRLyiqed November 9 200 1


The Owner and/or Operator shall orally report to the California Office of Emergency Services at(800) 852-7550 and the Department any incidents of noncompliance, with the conditions of this Permit andany of the provisions of Title 22 or Health and Safety Code, which may endanger health or the environmentwithin twenty-four (24) hours after becoming aware of such circumstances . The report shall include theinformation as required in 22 CCR 66270 .30(l)(6) (A) and (B) .

L . NOTICE OF PLANNED PHYSICAL CHANGE S

The Owner and/or Operator shall give notice to the Department as soon as possible, and at least thirty (30)calendar days in advance, of any planned physical alterations or additions to the permitted Facility .

M. OPERATIONS AT NIGHT

When the Facility is operated during hours of darkness, the Owner and/or Operator shall provide sufficientlighting to ensure safe, effective management of hazardous wastes .

N. PART B PERMIT APPLICATION (OPERATION PLAN)

1 By the issuance of this Permit, the Part B Permit Application, consisting of the documents titled"Groundwater Remediation Operation Plan, NASA Site (Area II), Santa Susana Field Laboratory ,

25, f 99 Revision 3, October 11, 2000 . ," "Revised Area II, Surface ImpoundmentPost Closure Plan, Santa Susana Field Laboratory," dated January, 1993 and subsequent revisionsand additions (as per Rocketdyne's letters to the Department dated 14 October 1992, 3 September1993, and 13 and 16 December 1993, and the Department's letter to Rocketdyne dated 10 September1993) is hereby approved . This Part B Permit Application and any subsequent revisions andadditions thereto, are subject to the permit modification requirements contained in 22 CCR 66270 .41

and 66270 .42, and are by this reference made part of this Permit . Specific sections of this Part BPermit Application are referenced elsewhere in this Permit .

2. The Owner and/or Operator shall modify, operate, maintain and close the Facility in accordance withthe Part B Permit Application, unless otherwise specifically stated elsewhere in this Permit .

3 . In the event of any conflict between this Permit and the Part B Permit Application referenced herein,the most stringent provisions shall be controlling .

4. The Part B Permit Application and this Permit shall be maintained at SSFL site at all times untilpost-closure care is completed and acknowledged by the Department . If operational control of theNASA-owned facility is changed, the permit documents shall be maintained at some location on theproperty .

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5 . The Owner and/or Operator shall maintain the following w ritten operating records at the Facility,in accord ance with 22 CCR 66264 .73 :

a. Cap Inspection and Repair Logs ;

b. Copy of Annual and Biennial Report s . (22 CCR 66264 .75)

6. The Owner and/or Operator shall maintain at the NASA/Boeing SSFL Facility, until post-closurecare is completed and certified by an independent, professional engineer registered in the State ofCalifornia, the following documents and all amendments, revisions and modifications to these

documents .

a. The RCRA Facility Assessment (RFA) .

b. The RCRA Facility Investigation (RFI) Workplan and related documents when they areprepared.

c. Inspection schedules , as required by CCR, Title 22, Section 66264.15 and this Permit.

d. Personnel training documents and records , as required by CCR, Title 22, Section 66264 .16and this Permit.

e . Contingency Plan, as required by CCR, Title 22, Section 66264 . 53 and this Permit .

f. Operating records , as required by CCR, Title 22, Section 66264 .73 and this Permit.

g. Post-Closure Plan and Final Closure Plan as required by CCR, Title 22, Section 66264 .112and 66264 . 118 and this Permit .

h. All other documents required by this Permit .

0. GF. AL RESPONSIBILITIES

1 . Complianc e

The Owner and/or Operator shall comply with all conditions of this Permit in accordance with 22CCR 66270.30(a) . The Owner and/or Operator shall comply with all laws, regulations, permits,zoning conditions, and all other requirements established by federal, state, and local agencies .

2 . Transfer of the Permi t

This Permit may be transferred to a new owner and/or operator only if it is modified or revoked andreissued pursuant to 22 CCR 66270 .40 or 66270 .41(b)(2) . Before transferring ownership oroperation of the Facility during its operating life or during the post-closure care period, if any, theOwner and/or Operator shall notify the new owner in writing of the requirements of this Permit,"Health and Safety Code" and "Title 22 ." The new owner or operator shall submit a revised permitapplication to the Department at least ninety (90) days prior to the scheduled date of transfer . Therevised permit application shall include a written agreement containing a specific date for transferof permit responsibility, coverage and liability between the current and new owners and/or operatorsin accordance with 22 CCR 66270 .40(b) .

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3 . Operation and Maintenanc e

a . The Facility shall be maintained at all times and operated to minimize the possibility of afire, explosion, or any unplanned sudden or non-sudden release of hazardous waste orhazardous waste constituents to air, soil, surface water, or groundwater which could threatenhuman health or the environment .

b. All equipment, pipes, and lines used at the Facility to handle, transfer, pump, or storehazardous wastes shall be maintained in a manner that prevents the leaking and spilling of

hazardous wastes .

c . The Owner and/or Operator shall at all times properly operate and maintain all facilities andsystems of treatment and control in accordance with 22 CCR 66270.30(e) .

d. Conditions a, b, and c above shall apply to portable tanks used for the management ofcontaminated groundwater . Such tanks shall also be labeled so as to prevent drinking orother uses of the contents .

4 . Monitoring and Records

a. Samples and measurements taken for the purpose of monitoring shall be representative ofthe monitored activity. The method used to obtain a representative sample of the waste tobe analyzed must be the appropriate method from Appendix IX of Title 22 CCR Chapter 14or an equivalent method approved by the Department . Laboratory methods must be thosespecified in Test Methods for Evaluating Solid Waste : Physical/Chemical Methods SW-846,Standard Methods of Waste Water Analysis, or an equivalent method, as specified in theSampling and Analysis Plan (SAP) and Operations Plan .

b. The Owner and/or Operator shall retain records of all monitoring information, including allcalibration and maintenance records and all original strip chart recordings for continuousmonitoring instrumentation, copies of all reports and records required by this Permit, thecertification, required by 22 CCR 66264 .73(b)(9), and records of all data used to completethe application for this Permit for a period of at least 3 years from the date of the sample,measurement, report, record, certification, or application . These periods may be extendedby request of the Department at any time and are automatically extended during the courseof any unresolved enforcement action regarding this Facility . [22 CCR 66264.74(b),

66270.30(j)(2)]

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Attachment A - P age 1 4

c. Pursuant to 22 CCR 66270 . 30(j)(3), records of monitoring information shall specify :

The dates, exact place , and times of sampling or measurements ;

The individuals who performed the sampling or measurements ;

The dates analyses were performed ;

The individuals who performed the analyses ;

The analytical techniques or methods used; and

The results of such analyses .

5 . Submittal ofRequested Information

The Owner and/or Operator shall furnish to the Department, within the time specified by theDepartment in its request, any relevant information which the Department may request to determinewhether cause exists for modifying, revoking and reissuing, or terminating this Permit, or todetermine compliance with this Permit . The Owner and/or Operator shall also furnish to theDepartment, upon request, copies of records required to be kept by this Permit.

6. Hazardous Waste Lis t

The Owner and/or Operator shall maintain a current list of hazardous wastes which corresponds tothe Constituents of Concern (V .D.3) and spent activated carbon and any other hazardous wasteswhich may be generated as a result of the post-closure care required in this Permit .

7 . Anticipated Noncompliance

The Owner and/or Operator shall give advance notice to the Department of any planned changes inthe permitted Facility or activity which may result in noncompliance with permit requirements, inaccordance with 22 CCR 66270 .30(l)(2) .

8 . Noncompliance

a. In the event of noncompliance with this Permit, the Owner and/or Operator shall take allreasonable steps to minimize or correct releases to the environment, and shall carry out allmeasures as are reasonable to prevent and correct adverse impacts on human health or theenvironment .

b. The Owner and/or Operator shall report to the Department in writing all instances ofnoncompliance not specifically required under this Permit, as per 22 CCR 66270.3 0(1)(l 0 )

9 . Incomplete and/or Incorrect Information

Where the Owner and/or Operator becomes aware that any relevant facts were not submitted in apermit application, or incorrect information was submitted in a permit application or in any reportto the Department, the Owner and/or Operator shall promptly submit such facts or information .

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P. SIGNATORY REQUIREMENTS



1 . The Owner and/or Operator shall comply with the signatory requirements in 22 CCR 66270 .11 forall applications, reports, or information submitted to the Department.

2. The Owner and/or Operator must maintain documentation of an agreement for operation of theFacility between the property owner and the Facility operator at the Facility, if the Facility operatoris different from the property owner . Whenever there is a change in the agreement, the Owner

and/or Operator shall submit a copy of the new or revised agreement to the Department within thirty(30) calendar days of such a change .

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PART II I

SPECIAL CONDITIONS

A. SECURITY



The Owner and/or Operator shall comply with the security provisions of 22 CCR 66264.14. The Owner

and/or Operator shall maintain the security measures described in the Part B Permit Application (Section II .D

of this Permit) .

B . GENERAL INSPECTION REQUIREMENT S

1 The Owner and/or Operator shall inspect the Facility including groundwater systems andimpoundment caps for malfunctions, erosion, deterioration, and discharges which may be causing,or may lead to, release of hazardous waste constituents to the environment or that threaten human

health . The Owner and/or Operator shall conduct these inspections often enough to identifyproblems in time to correct them before they harm human health or the environment .

2 . The Owner and/or Operator shall follow the written schedule in the Permit Condition VIII .D of the

Part B Permit Application, June, 1991 Revised version for inspecting all monitoring equipment,safety equipment, security devices, and structural devices that are important to preventing, detecting,or responding to environmental or human health hazards .

3 . The Owner and/or Operator shall remedy any deterioration or malfunction of equipment orstructures which has been identified during an inspection . All remedial actions shall ensure that theproblem does not lead to an environmental or human health hazard . Where a hazard is imminent

or has already occurred, remedial action shall be taken immediately . The Department must be

notified in writing within five business days of any remedial actions . [22 CCR 66264 .15(c) ]

4. The Owner and/or Operator shall keep the schedule specified in B .2 above at the Facility and

maintain it with other documents required by this Permit .

5 . The Owner and/or Operator shall record inspections in an inspection log or summary. At a

minimum, these records shall include the date and time of the inspection, the name of the inspector,a notation of the observations made, and the date and nature of any repairs or other remedial actions .

[22 CCR 66264 .15(d) ]

C. PERSONNEL. TRAININ G

1 Facility personnel shall successfully complete a program of inst ruction or on-the-job training thatteaches them to perform their duties in a way that ensures the Facili ty 's compliance with the

conditions of this Permit . The Owner an d/or Operator shall ensure that this program includes all theelements described under Permit condition III .C .

a. This program shall include instruction which teaches facility personnel hazardous waste

management procedures (including contingency plan implementation) .

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b. At a minimum, the training program shall be designed to ensure that facility personnel areable to respond effectively to emergencies by familiarizing them with emergencyprocedures, emergency equipment, and emergency systems, including procedures forinspecting and responding to releases from the Facility .

2. The Owner and/or Operator shall conduct personnel training, as required by 22 CCR 66264 .16. This

training program shall follow Section IX of the Part B Permit Application . The Owner and/or

Operator shall maintain training documents and records, as required by 22 CCR 66264 .16(d) .

3. All employees who are designated to perform the waste sampling shall be trained in proper samplingtechniques and implementation of the waste analysis plan . Such training shall include, at a

minimum, but not be limited to the following :

a . procedures to operate, clean and maintain the waste testing or sampling equipment ;

b. methods for sampling wastes in tanks including explanation of sampling devices, numberof samples needed, sampling techniques, sample containers, tamper-proof custody seals, andchain-of-custody procedures;

c . safety equipment to be worn during inspection ; and

d. procedures for labeling and marking containers .

This training shall be provided in addition to the training required by 22 CCR 66264.16. The Owner

and/or Operator shall also provide annual refresher courses for such training to all personnelhandling hazardous wastes .

D. PREPAREDNESS AND PREVENTION

1 . Required Equipment

At a minimum, the Owner and/or Operator shall maintain at the Facility the equipment set forth in

Section X .A.I .d. of the Part B Permit Application as required by 22 CCR 66264 .32 .

2. Testing and Maintenance of Equipment

The Owner and/or Operator shall test and maintain the equipment specified in Permit Condition

III .D.1, as necessary, to assure its proper operation in time of emergency, as required by 22 CCR

66264.33 .

3. Arrangements with Local Authoritie s

The Owner and/or Operator shall maintain arrangements with state and local authorities, as required

by 22 CCR 66264 .37. If state or local officials refuse to enter into preparedness and preventionarrangements with the Owner and/or Operator, the Owner and/or Operator must document thisrefusal in the operating record .

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E. CONTINGENCY PLAN

1 . Implementation of Plan



The Owner and/or Operator shall immediately carry out the provisions in the Contingency Plandesigned to minimize hazards to human health and the environment whenever there is a fire,explosion, or release of hazardous waste or constituents which could threaten human health or theenvironment . [22 CCR 66264 .51 ]

2 . Copies of Plan

The Owner and/or Operator shall comply with the requirements of 22 CCR 66264 .53 .

3 . Amendments to Plan

The Owner and/or Operator shall review and immediately amend , if necessary, the ContingencyPlan, as required by 22 CCR 66264.54 .

4 . Emergency Coordinator

A trained emergency coordinator shall be available at all times in case of an emergency , as requiredby 22 CCR 66264.55 .

F. RF. .O KEEPING AND REPORTING

In addition to the record keeping and reporting requirements specified elsewhere in this Permit, the Ownerand/or Operator shall do the following :

1 . Maintain the Post-Closure Permit and other Environmental Permits on the SSFL site , or on thefacility property if operational control of the facility changes .

2. The Owner and/or Operator shall notify the Department at least fourteen (14) days before engagingin any non-routine field activities, well drilling, installation of equipment, or sampling unlessNASA/Boeing can demonstrate that such notice was not feasible . Upon request NASA/Boeing mustbe prepared to show that such notice was not feasible . At the request of Department, the Ownerand/or Operator shall allow the Department or its authorized representative to take split samples ofall samples collected by the Owner and/or Operator pursuant to this Permit .

G. MANIFEST REQUIREMENTS

The Owner and/or Operator shall comply with the manifest requirements of 22 CCR 66264 .71, 66264.72 and66264.76 whenever a shipment of hazardous waste is initiated from the Facility . The Owner and/or Operatorshall comply with the requirements of 22 CCR Chapter 12 (Section 66262.10, et seq .) for generators ofhazardous waste .

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H. GENERATORS REQUIREMENTS

1.



The Owner and/or Operator shall comply with all applicable requirements of 22 CCR Chapter 12 through16 and the Health and Safety Code for hazardous waste generators for those wastes generated from normaloperation, maintenance and/or post-closure activities .

REO 11REMENTS FOR IGNITABLE OR P

1. The Owner and/or Operator shall take precautions to prevent accidental ignition or reaction ofignitable or reactive waste as required in 22 CCR 66264.17(a) .

2. The Owner and/or Operator shall not locate containers holding ignitable or reactive waste within 15meters (50 feet) of the Facility's property line as specified in 22 CCR 66264.176, unless otherwisespecifically approved by a local fire authority .

3 . The Owner and/or Operator shall not place ignitable or reactive waste in the tank system or in thesecondary containment system .

4. The Owner and/or Operator shall comply with the applicable protective distance requirements forstoring or treating ignitable or reactive wastes in tank systems and containers as required in Tables2-1 through 2-6 of the National Fire Protection Association's "Flammable and Combustible LiquidsCode" (1977 or 1981), unless otherwise specifically approved by a local fire authority . The Ownerand/or Operator shall consult with Ventura County Fire Department to determine the protectivedistance required for storing or treating ignitable materials in the tank systems and containers, andprovide documentation of compliance with such requirements to the Department within sixty (60)calendar days after the effective date of this Permit. [22 CCR 66264 .198(b) ]

5 . The Owner and/or Operator shall comply with the applicable requirements of 22 CCR Chapter 16and Chapter 18 (Article 12) for recyclable/incinerable materials . [22 CCR 66266 .1, 66266 .31 and

66266.34]

J. PROHIBITION OF DISPOSAL

Pursuant to H&SC Section 25203, hazardous wastes shall not be disposed of at the Facility .

K. ANALYSIS OF WASTES GENERATED DURING POST- . .OS TRF.

1 . Samples taken for the purpose of monitoring shall be representative of the monitored activity .

2 . The Owner and/or Operator shall retain records of all monitoring information as part of the operatingrecord until closure of the Facility .

3. Records of monitoring information shall include:

a. The date, exact place, and time of sampling or measurement ;

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b. The individual(s) who performed the sampling or measurements ;

c. The date (s) analyses were performed ;

d. The individual(s) who performed the analyses;

e . The analytical techniques or methods used ;

f. The results of such analyses ; and

g. Collected drain water sampling /disposal .

4. All laboratory work done in connection with this Facili ty shall be performed by a laborato ry certifiedby the State of California ' s Hazardous Waste Laboratory Certification Program .

5 . For this Facili ty the Groundwater Sampling Plan shall be considered the Waste Analysis Pl an . The

Owner and/or Operator shall veri fy the waste analysis plan as related to groundwater and as set forthin this Permit . The Owner and/or Operator shall ensure that this plan includes all elements describedunder Permit condition V .G.2. This quality assurance program will be in accordance with currentU.S. EPA practices (Test Methods for Evaluating Solid Wastes : Physical /Chemical Methods SW-846, 3rd edition) or equivalent methods approved by the Department ; and at a minimum ensure thatthe Owner and/or Operator maintains proper functional instruments , uses approved sampling andanalytical methods, assures the validi ty of sampling and analytical procedures , and performs correctcalculations .

6 . Upon the effective date of this permit , the Owner and/or Operator shall follow the written wasteanalysis pl an as related to groundwater monitoring.

7 . The Owner and/or Operator should include within its groundwater sampling annual report adiscussion summarizing the findings of the groundwater sampling .

The Owner and/or Operator shall ensure that the treatment of any hazardous waste will not :

a. Generate extreme heat or pressure , fire or explosion , or violent reaction ;

b. Produce uncontrolled toxic mists , fumes, dusts, or gases in sufficient quantities to threatenhuman health or the environment ;

c . Produce uncontrolled flammable fumes or gases in sufficient quan tities to pose a risk of fireor explosions ;

d. Damage the structural integrity of the device or facili ty containing the waste ; or

e . Through other like means threaten hum an health or the environment .

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PART IV

POST-CLOSURE CARE

A. POST-CLOSURE ACTIVITIES



Post-closure activities for the closed hazardous waste surface impoundment units include inspection and

maintenance of caps , rainfall run-off control , and operation and maintenance of monito ring systems

(groundwater monitoring and treatment) . The types and quantities of waste are described in the attachment

of Part A permit application . The 30-year post-closure period began after completion of closure and may

be shortened or extended as described in Permit Condition V.E. The 30-year post-closure began on August

9, 1994 .

B. UNIT IDENTIFICATION

The Owner and/or Operator shall provide post-closure care for the following hazardous waste managementunits, subject to the terms and conditions of this Permit, and described as follows :

1 . The groundwater extraction and monitoring system :

2 . The following former surface impoundments , their caps and run-on control :

a. ALFA Bravo Skim Pond, ABSP

b. Storable Propellants Area Pond, SPA-1

c . Storable Propellants Area Pond, SPA-2

d. Delta Area Pond, Delta

C. POST-Ci OSUTRE PROCEDURE AND USE OF PROPERTY

1 The Owner and/or Operator shall conduct post-closure care for the hazardous waste m anagement

units listed in Permit Condition IV .B .2 . above , and continue for 30 years after August 9, 1994,except that the 30-year post-closure care period may be sho rtened upon application anddemonstration approved by the Department that the Facili ty is secure , or may be extended by theDepartment if the Department finds this necessa ry to protect human health and the environment .

[22 CCR 66264 . 117(a) ]

2. The Owner and/or Operator shall maintain and monitor the groundwater monito ring system andcomply with all other applicable requirements of 22 CCR Pa rt 66264 . 90 - 100, during the post-

closure period . [22 CCR 66264 . 117(A)(1)]

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3 . The Owner and/or Operator shall comply with the requirements for surface impoundments as

follows: [22 CCR 66264.228(b)]

a . Maintain the integrity and effectiveness of the final cover, including making repairs to thecap, as necessary, to correct the effects of settling, subsidence, erosion, storms, droughts andother events ;

b. Maintain and monitor the groundwater monitoring system and comply with all otherapplicable requirements of Section V of this permit and 22 CCR Chapter 14, Article 6 where

applicable .

c . Prevent run-on and run-off from eroding or otherwise damaging the final cover ;

d. Protect and maintaining surveyed benchmarks used in complying with the surveying andrecord keeping requirements;

4. The Owner and/or Operator shall comply with all securi ty requirements . [22 CCR 66264.117 ]

5. The Owner and /or Operator shall not allow any use of the units designated in Permit Condition IV .B

which will disturb the integrity of the final cover, ofany components of the environmental control(containment) systems , or of the function of the Facility 's monito ring systems during thepost-closure care period . [22 CCR 66264 .117]

6. The Owner and/or Operator shall implement the Post-Closure Plan .

All post-closure care activities must be conducted in accordance with the provisions of the Post-Closure Plan . [22 CCR 66264.117(e) and 66264.118(b) ]

7. If any repair to the groundwater control systems, exclusive of routine maintenance and post-repairmonitoring is found to extend beyond one week from the initiation of the work, the Owner and/orOperator shall inform the Department and the Ventura County Air Pollution Control District of therepair immediately after such a finding by telephone or fax, and in writing within 24 hours of sucha finding .

8. Cracks and/or erosion in the cap shall be staked and repaired within 20 working days, or before thenext rainfall event, whichever occurs first . In the event of ponding, the Owner and/or Operator shalleliminate standing water on the cap within 48 hours, and adjust the grading and drainage within 20days or before the next rainstorm, whichever occurs first .

9 . Repairs shall be completed before the next rainfall event . If this is not possible, the Owner and/or

Operator shall take temporary measures to minimize infiltration and shall document their efforts andthe reasons completion was not possible prior to the rainfall, and shall notify the Department .

10. Well abandonment procedures shall conform with requirements of all State and local agencies asapplicable .

11 . An inspection and monitoring program shall be establish at every closed disposal area wherein anindependent, qualified engineer registered in California shall annually evaluate and document thecondition of all surface improvements, drainage facilities, erosion control facilities, and vegetative

cover. The engineer shall also evaluate the items listed at 66264 .228.(k) 1- 14 as applicable .

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12. Soil borings must be logged or directly overseen by a California registered geologist, civil engineer,or certified engineering geologist . The Unified Soil Classification System must be used, and percentrecovery reported on the logs . All reports detailing and interpreting results of the subsurfaceinvestigation activities at the site must be signed by either a registered geologist, civil engineer ora certified engineering geologist properly registered in the state of California . This registeredindividual must have provided direct oversight of the project, and be present at the site duringenough of the sampling activities to demonstrate span-of-control .

13. The Owner and/or Operator shall notify the Department at least two weeks before beginning theinstallation of any wells and probes necessary to gather data to assess groundwater extractiontreatment effectiveness except as in response to an emergency condition or potential noncompliance .

14. Inspection of all blowers, pumps, etc ., shall include inspection of bearings and leak testing of sealsat a frequency recommended by the manufacturer .

D. AMENDMENT TO POT- . .OS IRE. PLAN

The Owner and/or Operator shall amend the Post-Closure Plan in accordance with 22 CCR 66264 .118(d),whenever necessary .

E. NOTICES AND CERTIFICATION

1 No later than 90 days after the effec tive date of the permit, the Owner and/or Operator shall submitto the local zoning authori ty , or the authority with jurisdiction over local land use , and to theDirector a record of the type , location, and quantity of hazardous wastes disposed of within each cellor other disposal unit at the Facility . For hazardous wastes disposed of before January 12, 1981, theOwner and/or Operator shall identify the type, location , and quantity of the hazardous wastes to thebest of his knowledge and in accordance with any records he has kept . [22 CCR 66264. 119(a)]

2. Within 90 days after the effective date of the permit, the Owner and/or Operator shall :

a . Record, in accordance with California law, a notation on the deed to the Facility propertyor on some other instrument that is normally examined during a title search, that will inperpetuity notify any potential purchaser of the property that :

► The land has been used to manage hazardous wastes ; and

► Its use is restricted under 22 CCR 66264 .117 .

b. Submit a certification to the Department, signed by the Owner and/or Operator, that he hasrecorded the notation specified in Permit Condition IV .E.2.i, including a copy of thedocument in which the notation has been placed . [22 CCR 66264.119(b)]

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3 . If the Owner and/or Operator or any subsequent owner or operator of the land upon which thegroundwater extraction and monitoring appurtenant equipment is located, wishes to removehazardous wastes and hazardous waste residues, or contaminated soils, then he shall request amodification to this Post Closure Permit in accordance with the applicable requirements in 22 CCRParts 66264 and 66270. The Owner and/or Operator or any subsequent owner or operator of the landshall demonstrate that the removal of hazardous wastes will satisfy the criteria of 22 CCR66264.117(c) . [22 CCR 66264 .119(c)]

F. POST- i OS TRF, PLAN MODIFICATION S

The Owner and/or Operator must request a permit modification to authorize any change in the approvedPost-Closure Plan . This request must be in accordance with applicable requirements of 22 CCR Parts 66264and 66270, and must include a copy of the proposed amended Post-Closure Plan for approval by theDepartment . The Owner and/or Operator shall request a permit modification whenever changes in operatingplans or facility design affect the approved Post-Closure Plan . The Owner and/or Operator must submit awritten request for a permit modification at least 60 days prior to the proposed change in facility design oroperation, or no later than 60 days after an unexpected event has occurred which has affected thePost-Closure Plan. [22 CCR 66264 .118(d)]

G. CERTIFICATION OF COMPLETION OF POST-CLOSUR E

No later than 60 days after completion of the established post-closure care period for a hazardous wastedisposal unit, the Owner and/or Operator shall submit to the Department, by registered mail, a certificationthat post-closure care for the hazardous waste disposal unit was performed in accordance with thespecifications in the approved Post-Closure Plan . The certification must be signed by the Owner and/orOperator and an independent, registered professional engineer . Documentation supporting the independent,registered professional engineer's certification must be furnished to the Director upon request until theDirector releases the Owner and/or Operator from the financial assurance requirements for post-closure careunder 22 CCR 66264 .145(I), and 22 CCR 66264 .120 .

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PART V

GROUNDWATER MONITORING

A. INTRODUCTION



This part of the permit address the requirements of 22 CCR 66264.90 eI. sea ., Article 6 - Water Quality

Monitoring and Response Program for Permitted Facility . As "regulated units" as defined in 22 CCR

66264.90, the closed hazardous waste surface impoundments at the Facility must be in compliance with 22

CCR 66264.90 through 66264.100.

The regulated units consist of the 4 surface impoundments (SIs) located within the 410-acre Area II facility .

These SIs have undergone closure following a closure plan approved by the Department in 1988 .

The Owner and/or Operator shall conduct a monitoring and response program for each regulated unit . The

Owner and/or Operator will institute an evaluation monitoring program since there exists statisticallysignificant evidence of a release from the surface impoundment areas . The specific elements of eachmonitoring and response program are discussed below and are summarized in Table 2 - Water QualityMonitoring Program. In conjunction with the evaluation monitoring program, the Owner and/or Operatorwill conduct a detection monitoring program at the limit of the plume to provide the best assurance of plumedefinition and containment.

Under 22 CCR 66270 . 14(c)(8), the Owner and/or Operator is required to submit information , data, andanalysis to establish a "corrective action program" under 22 CCR 66264 .100 . The Owner and/or Operatoris currently performing site characte rization of groundwater contamination under a previously issued Order .Until the site characterization is completed and a specific corrective measure is selected by the Department,detailed plans and an engineering report desc ribing the final corrective action to be taken and a specificgroundwater monitoring program capable of demonstrating the adequacy of the corrective action may bedeferred . This does not affect the Owner and/or Operator 's responsibility to implement inte rim remedialmeasures and evaluation groundwater monitoring or limit the requirements of any other regulato ry agency .

The components of the Water Quality Protection Standard (WQPS) are detailed in the next sections . This

WQPS will apply for both the detection and evaluation monitoring programs .

B. COMPLIANCE WITH GROUNDWATER CORRECTIVE ACTION

Until such time as a corrective action program is approved and incorporated into this permit , the Ownerand/or Operator shall monitor and maintain groundwater wells as required under interim remedial measures .

C. WASTE MANAGEMENT AREA

The Waste Management Area is considered to be the area affected by the release .

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D. GROUNDWATER PROTECTION STANDARD



The Owner and/or Operator must submit to the Department for review and approval any proposal for theinstallation of groundwater monitoring well(s) which will be used to fulfill the requirements of this permit(Table 2) .

1 . Point of Compliance - Groundwater Monitoring Well s

The following wells, in Table 1, shall be considered the Point of Compliance Monitoring Wells forthe NASA/Boeing facility in Area II .

TABLE 1 - POINT OF COMPLIANCE WELL S

2 .

Regulated UnitArea II SIs

Point of ComplianceWel l

ABSP RS- 8

SPA-1 HAR-14

SPA-2 HAR-1 5

Delta HAR-7

Background Well s

In order to establish background concentrations for the constituents of concern and to select anappropriate statistical method, the Owner and/or Operator shall sample designated backgroundwells for those chemical constituents and physical parameters listed in Tables 3 and 4, quarterlyfor a period of at least 1 year.

Designated background wells

RD-6RD-47RD-13RD-48 A, B, C

These wells represent background water quality and will be used for comparison to point-of-compliance wells during Appendix IX analyses .

The background monitoring wells are not located hydraulically upgradient of any of the

regulated units . If any constituents of concern are detected in a background monitoring wellabove the concentration limit and verified, the Owner and/or Operator shall submit, to theDepartment, in the next quarterly progress report, a proposal for an alternate well . Backgroundshall then be recalculated using data from the new, Department-approved well together with the

remaining background wells .

HDMSP00118602


TABLE 2WATER QUALITY MONITORING PROGRAM



SamplingFrequency

MonitoringParameters

COC'(Table 3)

AnnualAppendix

IX

DETECTION MONITORING PROGRAM

Background Wells : (Table 3&4)', Table 5 every 5 years NO

RD-6

RD-1 3

RD-47

RD-48A

RD-48B

RD-48C

Detection Wells : Table 6 every 5 years NO

RD-5B

RD-5C

RD-1 6

RD-3 7

RD-32

RD-3 9

RD-43A

RD-43B

RD-43C

RD-44

RD-51 C

RD-52C

RD-58B

RD-58C

RD-61

HDMSP00118603





SamplingFrequency


COC a(Table 3)

AnnualAppendix

Ix

RD-62

WS-4A

EVALUATION MONITORINGPROGRAM

Point of Compliance for Areas I and III : SA Table 5 YES

APTF-1 = HAR-16

APTF-2 = HAR-1 6

STL-IV-1 = HAR-17

STL-IV-2 = HAR-17

ECL = SH-4

Point of Compliance for Area II : SA Table 5 YES

ABSP = RS-8

SPA- I = HAR-14

SPA-2 = HAR-1 5

Delta = HAR-7 6

Monitoring Points : SA Table 6 every 5 years NO

HAR-3

HAR-1 1

HAR-2 2

HAR-2 3

HAR-24

HAR-26

HAR-27

HDMSP00118604

NASA/Boeing , SSFL, Area 1 1





SamplingFrequency


coca(Table 3)

Annua lAppendix

IX

RD-3

RD-5A

RD-1 0

RD-26

RD-36A

RD-36B

RD-36C

RD-38

RD-40

RD-45A

RD-45B

RD-45C

RD-46

RD-51 A

RD-51 B

RD-52A

RD-52B

RD-55A

RD-55B

RD-58A

RD-60

RS- 1

RS-7

RS-1 0

RS-1 1

RS-13

HDMSP00118605

NASA/Boeing, SSFL, Area I IHazardous Waste Facility Post -Closure PermitPC-94/95-3-03 / MOD-SC3-110901-B / CA1 800090010




SamplingFrequency


coca(Table 3)

AnnualAppendix

IX

RS-1 9

RS-2 1

SH-3

SH-1 1

Interim Corrective Measures :EXTRACTION WELL (TREATMENT SYSTEM

SA Table 5 NO

ES-1 (Area I: Road AS, WS-5 UV/P)






ES-11 (Area I: WS-5 UV/P

ES-14 (Area III : STL-IV AS)


ES-21 (Area II : RD-9 UV/P, Bravo AS)

ES-22 (Area II : RD-9 UV/P, Bravo AS)







HAR-4 (Area I : WS-5 UV/P

HAR-7 (Area II : Delta AS)

HAR-16 (Area I : WS-5 UV/P)

HAR-17 (Area III : STL-IV AS)

HDMSP00118606

NASA/Boeing, SSFL, Area I IHazardous Waste Facility Post-Closu re PermitPC-94/95-3-03 / MOD-SC3-110901 -B / CA 1800090010




SamplingFrequency


coca(Table 3)

AnnualAppendix

Ix

HAR-18 (Area III : STL-IV AS)

RD-1 (Area I: Canon AS, WS-5 UV/P

RD-2 (Area I: Road AS, WS-5 UV/P

RD-4 (Area II: Bravo AS)

RD-9 (Area II: RD-9 UV/P, Bravo AS)

WS-5 (Area I: WS-5 UV/P

WS-6 (Area I : Alfa AS)

WS-9 (Area II: Bravo AS)

WS-9A (Area II : Delta AS)

ECL French Drain (Area III : STL-IV AS)

ECL Sump (Area III: STL-IV AS

a Constituent of Concernsb Extraction Wel l

For One Year

AS = Air Stripping System Q = QuarterlyUV/P = UV/Peroxidation System SA = Semi annually

HDMSP00118607

NASA/Boeing , SSFL, Area IIHazardous Waste Facility Post -Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 180009001 0

3 . Constituents of Concern

a .



The following list of chemicals shall be considered "Constituents of Concern" asrequired in 22 CCR 66264.93 .

TABLE 3 - CONSTITUENTS OF CONCERN

Constituents of Concern AnalyticalMethod *

ConcentrationLimits `

Acetone EPA 8240 or 8010 To be determined

Carbon Tetrachloride EPA 8010 or 8240 To be determined

Methylene Chloride EPA 8010 or 8240 To be determined

Chloroform EPA 8010 or 8240 To be determined

Fluoride EPA 340.2 To be determined

Freon 11 EPA 8240 or 8010 To be determined

Freon 113 EPA 8240 or 8010 To be determined

Formaldehyde ASTM D-19 To be determinedAmmonia EPA 350.2 To be determinedNitrate EPA 353.2 To be determined

Methyl Ethyl Ketone EPA 8240 or 8010 To be determinedBenzene EPA 8020 or 8240 To be determined

Toluene EPA 8020 or 8240 To be determined

Xylenes EPA 8020 or 8240 To be determined

Ethylbenzene EPA 8020 or 8240 To be determined

PCE EPA 8010 or 8240 To be determine d

TCE EPA 8010 or 8240 To be determine d

Cis-1,2-DCE EPA 8010 or 8240 To be determine d

Trans-1,2-DCE EPA 8010 or 8240 To be determine d

1,1-DCE EPA 8010 or 8240 To be determinedVinyl Chloride EPA 8010 or 8240 To be determined

1,1,1-TCA EPA 8010 or 8240 To be determined1,1,2-TCA EPA 8010 or 8240 To be determined

1,2-DCA EPA 8010 or 8240 To be determined

1,1-DCA EPA 8010 or 8240 To be determined1,4-dioxane EPA 8240 To be determine d

N-nitrosodimethylamine EPA 8270 To be determine d

(NDMA)nitrobenzene EPA 8270 To be determine d

* Decision on using method 8010/8020 or 8240 will depend on the monitoring programunder which each specific well is included (8010/8020 for detection monitoring, 8240 for

evaluation monitoring) .

** Per Permit Condition V .D.4

HDMSP00118608

NASA/Boeing, SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B /CAI 800090010



b. Based on the results of analysis of Appendix IX sampling, any non-naturallyoccurring constituents detected or natural constituents detected above background,and not already on the current list of Constituents of Concern, shall be added to thelist .

4 . Concentration Limits

The concentration limits for the constituents of concern are listed in Table 3 and shall beestablished as follows :

Equal to the background value of each constituent as determined pursuant to 22 CCR66264 . 97(e)(1 1)(B) .

During detection and evaluation monitoring, concentration limits are set equal tobackground . Constituents of concern will fall into one of the following four categories :Category 1 - compounds that are never detected in background wells ; category 2 -compounds detected in less than 50% of background samples ; category 3 - compoundsdetected in greater than 50% of background samples ; and category 4 - common laboratory

contaminants .

a. CATEGORY 1 : For category 1 compounds , the concentration limit shall be equalto the Practical Quantification Limit (PQL) .

Note: Because this method will fail to identify consistent low level indications ofa release, the following conditions will be considered significant evidence of arelease :

a compound is detected above the PQL in a downgradient monitoringpoint;

(2) . a compound is detected above the detection limit , but below the PQL, intwo successive samples or more th an once in a twelve-month period ;

(3) . more than one compound is detected above the detection limit , but belowthe PQL at a single monitoring point during a single monitoring event ; o r

(4) . a compound is detected above the detection limit , but below the PQL, anda review of the available data shows trends or other indications that arelease may have occurred .

b. CATEGORY 2: For category 2 compounds, the concentration limit shall be equalto the maximum concentration reported for the background data or the PQL

(whichever is highest ) with additional provisions for detecting low levelcontamination as presented below :

(1) . a compound is detected in a downgradient monitoring point above themaximum concentration that has been reported for background data .

HDMSP00118609

NASA/Boeing , SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-13 / CA 1800090010


Attachment A - Pa ge 34

Note : The distribution of background data should be tested so that outliersare identified. Outliers must not be used to represent the maximumbackground concentration for a compound . The ASTME-178-75 document"Statistical Analysis of Groundwater Monito ring Data at RCRA Facilities,Interim Final Guidance , 1989", pages 8-11 through 8-14, and the July 1992

addendum thereto , pages 80 and 81 , have been placed in Attachment B ofthis Permit and will be employed to test if a data point is an outlier .

(2) . a compound is detected above the method detection limit but below themaximum background concentration, and a review of available data showstrends or other indications that a release may have occurred .

c. CATEGORY 3: For category 3 compounds, the concentration limit shall be equalto background as determined using the procedures discussed in Permit ConditionV.J.

d. CATEGORY 4: For category 4 compounds (common laboratory contaminants suchas methylene chloride and acetone ), the Concentration Limit shall be determinedby the appropriate method, either under Category 1, 2, or 3, based on evaluation ofthe analytical data . However , the statistical procedure need not be performed inthose instances where the detected compound was obviously present as the resultof laboratory contamination , and this can be verified and documented by thelaboratory . In the event that the laborato ry cannot document that the compoundwas present as the result of laboratory contamination , the appropriate statisticalprocedure must be performed .

Based on these criteria, the Owner and/or Operator shall propose concentration limits foreach constituent of concern .

For a corrective action program , the Owner and/or Operator may propose concentrationlimits greater than background after meeting the requirements of 22 CCR subsections66264 .94(c), (d), (e), (f), and (g) .

E. COMPLIANCE PERIOD

The compliance period is the time during which the groundwater protection standard applies . It is

set as the number of years equal to the active life of the waste management area (including any wastemanagement activity prior to permitting and the closure period) . The calculation of the complianceperiod includes the time that the unit was operating prior to permitting .

Closure Date : August 1994First Waste Disposal : 1948Compliance Period : 46 years

The compliance pe riod shall begin when the Owner and/or Operator initiates a compli ance

monitoring program meeting the requirements of 22 CCR 66264 . 99. The compliance monitoring

program shall be approved by the Department and shall begin a fter completion of the correctiveaction program.

HDMSP00118610

NASA/Boeing, SSFL, Area I IHazardous Waste Facility Post -Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA1800090010



If the Owner and/or Operator is engaged in a corrective action program at the end of the complianceperiod, the compliance period is extended until the owner/operator can demonstrate that theconcentrations limits have not been exceeded for a period of three consecutive years .

F . APPENDIX IX MONITORING

Unless all constituents of concern at the point of compliance are reduced to "non-detectable" fornon-naturally occurring organic species and to background for any naturally occurring organic andinorganic species, the Owner and/or Operator shall monitor Point of Compliance Wells RS-8, HAR-14, HAR-15, and HAR-7 for all Appendix IX constituents annually as specified in Table 2 (22 CCR

66264 Appendix IX) .

The Owner and/or Operator will analyze samples for those constituents listed in Table 5 semi-annually, and for Appendix IX constituents on an annual basis . The Owner and/or Operator maypropose modifications to the list of Appendix IX constituents and the sampling locations after the

first year .

G. GENERAL WATER QUALITY MONITORING AND SYSTEM REQUIREMENTS

1 . General Groundwater Requirement s

The detection and evaluation water quality monitoring programs shall comply with PermitCondition V .D and the following subsections:

a. The point-of-compliance wells are not in detection monitoring since a release hasalready been detected. The detection monitoring wells are located at the outerboundary of the known contaminant plume and are listed in Table 2 .

b. For the evaluation monitoring program, one well at each impoundment willrepresent the quality of water passing the point of compliance, and additional wellswill monitor other areas of the facility to provide data needed to evaluate changesin water quality due to the releases from the regulated units . All wells are includedin Table 2 .

c . An interim corrective measures monitoring program is included in the evaluationmonitoring program (Table 2) . This Permit will be modified to includeimplementation of selected corrective measures after completion of the correctivemeasures study (part of corrective action) .

d. A copy of the driller' s logs shall be filed with the Department of Water Resourcesfor all wells in the Post-Closure Plan .

e. All monitoring wells shall be constructed properly to enable collection ofrepresentative groundwater samples . Not all current wells have adequate seals toprevent the borehole from acting as a conduit for the vertical migration ofcontamination . The Owner and/or Operator will videolog all Chatsworth Formationwells included in this program to determine if the wells have adequate seals andprovide a document, 1 year from the effective date of this Permit, whichdemonstrates that all wells in the monitoring program have adequate seals and are

HDMSP00118611

NASA/Boeing, SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94195-3-03 / MOD-SC3-063000-B / CA 1800090010



not acting as conduits for vertical migration of contaminants . Extraction wells and

water supply wells are not subject to this requirement .

f. All monitoring wells drilled to satisfy the requirements of this Permit shall belogged during drilling under the direct supervision of a California registered

geologist .

g• Surface water and vadose zone monitoring will not be required under theGroundwater Monitoring section of this Permit because the need for these twoitems will be addressed under the Corrective Action for Solid Waste Management

Units, Section VII .

2 . Sampling and Analysis Procedures

a. The approved sampling and analysis plan (SAP), to be submitted as a separatedocument, shall include sampling and analytical procedures that are designed toensure that monitoring results provide a reliable indication of water quality at allmonitoring points and background monitoring points . The SAP shall meet therequirements of these subsections and include a detailed Quality Assurance ProjectPlan (QAPP). The Owner and/or Operator shall follow all procedures and reportingrequirements in the approved SAP . The SAP shall be a stand alone document .

b. Groundwater sampling shall be conducted quarterly for detection monitoring wellsand semiannually for evaluation monitoring wells as specified in Table 2 . Thesampling should coincide with the anticipated maximum and minimumgroundwater elevation levels .

c. The Owner and/or Operator shall determine the water table or potentiometricsurface elevation at each well every time groundwater is sampled .

d. Sampling shall occur at each monitoring point at the frequencies listed in Table 2 .

e . The Owner and/or Operator shall measure the water level in each well anddetermine the groundwater flow rate and direction in the uppermost aquifer(shallow zone and Chatsworth Formation), monthly for an initial 12 month periodbeginning with the first regularly scheduled monitoring event . NASA/Boeing mayrequest a waiver from this requirement on a well-by-well basis where there has notbeen significant variation of groundwater elevations between quarterly gauging

events . Thereafter, these measurements may be made quarterly, including the timesof expected highest and lowest elevations of the water levels in the wells . The SAPshall contain explicit details of how water levels will be determined and duringwhich months the measurements will be made .

f. The Owner and/or Operator shall accurately determine the groundwater surfaceelevation (to calculate purging volume) and field parameters (temperature,electrical conductivity, turbidity, and pH) at each well each time the groundwateris sampled . Turbidity may be measured in the laboratory rather than in the field .

Details of the collection procedures will be specified in the SAP .

HDMSP00118612


3 . Well Abandonment


Attachment A - P age 3 7

Any wells or boring which are abandoned shall be plugged and abandoned as specified bythe Department, RWQCB and any other agencies with regulatory responsibility .

4. Assignment of Wells in the Groundwater Program

A permit modification will not be required for a transfer of a well between detection,evaluation or corrective action portions of the program or construction of new extractionwells, for example, since elements of multiple groundwater programs are already includedsimultaneously in this Permit . However, NASA/Boeing must provide notice to theDepartment prior to any such transfer or construction and obtain prior written approval fromthe Branch Chief. Furthermore, NASA/Boeing must submit, as part of its annualgroundwater monitoring reports, a listing of the wells currently included under eachprogram and a summary of the modifications made to the program during the previous

calendar year . Permit modifications will still be required for significant changes to thegroundwater program such as cessation of corrective action .

H. DETECTION MONITORING PROGRAM

The Owner and/or Operator shall operate a detection monitoring program designed to monitor theouter boundaries of the site-wide contaminant plume . Table 2 shows the wells that are to be sampled

pursuant to this detection monitoring program .

The detection monitoring system will comply with the provisions of 22 CCR 66264 .98, which

includes the list of constituents of concern (Table 3), concentration limits, and establishes a waterquality protection standard. For the first year of this Permit, the Owner and/or Operator shall collectsamples from the designated background wells quarterly for the constituents listed in Tables 3 & 4 .

Subsequently, samples shall be collected quarterly for those constituents listed in Table 5 . TheOwner and/or Operator shall collect samples from the detection monitoring wells quarterly, for the

monitoring parameters listed in Table 6 . In addition, NASA/Boeing shall monitor these wells for

all constituents of concern every 5 years .

For the detection monitoring system, the Owner and/or Operator shall determine if there isstatistically significant evidence of a release as specified in this monitoring plan, Permit Condition

V.J. The Owner and/or Operator shall make this determination within 60 days of collecting samples .If a release is verified, the Owner and/or Operator shall (1) notify the Department within 7 days ofreceiving verification, (2) sample the impacted well for Appendix IX constituents within 60 days,(3) and submit a proposal for a replacement detection well within 90 days . However, if the Ownerand/or Operator does not think that this Appendix IX sampling will produce useful information, theymay petition the Department for a waiver of this requirement . The impacted well will be moved to

the evaluation monitoring program . A permit modification and feasibility study will not be requiredbecause corrective action for the entire site will be addressed as part of the corrective measures .However, the Owner and/or Operator must report these determinations in the next quarterly reportand the information must be incorporated into the site-wide interim corrective measures if necessary .

1 . If the Owner and/or Operator determines that there is statistical significant evidence of arelease, the Owner and/or Operator may demonstrate that a source other than the SantaSusana facility caused the evidence of a release or that such evidence is an artifact causedby an error in sampling, analysis, or statistical evaluation, or by natural variation in th e

HDMSP00118613




ground water [22 CCR 66264 .98(k)(7)] . In making a demonstration pursuant to thissubsection, the Owner and/or Operator shall :

a. Within seven days of determining statistically significant evidence of a release,notify the Department by ce rtified mail that the Owner and/or Operator intends tomake a demonstration pursuant to this subsection [22 CCR 66264 .(k)(7)(A)] .

b. Within 90 days of determining statistically significant evidence of a release , submita report to the Department that demonstrates that a source other than the S an taSusana facility caused the evidence , or that the evidence resulted from error insampling, analysis, or evaluation , or from natural variation in ground water [22CCR 66264 .98(k)(7)(B)] .

c. A permit modification will be required if a new release causes a change to themonitoring program, except as provided in Permit section V .G.4 [22 CCR

66264.98(k)(7)(C)] .

d. Continue to monitor in accordance with the detection monitoring programestablished under this section [22 CCR 66264 .98(k)(7)(D)] .

2 . If the Owner and/or Operator determines that there is significant physical evidence of arelease as described in subsection 66264 .9l(a)(3) or that the detection monitoring programdoes not satisfy the requirements of this section, the Owner and/or Operator shall :

a . notify the Department by certified mail within seven days of such determination;

and

b. submit an application for a permit modification to make any appropriate changesto the program [22 CCR 66264 .98(1)] .

3. Whenever the Department determines that the detection monitoring program does notsatisfy the requirements of this section of the Permit, the Department shall send writtennotification of such determination to the Owner and/or Operator by certified mail, returnreceipt requested . The Owner and/or Operator shall, within 90 days after receipt of suchnotification by the Department, submit an application for a permit modification to make anyappropriate changes to the program [22 CCR 66264 .98(m)] .

4. 22 CCR 66264. 98(n) shall only apply after completion of a corrective action program [22CCR 66264 . 98(n)] .

HDMSP00118614




5. Although vadose zone monitoring is not specifically required under this Permit, since arelease to groundwater has been confirmed, the Owner and/or Operator will be required toperform additional vadose zone assessment in their RFI . Findings of additional vadose zonecontamination may necessitate the modification of this Permit .

I. EVALUATION MONITORING

The purpose of this evaluation monitoring program is to provide a reliable indication of anymigration of the known contaminant plume and to monitor for changes within the plume until adetermination of the horizontal and vertical extent of contamination are defined and the pattern ofgroundwater movement is understood . This characterization cannot be completed within 90 daysand will not be required at this time . It is the Owner and/or Operator's responsibility to determinethe nature and extent of contamination as soon as it is technically feasible . Also, the update to theengineering feasibility study will not be required when the Department determines that the sitecharacterization is complete and a corrective measures study has been approved.

As stated above, the Owner and/or Operator will monitor groundwater to evaluate changes in waterquality partially resulting from releases from the regulated units . Table 2 shows the wells that areto be sampled pursuant to this evaluation monitoring program and complies with the provisions of22 CCR 66264 .97. The Owner and/or Operator shall sample each evaluation monitoring well,except the point-of-compliance wells, for the monitoring parameters listed in Table 6 on a semi-

annual basis . Every five years the evaluation monitoring wells will also be sampled for allconstituents of concern (Table 3) . The point-of-compliance wells will be sampled semi-annuallyfor the monitoring parameters listed in Table 5 and for Appendix IX parameters annually . If theOwner and/or Operator finds Appendix IX constituents that are not already identified as constituentsof concern, the Owner and/or Operator may re-sample within one month and repeat the analysis for

those constituents . If the second analysis confirms the presence of new constituents, the Ownerand/or Operator shall report the concentration of these additional constituents to the Department inthe next quarterly progress report . The Department will add them to the list of constituents ofconcern unless the Owner and/or Operator demonstrates that a source other than the Santa Susanafacility caused the evidence .

Since the Owner and/or Operator is conducting interim corrective measures (extraction andtreatment), monitoring at all extraction wells will be required . The Owner and/or Operator shallcollect samples for the constituents listed in Table 5, semi-annually. In the case of shallow wellsthat do not have sufficient water to extract, monitoring will be required only when extraction isoccurring, up to a frequency of quarterly . Table 2 includes the extraction wells which are part of the

evaluation monitoring program .

If the Owner and/or Operator determines that the evaluation monitoring program does not satisfythe requirements of this section of the Permit, the Owner and/or Operator shall, within 90 days,submit an application for a permit modification to make any appropriate changes to the program .

Whenever the Department determines that the evaluation monitoring program does not satisfy therequirements of this section of the Permit, the Department shall send written notification of suchdetermination to the Owner and/or Operator by certified mail, return receipt requested. The Ownerand/or Operator shall, within 90 days of such notification, submit an application for a permitmodification to make appropriate changes to the program .

HDMSP00118615

NASABoeing, SSFL, Area IIHazardous Waste Facility Post- Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 180009001 0

J. STATISTICAL PROCEDURE



After review of the data collected from the background wells, as specified in 22 CCR 264 . 97(e)(6),the Owner and/or Operator shall propose an appropriate statistical method , pursuant to CCR66264 .97(e)(7), for comparison to background for each constituent of concern and each monito ringparameter . An ANOVA statistical test, as proposed by the Owner and/or Operator, is allowed bythe regulations , but may not be the most effective or efficient statistical technique .

Statistical Methods

For the purpose of this permit, the Practical Quantification Limit (PLQ) is defined as 5 to 10 timesthe Method Detection Limit (MDL) . The individual state-certified laboratory performing theanalysis will provide the exact determination (between 5 and 10 times the MDL) according to themost reliably reached limits while conducting the analysis under routine laboratory operatingconditions . All compounds detected at concentrations above the MDL but below the PQL must bereported as estimated concentrations and flagged as such in all reports .

This subsection describes acceptable statistical methods . In addition to the statistical procedureslisted under this subsection, the following are acceptable tests for censored data (i .e ., data below the

PQL) :

1 . For compounds that have never been detected in background samples, each of the followingconditions will be considered significant evidence of a release and will require thatapproved verification procedures be implemented during the next regularly scheduledquarterly sampling :

a. a compound is detected above the PQL in a downgradient monitoring point ;

b . a compound is detected above the detection limit, but below the PQL, in twosuccessive samples or more than once in a twelve-month period ;

c. more than one compound is detected above the detection limit , but below the PQLat a single monitoring point during a single monitoring event ; or

d. a compound is detected above the detection limit, but below the PQL, and a reviewof the available data shows trends or other indications that a release may haveoccurred .

2. For compounds detected in less than 50% of all background samples, which do not fall under thefirst category, the following conditions will be considered significant evidence of a release and willrequire that approved verification procedures be implemented during the next regularly scheduledquarterly sampling :

a. a compound is detected in a downgradient monitoring point above the maximumconcentration that has been reported for background data.

HDMSP00118616

NASA/Boeing , SSFL, Area I IHazardous Waste Facility Post-Closure PermitPC-94195-3-03 / MOD-SC3-063000-B / CA1800090010



Note: The distribution of background data should be tested so that outliers are identified .Outliers must not be used to represent the maximum background concentration fora compound . The ASTME-178-75 document "Statistical Analysis of GroundwaterMonitoring Data at RCRA Facilities, Interim Final Guidance, 1989", pages 8-11through 8-14, and the July 1992 addendum thereto, pages 80 and 81, have beenplaced in Attachment B of this Permit and will be employed to test if a data pointis an outlier.

b. a compound is detected above the method detection limit but below the maximumbackground concentration, and a review of available data shows trends or otherindications that a release may have occurred .

Note: Method Detection Limits (MDLs) shall be derived by the laboratory for eachanalytical procedure, according to the State of California Environmental LaboratoryAccreditation Program (ELAP), (which currently references procedures in 40 CFRPart 136, Appendix B) . The MDL should always be calculated such that itrepresents a concentration associated with a 99% reliability of a "non-zero" result.These MDLs shall reflect the detection capabilities of the specific analyticalprocedure and equipment used by the laboratory (also in the QAPP) . MDLsreported should not simply be restated from U .S . EPA analytical method manuals .

These methods shall be used to determine statistically significant evidence of a

release .

c . Verification

(1) . The Owner and/or Operator must submit (along with the statisticalmethods) a proposed verification procedure to be implemented whenever

the facility determines that there is statistically significant evidence of arelease for any monitoring parameter or constituent of concern at any

monitoring point .

Note: CCR 66264 .97(e)(8)(E) states that verification must begin within 30 daysof determining statistically significant evidence of a release . TheDepartment will allow verification samples to be collected at the nextscheduled quarterly sampling .

(2). The proposed statistical methods, discussed in Permit Condition V.J. mustmeet the performance standards in CCR 66264.97(e)(9) .

Based on the statistical methods proposed in Permit Condition V .J . andbased on the background data collected, the Owner and/or Operator shallchoose an appropriate statistical procedure for determining background andsubmit the calculated values to the Department .

HDMSP00118617

NASA/Boeing , SSFL, Area I IHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 180009001 0

K. RECD n F PIN NI) REPORTING


Attachment A - Pag e 4 2

The Owner and/or Operator shall submit annual comprehensive monitoring reports . These reportsshall be submitted to the Branch Chief of the Southern California Permitting Branch, DTSCGlendale Office . These reports must contain the following information :

1 . Raw monitoring data (field logs and activity sheets that support interpretations in reports,depth to water data, well-head data, immiscible layer data, field monitoring parameterresults, purge volume data, and on-scene observations).

2. Sampling and transport data (field data sheets and chain-of-custody forms that supportinterpretations in reports).

3. Laboratory summary sheets (chromatograph, IR spectra , other machine outputs, and QAJQC

data that support interpretations in reports ) . This information may be in electroniccomputer-readable form.

4. Data tabulations, graphic water level, potentiometric surface, flow direction, and availableflow rate data .

5 . Contaminant plume maps for all contaminants for which there are more than solitaryspatially isolated detects and where the spatial distribution of a contaminant warrantspreparation of such a map as confirmed by DTSC .

In addition, the Owner and/or Operator will submit quarterly progress reports with ground water leveltabulated, and a potentiometric surface map showing flow directions . Any significant findings or changes

to the monitoring program will be discussed in these reports .

HDMSP00118618

NASAIBoeing , SSFL, Area I I

Hazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 180009001 0

Table 4 : Background Monitoring Parameters

PhElectroconductivityCalciumMagnesiumSodiumPotassiumManganeseIronStrontiumZincAmmoniaAlkalinityChlorideNitrateFluorideTotal Dissolved SolidsTurbiditySulfate

Table 5 : Expanded List of Monitoring Parameter s

tetrachloroethenetrichloroethene1,1,1-trichloroethane1,1,2-trichloroethanecis-l,2-dichloroethenetrans-l,2-dichloroethene1,1-dichloroethene1,1-dichloroethane1,2-dichloroethanevinyl chloridecarbon tetrachloridemethylene chloridechloroformmethyl ethyl ketonebenzenetolueneethylbenzene



HDMSPOOI18619


Table 6 : Reduced List of Monitoring Parameter s

tetrachloroethenetrichloroethene1,1,1-trichloroethane1,1,2-trichloroethanecis- l,2-dichloroethenetrans- l ,2-dichloroethene1,1-dichloroethene1,1-dichloroethane1,2-dichloroethanevinyl chloridecarbon tetrachloridemethylene chloridechloroform



HDMSP00118620


PART VI

TANKS AND APPURTENANT EQUIPMENT

A. INTRODUCTION



This part of the Permit addresses the requirements of 22 CCR Chapter 14, Articles 9 and 10 as theyapply to the use of tanks, containers, and appurtenant equipment for the management of hazardous

waste (Table 7) .

B. PERMITTED AND PROHIBITED WASTE IDENTIFICATIO N

The Owner and/or Operator may only store or treat contaminated groundwater, as described inPart V of this Permit, and other hazardous wastes associated with post-closure activities, at the unitslisted in Table 7 .

C. SECONDARY CONTAINMENT AND INTEGRITY ASSESSMENT S

For tank systems used to store or treat materials that are defined as hazardous waste in thefuture , the Owner and/or Operator must obtain a written assessment of the existing tanksystem integrity within 12 months from the date the waste is defined as hazardous . [22 CCR

66264 . 191(c )] The assessment shall be cert ified by an independent , qualified , registeredprofessional engineer . [22 CCR 66264 .191(a) and (b)]

2. The Owner and/or Operator shall inspect, maintain and operate secondary containmentsystems in accordance with the detailed descriptions contained in Section VIII . D of the Part

B Permit Application. [22 CCR 66264 .193(b)-(f) ]

a . For ancillary equipment, a leak test (or other integrity method as approved by theDepartment) must be conducted . [22 CCR 66264.193(1)(3)]

b. If a tank system or component is found to be leaking or unfit for use as a result ofthe leak test or assessment, the Owner and/or Operator shall comply with PermitCondition VI .E. of this Permit and notify the Regional Administrator, in accordancewith Permit Condition VI.G. of this Permit . [22 CCR 66264.193(i)(6)]

D. OPERATING REQUIRE MENTS

1 . The Owner and/or Operator shall not place hazardous wastes or treatment reagents in thetank system if they could cause the tank, its ancillary equipment, or a containment systemto rupture, leak, corrode, or otherwise fail . [22 CCR 66264 .194(a) ]

2. The Owner and/or Operator shall prevent spills and overflows from the tank or containmentsystems . [22 CCR 66264 .194(b)]

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NASA/Boeing , SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 1 80009001 0

E. RESPONSE TO LEAKS OR SPH.LS



In the event of a leak or a spill from the tank system, from a secondary containment system, or if asystem becomes unfit for continued use, the Owner and/or Operator shall remove the system fromservice immediately and complete the following actions [22 CCR 66264 .196(a)-(f)] :

1 . Stop the flow of hazardous waste into the system and inspect the system to determine the

cause of the release .

2. Remove waste and accumulated precipitation from the system within 24 hours of thedetection of the leak to prevent further release and to allow inspection and repair of the

system. If the Owner and/or Operator finds that it will be impossible to meet this time

period, the Owner and/or Operator shall notify the Department and demonstrate that a

longer time period is required .

If the collected material is a California or RCRA hazardous waste, it must be managed inaccordance with all applicable requirements of 22 CCR. The Owner and/or Operator shall

note that if the collected material is discharged through a point source to U .S. waters or to

a POTW, it is subject to requirements of the Clean Water Act. If the collected material isreleased to the environment, it may be subject to reporting under 40 CFR Part 302 .

3. Contain visible releases to the environment. The Owner and/or Operator shall immediatelyconduct a visual inspection of all releases to the environment and based on that inspection :

a . prevent further migration of the leak or spill to soils or surface water ; and

b. remove and properly dispose of any visible contamination of the soil or surfacewater .

4. Spilled or leaked waste and accumulated precipitation must be removed from the trench,

sump or collection area within twenty-four (24) hours after its discovery .

5 . The collected material from a leak, a spill or accumulated precipita tion at any solid wastemanagement unit or its containment system shall be managed as hazardous waste unless the

Owner and /or Operator has established in accordance with the requirements of 22 CCR

66261 .3(d) that the collected mate rial is not a hazardous waste. The Owner and/or Operator

shall comply with the applicable requirements of 22 CCR 66264 .176, 66264 .178 and

66264.193(c)(4) concerning the collected mate rial .

6 . For all major repairs to eliminate leaks or restore the integri ty of the tank system, the

Owner and/or Operator must obtain a certification by an independent , qualified , registeredprofessional engineer that the repaired system is capable of handling hazardous wasteswithout leaking for the intended life of the system before return ing the system to serv ice .

Examples of major repairs are : installation of an inte rnal liner, repair of a ruptured tank, orrepair or replacement of a seconda ry containment vault.

HDMSP00118622

NASA/Boeing, SSFL, Area 1 1Hazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-110901-B / CA 180009001 0

F. INSPECTION SCHEDITLES AND PROCEDURES



1 . The Owner and/or Operator shall inspect the tank systems , in accordance with the

Inspection Schedules .

2 . The Owner or Operator shall develop and follow a schedule and procedure for inspectingoverfill controls and shall inspect the overfill controls at least once each operating day toensure that they are in good working order . [22 CCR 66264. 195(a)]

3 . The Owner or Operator shall inspect at least once each operating day [22 CCR66264.195(b)] :

a. aboveground portion of the tank system, if any, to detect corrosion or releases of

waste ;

b. data gathered from monitoring and leak detection equipment (e .g., pressure ortemperature gauges, monitoring wells) to ensure that the tank system is beingoperated according to its design ; and

c. the construction materials and the area immediately surrounding the externallyaccessible portion of the tank system, including the secondary containment system(e.g. dikes) to detect corrosion, erosion or signs of releases of hazardous waste (e .g .,wet spots, dead vegetation) .

4. The Owner and/or Operator shall document compliance with Permit Conditions VI .F.2 .- 3 .and place this documentation in the operating record for the facility . [22 CCR

66264.195(d) ]

G. RECORD-KEEPING AND REPORTING

1 . The Owner and/or Operator shall report to the Department , within 24 hours of detection,when a leak or spill occurs from the tank system or secondary containment system to theenvironment. [22 CCR 66264 .196(d)( 1)] (A leak or spill of one pound or less of hazardouswaste , that is immediately contained and cleaned - up, need not be reported .) [22 CCR

66264 . 196(b)(5)(B)] (Releases that are contained within a seconda ry containment systemneed not be reported .) If the Owner and/or Operator has reported the release pursuant to 40CFR Part 302 , this report satisfies the requirements of this Permit Condition . [22 CCR

66264.196(d)(1) ]

2 . Within 30 days of detecting a release to the environment from the tank system or secondary

containment system, the Owner and/or Operator shall report the following information to

the Department: [22 CCR 66264 .196(d)(3)]

a. Likely route of migration of the release ;

b. Characteristics of the surrounding soil (including soil composition , geology,

hydrogeology, and climate) ;

c . Results of any monitoring or sampling conducted in connection with the release ;

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NASA/Boeing, SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 1800 090010



d. Proximity of downgradient drinking water, surface water , and populated areas; and

e. Description of response actions taken or planned .

If the Owner and/or Operator finds it will be impossible to meet the 30 day due date, the

Owner and/or Operator should provide the Department with a schedule of when the resultswill be available . This schedule must be provided before the required 30-day submittalperiod expires .

3. The Owner and/or Operator shall submit to the Department all ce rtifications of major repairs

to correct leaks within seven days from returning the tank system to use . [22 CCR

66264 . 196(f) ]

4. The Owner and/or Operator shall keep on file at the facility the wri tten assessment of the

tank system's integ rity. [22 CCR 66264. 191(a)]

5 . The Owner and/or Operator shall maintain at the facility a record of the results of leak tests

and integrity tests conducted.

H. CLOSURE AND POST-CLOSURE CARE

The Owner and/or Operator shall continue to operate the groundwater extraction systems as long ashazardous waste or hazardous waste constituents remain at the site in quantities which could

endanger human health and the environment. At the end of the surface impoundment unit's post-closure period, or sooner, if Corrective Action is complete, the Owner and/or Operator shall closethe tank system(s), following the procedures in the final closure plan .

MAXI TM STORAGE TIME AND LABEL REQUIREMENTS

The Owner and/or Operator shall not store off-site generated hazardous waste at all, or on-sitegenerated waste in the facility for a period of more than one year from the accumulation date the

waste is generated. A label shall be maintained on all containers in which hazardous wastes are

stored. Labels shall include the following information :

1 . composition and physical state of the waste ;

2. special safety recommendations and precautions for handling the waste ;

3 . statements which call attention to the particular hazardous properties of the waste ;

4. name and address of the person producing the waste ; and

5 . date the accumulation began .

HDMSP00118624


J. CONTAMINATED CONTAINER REQUIREMENTS



Drums contaminated with hazardous wastes shall be decontaminated [or treated in accordance with22 CCR 67450 .11(a)(11)(A)] before being reused to store chemical products or reclaimed material .Any empty drums shall be handled as hazardous wastes except as provided in 22 CCR 66261 .7 .

K. SPECIAL TANK PROVISIONS FOR IGNITABLE OR REACTIVE WASTE S

1 . The Owner and/or Operator shall not place ignitable or reactive waste in the tank system orin the secondary containment system . [22 CCR 66264 . 198(a) ]

2. The Owner and/or Operator shall comply with the requirements for the maintenance ofprotective distances between the waste management area and any public ways, streets,alleys, or an adjoining property line than can be built upon, as required in Tables 2-1through 2-6 of the National Fire Protection Association's "Flammable and CombustibleLiquids Code" (1977 or 1981). [22 CCR 66264.198(b) ]

L. SPECIAL TANK PROVISIONS FOR INCOMPATIBLE WASTE S

1 . The Owner and/or Operator shall not place incompatible wastes , or incompatible wastesand materials, in the same tank system or the same secondary containment system .

2. The Owner and/or Operator shall not place hazardous waste in a tank system that has notbeen decontaminated and that previously held an incompatible waste or material . [22 CCR

66264.17(b)]

HDMSP00118625

NASA/Boeing , SSFL, Area IIHazardous Waste Facility Post- Closure PermitPC-94/95-3-03 / MOD-SC3-110901-B / CA1800090010

Table 7

TANKS/CONTAINERSCONTAINMENT VOLUMES/CAPACITY

AREA II


Attach ment A - Page 5 0

Treatment Description Content Capaci ty Capacity Largest vessel Containment

System ( gpm) (gal) at treatment Volum e

Location unit (gal)* (gal)

Bravo AS 2 air stripping contaminated 75 1128 251 0

towers groundwater

Bravo AS 2 55-gallon vapor phase 11 0carbon VOCs adsorbe dcanisters to carbon

Bravo AS 5 55-gallon treated 275liquid-phase groundwatercarbon from aircanisters stripping

towers

Delta AS 2 air stripping contaminated 175 1128 174 5

towers groundwater

Delta AS 8 55-gallon vapor phase 440carbon VOCs adsorbedcanisters to carbon

RD-9 LN/P ultra-violet contaminated 120 300 142 2light / hydrogen groundwaterperoxide

treatment

RD-9 LN/P hydrogen 50% H202 300peroxide feedtan k

RD-9 LN/P 2 holding tanks contaminated 8850 4275 4300

for LTV System groundwater (4275 ea)

* Assumes 7 .05" free board for rain which is not included in the volumeAS - air stripping systemVOC - volatile organic compound s1N/P - ultra-violet light /peroxidation system

gpm - gallons per minutegal - gallon sH,02 - Hydrogen peroxide

HDMSP00118626

NASA/Boeing, SSFL, Area I IHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA1800090010

PART VII



CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS

A. AUTHORITY

The Health and Safety Code (H&SC) Section 25200 .10 requires that permits issued by theDepartment of Toxic Substances Control (Department) must address corrective action for releasesof hazardous waste including hazardous constituents from any Solid Waste Management Unit(SWMU) at the facility, regardless of when the waste was placed in the unit.

Failure to comply with any term or condition set forth in this Part of the Permit in the time ormanner specified herein will subject the Owner and/or Operator to possible enforcement action andpenalties pursuant to H&SC Section 25187 .

In addition, failure to submit the information required in this Pa rt of the Permit , or falsificationand/or misrepresentation of any submitted information , is grounds for termination of this Permit (22CCR 66270.43) .

Compliance by the Owner and/or Operator with the terms of this Part of the Permit shall not relievethe Owner and/or Operator of its obligation to comply with any other applicable local, state orfederal laws and regulations including, but not limited to, waste discharge requirements, cleanup andabatement orders or any other enforcement orders issued by a Regional Water Quality ControlBoard.

B. STATEMENT OF PURPOSE

The purposes of this part of the Permit are : (1) to provide a specification to the Permittee as to themanner of completing work previously begun relating to corrective action for solid wastemanagement units, and (2) to report and remediate newly identified releases or newly discoveredSWMUs through adequate Corrective Action procedures .

1 . With regard to SWMUs already identified in the RFA report, NASA/Boeing shall employthe attached Scopes of Work for all future corrective action activities . (NASA/Boeing neednot submit an RFI workplan and Current Conditions Repo rt for these SWMUs, since thisworkplan has already been submi tted and approved . )

These specifications and procedures shall include requirements, as appropriate, to :

a. if necessary, perform Interim Measures (IM) at the Facility to relieve threats tohuman health and/or the environment ,

b. implement the RCRA Facility Investigation (RFI) to determine fully the nature andextent of any release of hazardous waste and /or hazardous constituents at or fromthe Facility ;

c. perform a Corrective Measure Study (CMS) to identify and evaluate alternatives forthe corrective action necessary to prevent, mitigate and/or remediate any releasesof hazardous wastes or hazardous constituents at or from the Facility ;

HDMSP00118627

NASA/Boeing , SSFL, Area I IHazardous Waste Facili ty Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000 -B / CAI 800090010



d. perform Corrective Measure Implementation (CMI) to implement the correctivemeasure or measures selected by the Department at the Facility ; and

e . perform any other activities necessary to correct actual or potential threats to humanhealth and/or the environment resulting from the release or potential release ofhazardous waste or hazardous constituents at the Facility.

Since the groundwater contamination at the site is apparently a result of releases from bothSWMUs and regulated units (the closed surface impoundments), the groundwatercharacterization and cleanup previously addressed under the interim status post-closureregulations, shall now be under the groundwater section of the Post-Closure Permit .

Contaminated soils at the SWMUs is to be addressed under this Corrective Action sectionof the Post-Closure Permit .

2 . For any new SWMU, not previously known to DISC or identified as needing investigation

or corrective action, NASA/Boeing shall perform items a .-e . above, following the attached

Scopes of Work, as outlined below in F (Work to be Performed) .

C . DEFINITIONS

The following definitions and others that may apply to this Part of the Permit shall be consistent wi th22 CCR 66260 . 10 and H&SC Section 25110 :

"Action Levels" means health-based and environmental-based levels determined by U .S . EPA to

be indicators for protection of human health and/or the environment . Contamination exceedingaction levels indicates a potential threat to human health and/or the environment which may requirefurther study. Action levels are also used as a reference point for developing final cleanup standards .

"Day" means a calendar day. Periods of time are calculated by excluding the first day and includingthe last . Except, if the last day is a Saturday, Sunday or other holiday specified in Government Codesection 6700 it is also excluded .

"Facility" means all contiguous property under the control of the owner or operator seeking a permitunder Title 22, Division 4 .5 of the California Code of Regulations . This definition also applies to

facilities implementing corrective action under Health and Safety Code section 25187 or federal

RCRA Section 3008(h) [U.S.C. Title 42, Section 6928(h)] .

"Hazardous Constituent" means a constituent identified in Appendix VIII to Chapter 11, Division

4.5, Title 22, CCR ; or any other element, chemical compound, or mixture of compounds which isa component of a hazardous waste or leachate and which has a physical or chemical property thatcauses the waste or leachate to be identified as a hazardous waste .

"Hazardous Waste" means a hazardous waste as defined in 22 CCR 66261 . 3. Hazardous waste

includes extremely hazardous waste, acutely hazardous waste, RCRA hazardous waste , non-RCRA

hazardous waste, and special waste .

HDMSP00118628




"Release" means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting,escaping, leaching, dumping, or disposing into the environment . Release does not include items

described in 22 CCR 66260 .10, Definition for "Release", Subsections (b)(1-3) .

"Solid Waste Management Unit" or "SWMU" means any unit at a hazardous waste facility fromwhich hazardous constituents might migrate, irrespective of whether the units were intended for themanagement of wastes, including but not limited to : containers, tanks, surface impoundments, wastepiles, land treatment units, landfills, incinerators and underground injection wells .

"Waste" means waste as defined in 22 CCR 66261 .2 .

D. SUMMARY OF CORRE CTIVE ACTION

1 The RCRA Facility Assessment (RFA) for the SSFL was conducted by DTSC and theUnited States Environmental Protection Agency (U .S . EPA) in 1990 and a preliminary RFAreport was prepared for the U .S . EPA by EPA's contractor in 1991 (SAIC, July 1991) . Afinal RCRA Facility Assessment Report for Rockwell International Corporation was issuedin 1994 (SAIC, May 1994) . From the final results of the Preliminary Review (PR) and theVisual Site Inspection (VSI), the 1994 RFA Report accounts for a total of 69 Solid WasteManagement Units (SWMUs) and 55 Areas of Concern (AOCs) in Areas I, II, III, IV, andthe Buffer Zone .

2. In November 1992, Rockwell entered into a Stipulated Enforcement Order with the DTSCfor RCRA Corrective Action activities at the entire SSFL pursuant to the California Healthand Safety Code section 25187 . This Permit does not terminate, alter, or amend anyobligations in that Order.

The Enforcement Order required Rockwell to perform the following :

a. Address all SWMUs and AOCs identified in the RFA .

b. Prepare a Current Condition Report on the SWMUs and AOCs .

c. Prepare a draft RFI Workplan.

The Order also contemplated a RCRA Facility Investigation (RFI) Report, CorrectiveMeasures Studies, and final cleanup of the areas identified in the final approved CorrectiveMeasure Studies .

HDMSP00118629

NASA/Boeing , SSFL, Area I IHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CAI 800090010



3 . In October 1993, the following documents were submitted in response to the EnforcementOrder :

a. Santa Susana Field Laboratory - Area I and III Current Conditions Report and draftRFI Work Plan .

b. Santa Susana Field Laboratory - Area II Current Conditions Report and draft RFIWork Plan .

c. Santa Susana Field Laboratory - Area IV Current Conditions Report and draft RFI

Work Plan .

d. Santa Susana Field Laboratory Pre-Investigation Evaluation of Corrective MeasureTechnologies - Areas I - IV .

4. In June 1994, DTSC conditionally approved the RFI Workplan .

5 . Table 8 contains a list of the Solid Waste Management Units (SWMUs) identified at thefacility in the May 1994 Final RCRA Facility Assessment :

TABLE 8

SOLID WASTE MANAGEMENT UNITSAREAS I, II, III , IV and BUFFER ZON E

SWMU No. DESCRIPTION

4.0 AREA I

4.1 Old B-1 Area

4.2 Old Area I Landfill

4.3 Building 324 Instrument Lab Hazardous Waste Tan k

4.4 Building 301 Equipment Laboratory TCA Distillation Unit and Used Produc t

Tank

4.5 LOX Plant Waste Oil Sump and Cla ri fie r

4.6 Asbestos and Drum Landfill Near LOX Plan t

4.7 Component Test Laboratory (CTL-III)

4 .8 Burn Pit

4 .9 Advanced Propulsion Test Facility

4 .10 Advanced Propulsion Test Facility Pond #1 (APTF- 1 )

4 .11 Advanced Propulsion Test Facility Pond # 2 (APTF-2)

4 .12 Laser Engineering Test Facility (LETF) Area

4.13 Laser Engineering Test Facility (LEFT) Pond

4.14 Canyon Retention Pond, Canyon Skim Pond, and Canyon Test Area

HDMSP00118630

NASA /Boeing, SSFL, Area I IHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3 - 063000 - B / CA 1800090010

TABLE 8

SOLID WASTE MANAGEMENT UNITSAREAS 1, 11, 111, IV and BUFFER ZONE



4.15 Bowl Retention Pond, Bowl Skim Pond, and Bowl Test Stands

4 .16 Area I Reservoir (R-1 )

4 .17 Perimeter Pond

4.18 Air St ripping Towers (Canyon Alfa and Bowl) for Groundwater Treatment

4 .19 Areas of Concern - Area I

5 .0 AREA II

5 .1 Area II Landfill

5 .2 Building 206 - ELV Final Assembly

5 .3 Building 231 PCB Storage Facility

5 .4 Swimming Pool UV/H202 Treatment System

5 .5 Building 204 Plant Se rv ice Waste Oil Tank

5 .6 Area II Incinerator Ash Pile

5 .7 Hazardous Waste Storage Area (HWSA) Waste Coolant Tank

5 .8 Hazardous Waste Storage Area (HWSA) Container Storage Area

5 .9 Alfa Test Are a

5 .10 Alfa Test Area Tanks

5 .11 Alfa Skim Pond and Alfa Retention Pond and Associated Drainages

5 .12 Alfa - Bravo Skim Pond (ABSP)

5 .13 Bravo Test Are a

5 .14 Bravo Test Stand Waste Tank

5 .15 Bravo Skim Pond and Associated Drainage s

5 .16 Storable Propellant Area Pond 1 (SPA- 1) and Associated Drainages

5 .17 Storable Propellant Area Pond 2 (SPA-2 ) and Associated Drainages

5 .18 Coca Test Are a

5 .19 Coca Skim Pond and Associated Drainage s

5 .20 Propellant Load Facility ( PLF) Waste Tank

5 .21 Propellant Load Facility (PLF) Ozonator Tank

5 .22 Propell ant Load Facility ( PLF) Surface Impoundmen t

5 .23 Delta Test Are a

5 .24 Delta Skim Pond and Associated Drainages

5 .25 Purge Waste Tank near Delta Treatment System

HDMSP00118631

NASA/Boeing , SSFL, Area I IHazardous Waste Facili ty Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000 -B / CAI 800090010

TABLE 8

SOLID WASTE MANAGEMENT UNITSAREAS I, II, III, IV and BUFFER ZONE



5 .26 R-2A and R-2B Discharge Ponds and Associated Drainage s

5.27 Air Stripping Towers for Groundwater Treatment

5.28 Areas of Concern - Area II

6.0 AREA II I

6 .1 Building 260 ECL Waste Tank, Building, and Associated ContainerStorage Area

6.2 ECL and Suspect Water Ponds

6.3 ECL Collection Tank

6.4 Building 418 Compound A Facility

6.5 Systems Test Laboratory IV (STL-IV) Test Area Including MMHOzonator Tank

6.6 Systems Test Laboratory IV Pond #1 (STL-IV- 1) and Associate d

Drainages

6.7 Systems Test Laboratory IV Pond #2 (STL-IV-2) and Associate d

Drainages

6.8 Silvernale Reservoir and Associated Drainages

6.9 Building 227, 224, Environmental Effects La b

6.10 STL-VI Groundwater Treatment System

6.11 Areas of Concern - Area II I

7.0 AREA IV

7 .1 Building 056 Landfil l

7.2 Building 133 Sodium Burn Facility

7.3 Building 886 Former Sodium Disposal Facilit y

7.4 Container Storage Area (Old Conservation Yard)

7.5 Building 100 Trenc h

7.6 Radioactive Materials Disposal Facility (RMDF )

7.7 Rockwell International Hot Laboratory (RIHL) (Building 20 )

7 .8 New Conservation Yard

7.9 ESADA Chemical Storage Yard

7.10 Building 05 Coal Gasification

7.11 Building 29 Reactive Metal Storage Yard

HDMSP00118632

NASA/Boeing, SSFL , Area I IHazardous Waste Facili ty Post -Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CAI 800090010

TABLE 8

SOLID WASTE MANAGEMENT UNITSAREAS I, II, III, IV and BUFFER ZONE

7.12 IAreas of Concern - Area IV

BUFFER ZON E

Discharge Point 00 1

Discharge Point 00 2

6. Areas of Concern (AOC) .



During the evaluation of Rockwell International's waste management and release data, anumber of areas were identified as Potential SWMUs and/or Areas of Concern. These

areas or units includes :

Area I :Happy ValleyLeachfields for Area IAPTF Aboveground Storage TanksStorage Underground Tank s

Area II :Leach fields for Area IIBuilding 207 Underground Diesel Tan kUnderground Tank Across From Alfa-Bravo Fuel Farm AreaBuilding 206 Metal Diesel TankBuilding 204 Two Metal Underground Gasoline Tanks at Plant ServicesAlfa-Bravo Fuel Farm Storm Water BasinStorable Propellant Area (SPA)Drainage Pipes Under Alfa-Bravo Skim PondBuilding 515 Sewage Treatment Plant

Area III :Leachfields for Area II IBuilding 206 ECL Run-off TanksArea III Sewage Treatment Plant

7. Discussions of any releases and potential releases from the above units are included in theRFA Report, the Current Conditions Report and the draft RFI Workplan referenced above .

E. PROJECT COORDINATOR

Within 30 days of the effective date of this Permit, the Owner and/or Operator shalldesignate a Project Coordinator and shall notify the Department in writing of the ProjectCoordinator it has selected . The Owner and/or Operator's Project Coordinator shall beresponsible for overseeing the implementation of corrective action at the Facility i n

HDMSP00118633

NASA/Boeing, SSFL, Area IIHazardous Waste Facility Post-Closure PermitPC-94/95-3-03 / MOD-SC3-063000-B / CA 1800090010



accordance with this Part of the Permit and for designating a person to action in his/her

absence. The Department will also designate a Project Coordinator. All communicationsbetween the Owner and/or Operator and the Department, and all documents, reports,approvals and other correspondence concerning the activities performed pursuant to thisPart of the Permit shall be directed through the Project Coordinators .

2. The Owner and/or Operator will provide at least seven (7) days wri tten notice to theDepartment prior to changing Project Coordinator.

3. The absence of the Department Project Coordinator from the Facility shall not be cause forthe stoppage of work.

F. WORK TO HE PERFORMED

The Owner and/or Operator shall continue interim measures and corrective action for groundwatercontamination as required in Section V of this permit .

The Owner and/or Operator shall perform the work specified in this Part of the Permit in the mannerand by the dates specified herein . All work undertaken pursuant to this Part of the Permit shall beperformed in a manner consistent with, at a minimum : the attached Scopes of Work; theDepartment-approved Interim Measures Workplan, the RCRA Facility Investigation Workplan, ifrequired, Corrective Measures Study Workplan, and any other Department approved Workplans ;

and applicable State law and implementing regulations . All attachments to this Permit are

incorporated by reference as if fully set forth herein .

The Owner and/or Operator shall complete the tasks required by this Part of the Permit inaccordance with the approved schedules of compliance . Schedules of compliance may provide forimplementation of tasks beyond the termination date of this Permit . All corrective action shallcontinue until the media cleanup standards are achieved and all required work has been completed .

1 . Inte rim Measures (IM)

a. The Owner and/or Operator shall evaluate available data and assess the need forinterim measures in addition to those specifically required by this Part of thePermit . The interim measures assessment shall be incorporated into the CurrentConditions Report portion of the RCRA Facility Investigation . Interim measures

shall be used whenever possible to achieve the goal of stabilization which is tocontrol or abate immediate threats to human health and/or the environment, and toprevent or minimize the spread of contaminants while long-term corrective actionalternatives are being evaluated .

b. All IM Workplans which may be required in the future shall ensure that the interimmeasures are designed to mitigate current or potential threat (s) to human healthand/or the environment, and should, to the extent practicable , be consistent wi th theobjectives of, and contribute to the performance of any future remedy which maybe required at the Facility .

HDMSP00118634




c . Concurrent with the submission of an IM Workplan, the Owner and/or Operatorshall submit to the Department a Health and Safety Plan . The Health and Safety

Plan shall be developed in accordance with the Scope of Work for a Health andSafety Plan, Attachment F of this Permit .

d. Concurrent with the submission of an IM Workplan, the Owner and/or Operatorshall submit to the Department a Public Involvement Plan . The Public InvolvementPlan must be developed in accordance with Attachment G of this Permit .

2 . Potential or Immediate Threats/Newly Identified Releases/Newly Identified SWMU s

a. In the event the Owner and/or Operator identifies an immediate or potential threatto human health and/or the environment, discovers new releases of hazardous wasteand/or hazardous constituents, or discovers new SWMUs not previously identified,the Owner and/or Operator shall notify the Department orally within 48 hours ofdiscovery and notify the Department in writing within 30 days of such discoverysummarizing the findings including the immediacy and magnitude of any potentialthreat(s) to human health and/or the environment.

b. The Department may require the Owner and/or Operator to investigate, mitigateand/or take other applicable action to address any immediate or potential threats tohuman health and/or the environment, newly identified releases of hazardous wasteand/or hazardous constituents, or newly identified SWMUs . Upon written requestby the Department, the Owner and/or Operator shall submit to the Department anyrequired documents which may include, but are not limited to, IM Workplansand/or RCRA Facility Investigation Workplans . The required documents shall bedeveloped in a manner consistent with the applicable Scope of Work appended tothis Permit or with other guidance to be provided by the Department . The

Department will review the required documents and notify the Owner and/orOperator in writing of the Department's approval or disapproval, including anycomments and/or modification, in accordance with the DepartmentApproval/Reporting/Proposed Contractor/Additional Work section of this Part ofthe Permit . If the Department determines that immediate action is required, theDepartment's Project Coordinator may orally authorize the Owner and/or Operatorto act prior to the Department's receipt or approval of any required workplans .

3 . R . A Facility Investigation (REI )

a. In accordance with section VII .F .2 .b, the Department may require the Owner and/orOperator to submit to the Department a Current Conditions Report and/or aWorkplan for a RCRA Facility Investigation ("RFI Workplan") within 90 days of

such request . The Current Conditions Report and RFI Workplan shall be developedin a manner consistent with the Scope of Work for a RCRA Facility Investigationcontained in Attachment D . The Department will review the Current ConditionsReport and RFI Workplan and notify the Owner and/or Operator in writing of theDepartment's approval or disapproval, including any comments and/ormodifications, in accordance with the Department Approval/Reporting/ ProposedContractor/Additional Work section of this Part of the Permit.

HDMSP00118635

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b. The RFI Workplan shall detail the methodology to :

(1) .



gather data needed to make decisions on interim measures/stabilizationduring the early phases of the RCRA Facility Investigation ;

(2) . identify and characterize all sources of contamination ;

(3) . define the nature, degree and extent of contamination ;

(4) . characterize the potential pathways of contaminant migration;

(5) . define the rate of movement and direction of contaminant flow

(6) . identify actual or potential human and/or ecological receptors ; and

(7) . support development of alternative remedial approaches or methods fromwhich a corrective measure will be selected by the Department .

A specific schedule for implementation of all activities shall be included in the RFIWorkplan ( e .g ., submittal of phase 2 workplan, submittal of RFI Reports , etc .) .

c. The Owner and/or Operator shall submit a RFI Report to the Department inaccordance with the schedule contained in the approved RFI Workplan . The RFIReport shall be developed in a manner consistent with the Scope of Work for aRCRA Facility Investigation contained in Attachment D . If there is a phasedinvestigation, separate RFI Reports for each phase and a summary report thatsummarizes the findings from all phases of the RFI must be submitted to theDepartment . The Department will review the RFI Report(s) and notify the Ownerand/or Operator in writing of the Department's approval or disapproval, includingany comments and/or modifications, in accordance with the DepartmentApproval/Reporting/Proposed Contractor/Additional Work section of this Part ofthe Permit .

d. Concurrent with the submission of a RFI Workplan, the Owner and/or Operatorshall submit to the department a Health and Safety Plan in accordance withAttachment F of this Permit . If Workplans for both interim measures and RFI arerequired by this Part of the Permit, the Owner and/or Operator may submit a singleHealth and Safety Plan that addresses the combined IM and RFI activities .

e . The Owner and/or Operator shall submit a RFI Summary Fact Sheet to theDepartment that summarizes the findings from all phases of the RFI . The RFISummary Fact Sheet shall be submitted to the Department in accordance with theschedule contained in the approved RFI Workplan . The Department will review theRFI Summary Fact Sheet and notify the Owner and/or Operator in writing of theDepartment's approval or disapproval, including any comments and/ormodifications, in accordance with the Department Approval/Reporting/ProposedContractor/Additional Work section of this Part of the Permit . When theDepartment approves the RFI Summary Fact Sheet, the Owner and/or Operatorshall mail the approved RFI Summary Fact Sheet to all individuals on the facilitymailing list established pursuant to 22 CCR 66271 .9(c)(1)(D), within 15 calendardays of receipt of written approval .

HDMSP00118636




f. Concurrent with the submission of a RFI Worlplan, the Owner and/or Operatorshall submit to the Department a Public Involvement Plan . The Public InvolvementPlan shall be developed in accordance with Attachment G of this Permit . AnyPublic Involvement Plan developed for Interim Measures may be revised to includeRFI activities .

4. Corrective Measures Study (CMS )

a. The Department will require a Corrective Measures Study if contaminantconcentrations exceed current health-based action levels and/or if the Departmentdetermines that the contaminant releases pose a potential threat to human healthand/or the environment .

b . Within 90 days after the Owner and/or Operator receives a written request from theDepartment, the Owner and/or Operator shall submit a CMS Workplan to theDepartment. The CMS Workplan shall be developed in a manner consistent withthe Scope of Work for a Corrective Measures Study contained in Attachment E tothis Permit . The Department will review the CMS Workplan and notify the Ownerand/or Operator in writing of the Department's approval or disapproval, includingany comments and/or modifications, in accordance with the DepartmentApproval/Reporting/ Proposed Contractor/Additional Work section of this Part ofthe Permit .

c . The CMS Workplan shall detail the methodology for developing and evaluatingpotential corrective measures to remedy any contamination at the Facility . The

CMS Workplan shall identify the potential corrective measures, including anyinnovative technologies, that may be used for the containment, treatment,remediation, and/or disposal of contamination .

d. The Owner and/or Operator shall conduct treatability studies for all potentialcorrective measures that involve treatment except where the Owner and/or Operatorcan demonstrate to the Department's satisfaction that they are not needed. TheCMS Workplan shall include, at a minimum, a summary of the proposed treatabilitystudy including a conceptual design, treatability study including a conceptualdesign, a schedule for submitting a treatability study workplan, or the Owner and/orOperator's justification for not proposing a treatability study .

e . The Owner and/or Operator shall submit a CMS Report to the Department inaccordance with the schedule contained in the approved CMS Workplan . The CMSReport shall be developed in a manner consistent with the Scope of Work for aCorrective Measures Study contained in Attachment E to this Permit. TheDepartment will review the CMS Report and notify the Owner and/or Operator inwriting of the Department's approval or disapproval, including any commentsand/or modifications, in accordance with the DepartmentApproval/Reporting/Proposed Contractor/Additional Work section of this Part of

the Permit .

HDMSP00118637


5 . California Environmental Quality Ac



The Department must comply with the California Environmental Quality Act (CEQA)

insofar as activities required by this Permit may be projects requiring CEQA compliance .The Department will prepare a Notice of Exemption or an Initial Study as required byCEQA . Based on the results of an Initial Study, the Department will determine if aNegative Declaration or Environmental Impact Report (EIR) should be prepared. TheDepartment will prepare and process any such Negative Declarations . However, should theInitial Study indicate that an EIR is necessary, such an EIR would be prepared underseparate agreement between the Department and the Owner and/or Operator .

6 . Corrective Measures Implementation (CMI)

a. The Department will evaluate corrective measure alternatives presented in theapproved CMS Report . Based on the evaluation, the Department may propose acorrective measure (or measures) for implementation at the Facility . The proposedcorrective measures(s) must :

( 1) . be protective of human health and/or the environment;

(2). meet the media cleanup standards ;

(3) . control the source(s) of releases (s) so as to reduce or eliminate, to themaximum extent practicable , further releases that might pose a threat tohuman health and/or the environment; and

(4). meet all applicable waste management requirements .

b . The Department may modify this Permit to require the Owner and/or Operator toimplement the proposed corrective measure(s). The permit modification will bedone in accordance with the requirements contained in 22 CCR 66270 . 41 . As a part

of the permit modification process , the public will have an opportuni ty to reviewand comment on a draft of the modified permit, the Department's proposedcorrective measure(s) for the Facili ty, and the Department 's justification forselection of such corrective measure (s) (the "Statement of Basis") .

c. Following the public comment pe riod , the Department will prepare a formal

response to all public comments received regarding the Permit modification

("Response to Comments") . The Department may, as a result of the public

comments , issue the final modified permit , require the Owner and/or Operator to

do additional work, or select an alternative corrective measure for implementation

at the Facility .

d. Nothing in this Permit shall limit the Department 's authority to implement the

selected corrective measure(s) or to take any o ther appropriate action under the laws

and regulations of the State of Califo rn ia, or any o ther legal authority, including thefiling of a civil action seeking a judicial order directing the Owner and/or Operatorto implement the selected corrective measure(s) .

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e . The Department will review all required CMI documents and notify the Permitteein writing of the Department's approval or disapproval, including any commentsand/or modifications, in accordance with the DepartmentApproval/Reporting/Proposed Contractor/Additional Work section of this Part ofthe Permit .

f. Nothing in this Permit shall limit the Department's authority to implement aselected corrective measure(s) or to take any other appropriate action under the lawsand regulations of the State of California, or any other legal authority, including thefiling of a civil action seeking a judicial order directing the Owner and/or Operatorto implement a selected corrective measure(s) .

G. DEPARTMENT APPROV i EPORTIN /PROPOSED ONT A TOR/ DDITIONAL

WORK

Department Approva l

a . The Department will provide the Owner and/or Operator with its written approval,approval with conditions and/or modifications, disapproval, or disapproval withcomments for any workplan, report (except progress reports), specification orschedule submitted pursuant to or required by this Permit .

b. The Owner and/or Operator shall revise any workplan, report, specification orschedule in accordance with the Department's written comments . The Ownerand/or Operator shall submit to the Department any revised submittals inaccordance with a due date specified by the Department . Revised submittals aresubject to Department approval or disapproval, with comments and/or modification .

c . Upon receipt of the Department's written approval, the Owner and/or Operator shallcommence work and implement any approved workplan or plan in accordance withthe schedule and provisions contained therein .

d. Any Department approved workplan, report, specification, or schedule, shall bedeemed incorporated into this Permit. Any non-compliance with such approvedworkplans, reports, specifications or schedules shall be considered non-compliancewith this Permit. Prior to this written approval, no workplan, report, specificationor schedule shall be construed as approved and final . Verbal advice, suggestions,or comments given by the Department representatives will not constitute an officialapproval, nor shall any verbal approval or verbal assurance be considered binding .

2 . Reporting

a. Beginning 90 days following the effective date of this Permit, until suspended bythe Department in writing, the Owner and/or Operator shall provide the Departmentwith quarterly progress reports of corrective action activities conducted and to beconducted pursuant to this Part of the Permit . Progress reports are due on the 15thday of the month when reports are due . The progress reports shall conform to therequirements contained in Attachment Ito this Permit . The Department may adjustthe frequency of progress reporting to be consistent with site-specific activities .

HDMSP00118639



Attachment A - P age 64

b. Any report or other document submitted by the Owner and/or Operator pursuant tothis Part of the Permit shall be signed and certified by a responsible corporateofficer of the Owner and/or Operator or a duly authorized representative inaccordance with 22 CCR 66270 .11 .

c . Three copies of all documents, including but not limited to, workplan(s), reports,and other correspondence to be submitted pursuant to this Part of the Permit shallbe hand delivered, sent by certified mail, return receipt requested, or by overnightexpress mail to the Department Project Coordinator or to other addresses she/hedesignates. Submittals specifically exempted from the three copy requirementoutlined above are all progress reports, and any other correspondence of less than15 pages, of which one copy is required . All submittals required by this Permitshall be printed on recycled paper and shall be copied double-sided wheneverpracticable .

d. Unless otherwise specified, all reports, correspondence, approvals, disapprovals,notices or other submissions relating to or required under this Part of the Permitshall be in writing and shall be sent to the respective Project Coordinators .

e . The Owner and/or Operator shall submit to the Department upon request the resultsof all sampling and/or tests or other data generated pursuant to this Part of thePermit.

3 . Proposed Contractor/Consultan t

All work performed pursuant to this Part of the Permit shall be under the direction andsupervision of a California registered professional engineer, hydrologist, or geologist withexpertise in hazardous waste site cleanup . The Owner and/or Operator's contractor orconsultant shall have the technical expertise sufficient to adequately perform all aspects ofthe work for which they are responsible . Within 60 days of the effective date of this Permit,the Owner and/or Operator shall notify the Department Project Coordinator in writing of thename, title, and qualifications of the engineer or geologist, and of any contractors orconsultants and their personnel to be used in carrying out this Part of the Permit .

4 . Additional Work

The Department may determine or the Owner and/or Operator may propose that certaintasks, including investigatory work, remedial action, engineering evaluation, orprocedure/methodology modification are necessary in addition to, or in lieu of, the tasks anddeliverables included in any workplan approved by the Department . The Department shallrequest in writing that the Owner and/or Operator perform the additional work and shallspecify the basis and reasons for the Department's determination that the additional workis necessary . Within 14 days after the receipt of such determination, the Owner and/orOperator shall have the opportunity to meet or confer with the Department to discuss theadditional work the Department has requested. If required by the Department, the Ownerand/or Operator shall submit a workplan to the Department for additional work . Suchworkplan shall be submitted to the Department according to a schedule established by theDepartment. Upon approval of a workplan, the Owner and/or Operator shall implement itin accordance with the provisions and schedule contained therein .

HDMSP00118640




H. QUALITY ASSURANCE

1 . Workplans shall contain quality assurance/quality control and chain of custody proceduresfor all sampling, monitoring and analytical activities.

2. The name(s), address and telephone numbers of the California State certified analyticallaboratories the Owner and/or Operator proposes to use must be specified in the applicableworkplan(s) .

3 . All workplans required under this Part of the Permit shall include data quality objectives foreach data collection activity to ensure that data of known and appropriate quality areobtained and that data are sufficient to support their intended use(s) .

4. The Owner and/or Operator shall ensure that data of appropriate quality are obtained by itsconsultant or contract laboratories. The Owner and/or Operator shall ensure that CaliforniaState Certified laboratories used by the Owner and/or Operator have in place a qualityassurance program plan and perform analyses according to the latest approved edition of"Test Methods for Evaluating Solid Waste, (SW-846)", or other methods deemedsatisfactory by the Department. If methods other than standard methods are to be used, theOwner and/or Operator shall specify all such methods in the applicable workplan (e .g, RFI

workplan). The Department may reject any data that does not meet the requirements of theapproved workplan or the analytical methods, and may require resampling and analysis .

5 . The Department may conduct a performance and quality assurance/quality control audit of

the laboratories chosen by the Owner and/or Operator before, during or after sampleanalyses . Upon request by the Department, the Owner and/or Operator shall have itsselected California State certified laboratory perform analyses of samples provided by theDepartment to demonstrate laboratory performance . If the audit reveals deficiencies in a

laboratory's performance or quality assurance/quality control, resampling and analysis may

be required .

1. SAMPLING/ACCES S

Sampl ing

a. The Owner and/or Operator shall notify the Department in writing at least 14 day s

prior to beginning each separate phase of field work approved under any workplanrequired by this Part of the Permit . If the Owner and/or Operator believes it mustcommence emergency field activities without delay, the Owner and/or Operatormay seek emergency telephone authorization from the Department ProjectCoordinator or, if the Project Coordinator is unavailable, his/her immediatesupervisor, to commence such activities immediately . At the request of theDepartment, the Owner and/or Operator shall provide or allow the Department orits authorized representative to take split or duplicate samples of all samplescollected by the Owner and/or Operator pursuant to this Part of the Permit .

b . The Owner and/or Operator shall submit to the Department upon request the resultsof all sampling and/or tests or other data generated by it's employees, divisions,agents, consultants or contractors pursuant to this permit .

HDMSP00118641

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c. Notwi thstanding any o ther provisions of this Permit , the Department retains all ofit's information gathering and inspection authority and rights including enforcementactions related thereto , under H&SC and any other applicable state or federalstatutes or regulations .

2 . Access

a. In accordance with Permit condition II .D, the Department, its con tractors,employees , and/or any U.S. EPA representatives are authorized to enter and freelymove about the Facility pursuant to this Part of the Permit for the purposes of :interviewing Facility personnel and contractors ; inspecting records , operating logs,and contracts related to the Facility ; reviewing the progress of the Owner and/orOperator in carrying out the terms of this Part of the Permit; conducting such tests,sampling or monitoring as the Department or its Project Coordinator deemsnecessary; using a camera , sound recording , or other documentary type equipment ;

and veri fying the reports and data submitted to the Department by the Owner and/orOperator. The Owner and/or Operator shall provide the Department and itsrepresentatives access at all reasonable times to the Facility and any other propertyto which access is required for implementation of this Part of the Permit and shallpermit such persons to inspect and copy all records, files , photographs , documents,including all sampling and monitoring data, that pertain to work undertakenpursuant to this Part of the Permit .

b. To the extent that work being performed pursu ant to this Part of the Permit must bedone on property not owned or controlled by the Owner and/or Operator, the Ownerand/or Operator shall use its best efforts to obtain access agreements necessary tocomplete work required by this Part of the Permit from the present owner(s) of suchproperty within 30 days of approval of any workplan for which access is required.Best efforts as used in this paragraph shall include , at a minimum , a certified le tterfrom the Owner and/or Operator to the present owner(s) of such property requestingaccess agreement(s) to allow the Owner and/or Operator and the Department andits authorized representatives access to such property and the payment of reasonablesums of money in consideration of granting access . The Owner and/or Operatorshall provide the Department Project Coordinator with a copy of any accessagreement(s) . In the event that agreements for access are not obtained within 30days of approval of any workplan for which access is required , or of the date thatthe need for access become known to the Owner and/or Operator, the Owner and/orOperator shall notify the Department in w riting within fourteen ( 14) days thereafterregarding both the efforts undertaken to obtain access and its failure to obtain suchagreements . In the event the Department obtains access, the Owner and/or Operatorshall undertake approved work on such property .

c. No thing in this Part of the Permit shall be construed to limit or otherwise affect theOwner and/or Operator 's liability and obligation to perform corrective actionincluding correction action beyond the Facility boundary, notwithstanding the lackof access . The Department may determine that additional on-site measures mustbe taken to address releases beyond the Facility boundary if access to off-site areascannot be obtained .

d. No thing in this section limits or otherwise affects the Department ' s right of accessand entry pursuant to any applicable state or federal laws and regulations .

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J. RECORD PRESERVATION



1 . The Owner and/or Operator shall retain, during the term of this Permit, all data, records anddocuments gathered or generated during activities undertaken pursuant to this Part of thePermit . All such documents shall be stored in a centralized location at the SSFL (or otherlocation approved by the Department) and be made available to the Department or itsrepresentatives upon request . The Owner and/or Operator shall notify the Department inwriting at least 90 days prior to final expiration of this Permit, and shall provide theDepartment with the opportunity to take possession of any such records . Such writtennotification shall reference this Permit (including expiration date) and shall be addressedto the Department Project Coordinator .

2 . The Owner and/or Operator shall obtain copies of all data, records and documents gatheredor generated by any agent, consultant, or contractor employed by the Owner and/or Operator

to carry out the terms of this Part of the Permit .

K. DISPUTE RESOLUTION

1 . The Department and the Owner and/or Operator shall use their best efforts to informally andin good faith resolve all disputes or differences of opinion .

2. If the Owner and/or Operator disagrees, in whole or in part, with any written decision by theDepartment relating to Department modification of interim deliverables submitted by theOwner and/or Operator or to additional work required by the Department pursuant to thisPart of the Permit, the Owner and/or Operator Project Coordinator shall orally notify theDepartment Project Coordinator of the dispute . The Project Coordinators shall attempt toresolve the dispute informally .

3 . If the Project Coordinators cannot resolve the dispute informally, the Owner and/or

Operator may pursue the matter formally by placing its objections in writing . The Ownerand/or Operator's written objections must be directed to the Permitting Branch Chief, with

a copy to the Department Project Coordinator, within 14 days of the Owner and/orOperator's receipt of the Department decision . The Owner and/or Operator's writtenobjection must set forth the specific points of the dispute and the basis for the Owner and/or

Operator's position .

4. The Department and the Owner and/or Operator shall have 14 days from the Department'sreceipt of the Owner and/or Operator' s written objections to a ttempt to resolve the disputethrough formal discussions . This time period may be extended by the Department for goodcause . During such time period , the Owner and/or Operator will have an opportunity tomeet or confer with the Department to discuss the dispute and the Owner and/or Operator'sobjections .

5. After the formal discussion period, the Department will provide the Owner and/or Operatorwith its written decision on the dispute . The Department's written decision will reflect anyagreements reached during the formal discussion period and be signed by Permitting BranchChief. The decision shall be incorporated into and become an enforceable part of thisPermit . The decision is not subject to further dispute resolution .

HDMSP00118643




6. If the Owner and/or Operator fails to follow any of the requirements contained in this Partof the Permit then it shall have waived its right to further consideration of the disputed issue .

7 . The existence of a dispute as defined herein, and the Department's consideration of suchmatters as placed into dispute shall not excuse, toll or suspend any compliance obligationor deadline required pursuant to this Part of the Permit during the pendency of the disputeresolution process .

L. MODIFICATIO N

The Owner and/or Operator must request a permit modification to revise any submittal dates

specified in this Part of the Permit . To request such a revision , the Owner and/or Operator

must use the procedures for a Class 1 permit modification with prior Department approval

in accordance with 22 CCR 66270 .42. Such requests must be timely and providejustification for any proposed submittal date revisions .

2. If at any time the Department determines that modification of this Part of the Permit isnecessary, the Department may initiate a modification to this Part of the Permit accordingto the procedures in 22 CCR 66270.41 .

3 . Any requests for a revision of an approved workplan (or plan) requirement must be in

writing . Such requests must be timely and provide justification for any proposed workplanrevision. The Department has no obligation to approve such requests, but if it does so, suchapproval will be in writing and signed by the Permitting Branch Chief . Any approvedworkplan modification shall be incorporated by reference into this Permit .

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M. FACILITY SUBMITTAI , SUMMARY


Attachme nt A - Page 69

Below is a summary of the major reporting requirements contained in this Part of the Permit . The

summary is provided as a general guide and thus does not contain all requirements. Please refer to

the specific language of this Part of the Permit for all the requirements .

Facility Submission Requirements Due Date

Designate Project Coordinator and notify the Department in 30 days from effective date of Permi t

writing

Notify the Department in writing of contractors to carry out 60 days from effective date of Permi t

terms of Permi t

Submit first Progress Report 45 days after the effective date of thi sPermit

Submit Progress Reports quarterly, 15 days after the end of th ereporting period

Notify the Department of when field work starts 14 days before each phase of field work

Submit CMS Workplan 90 days after Department reques t

Implement approved Workplans In accordance with schedules containe din approved Workplans

Verbal notification of immediate or potential threats to 48 hours after discoveryhuman health or the environment, newly identified release sor newly discovered SWMUs

Written notification of immediate or potential threats to 30 days after discovery

human health or the environment, newly identified release sor newly discovered SWMUs

HDMSP00118645


PART VIII

COMPLIANCE SCHEDULE

A. REPORTING REQUIREMENTS


A tt achment A - Page 7 0

The Owner and/or Operator shall submit repo rts of compliance or noncompliance with, or anyprogress reports on, interim and final requirements contained in any compliance schedule of this

Permit no later than fourteen (14) calendar days after each scheduled date . [22 CCR 66270 .30(l)(5) ]

B. SUMMARY OF COMPLIANCE SCHEDUL E

In addition to the reporting requirements for a Corrective Action Program as specified in Permit

Condition VII.G, the following documents shall be submi tted to the Department by the dates shown :

Document Due Date

Documentation of compliance with protective distance Within sixty (60) calendar days after th e

requirements as required by Permit Condition 111 .1 .4 effective date of this Permit

Groundwater Sampling and Analysis Plan (SAP), including Within 30 calendar days after the

provisions for checking for free phase liquids, turbidity effective date of this permit.testing and reporting status of activated carbon canisters .

Document demonstrating adequate seals for groundwater 1 year from the effective date of thi s

wells as required in Permit section V .G. Le . permit .

Groundwater concentration limits As part of the next Annual GroundwaterReport, V .K due March 1996.

Submit a proposed replacement detection well or wells for Within 60 days of the effective date of

RD52-B . this permit .

Modify the Part A Permit Application to include spent Within sixty (60) days after the effectiv e

carbon canisters holding hazardous waste constituents, date of this permit.

reagent supply (peroxide) tanks and holding tanks .

Provide the ECL unit containment volume . Within thirty (30) days after the effectiv edate of this permit.

H D M S P00118646

ATTACHMENT B

EXCERPT FROM "STATISTICAL ANALYSIS OF GROUNDWATERMONITORING DATA AT RCRA FACILITIES" AND ADDENDUM

HAZARDOUS WASTE FACILITY POST-CLOSURE PERMITNational Aeronautic & Space Administration /

The Boeing CompanySanta Susana Field Laboratory, Area II

Permit Number: PC-94195-3-03Modification Number : MOD-SC3-063000-B

EPA I .D. No . CA1800090010

HDMSP00118647

[page purposely left blank]

HDMSP00118648



Attachment B - Page 1

STATISTICAL ANALYSIS OFGROUND-WATER MONITORING DATA

AT RCRA FACILITIES

INTERIM FINAL GUIDANC E

OFFICE OF SOLID WASTEWASTE MANAGEMENT DIVISIO NU .S. ENVIRONMENTAL PROTECTION AGENCY401 M STREET, S .W.WASHINGTON, D .C. 20460

APRIL 198 9

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Attachment B - Page _2

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Observation from compliance wells in excess of 2,082 mg/L would give stat-istically significant evidence of contamination .

INTERPRETATION

Cohen's method provides maximum likelihood estimates of the meanand variance of a censored normal distribution. That is, of observations thatfollow a normal distribution except for those below a limit of detection, whichare reported as "not detected ." The modified estimates reflect the fact that thenot detected observations are below the limit of detections, but not necessarilyzero. The large sample properties of the modified estimates allow for them tobe used with the normal theory procedures as a means of adjusting for notdetected values in the data . Use of Cohen's method in more complicatedcalculations such as those required for analysis of variance procedures,requires special consideration from a professional statistician .

8.2 OUTLIERS

A ground-water constituent concentration value that is much differentfrom most other values in a data set for the same ground-water constituentconcentration can be referred to as an "outlier ." Possible reasons for outlierscan be:

• A catastrophic unnatural occurrence such as a spill ;

• Inconsistent sampling or analytical chemistry methodology thatmay result in laboratory contamination or other anomalies ;

• Errors in the transcription of data values or decimal points ; and

• True but extreme ground-water constituent concentrationmeasurements .

There are several tests to determine if there is statistical evidence thatan observation is an outlier . The reference for the test presented here isASTM paper E178-75 .

PURPOSE

The purpose of a test for outliers is to determine whether there isstatistical evidence that an observation that appears extreme does not fit thedistribution of the rest of the data . If a suspect observation is identified as anoutlier, then steps need to be taken to determine whether it is the result of anerror or a valid extreme observation .

PROCEDURE

Let the sample of observations of a hazardous constituent of groundwater be denoted by xt, . . ., x~. For specificity , assume that the data have beenordered and that the largest observation, denoted by x~, is suspected of beingan outlier . Generally, inspection of the data suggests values that do no t

8-11

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appear to belong to the data set . For example, if the largest observation is anorder of magnitude larger than the other observations, it would be suspect .

Step 1 . Calculate the mean, X and the standard deviation, S, of thedata including all observations .

Step 2 . Form the statistic, T~ :

T„=(x„-X)/ SNote that T„ is the difference between the largest observation and the samplemean , divided by the sample standard deviation .

Step 3 . Compare the statistic T~ to the c ri tical value given the samplesixe, n , in Table 8 in Appendix B . If the T~ statistic exceeds the critical valuefrom the table , this is evidence that the suspect observation , xn, is a statisticaloutlier .

Step 4 . If the value is identified as an outlier, one of the actionsoutlined below should be taken . (The appropriate action depends on what canbe learned about the observation .) The records of the sampling and analysisof the sample that led to it should be investigated to determine whether theoutlier resulted from an error that can be identified .

• If an error ( in transcription , dilution , analytical procedure , etc.) canbe identified and the correct value recovered , the observation should bereplaced by its corrected value and the appropriate statistical analysis donewith the corrected value .

• If it can be determined that the observation is in error , but thecorrected value cannot be determined , then the observation should be deletedfrom the data set and the appropriate statistical analysis performed . The factthat the observation was deleted and the reasons for its deletion should bereported when reporting the results of the statistical analysis .

• If no error in the value can be documented then it must be assumedthat the observation is a true but extreme value . In this case it must not bealtered . It may be desirable to obtain another sample to confirm theobse rvation . However, analysis and reporting should retain the observationand state that no error was found in tracing the sample that led to the extremeobservation.

EXAMPLE

Table 8-4 contains 19 values of total organic carbon (TOC) that wereobtained from a monitoring well . Inspection shows one value which at 11,000mg/L is nearly an order of magnitude larger than most of the otherobse rvations . It is a suspected outlier .

8-11

HDMSP00118652


TABLE 8-4. EXAMPLE DATA FOR TESTING FOR AN OUTLIE R

Total organic carbon (mg/L )

1,7001,9001,5001,300

11,0001,2501,0001,3001,2001,4501,0001,3001,0002,2004,9003,7001,6002,5001,900

Step 1 . Calculate the mean and standard deviation of the data

R=2300 and S =2325 . 9

Step 2. Calculate the statistic T19 .

T19 = (11000-2300)/2325.9 = 3 .74



Step 3. Referring to Table 8 of Appendix B for the upper 5%significance level, with n = 19, the critical value is 2 .532. Since the value of thestatistic T19 = 3 .74 is greater than 2 .532, there is statistical evidence that thelargest observation is an outlier .

Step 4. In this case, tracking the data revealed that the unusual valueof 11,000 resulted from a keying error and that the correct value was 1,100 .This correction was then made in the data .

INTERPRETATION

An observation that is 4 or 5 times as large as the rest of the data isgenerally viewed with suspicion . An observation that is an order of magnitudedifferent could arise by a common error of misplacing a decimal . The test foran outlier provides a statistical basis for determining whether an observation

8-11

HDMSP00118653



A ttachment B - P age 6

is statistically different from the rest of the data . If it is, then it is a statisticaloutlier . However , a statistical outlier may not be dropped or altered justbecause it has been identified as an outlier . The test provides a formalidentification of an observation as an outlier, but does not identify the cause ofthe difference .

Whether or not a statistical test is done , any suspect data point shouldbe checked . An observation may be corrected or dropped only if it can bedetermined that an error has occurred . If the error can be identified andcorrected (as in transcription or keying ) the correction should be made and thecorrected values used . A value that is demonstrated to be incorrect may bedeleted from the data . However, if no specific error can be documented, theobse rvation must be retained in the data . Identification of an observation asan outlier but with no error documented could be used to suggest resamplingto confirm the value .

8-11

HDMSPOO118654


STATISTICAL ANALYSIS OFGROUND-WATER MONITORIN G

DATA AT RCRA FACILITIES

DRAFT

ADDENDUM TO INTERIM FINALGUIDANCE

OFFICE OF SOLID WASTEPERMITS AND STATE PROGRAMS DIVISIONU.S. ENVIRONMENTAL PROTECTION AGENCY401 M STREET, S.W.WASHINGTON , D.C. 20460

JULY 1992



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Attachment B - P age 8

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6

5

4

3

2

1

0

- 1

-28 10


A ttachment B - Page 9

hSCL

--zCUSUM

SAMPLING PERIOD

Note : In the above Control Chart, the CUSUMs are compared to threshold h, while the standardized

means (Z) are compared to the SCL threshold.

6.2 OUTLIER TEST ING

Formal testing for outliers should be done only if an observation seems particularly high (by

orders of magnitude) compared to the rest of the data set . If a sample value is suspect, one should

run the outlier test described on pp . 8-11 to 8-14 of the EPA guidance document . It should becautioned, however, that this outlier test assumes that the rest of the data values, except for thesuspect observation, are Normally distributed (Barnett and Lewis, 1978) . Since Lognormally

distributed measurements often contain one or more values that appear high relative to the rest, itis recommended that the outlier test be run on the logarithms of the data instead of the original

observations . That way, one can avoid classifying a high Lognormal measurement as an outlier just

because the test assumptions were violated .

If the test designates an observation as a statistical outlier, the sample should not be treated

as such until a specific reason for the abnormal measurement can be determined . Valid reasons may,

for example, include contaminated sampling equipment, laboratory contamination of the sample ,

0 2 4 6

10

CONTROL CHART FOR NICKEL DATAMU = 27 ppb SIGMA = 26 ppb

HDMSP00118657



Attachment B - Page 1 0

or errors in transcription of the data values . Once a specific reason is documented, the sampleshould be excluded from any further statistical analysis . If a plausible reason cannot be found, thesample should be treated as a true but extreme value, ncll to be excluded from further analysis .

EXAMPLE 19

The table below contains data from five wells measured over a 4-month period. The value

7066 is found in the second month at well 3 . Determine whether there is statistical evidence that thisobservation is an outlier.

Carbon Tetrachloride Concentration (ppb)

Well1 Well2 Well3 Well4 Well 5

1 .69 3 .02 16 .2 199 275

3 .25 35 .1 7066 41 .6 6 . 5

7 .3 15 .6 350 75.4 59 . 7

12 .1 13 .7 70.14 57 .9 68 . 4

SOLUTION

Step 1 . Take logarithms of each observation . Then order and list the logged concentrations .

10

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ATTACHMENT C


Attachment C - Page 1

SCOPE OF WORK FOR INTERIM MEASURES IMPLEMENTATIO N

PURPOSE

Interim measures are actions to control and/or eliminate releases of hazardous waste and/or hazardousconstituents from a facility prior to the implementation of a final corrective measure . Interim measures must be

used whenever possible to achieve the goal of stabilization which is to control or abate threats to human healthand/or the environment, and to prevent or minimize the spread of contaminants while long-tern corrective action

alternatives are being evaluated .

SCOPE

The documents required for Interim Measures (IM) are, unless the Department of Toxic Substances Control(Department) specifies otherwise, an IM Workplan, an Operation and Maintenance Plan and IM Plans and

Specifications . The scope of work (SOW) for each document is specified below . The SOWS are intended to be

flexible documents capable of addressing both simple and complex site situations . If the Owner/Operator or

Respondent can justify, to the satisfaction of the Department, that a plan or portions thereof are not needed inthe given site specific situation, then the Department may waive that requirement .

The scope and substance of interim measures should be focused to fit the site specific situation and be balanced

against the need to take quick action .

The Department may require the Owner/Operator or Respondent to conduct additional studies beyond what isdiscussed in the SOWs in order to support the IM program . The Owner/Operator or Respondent will furnish all

personnel, materials and services necessary to conduct the additional tasks .

A. Interim Measures Workplan

The Owner/Operator or Respondent shall prepare an IM Workplan that evaluates interim measureoptions and clearly describes the proposed interim measure, the key components or elements that arcneeded, describes the designer's vision of the interim measure in the form of conceptual drawings andschematics, and includes procedures and schedules for implementing the interim measure(s) . The 1M

Workplan must be approved by the Department prior to implementation . The IM Workplan must, at a

minimum, include the following elements :

1 . Introduction/Purpos e

Describe the purpose of the document and provide a summary of the project .

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2 . Conceptual Model of Contaminant Migratio n

It is important to know where the contaminants are and to understand how they are movingbefore an adequate interim measure can be developed . To address this critical question, theOwner/Operator or Respondent must present a conceptual model of the site and contaminant

migration. The conceptual model consists of a working hypothesis of how the contaminantsmay move from the release source to the receptor population . The conceptual model is

developed by looking at the applicable physical parameters (e .g., water solubility, density,

Henry's Law Constant, etc .) for each contaminant and assessing how the contaminant maymigrate given the existing site conditions (geologic features, depth to ground water, etc .) .

Describe the phase (water, soil, gas, non-aqueous) and location where contaminants are likely

to be found. This analysis may have already been done as part of earlier work (e .g., Current

Conditions Report) . If this is the case, then provide a summary of the conceptual model with

a reference to the earlier document.

3 . Evaluation of Interim Measure Alternatives

List, describe and evaluate interim measure alternatives that have the potential to stabilize the

facility . Propose interim measures for implementation and provide rationale for the selection .

Document the reasons for excluding any interim measure alternatives.

4. Description of Interim Measure s

Qualitatively describe what the proposed interim measure is supposed to do and how it willfunction at the facility .

5. Data Sufficiency

Review existing data needed to support the design effort and establish whether there aresufficient accurate data available for this purpose . The Owner/Operator or Respondent mustsummarize the assessment findings and specify any additional data needed to complete the

interim measure design . The Department may require or the Owner/Operator or Respondentmay propose that sampling and analysis plans and/or treatability study workplans be developed

to obtain the additional data . Submittal times for any new sampling and analysis plans and/ortreatability study workplans must be included in the project schedule .

6. Project Management

Describe the levels of authority and responsibility (include organization chart), lines ofcommunication and a description of the qualifications of key personnel who will direct theinterim measure design and implementation effort (including contractor personnel) .

7. Project Schedule

The project schedule must specify all significant steps in the process, when any key documents

(e .g ., plans and specifications, operation and maintenance plan) are to be submitted to theDepartment and when the interim measure is to be implemented .

HDMSP00118660


8 . Design Basis



Discuss the process and methods used to design all major components of the interim measure .Discuss the significant assumptions made and possible sources of error . Provide justification

for the assumptions .

9 . Conceptual Process/Schematic Diagrams .

10. Site plan showing preliminary plant layout and/or treatment area.

11 . Tables listing number and type of major components with approximate dimensions .

12. Tables giving preliminary mass balances .

13. Site safety and security provisions (e .g ., fences, fire control, etc .) .

14. Waste Management Practice s

Describe the wastes generated by the construction of the interim measure and how they will be

managed. Also discuss drainage and indicate how rainwater runoff will be managed .

15. Required Permit s

List and describe the permits needed to construct the interim measure . Indicate on the projectschedule when the permit applications will be submitted to the applicable agencies and an

estimate of the permit issuance date .

16. Sampling and Monitorin g

Sampling and monitoring activities may be needed for design and during construction of theinterim measure . If sampling activi ties are necessary, the IM Workplan must include a completesampling and analysis section which specifies at a minimum the following information :

a. Desc ription and purpose of monitoring tasks ;b. Data quality objectives ;c . Analytical test methods and detection limits ;d. Name of analytical laboratory ;e. Laboratory quality control ( include laboratory QA/QC procedures in appendices)

f. Sample collection procedures and equipment ;

HDMSP00118661


g• Field quality control procedures :



duplicates (10% of all field samples)blanks (field, equipment, etc .)equipment calibration and maintenanceequipment decontaminationsample containerssample preservationsample holding times (must be specified)sample packaging and shipmentsample documentation (field notebooks, sample labeling, etc.) ;chain of custody ;

h. Criteria for data acceptance and rejection; andi. Schedule of monitoring frequency .

The Owner/Operator or Respondent shall follow all Department and U .S . EPA guidance for

sampling and analysis . The Department may request that the sampling and analysis section be

a separate document .

17. Appendices including :

a . Design Data - Tabulations of significant data used in the design effort ;

b. Equations - List and describe the source of major equations used in the design process ;

c . Sample Calculations - Present and explain one example calculation for significantcalculations ; and

d. Laboratory or Field Test Results .

B. Interim Measures Operation and Maintenance Pla n

The Owner/Operator or Respondent shall prepare an Interim Measures Operation and Maintenance(O&M) Plan that includes a strategy and procedures for performing operations, maintenance, andmonitoring of the interim measure(s) . An Interim Measures Operation and Maintenance Plan shall be

submitted to the Department simultaneously with the Plans and Specifications . The O&M plan shall .

at a minimum, include the following elements :

1 . Purpose/Approach

Describe the purpose of the document and provide a summary of the project.


Describe the levels of authority and responsibility (include organization chart), lines ofcommunication and a description of the qualifications of key personnel who will operate andmaintain the interim measure(s) (including contractor personnel) .

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3 . System Desc ription

Describe the interim measure and identify significant equipment .

4. Personnel Training


Attachment C- Page 5

Describe the training process for O&M personnel . The Owner/Operator or Respondent shall

prepare , and include in the technical specifications govern ing treatment systems , contractor

requirements for providing: appropriate service visits by experienced personnel to supervise the

installation , adjustment , start up and operation of the treatment systems , and training covering

appropriate operational procedures once the start-up has been successfully accomplished .

5. Start-Up Procedures

Desc ribe system start-up procedures including any operational testing .

6 . Operation and Maintenance Procedure s

Describe normal operation and maintenance procedures including :

a. Desc ription of tasks for operation ;

b. Desc ription of tasks for maintenance ;

c. Desc ription of presc ribed treatment or operation condition, and

d. Schedule showing frequency of each O&M task .

7 . Replacement schedule for equipment and installed components .

8 . Waste Management Practices

Describe the wastes generated by operation of the inte rim measure and how they will be

managed . Also discuss drainage and indicate how rainwater runoff will be managed .

9. Sampling and Monitoring

Sampling and monitoring activities may be needed for effective operation and maintenance ofthe interim measure . If sampling activities are necessa ry, the O&M plan must include acomplete sampling and analysis section which specifies at a minimum the followinginformation :

a. Description and purpose of monito ring tasks;

b. Data quality objectives;

c . Analytical test methods and detection limits ;

d. Name of analytical laboratory ;

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e. Laboratory quality control (include laboratory QA/QC procedures in appendices)


g. Field quality control procedures :

duplicates (10% of all field samples)blanks (field, equipment, etc .)equipment calibration and maintenanceequipment decontaminationsample containerssample preservationsample holding times (must be specified)sample packaging and shipmen tsample documentation (field notebooks, sample labeling, etc .) ;chain of custody;

h. Criteria for data acceptance and rejection ; and

i . Schedule of monitoring frequency .

The Owner/Operator or Respondent shall follow all Department and U.S. EPA guidance for

sampling and analysis. The Department may request that the sampling and analysis section be


10. O&M Contingency Procedures :

a . Procedures to address system breakdowns and operational problems including a list ofredundant and emergency back-up equipment and procedures ;

b. Should the interim measure suffer complete failure, specify alternate procedures toprevent release or threatened releases of hazardous substances, pollutants orcontaminants which may endanger public health and/or the environment or exceedcleanup standards ; and

c. The O&M Plan must specify that, in the event of a major breakdown and/or completefailure of the interim measure (includes emergency situations), the Owner/Operator orRespondent will orally notify the Department within 24 hours of the event and willnotify the Department in writing within 72 hours of the event . The written notificationmust, at a minimum, specify what happened, what response action is being taken and/oris planned, and any potential impacts on human health and the environment .

11 . Data Management and Documentation Requirement s

Describe how analytical data and results will be evaluated, documented and managed, includingdevelopment of an analytical database . State the criteria that will be used by the project team

to review and determine the quality of data .

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A ttachment C - Page 7

The O&M Plan shall specify that the Owner /Operator or Respondent collect and maintain thefollowing information :

a. Progress Report Information

(1) . Work Accomplishments (e .g., performance levels achieved, hours of treatmentoperation, treated and/or excavated volumes, concen tration of contaminants intreated and/or excavated volumes , nature and volume of wastes generated, etc .) .

(2) . Record of significant activities (e.g., sampling events , inspections , problemsencountered , action taken to rectify problems, etc .) .

b. Monitoring and laboratory data ;

c . Records of operating costs; and

d. Personnel , mainten ance and inspection records .

The Department may require that the Owner/Operator or Respondent submit additional repo rtsthat evaluate the effectiveness of the interim measure in meeting the stabilization goal .

C. Interim Measures Plans and Specification s

The Owner/Operator or Respondent shall prepare Plans and Specifications for the interimmeasure that are based on the conceptual design but include additional detail . The Plan s andSpecifications shall be submitted to the Department simultaneously with the Operation andMaintenance Plan. The design package must include drawings and specifications needed toconstruct the interim measure . Depending on the nature of the inte rim measure, many differenttypes of drawings and specifications may be needed . Some of the elements that may be requiredare :

General Site PlansProcess Flow DiagramsMechanical DrawingsElectrical DrawingsStructural Drawing sPiping and Instrumentation DiagramsExcavation and Earthwork DrawingsEquipment ListsSite Preparation and Field Work St andardsPreliminary Specifications for Equipment and Mate rial

HDMSP00118665




2. General correlation between drawings and technical specifications is a basic requirement of anyset of working construction plans and specifications . Before submitting the projectspecifications to the Department, the Owner/Operator or Respondent shall :

a. Proofread the specifications for accuracy and consistency with the conceptual design;

and

b. Coordinate and cross-check the specifications and drawings .

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ATTACHMENT D


Attachment D - Page 1

SCOPE OF WORK FOR A RCRA FACILITY INVESTIGATIO N

PURPOSE

The purpose of this RCRA Facility Investigation (RFI) is to determine the nature and extent of releases ofhazardous waste or constituents from regulated units, solid waste management units, and other source areas atthe Facility and to gather all necessary data to support the Corrective Measures Study . The RFI must includecharacterization of the facility (processes, waste management, etc), environmental setting, source areas, natureand extent of contamination, migration pathways (transport mechanisms) and all potential receptors .

SCOPE

The documents required for a RFI are, unless the Department of Toxic Substances Control (Department)specifies otherwise, a Current Conditions Report, a RCRA Facility Investigation Workplan and a RCRA Facility

Investigation Report . The scope of work (SOW) for each document is specified below . The SOWs are intended

to be flexible documents capable of addressing both simple and complex site situations . If the Owner/Operatoror Respondent can justify, to the satisfaction of the Department, that a plan and/or report or portions thereof arenot needed in the given site specific situation, then the Department may waive that requirement .

The scope and substance of the RFI should be focused to fit the complexity of the site-specific situation . It isanticipated that Owner/Operator's or Respondent's of sites with complex environmental problems may need moreextensive RFI's than other facilities with less complex problems .

The Department may require the Owner/Operator or Respondent to conduct additional studies beyond what isdiscussed in the SOWs in order to meet the objectives of the RFI . The Owner/Operator or Respondent will

furnish all personnel, materials and services necessary to conduct the additional tasks .

A. Current Conditions Report

The Current Conditions Report must describe existing information pertinent to the facility includingoperations, processes, waste management, geology, hydrogeology, contamination, migration pathways,potential receptor populations and interim corrective measures . The required format for a current

conditions report is described below. If some of this information does not exist, so indicate in theapplicable section .

1 . Introduction

a . P=ose

Describe the purpose of the current conditions report (e .g ., summary and evaluation of

existing information related to the facility ; required as a component of RFI) .

HDMSP00118667




b . Organization of Rep

Describe how the report is organized .

2. Facility Description

Summarize background, current operations, waste management and products produced at thefacility . Include a map that shows the general geographic location of the facility .

Describe current facility structures including any buildings, tanks, sumps, wells, wastemanagement areas, landfills, ponds, process areas and storage areas .

Include detailed facility maps that clearly show current property lines, the owners of all adjacentproperty, surrounding land use (residential, commercial, agricultural, recreational, etc .), alltanks, buildings, process areas, utilities, paved areas, easements, rights-of-way, wastemanagement areas, ponds, landfills, piles, underground tanks, wells and other facility features .

3 . Facility History

a . Ownership History

Describe the ownership history of the facility .

b . Operational History

Describe in detail how facility operations, processes and products have changed overtime (historical aerial photographs could be useful for this purpose) .

c . Regulatory History

Describe all permits (including waste discharge requirements) requested or received,any enforcement actions taken by the Department or designated agencies and anyclosure activities that are planned or underway .

d . Waste Generation

Describe all wastes (solid or hazardous) that have been generated at the facility . Includeapproximate waste volumes generated and summaries of any waste analysis data . Showhow the waste stream (volume and chemical composition) has changed over time .

e . Waste Managemen t

Describe in detail all past solid and hazardous waste treatment, storage and disposalactivities at the facility. Show how these activities have changed over time andindicate the current status . Make a clear distinction between active waste managementunits and older out of service waste management units. Identify which wastemanagement units are regulated under RCRA or California Health and Safety Code .

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Include maps showing : (1) all solid or hazardous waste treatment, storage or disposalareas active after November 19, 1980, (2) all known past solid waste or hazardous wastetreatment, storage or disposal areas regardless of whether they were active onNovember 19, 1980 and (3) all known past or present underground tanks or piping.

f. Spill and Discharge History

Provide approximate dates or periods of past product and waste spills, identify thematerials spilled and describe any response actions conducted . Include a summaryof any sampling data generated as a result of the spill . Include a map showingapproximate locations of spill areas at the facility.

g. Chronology of Critical Events

Provide a chronological list (including a brief description) of major events,communications, agreements, notices of violation, spills, discharges that occurredthroughout the facility's history .

4. Environmental Setting

a . Location/Land Ilse

Discuss facility size, location and adjacent land use . Include a rough demographicprofile of the human population who use or have access to the facility and adjacentlands . Provide approximate distance to nearest residential areas, schools, nursinghomes, hospitals, parks, playgrounds, etc .

b . Local Ecology

Describe any endangered or threatened species near the facility . Include a desc riptionof the ecological setting on and adjacent to the facility. Provide approximatedistance to nearest environmentally sensitive areas such as marsh lands , wetlands,streams , oceans, forests, etc .

c . Topography and Surface Drainage

Describe the regional and site specific topography and surface drainage patterns thatexist at the facility . Include a map that shows the topography and surface drainagedepicting all waterways, wetlands, floodplains, water features, drainage patterns andsurface water containment areas .

d. Climate

Discuss mean annual temperatures, temperature ex tremes , 25-year 24 -hour maximumrainfall , average annual rainfall, prevailing wind direction, etc .

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e . Surface Water Hydrology



Desc ribe the facility's proximity (distance) and access to surface water bodies (e .g .,coastal waters, lakes , rivers, creeks, drainage basins, floodplains , vernal pools , wetlands,etc .) . Describe flows on-site that lead to holding basins , etc ., and desc ribe flows thatleave the site .

f. Geology

g.

Describe the regional and site specific geology including stratigraphy and structure .Include a geologic map and cross-sections to show the subsurface structure . Cross-sections should be at a natural scale (vertical equals horizontal) and of sufficient detailto accurately plot cut and fills, alluvium, and structural features . Cross-sections shouldbe taken on a grid pattern oriented normal to major geologic structure and spaced closeenough to determine geology and ground water flow on a unit-by-unit basis .

Hydrogeology

Describe the regional and site specific hydrogeologic setting including any informationconcerning local aquifers, ground water levels, gradients, flow direction, hydraulicconductivity, and velocity . Include potentiometric surface contour maps . Describe thebeneficial uses of the ground water (e .g ., drinking water supply, agricultural watersupply, etc .) . Plot ground water elevations on the geologic cross-sections and indicateground water flow directions and likely contaminant pathways . Describe temporalvariations (seasonal and historical) .

h . Ground Water Monitoring System

Describe the facility's ground water monitoring system including a table detailing theexisting well construction . The table must, at a minimum, identify the followingconstruction details for each well :

Well IDCompletion DateDri lling MethodBorehole Diameter ( inches)Well Casing Diameter and TypeMeasuring Point Elevation (feet MSL)Borehole Depth (feet BGS)Depth of Well (feet)Screened IntervalFormation ScreenedSlot Size & Type (inches)Filter Pack MaterialFilter Pack Thickness and SpacingType of Filter Pack Seal

HDMSP00118670


(15). Thickness of Filter Pack Seal(16). Pump System (dedicated or non-dedicated)(17). Type of Pump and Depth in the Wel l(18). Approximate Depth to Water (feet BGS)



If some of this information is not available, so indicate on the table with an "NA" .(BGS : Below Ground Surface, MSL: Mean Sea Level )

The monitoring well locations must be shown on the facility map (see Section A .2 ofthis Attachment) .

5 . Existing Degree and Extent of Contaminatio n

For each medium where the Permit or Order identifies a release (e .g ., soil, ground water, surfacewater, air, etc .), describe the existing extent of contamination. This description must includeall available monitoring data and qualitative information on the locations and levels ofcontamination at the facility (both onsite and offsite) . Include a general assessment of the dataquality, a map showing the location of all existing sampling points and potential source areasand contour maps showing any existing ground water plumes at the facility (if ground waterrelease) . Highlight potential ongoing release areas that would warrant use of interim correctivemeasures (see Section 8, Interim Corrective Measures) .

a . Previous Investigation s

List and briefly describe all previous investigations that have occurred at the facility,agencies (e .g., the Department's Site Mitigation Branch, the Regional Water QualityControl Board, etc .) which required and/or oversaw the investigations, and agencycontacts .

6. Potential Migration Pathways

a . Physical Properties of Contaminants

Identify the applicable physical properties for each contaminant that may influence howthe contaminant moves in the environment. These properties could include meltingpoint (degrees C), water solubility (mg/1), vapor pressure (mm Hg), Henry's lawconstant (atm-m3/mol), density (g/cc), dynamic viscosity (cp), kinematic viscosity (cs),octanol/water partition coefficient (log K0 ), soil organic carbon/water partitioncoefficient (log ka) and soil/water partition coefficients, etc . Include a table thatsummarizes the applicable physical properties for each contaminant .

b . Conceptual Model of Contaminant Migration

Develop a conceptual model of contaminant migration . The conceptual model consistsof a working hypothesis of how the contaminants may move from the release source tothe receptor population . The conceptual model is developed by looking at theapplicable physical parameters for each contaminant and assessing how the contaminantmay migrate given the existing site conditions (geologic features, depth to groundwater, etc .) .

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Describe the phase (water, soil, gas, non-aqueous) and location where contaminants arelikely to be found (e .g ., if a ground water contaminant has a low water solubility anda high density, then the contaminant will likely sink and be found at the bottom of theaquifer, phase : non-aqueous) . Include a discussion of potential transformation reactionsthat could impact the type and number of contaminants (i .e ., what additionalcontaminants could be expected as a result of biotic and abiotic transformation reactionsgiven the existing soil conditions) .

A typical conceptual model should include a discussion similar to the following :benzene, ethylbenzene, toluene and xylenes are potential contaminants at the facility .Based on their high vapor pressures and relatively low water solubilities (see Henry'sLaw constant), the primary fate of these compounds in surface soils or surface water isexpected to be volatilization to the atmosphere . These mono-cyclic aromatichydrocarbons may leach from soils into ground water . The log k. (soil organiccarbon/water partition coefficient) values for these compounds ranges from 1 .9 to 4 .0,indicating that sorption to organic matter in soils or sediments may occur only to alimited extent .

7 . Potential Impacts of Existing Contamination

Describe the potential impacts on human health and the environment from any existingcontamination and/or ongoing activi ties at the facility . This description must consider thepossible impacts on sensitive ecosystems and endangered species as well as on localpopulations . Potential impacts from any releases to ground water , surface water , soil (includingdirect contact with contaminated surface soil) and air (including evaporation of volati le organ iccompounds from contaminated soil) must be discussed . If air could be a significant pathway,soil gas or vapor emissions and/or ambient air monitoring should be described.

a. Ground Water Releases

Identify all wells (municipal, domestic, agricultural, industrial, etc .) within a 1-mileradius of the facility . Include a summary of available water sampling data for anyidentified municipal, industrial or domestic supply wells .

Develop a well inventory table that lists the following items for each identified well :

Well DesignationState IDReported OwnerDrillerDate of CompletionOriginal Use of WellCurrent Use of WellDrilling MethodBorehole Diameter (inches)Casing Diameter (inches)Perforated Interval (feet)Gravel Pack Interval (feet)

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(13). Total Well Depth (feet)(14) . Dep th to Water (feet below ground surface)(15) . Date of Water Level Measurement


Attachm ent D - Page 7

If some of this information is not available , so indicate on the table with an "NA" .

Include a regional map showing the facility, ground water flow direction (if known) andthe location of all identified wells within a 1-mile radius of the facili ty .

Identify and describe any potential ground water discharge to surface water bodies .

Identi fy and list all relevant and applicable water standards for the protection of humanhealth and the environment (e.g., maximum contaminant levels , water quality standards,etc) .

b . Surface Water Release s

Discuss the facili ty's potential impact on surface water wi th in a 2-mile radius of thefacility . Desc ribe the potential beneficial uses of the surface water (e .g., drinkingwater supply , recreational , agricultural , indust rial, or environmentally sensitive) .Identify all water supply intake points and contact areas wi thin a 2-mile radius of thefacility . Include a summary of the most recent water sampling data available for eachof the identified water supply intake points . Include a description of the biota in surfacewater bodies on , adjacent to, or which can be potentially affected by the release . Alsosummarize any available sediment sampling data.

Include a regional map showing the facility, surface water flow direction, beneficial useareas , and the location of any identi fied water supply intake points or contact areas thatare wi thin a 2-mile radius of the facility.

c . Sensitive Ecosystems/Habitats

Discuss the facility's poten tial impact on sensi tive ecosystems .

8. Interim Correc tive Measures and Stabilization Assessment

Identify all corrective measures that were or are being undertaken at the facili ty to stabilizecontaminant releases . Describe the objec tives of the corrective measures including how themeasure is mitigating a potential threat to human health and the environment . Summarize thedesign features of the corrective measure . Include a schedule for completing any ongoing orfuture work .

Identify and desc ribe potential interim corrective measure alternatives that could beimplemented immediately to stabilize any ongoing releases and/or prevent further migration ofcontaminants and control source areas.

HDMSPOO118673


9. Data Needs



Assess the amount and quality of existing data concerning the facility and determine whatadditional information must be collected to meet the objectives of the RFI . This assessmentmust identify any additional information that may be needed to (1) support development ofinterim measures for early action and (2) adequately evaluate and compare corrective measuresalternatives (e .g ., field work, treatability studies, computer modeling, literature searches, vendor

contacts, etc .) . For example, if soil vapor extraction (SVE) is a likely option to addresscontamination at the facility, then the RFI should collect applicable field data to assess SVE(e .g ., soil gas analysis, depth to ground water, etc .) . The RFI Workplan must detail how thisadditional information will be collected .

10. References

Provide a list of references cited in the Current Conditions Report .

B. RCRA Facility Investigation Workplan

The RFI Workplan shall define th e procedures necessary to :

o Gather all necessary data to determine where interim measures are needed and to support the useof interim measures to address immediate threats to human health and/or the environment, toprevent or minimize the spread of contaminants, to control sources of contamination and toaccelerate the corrective action process (required for all releases) ;

o Characterize the presence, magnitude, extent (horizontal and vertical), rate of movement anddirection of any ground water contamination in and around the facility (only required forreleases to ground water);

o Characterize the geology and hydrogeology in and around the facility (only required for releasesto ground water and possibly for releases to soil) ;

o Characterize the presence, magnitude, extent (horizontal and vertical), rate of movement anddirection of any soil contamination in and around the facility (only required for releases to soil) ;

o Characterize the presence, magnitude, extent (horizontal and vertical), rate of movement anddirection of any soil gas contamination in and around the facility (may be required for releasesto ground water and/or soil depending on the circumstances) ;

o Characterize the presence, magnitude, extent (horizontal and vertical), rate of movement anddirection of any surface water contamination (includes surface water sediments) at the facility(only required for releases to surface water) ;

o Characterize the presence , magnitude , extent (horizontal and vert ical), rate of movement anddirection of any air releases at the facility ( only required for air releases) ;

o Characterize any potential sources of contamination (required for all releases) ;

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o Characterize the potential pathways of contaminant migration (required for all releases) ;

o Identify any actual or potential receptors (required for all releases) ;

o Gather all data to support a risk and/or ecological assessment (if required) ;

o Gather all necessary data to support the Corrective Measures Study (required for all releases) .This could include conducting treatability, pilot, laboratory and/or bench scale studies to assessthe effectiveness of a treatment method .

The RFI Workplan shall describe all aspects of the investigation, including project management,sampling and analysis, well drilling and installation and quality assurance and quality control . If thescope of the investigation is such that more than one phase is necessary, the "Phase 1" RFI Workplanmust include a summary description of each phase . For example, the first phase of a RFI could be usedto gather information necessary to focus the second phase into key areas of the facility that need furtherinvestigation.

The required format for a RFI Workplan is described below :

1 . Introduction

Briefly introduce the RFI Workplan. Discuss the Order or Permit requiring the RFI and howthe RFI Workplan is organized.

2. Investigation Objectives

a. Project Objectives

Describe the overall objectives and critical elements of the RFI . State the generalinformation needed from the site (e .g ., soil chemistry, hydraulic conductivity of aquifer,stratigraphy, ground water flow direction, identification of potential receptors, etc .) .The general information should be consistent with the objectives of the RFI and the dataneeds identified in the Current Conditions Report .

b . Data Quality Objective s

Provide data quality objectives that identify what data are needed and the intended useof the data .

3. Project Managemen t

a. Describe how the investigation will be managed, including the following information :

(1) . Organization chart showing key personnel, levels of authority and lines of

communication;

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(2) . Project Schedule ; and


Attachment D - Page 1 0

(3) . Estimated Project Budget.

b. Identify the individuals or positions who are responsible for : project management, fieldactivities, laboratory analysis, database management, overall quality assurance, datavalidation, etc . Include a description of qualifications for personnel performing ordirecting the RFI, including contractor personnel .

4. Facility Background

Summarize existing contamination (e .g., contaminants, concentrations, etc .), local

hydrogeologic setting and any other areas of concern at the facility . Include a map showing thegeneral geographic location of the facility and a more detailed facility map showing the areasof contamination . Provide a reference to the Current Conditions Report and/or other applicabledocuments as a source of additional information .

5 . Field Investigation

a . Task Description

Provide a qualitative description of each investigation task. Example tasks may include,

but are not limited to the following :

(1). Task 1 : Surface Soil Sampling

(2). Task 2: Surface Geophysics, Subsurface Soil Boring, and BoreholeGeophysics

Task 3 : Data Gathering to Support Interim Corrective Measures

Task 4 : Monitoring Well Installation

Task 5 : Aquifer Testin g

Task 6 : Ground Water Sampling

Task 7 : Potential Receptor Identification

Task 8 : Treatability Studies

b . Rationale for Sampling

Describe where all samples will be collected (location and depth), types of media thatwill be sampled and the analytical parameters . Explain the rationale for each samplingpoint, the total number of sampling points, and any statistical approach used to selectthese points . The conceptual model of contaminant migration developed in the CurrentConditions Report should be considered when selecting sampling locations and depths .If some possible sampling points are excluded, explain why . Describe any field

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screening techniques that will be used to identify samples for laboratory analysis .

Include the rationale for use of field screening techniques and c ri teria for sampleselection .

Background Sample s

Background samples should be analyzed for the complete set of parameters foreach medium ; treat sediments , surface soils and subsurface soils as separatemedia. Background samples are collected , numbered, packaged , and sealed inthe same manner as other samples . For long term and/or especially largeprojects , it is recommended that 10% of samples collected be from backgroundlocations .

c . Sample Analysi s

(1) List and discuss all analyses proposed for the project . Include a table thatsummarizes the following information for each analysis to be performed :

(A). Analytical Parameters

(B). Analytical Method Reference Number (from U .S. EPA SW 846)

(C). Sample Preparation and/or Extraction Method Reference Number(from U.S. EPA SW 846)

(D) Detection and Practical Quantitation Limits (Data above the detectionlimit but below the practical quantitation limit must be reported with

the estimated concentration . )

(2). Discuss the rationale for selection of the analytical parameters . The rationale

must relate to site history and the RFI objectives . The achievable detection

limits or quantitation limits stated in the selected me thods must be adequate for

valid comparisons of analytical results against any action levels or standards .

For example, the objective may be to collect ground water data for compa rison

with Maximum Contaminant Levels (MCL's) . If th is were the case , it would

be important to ensure that any ground water test methods had detec tion limits

below the MCL's . Give an explanation if all samples from the same medium

will not be analyzed for the same parameters.

(3) . Provide the name (s) of the laboratory(s) that will be doing the analytical work.Indicate any special certifications or ratings of the laborato ry . Describe thesteps that will be taken to select and pre-qualify analytical laboratories to beused including any previous audits and/or o ther c riteria . If a definite laboratory

has not yet been selected , list at least 3 laboratories that are being consideredfor the analytical work.

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d . Sample Collection Procedure s

(1)



Describe how sampling points will be selected in the field, and how theselocations will be documented and marked for future reference . If a samplinggrid will be used, describe the dimensions and lay out planned for the grid .

Outline sequentially or step-by-step the procedure for collecting a sample foreach medium and each different sampling technique . Include a description ofsampling equipment (including materials of construction), field measurements,sample preservation, housekeeping/cleanliness techniques and well purgingprocedures . The procedure described must ensure that a representative sampleis collected, and that sample handling does not result in cross contamination orunnecessary loss of contaminants . Special care in sample handling for volatileorganic samples must be addressed .

Describe how and when duplicates, blanks, laboratory quality control samplesand background samples will be collected. If samples will be filtered, describefiltration equipment and procedures .

The Owner/Operator or Respondent must include sufficient maps and tables tofully describe the sampling effort. This shall include, at a minimum, a mapshowing all proposed sampling locations and tables that contain the following

information :

Sample Collection Table :

Sampling Location/Interva lAnalytical Parameters (e .g ., volatile organic compounds)Analytical Method NumberMediumPreservation MethodHolding Times (as specified in U .S. EPA SW 846)Containers (quantity, size, type plus footnotes that discuss source and

grade of containers)

(B) . Sample Summary Table :

Sample Description/Area (include QC samples)Analytical Parameter sAnalytical Method NumberPreparation or Extraction Method NumberMediumNumber of Sample SitesNumber of Analyses

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(2) Equipment Decontamination

(3)



Describe the decontamination procedure for all drilling, sampling equipment(including metal sleeves), and field-parameter testing equipment .

The following is a recommended generic procedure for decontamination ofsampling equipment:

o Wash with non-phosphate detergento Tap water rinseo 0.1M nitric acid rinse (when cross contamination from metals is a

concern )o Deionized/distilled water rinseo Pesticide grade solvent rinse (when semivolatiles and non-volatile

organic contamination may be present )

o Deionized/distilled water rinse (twice)o Organic free water rinse (HPLC grade)

The above procedure is not appropriate for every field condition . Clearly

document the decontamination procedures .

Equipment Calibration and Maintenanc e

Logbooks or pre-formatted calibration worksheets should be maintained formajor field instruments, to document servicing , maintenance and instrumentmodification. The calibration, maintenance and operating procedures for allinstruments, equipment and sampling tools must be based upon manufacturer'sinstructions . List all field equipment to be used, specify themaintenance/calibration frequency for each instrument and the calibrationprocedures (referenced in text and included in appendices) .

(4) Sample Packaging and Shipment

(5)

Describe how samples will be packaged and shipped. All applicableDepartment of Transportation regulations must be followed .

Sample Documentation

Discuss the use of all paperwork including field notebooks, record logs,photographs, sample paperwork, and Chain of Custody forms (include a blankcopy in RFI Workplan Appendices) and seals .

Describe how sample containers will be labeled and provide an example labelif available . At a minimum, each sample container label should include :project ID, sample location, analytical parameters, date sampled and anypreservative added to the sample .

HDMSP00118679



A ttachment D - Page 1 4

A bound field log book must be maintained by the sampling team to providea daily record of events . Field log books shall provide the means of recordingall data regarding sample collection . All documentation in field books must bemade in permanent ink. If an error is made, corrections must be made bycrossing a line through the error and entering the correct information. Changesmust be initialed, no entries shall be obliterated or rendered unreadable . Entriesin the log book must include, at a minimum, the following for each day's

sampling :

DateStarting TimeMeteorological ConditionsField Personnel PresentLevel of Personal ProtectionSite IdentificationField Observations/ParametersSample Identification NumbersLocation and Description of Sampling PointsNumber of Samples Collecte dTime of Sample CollectionSignature of Person Making the EntryObservation of Sample Characte ris ticsPhoto LogDeviation s

(6). Disposal of Contaminated Material s

Describe the storage and disposal methods for all contaminated cuttings, welldevelopment and purge water, disposable equipment, decontamination water,and any other contaminated materials . The waste material must be disposed ofin a manner consistent with local, state and federal regulations .

(7) . Standard Operating Procedure s

If Standard Operating Procedures (SOPs) are referenced, the relevant proceduremust be summarized in the RFI Workplan . The SOP must be specific to thetype of tasks proposed and be clearly referenced in the RFI Workplan . TheSOP must also be directly applicable, as written, to the RFI Workplan ;

otherwise, modifications to the SOP must be discussed . Include the full SOPdescription in the RFI Workplan appendix .

e . Well Construction and Aquifer Testing

When new monitoring wells (or piezometers) are proposed, describe the drillingmethod, well design and construction details (e .g ., depth of well, screen length, slot size,

filter pack material, etc .) and well development procedures . Describe the rationale forproposed well locations and selection of all well design and construction criteria (i .e .,provide rationale for selection of slot size and screen length) .

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When aquifer testing is proposed, describe the testing procedures, flow rates, whichwells are involved, test periods, how water levels will be measured, and any otherpertinent information.

6. Quality Assurance and Quality Control

Quality control checks of field and laboratory sampling and analysis serve two purposes : todocument the data quality, and to identify areas of weakness within the measurement processwhich need correction .

Include a summary table of data quality assurance objectives that, at a minimum, lists :

o Analysis Group (e.g., volatile organic compounds)o Mediumo Practical Quantitation Limits (PQL)o Spike Recovery Control Limits (%R)o Duplicate Control Limits +/-(RPD )o QA Sample Frequencyo Data Validation

A reference may note the specific pages from U.S. EPA's SW 846 Guidance Document that listthe test method objectives for precision and accuracy . If the field and laboratory numerical dataquality objectives for precision are the same and presented on a single table, then a statementshould be made to this effect and added as a footnote to the table (e .g ., "These limits apply toboth field and laboratory duplicates") . Include a copy of the analytical laboratory qualityassurance/quality control plan in the appendices of the RFI Workplan and provide the equationsfor calculating precision and accuracy.

a . Field Quality Control Samples

(1) . Field Duplicates

Duplicates are additional samples that must be collected to check for samplingand analytical precision . Duplicate samples for all parameters and media mustbe collected at a frequency of at least one sample per week or 10 percent of allfield samples, whichever is greater .

Duplicates should be collected from points which are known or suspected to becontaminated . For large projects, duplicates should be spread out over theentire site and collected at regular intervals .

Duplicates must be collected, numbered, packaged, and sealed in the samemanner as other samples; duplicate samples are assigned separate samplenumbers and submitted blind to the laboratory .

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(2) . Blank Samples


A ttac hment D - Page 1 6

Blanks are samples that must be collected to check for possible cross-contamination during sample collection and shipment and in the laboratory .Blank samples should be analyzed for all parameters being evaluated . At leastone blank sample per day must be done for all water and air sampling .Additionally, field blanks are required for soil sampling if non-dedicated fieldequipment is being used for sample collection .

Blank samples must be prepared using analytically-certified, organic-free(HPLC-grade) water for organic parameters and metal-free (deionized-distilled)water for inorganic parameters . Blanks must be collected, numbered,packaged, and sealed in the same manner as other samples ; blank samples areassigned separate sample numbers and submitted blind to the laboratory . Thefollowing types of blank samples may be required :

(A). Equipment Blank : An equipment blank must be collected whensampling equipment (e .g ., bladder pump) or a sample collection vessel

(e .g ., a bailer or beaker) is decontaminated and reused in the field . Use

the appropriate "blank" water to rinse the sampling equipment after theequipment has been decontaminated and then collect this water in theproper sample containers.

(B) .

b .

Field Bottle Blank : This type of blank must be collected whensampling equipment decontamination is not necessary . The field bottleblank is obtained by pouring the appropriate "blank" water into acontainer at a sampling point .

aboratorv Ouality Control Sample

Laboratories routinely perform medium spike and laboratory duplicate analysis on fieldsamples as a quality control check . A minimum of one field sample per week or 1 per20 samples (including field blanks and duplicates), whichever is greater, must bedesignated as the "Lab QC Sample" for the medium and laboratory duplicate analysis .

Laboratory quality control samples should be selected from sampling points which aresuspected to be moderately contaminated . Label the bottles and all copies of thepaperwork as "Lab QC Sample"; the laboratory must know that this sample is for theirQC analyses. The first laboratory QC sample of the sampling effort should be part ofthe first or second day's shipment. Subsequent laboratory QC samples should be spreadout over the entire sampling effort .

For water media, 2-3 times the normal sample volume must be collected for thelaboratory QC sample . Additional volume is usually not necessary for soil samples .

HDMSP00118682




c . Performance System Audits by the Owner/Operator or Respondent

This section should describe any internal performance and/or system audit which theOwner/Operator or Respondent will conduct to monitor the capability and performanceof the project. The extent of the audit program should reflect the data quality needs andintended data uses . Audits are used to quickly identify and correct problems thuspreventing and/or reducing costly errors. For example, a performance audit couldinclude monitoring field activities to ensure consistency with the workplan . If the auditstrategy has already been addressed in a QA program plan or standard operatingprocedure, cite the appropriate section which contains the information .

7. Data Management

Describe how investigation data and results will be evaluated, documented and managed,including development of an analytical database . State the criteria that will be used by theproject team to review and determine the quality of data . To document any quality assuranceanomalies, the RFI QC Summary Forms (see Appendix A of this attachment) must be completedby the analytical laboratory and submitted as part of the RFI Report. In addition, provideexamples of any other forms or checklists to be used .

Identify and discuss personnel and data management responsibilities, all field, laboratory andother data to be recorded and maintained, and any statistical methods that may be used tomanipulate the data.

8 . References

Provide a list of references cited in the RFI Workplan .

C. RCRA Facility Investigation Report

I A RFI Report must be prepared that describes the entire site investigation and presents the basic

results . The RFI Report must clearly present an evaluation of investigation results (e.g., all

potential contaminant source areas must be identified, potential migration pathways must bedescribed, and affected media shown, etc .) .

2 . The RFI Report must also include an evaluation of the completeness of the investigation andindicate if additional work is needed . This work could include additional investigation activitiesand/or interim corrective measures to stabilize contaminant release areas and limit contaminantmigration . If additional work is needed, the Owner/Operator or Respondent must submit aPhase 2 RFI Workplan and/or Interim Corrective Measures Workplan must be submitted to theDepartment along with the RFI Report .

3 . At a minimum, the RFI Report must include :

a. A summary of investigation results (include tables that summarize analytical results) .

b . A complete description of the investigation, including all data necessary to understandthe project in its entirety including all investigative methods and procedures .

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Attac hment D - Page 1 8

c. A discussion of key decision points encountered and resolved during the course of theinvestigation .

d. Graphical displays such as isopleths, potentiometric surface maps, cross-sections, plumecontour maps (showing concentration levels, isoconcentration contours), facility maps(showing sample locations, etc .) and regional maps (showing receptor areas, watersupply wells, etc .) that describe report results . Highlight important facts such asgeologic features that may affect contaminant transport.

e . Tables that list all chemistry data for each medium investigated .

f. An analysis of current and existing ground water data to illustrate temporal changes forboth water chemistry and piezometric data (use graphics whenever possible) .

g. A description of potential or known impacts on human and environmental receptors

from releases at the facility . Depending on the site specific circumstances, this analysiscould be based on the results from contaminant dispersion models if field validation isperformed.

h. A discussion of any upset conditions that occurred during any sampling events orlaboratory analysis that may influence the results . The discussion must include anyproblems with the chain of custody procedures , sample holding times , samplepreservation , handling and transport procedures, field equipment calibration andhandling, field blank results that show potential sample contamination and any fieldduplicate results that indicate a potential problem . Summary tables must be providedthat show the upset condition and the samples that could be impacted . The RFI QC

Summary Forms (see Append ix A of this attachment) must be completed by theanalytical laboratory and submi tted as part of the RFI Report .

I Assessment of the entire QA/QC program effectiveness .

J . Data validation results should be documented in the RFI Report .

4 . In addition to the RFI Report, the Department may require the Owner/Operator or Respondentto submit the analytical results (database) on a floppy disk (Department will specify the format) .

All raw laboratory and field data (e .g., analytical reports) must be kept at the facility and bemade available or sent to the Department upon request .

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ATTACHMENT D

APPENDIX A

RCRA INVESTIGATION QC SUMMARY FORMS


A tt achment D - Page 1 9

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HDMSP00118686

REGION 9 RCRA FACILITY INVESTIGATION LABORATORY QC SUMMARY

PART 1 : SUMMARY OF QC LIMITS

LABORATORY:

COMPLETED BY:

ORGANIZATION:

DATE :

SITE/PROJECT :

NUMBER OF SAMPLES :

TYPE OF SAMPLES :

BATCH NUMBER :

Inorganic Analyse s

Method :

QC SUMMARY ELEMENT LABORATORY CONTROL LIMITS FREQUENCY PERFORMED

LABORATORY BLANKS

SAMPLE DUPLICATE %RP D

LABORATORY CONTROL SAMPLE RECOVER Y

STANDARD ADDITION RESULTS*

ICP SERIAL DILUTION %D

SPIKED SAMPLE RECOVERY

INITIAL CALIBRATION VERIFICATION % D

CONTINUING CALIBRATION VERIFICATION %D

INTERFERENCE CHECK SAMPLE RECOVERY

* expressed as the correlation coefficien t

Describe any method modifications or specific problem areas :

1 . Does the laborato ry have access to the project QAPjP? YES/NO

2. Are the Laboratory Control Limits listed above the same as the limits in the QAPjP? YES/NO

3. Were there QC results outside the stated Control Limits or Frequency listed above ? YES/NO

4. If yes to 3, repo rt, in PART 2, all QC results which are outside the stated QC limits or frequency .

5 . Was a Case Narrative, describing any difficulties and deviations submitted? YES/NO

All information reported on this form are certified true and correct .

Name :

Title:

Date:

HDMSP00118687


HDMSP00118688

ANALYSISDATE

SAMPLE ID

REGION 9 RCRA FACILITY INVESTIGATION LABORATORY QC SUMMARYPART 2: SUMMARY OF RESULTS FOR INORGANIC ANALYSI SComplete for all parameters which do not meet QC criteria specified In Part I

LABORATORY:

SUBMITTED BY:

DATE:

SITE/PROJECT:

COMPOUND/

ANALYTE

BLANK RESULT BLANK TYPE QL

METHOD :

NUM OF SAMPLES :

TYPE OF SAMPLES :

BATCH NUMBER:

SAMPLEDUPLICATE

RPD

LCSPERCENT

RECOVERED

STANDARD

ADDITIONR2

CONTINUINGVERIFICATIONPERCENT'

SPIKEDSAMPL ERECOVERY

ICSRECOVERY

AREA


HDMSP00118690

REGION 9 RCRA FACILITY INVESTIGATION LABORATORY QC SUMMARY

PART 1 : SUMMARY OF QC LIMITS

LABORATORY :

COMPLETED BY :

ORGANIZATION :

DATE :

SITE /PROJECT :

NUMBER OF SAMPLES :

TYPE OF SAMPLES :

BATCH NUMBER:

Organic Analyses

Method :

QC SUMMARY ELEMENT LABORATORY CONTROL LIMITS FREQUENCY PERFORMED

LABORATORY BLANKS

INITIAL CALIBRATION - % RSD

CONTINUING CALIBRATION - % D

MATRIX SPIKE/SPIKE DUPLICATE RECOVERY

MATRIX SPIKE/SPIKE DUPLICATE % RPD

SURROGATE PERCENT RECOVERY

INTERNAL STANDARD AREA

SECOND COLUMN CONFIRMATIO N

1 . Method surrogates used :

2 . Internal standards used :

3 . Describe any method modifications or specific problem areas :

1 . Does the laboratory have access to the project QAPjP? YES/NO

2. Are the Laboratory Control Limits listed above the same as the limits in the QAPjP? YES/NO

3. Were there QC results outside the stated Control Limits or Frequency listed above? YES/NO

4. If yes to 3, report, in PART 2, all QC results which are outside the stated QC limits or frequency.

5. Was a Case Narrative, describing any difficulties and deviations submi tted? YES/NO

All information reported on this form are certified true and correct.

Name :

Title :

Date :

HDMSP00118691


HDMSP00118692

ANALYSISDATE

SAMPLE ID

LABORATORY:

SUBMITTED BY:

DATE:

SITE/PROJECT :

COMPOUND/ANALYTE

BLANK RESULT

REGION 9 RCRA FACILITY INVESTIGATION LABORATORY QC SUMMARYPART 2 : SUMMARY OF RESULTS FOR ORGANIC ANALYSISComplete for all parameters which do not meet QC criteria specified in Part 1

BLANK TYPE

METHOD :

NUMBER OF SAMPLES :

TYPE OF SAMPLES :

BATCH NUMBER :

QL MSIMSD% RPD

MSIMSDPERCENTRECOVERY

INITIALCALIBRATIO N

% RPD

CONTINUINGCALIBRATION

%D

SURROGATE

PERCENTRECOVERY

INTERNALSTANDARDAREA


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ATTACHMENT E


Attachmen t E - Page 1

SCOPE OF WORK FOR A CORRECTIVE MEASURES STUDY

PURPOSE

The purpose of the Corrective Measures Study (CMS) is to identify and evaluate potential remedial alternatives

to address contaminant releases from a facility .

SCOPE

A Corrective Measures Study Workplan and a Corrective Measures Study Report are, unless otherwise specifiedby the Department of Toxic Substances Control (Department), required elements of the CMS . The Scope ofWork (SOW) for the Corrective Measures Study Workplan and Report describe what should be included in each

document. The SOWs are intended to be flexible documents capable of addressing both simple and complex site

situations . If the Owner/Operator or Respondent can justify, to the satisfaction of the Department, that sectionsof a plan and/or report are not needed in the given site specific situation, then the Department may waive thatrequirement .

The scope and substance of the CMS should be focused to fit the complexity of the site-specific situation. It isanticipated that Owner/Operator's or Respondent's of sites with complex environmental problems may need toevaluate a number of technologies and corrective measure alternatives . For other facilities, however, it may be

appropriate to evaluate a single corrective measure alternative .

The Department may require the Owner/Operator or Respondent to conduct additional studies beyond what isdiscussed in the SOWS in order to support the CMS . The Owner/Operator or Respondent will furnish all

personnel, materials and services necessary to conduct the additional tasks . The SOW for the Corrective

Measures Study Workplan and Report are specified below :

A. Corrective Measures Study Workpla n

The purpose of the Corrective Measures Study (CMS) Workplan is to specify how the CMS Report will

be prepared . The CMS Workplan shall, at a minimum , include the following elements :

1 . A brief project summary ;

2 . A site-specific description of the overall purpose of the CMS ;

3 . A description of the proposed media cleanup standards and points of compliance that will beused in the corrective measures study report . Include the justification and supporting rationale

for the proposed media cleanup standards and points of compliance . The proposed mediacleanup standards must be based on available promulgated federal and state cleanup standards,risk based analysis, data and information gathered during the corrective action process (e .g .,

from RCRA Facility Investigation, etc .), and/or information from other applicable guidance

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Attachment E - Page 2

documents . The Department may require that the Owner/Operator or Respondent conduct a risk

assessment to gather information for establishing cleanup standards . Based on the CMS Reportand other information including public comments, the Department will establish final cleanupstandards and points of compliance as part of the remedy selection process .

4. A description of the specific corrective measure technologies and/or corrective measurealternatives which will be studied;

5 . A description of the general approach to investigating and evaluating potential corrective

measures;

6. A detailed description of any proposed treatability, pilot, laboratory and/or bench scale studies .

Proposed studies must be further detailed in either the CMS Workplan or in separate workplans .

Submittal times for separate workplans must be included in the CMS Workplan project

schedule;

7. A proposed outline for the CMS Report including a description of how information will bepresented ;

8. A description of overall project management including overall approach, levels of authority(include organization chart), lines of communication, budget and personnel . Include a

description of qualifications for personnel directing or performing the work ; and

9. A project schedule that specifies all significant steps in the process and when key documents

(e .g ., CMS Report) are to be submitted to the Department.

B. Corrective Measures Study Report

The CMS Report shall, at a minimum, include the following elements :

1 . Introduction/Purpose

Describe the purpose and intent of the document .

2. Description of Current Conditions

The Owner/Operator or Respondent shall include a brief discussion of any new information thathas been developed since the RCRA Facility Investigation Report was finalized . This discussionshould concentrate on those issues which could significantly affect the evaluation and selection

of the corrective measure alternative(s) .

3 . Proposed Media Cleanup Standard s

The Owner/Operator or Respondent shall describe and justify the proposed media cleanupstandards and points of compliance .

HDMSP00118696


4. Identification and Screening of Corrective Measure Technologie s

a . Identification



List and briefly describe potentially applicable technologies for each affected media thatmay be used to achieve the media cleanup standards. The Owner/Operator orRespondent should consider including a table that summarizes the availabletechnologies .

The Owner/Operator or Respondent should consider innovative treatment technologies,especially in situations where there are a limited number of applicable correctivemeasure technologies . Innovative technologies are defined as those technologies forsource control other than incineration, solidification/stabilization and pumping withconventional treatment for contaminated ground water . Innovative treatmenttechnologies may require extra initial effort to gather information, analyze options andto adapt the technology to site specific situations. However, in the long run, innovativetreatment technologies could be more cost effective . Treatability studies and on-sitepilot scale studies may be necessary for evaluating innovative treatment technologies .

b . Scieenmg

Technologies must be screened to eliminate those that may prove unfeasible toimplement given the existing set of waste and site-specific conditions . The screening

is accomplished by evaluating technology limitations (e .g., for volume, area,contaminant concentrations, interferences, etc .) and using contaminant and sitecharacterization information from the RCRA Facility Investigation to screen outtechnologies that cannot be fully implemented at the facility . The screening processmust focus on eliminating those technologies which have severe limitations for a givenset of waste and site-specific conditions (e .g ., depth to ground water and aquitards) . Aswith all decisions during the CMS, the screening of technologies must be fullydocumented . This is especially true if the screening step indicates that only onecorrective action technology should proceed to the next step and be evaluated in detail .

List the corrective action technologies selected for further evaluation . Also documentthe reasons for excluding any corrective action technologies . The Owner/Operator orRespondent should consider including a table that summarizes the findings .

5 . Corrective Measure Alternative Development

Assemble the technologies that pass the screening step into specific alternatives that havepotential to meet the corrective action objectives . Options for addressing less complex sitescould be relatively straightforward and may only require evaluation of a single or limitednumber of alternatives .

Each alternative may consist of an individual technology or a combination of technologies usedin sequence (e .g ., treatment train) . Depending on the site specific situation, different alternativesmay be considered for separate areas of the facility . List and briefly describe each correctivemeasure alternative .

HDMSP00118697


6. Evaluation of Corrective Measure Alternatives



The four corrective action standards and five remedy selection decision factors described belowshall be used to evaluate the corrective measure alternatives . All alternatives must meet thecorrective action standards before the remedy selection decision factors are used for furtherevaluation .

The corrective action standards are as follows:

o Be protective of human health and the environment ;

o Attain media cleanup standards ;

o Control the source(s) of releases in order to reduce or eliminate, to the extentpracticable, further releases of hazardous wastes (including hazardous constituents)that may pose a threat to human health and the environment ; and

o Comply with any applicable federal, state, and local standards for management ofwastes .

The remedy selection decision factors are as follows :

o Short- and Long-Term Effectiveness ;

o Reduction of Toxicity, Mobility and/or Volume ;

o Long-Term Reliability ;

o Implementability; and

o Cost.

The corrective action standards and decision factors are described in further detail below .

a . Be Protective of Human Health and the Environment

Describe in detail how each corrective measure alternative is protective of human healthand the environment .

This standard for protection of human health and the environment is a general mandate

of the RCRA statute . The standard requires that remedies include any measures that are

needed to be protective . These measures may or may not be directly related to media

cleanup, source control, or management of wastes . An example would be a requirement

to provide alternative drinking water supplies in order to prevent exposures to a

contaminated drinking water supply .

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b. Attain Media Cleanup Standards

Describe in detail each corrective measure alternatives ability to meet the proposed

media cleanup standards .

c . Control the Sources of Releases

Describe in detail each corrective measure alternatives ability to control the sources ofreleases .

A critical objective of any remedy must be to stop further environmental degradationby controlling or eliminating further releases that may pose a threat to human health andthe environment. Unless source control measures are taken, efforts to cleanup releasesmay be ineffective or, at best, will essentially involve a perpetual cleanup . Therefore,

an effective source control program is essential to ensure the long-term effectivenessand protectiveness of the corrective action effort .

The source control standard is not intended to mandate a specific remedy or class of

remedies . Instead, the Owner/Operator or Respondent is encouraged to examine a wide

range of options . This standard should not be interpreted to preclude the equalconsideration of using other protective remedies to control the source, such as partialwaste removal, capping, slurry walls, in-situ treatment/stabilization and consolidation .

d . Comply With Any Applicable Standards for Management of Waste s

Discuss how any specific waste management activities will be conducted in compliancewith all applicable state or federal regulations (e .g ., CAMU closure requirements, land

disposal restrictions) .

e . Short- and Long-Term Effectivenes s

Each corrective measure alternative must be evaluated with regard to its effectivenessin protecting human health and the environment and meeting the proposed mediacleanup standards . Both short- and long-term components of effectiveness must be

evaluated; short-term referring to the construction and implementation period, and long-term referring to the period after the remedial action is complete . Estimate

approximately how much time it will take to implement each corrective measurealternative, the length of time before initial beneficial results are obtained, and thelength of time required to achieve the proposed media cleanup standards .

The evaluation of short-term effectiveness must include possible threats to the safetyof nearby communities, workers, and environmentally sensitive areas (e .g ., oceans,

wetlands) during construction of the corrective measure alternative. Factors to considerare fire, explosion, exposure to hazardous substances and potential threats associatedwith treatment, excavation, transportation and re-disposal or containment of waste

material . Laboratory and/or field studies are extremely useful in estimating theeffectiveness of corrective measures and should be used whenever possible .

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A tt achment E - Page 6

The evaluation of long-term effectiveness must include possible threats to the safety ofnearby communities workers , and environmentally sensitive areas (e .g., oceans,wetlands) during operation of the corrective measure alternative .

f. Reduction of Toxicity, Mobility and/or Volum e

Each corrective measure alternative must be evaluated for its abili ty to reduce the

toxicity, mobility, and/or volume of the contaminated media . Reduction in toxicity ,

mobility, and/or volume refers to changes in one or more characte ristics of thecontaminated media by the use of corrective measures that decrease the inherent threatsassociated with the media .

g .

Estimate how much the corrective measure alternative will reduce the waste toxicity,

volume and /or mobility (compare initial site conditions to post-corrective measure

conditions) . In general, the Department strongly prefers corrective measures that havea high degree of permanence and reduce the contaminant toxicity, mobility and volume

through treatment .

Long-Term Reliability

Each corrective measure alternative must be evaluated with regards to its long-termreliability . This evaluation includes consideration of operation and maintenancerequirements .

Demonstrated and expected reliability is a way of assessing the risk and effect of

failure. Discuss whether the technology or combination of technologies have been usedeffectively together under analogous site conditions, whether failure of any onetechnology in the alternative has an impact on receptors or contaminant migration, andwhether the alternative would have the flexibility to deal with uncontrollable changes

at the site (e .g ., heavy rain storms, earthquakes, etc) .

Operation and maintenance requirements include the frequency and complexity of

necessary operation and maintenance . Technologies requiring frequent or complexoperation and maintenance activities should be regarded as less reliable thantechnologies requiring little or straightforward operation and maintenance . The

availability of labor and materials to meet these requirements must also be considered .

Most corrective measure technologies, with the exception of destruction, deteriorate

with time. Often, deterioration can be slowed through proper system operation andmaintenance, but the technology eventually may require replacement. Each correctivemeasure alternative shall be evaluated in terms of the projected useful life of the overall

alternative and of its component technologies . Useful life is defined as the length oftime the necessary or required level of effectiveness can be maintained .

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h. Implementability of Corrective Measure Alternatives

The implementability criterion addresses the technical and administrative feasibility ofimplementing a corrective measure alternative and the availability of various servicesand materials needed during implementation . Each corrective measure alternative mustbe evaluated using the following criteria :

(1) . Construction and Operation: Corrective measure alternatives must be feasibleto implement given the existing sqt of waste and site-specific conditions . Thisevaluation was initially done for specific technologies during the screeningprocess and is addressed again in this detailed analysis of the alternative as awhole. It is not intended that the screening process be repeated here, butinstead to highlight key differences and/or changes from the screening analysisthat may result from combining technologies .

(2) . Administrative Feasibility : Discuss the administrative activities needed toimplement the corrective measure alternative (e .g ., permits, public acceptance,

rights of way, off-site approvals, etc .) .

Availability of Services and Materials : Discuss the availability of adequate off-sitetreatment, storage capacity, disposal services, needed technical services and materials,and the availability of prospective technologies for each corrective measure alternative.

Develop a preliminary cost estimate for each corrective measure alternative (and foreach phase or segment of the alternative) . The cost estimate shall include both capital

and operation and maintenance costs . Include a description of how the costs wereestimated and what assumptions were used .

(1) . The preliminary capital cost estimate must consider all key costs including, ata minimum, costs for engineering, mobilization, demobilization, sitepreparation , construction, materials, labor, equipment purchase and rental,sampling, analysis , waste disposal, permitting and health and safety measures .

(2) . The preliminary operation and maintenance cost estimate must consider all keycosts including, at a minimum, costs for labor, training, sampling , analysis,mainten ance materials , uti lities , waste disposal , waste treatment, permitting andhealth and safety measures .

(3) . Calculate the net present value of preliminary capital and operation andmaintenance costs for each corrective measure alternative .

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7. Owner/Operator or Respondent 's Recommended Corrective Measure Alternative

The Owner/Operator or Respondent may recommend a preferred corrective measure alternative

for consideration by the Department. Such a recommendation should include a description and

supporting rationale for the preferred alternative that is consistent with the corrective actionstandards and remedy selection decision factors discussed above .

Based on the CMS Report and other information including public comments, the Departmentwill establish final cleanup standards, points of compliance and will select a final remedy for

the facility .

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ATTACHMENT F

SCOPE OF WORK FOR HEALTH AND SAFETY PLAN


Attachment F - Page 1

The Department of Toxic Substances Control (Department) may require that the Owner/Operator or Respondentprepare a Health and Safety Plan for any corrective action field activity (e .g., soil or ground water sampling,

drilling, construction, operation and maintenance of a treatment system, etc .) . The Health and Safety Plan must,

at a minimum, include the following elements:

Objectives

Describe the goals and objectives of the Health and Safety Plan (must apply to on-site personnel and

visitors) . The Health and Safety Plan must be consistent with the facility Contingency Plan, OSHARegulations, NEOSH Occupational Safety and Health Guidance Manual for Hazardous Waste SiteActivities (1985), all state and local regulations and other Department guidance as provided .

2 . Hazard Assessment

List and describe the potentially hazardous substances that could be encountered by field personnel

during field activities .

Discuss the following :

a. Inhalation Hazardsb. Dermal Exposurec . Ingestion Hazardsd. Physical Hazards

e. Overall Hazard Rating

Include a table that, at a minimum, lists : Known Contaminants, Highest Observed Concentration,

Media, Symptoms/Effects of Acute Exposure .

3 . Personal Protection/Monitoring Equipmen t

For each field task, describe personal protection levels and identify all monitoring equipment .

Describe any action levels and corresponding response actions (i .e., when will levels of safety be

upgraded) .

Describe decontamination procedures and areas .

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4. Site Organization and Emergency Contacts

List and identify all contacts (include phone numbers) . Identify the nearest hospital and provide a

regional map showing the shortest route from the facility to the hospital . Describe site emergency

procedures and any site safety organizations . Include evacuation procedures for neighbors (where

applicable) .

Include a facility Map showing emergency station locations (first aid , eye wash areas , etc .) .

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ATTACHMENT G


Attachment G - Page 1

SCOPE OF WORK FOR A PUBLIC INVOLVEMENT PLAN

The Public Involvement Plan (PIP) must address the public involvement needs for all aspects of corrective actionincluding Interim Measures, RCRA Facility Investigation (RFI), Corrective Measures Study (CMS), andCorrective Measures Implementation (CMI) (if required) . The PIP must be updated as necessary to address

changing public concerns and situations. For additional information, see the U .S . EPA guidance document,

RCRA Public Involvement Manual and the Department of Toxic Substances Control's (Department) guidance

document for community relation program . The PIP shall, unless the Department specifies otherwise, include

the following elements :

1. Introduction

Describe the public involvement goals and objectives for corrective action (e .g ., provide the community

with information updates and respond to inquiries, provide for citizen input and involvement) .

The amount of public involvement work must be consistent with the nature and degree of communityconcerns and with any state or federal requirements . The public involvement program should be flexibleand able to respond to changing public concerns as the corrective action process proceeds from the RFIto the CMS and into CMI.

2. Public Involvement Background

Identify and describe any known issues or community concerns . Indicate if any community or local

officials have been interviewed . Acquire and describe demographic information about the potentially

impacted community .

3. Techniques to Reach Public Involvement Goals

Many community relations techniques may be used to accomplish the objectives . These techniques

include : fact sheets, press releases, informal community workgroup meetings, community advisorycommittees, community meetings, information repositories, mailing lists and public service

announcements . Include a detailed description of how the local community will be contacted and

informed . At a minimum, the following items must be developed as described below :

a. Mailing ist

Establish and maintain a mailing list of all : local officials ; interested, affected and potentially

affected private citizens; residents within a one-half mile radius of the facility; and news media

representatives who should receive fact sheets or other information regarding theinvestigation/mitigation activities at the facility. The mailing list should at least include those

on the mailing list developed for the RCRA permitting process . The mailing list must be

expanded as time goes on to include all interested persons . The mailing list should be submitted

to the Department separately from the PIP .

HDMSP00118705



Attachment G - Page 2

b. Information Repository

Establish and maintain an information repository at a location convenient to public access (e .g .,

local library) . The purpose of the information repository is to allow open and convenient publicaccess to all site-related documents approved by the agency for public disclosure . At a

minimum, the repository for a site must include copies of the following :

o Administrative Order or Consent Decree;o RFI Workplans ;o RFI Reports ;o Interim Measures Workplans ;o Corrective Measures Study Workplans;o Corrective Measures Study Reports;o Public Involvement Plan ;o Statement of Basis for Remedy Selection ; and

other Information :

o Copy of RCRA ;o Copies of press releases and newspaper clippings that refer to the site ;o Brochures, fact sheets, and other information about RCRA program and specific site ;

ando Any other relevant material (e .g ., published studies on the potential risks associated

with specific chemicals that have been found at the site) .

c . Fact Sheet s

The Respondent shall prepare fact sheets to inform the community of key events in the

corrective action process (e .g., interim measures, RFI, RFI findings, etc .) .

It is important that all fact sheets be written clearly so that the public will understand the

information . In general, facility fact sheets should include a description of the overallinvestigation/remedial process from start to finish, a summary of existing contamination at thefacility, a summary of possible impacts on the local community (e .g ., drinking water supplies .

etc .), a summary of any interim measures being taken or planned at the facility, a synopsis ofupcoming tasks, and a brief description about the potential uses, available documents, and the

location of the information repository .

4. Submittal Schedule

The submittal schedule must specify when key documents are to be submitted to the Department andwhen public involvement activities are to be implemented .

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ATTACHMENT H


Attachment H - Page 1

SCOPE OF WORK FOR CORRECTIVE MEASURES IMPLEMENTATIO N

PURPOSE

The purpose of the Corrective Measures Implementation (CMI) program is to design, construct, operate, maintainand monitor the performance of the corrective measure or measures selected by the Department . Corrective

measures are intended to protect human health and/or the environment from hazardous waste releases from the

Facility . The Owner/Operator or Respondent will furnish all personnel, materials and services necessary toimplement the corrective measures program .

SCOPE

The documents required for Corrective Measures Implementation are, unless the Department of Toxic SubstancesControl (Department) specifies otherwise, a Corrective Measures Implementation Workplan, Operation andMaintenance Plan, Draft Plans and Specifications, Final Plans and Specifications, Construction Workplan,Construction Completion Report and Corrective Measure Completion Report . The scope of work (SOW) for

each document is specified below . The SOWs are intended to be flexible documents capable of addressing both

simple and complex site situations . If the Owner/Operator or Respondent can justify, to the satisfaction of theDepartment, that a plan and/or report or portions thereof are not needed in the given site specific situation, thenthe Department may waive that requirement .

The scope and substance of the CMI should be focused to fit the complexity of the site-specific situation . Not

all of the documents included in the CMI SOW may be needed for every facility .

The Department may require the Owner/Operator or Respondent to conduct additional studies beyond what isdiscussed in the SOWs in order to support the CMI program . The Owner/Operator or Respondent will furnish

all personnel, materials and services necessary to conduct the additional tasks .

A. Corrective Measures Implementation Workplan

The Owner/Operator or Respondent shall prepare a CMI Workplan that clearly describes the size, shape,form, and content of the proposed corrective measure, the key components or elements that are needed,describes the designers vision of the corrective measure in the form of conceptual drawings andschematics, and includes procedures and schedules for implementing the corrective measure(s) .

Note that more that one CMI Workplan may be needed in situations where there is a complex site withmultiple technologies being employed at different locations . The CMI Workplan must be approved by

the Department prior to implementation. The CMI Workplan must, at a minimum, include the following

elements :

HDMSP00118707





Describe the purpose of the document and provide a summary description of the project .

2. Media Cleanup Standards

Discuss the media cleanup standards for the facility .

3 . Conceptual Model of Contaminant Migration

It is important to know where the contaminants are and to understand how they are movingbefore an adequate corrective measure can be developed. To address this critical question, theOwner/Operator or Respondent must present a conceptual model of the site and contaminant

migration. The conceptual model consists of a working hypothesis of how the contaminantsmay move from the release source to the receptor population . The conceptual model isdeveloped by looking at the applicable physical parameters (e .g ., water solubility, density,

Henry's Law Constant, etc .) for each contaminant and assessing how the contaminant maymigrate given the existing site conditions (geologic features, depth to ground water, etc .) .

Describe the phase (water, soil, gas, non-aqueous) and location where contaminants are likelyto be found . This analysis may have already been done as part of earlier work (e .g., Current

Conditions Report) . If this is the case, then provide a summary of the conceptual model witha reference to the earlier document. If not, then field validation of the conceptual model is

required .

4. Description of Corrective Measure s

Considering the conceptual model of contaminant migration, qualitatively describe what thecorrective measure is supposed to do and how it will function at the Facility . Discuss the

constructability of the corrective measure and its ability to meet the corrective measureobjectives .

5 . Data Sufficiency

Review existing data needed to support the design effort and establish whether or not there aresufficient accurate data available for this purpose . The Owner/Operator or Respondent mustsummarize the assessment findings and specify any additional data needed to complete thecorrective measure design. The Department may require or the Owner/Operator or Respondentmay propose that sampling and analysis plans and/or treatability study workplans be developedto obtain the additional data . Submittal times for any new sampling and analysis plans and, ortreatability study workplans must be included in the project schedule .


Describe the management approach including levels of authority and responsibility (include

organization chart), lines of communication and the qualifications of key personnel who willdirect the corrective measure design and implementation effort (including contractor personnel) .

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A ttachment H - Page 3

7. Project Schedule

The project schedule must specify all signific ant steps in the process and when all CMIdeliverables (e .g ., Operation and Mainten ance Plan, Corrective Measure Construction Workpl an ,

etc .) are to be submi tted to the Department .

8. Design Cri teria

Specify performance requirements for the overall corrective measure and for each majorcomponent. The Owner/Operator or Respondent must select equipment that meets theperformance requirements .

9. Design Basis

Discuss the process and methods for designing all major components of the corrective measure .

Discuss the significant assumptions made and possible sources of error . Provide justificationfor the assumptions ;

10. Conceptual Process/Schematic Diagrams .

11 . Site plan showing preliminary plant layout and/or treatment area .

12 . Tables listing number and type of major components with approximate dimensions .

13 . Tables giving preliminary mass balances .

14. Site safety and security provisions (e.g ., fences , fire con trol , etc .) .

15 . Waste Management Practices

Desc ribe the wastes generated by the construction of the corrective measure and how they willbe managed . Also discuss drainage and indicate how rainwater runoff will be managed .

16. Required Permit s

List and describe the permits needed to const ruct and operate the corrective measure . Indicateon the project schedule when the permit applications will be submi tted to the applicableagencies and an estimate of the permit issuance date .

17. Long-Lead Procurement Consideration s

The Owner/Operator or Respondent shall prepare a list of any elements or components of thecorrective measure that will require custom fab rication or for some other reason must beconsidered as long-lead procurement items . The list must include the reason why the items areconsidered long-lead items , the length of time necessa ry for procurement, and recognized

sources of such procurement .

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Attachme nt H - Page 4

18. Appendices including :

a. Design Data - Tabulations of significant data and assumptions used in the design effort;

b. Equations - List and describe the source of major equations used in the design process ;

c. Sample Calculations - Present and explain one example calculation for significant orunique design calculations; and

d. Laboratory or Field Test Results .

B. Operation and Maintenance Plan

The Owner/Operator or Respondent shall prepare an Operation and Maintenance (O&M) Plan thatincludes a strategy and procedures for performing operations, long term maintenance, and monitoringof the corrective measure . A draft Operation and Maintenance Plan shall be submitted to the Departmentsimultaneously with the draft Plans and Specifications . A final Operation and Maintenance Plan shallbe submitted to the Department simultaneously with the final Plans and Specifications . The O&M plan

shall, at a minimum, include the following elements :




Describe the management approach including levels of authority and responsibility (includeorganization chart), lines of communication and the qualifications of key personnel who willoperate and maintain the corrective measures (including contractor personnel) ;

3. System Description

Describe the corrective measure and identify significant equipment .

4. Personnel Trainin g

Describe the training process for O&M personnel . The Owner/Operator or Respondent shallprepare, and include in the technical specifications governing treatment systems, contractorrequirements for providing: appropriate service visits by experienced personnel to supervise theinstallation, adjustment, start up and operation of the treatment systems, and training coveringappropriate operational procedures once the start-up has been successfully accomplished .

5. Start-Up Procedures

Describe system start-up procedures including and operational testing .

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6. Operation and Maintenance Procedure s

Describe normal operation and maintenance procedures including :

a. Description of tasks for operation ;

b. Description of tasks for maintenance ;

c. Description of prescribed treatment or operation conditions; and

d. Schedule showing frequency of each O&M task .



7. Replacement schedule for equipment and installed components .

8. Waste Management Practice s

Describe the wastes generated by operation of the corrective measure and how they will be

managed . Also discuss drainage and indicate how rainwater runoff will be managed .


Sampling and monitoring activities may be needed for effective operation and maintenance of

the corrective measure . If sampling activities are necessary, the O&M plan must include acomplete sampling and analysis section which specifies at a minimum the following

information :

a. Desc ription and purpose of monito ring tasks ;b. Data quality objectives ;c . Analytical test methods and detection limits ;d. Name of analytical laboratory;e . Laboratory quality control (include laboratory QA/QC procedures in appendices)


g. Field quality control procedures :o duplicates (10% of all field samples)o blanks (field , equipment, etc . )o equipment calibration and maintenanceo equipment decontaminationo sample containerso sample preservationo sample holding times (must be specified)o sample packaging and shipmen to sample documentation (field notebooks, sample labeling, etc)o chain of custody

h. Criteria for data acceptance and rejection; and

i. Schedule of monito ring frequency .

The Owner/Operator or Respondent shall follow all Department and U .S. EPA guidance for

sampling and analysis . The Department may request that the sampling and analysis section be

a separate document.

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10. Corrective Measure Completion Criteri a

Describe the process and criteria (e .g ., ground water cleanup goal met at all compliance points

for one year) for determining when corrective measures may cease . Also describe the process

and criteria for determining when maintenance and monitoring may cease . Criteria for

corrective measures such as a landfill cap must be carefully crafted to account for the fact thata landfill cap will never actually "cease" but will need to be maintained and monitored for a long

period of time. Satisfaction of the completion criteria will trigger preparation and submittal of

the Corrective Measure Completion Report .

11 . O&M Contingency Procedures :

a. Procedures to address system breakdowns and operational problems including a list ofredundant and emergency back-up equipment and procedures ;

b. Should the corrective measure suffer complete failure, specify alternate procedures toprevent release or threatened releases of hazardous substances, pollutants orcontaminants which may endanger public health and/or the environment or exceed

cleanup standards ;

c. The O&M Plan must specify that, in the event of a major breakdown and/or completefailure of the corrective measure (includes emergency situations), the Owner/Operatoror Respondent will orally notify the Department within 24 hours of the event and willnotify the Department in writing within 72 hours of the event . The written notification

must, at a minimum, specify what happened, what response action is being taken and/oris planned, and any potential impacts on human health and/or the environment; and

d. Procedures to be implemented in the event that the corrective measure is experiencingmajor operational problems, is not performing to design specifications and/or will notachieve the cleanup goals in the expected timeframe . For example, in certain

circumstances both a primary and secondary corrective measure may be selected for the

Facility . If the primary corrective measure were to fail, then the secondary would be

implemented . This section would thus specify that if the primary corrective measurefailed, then design plans would be developed for the secondary measure .

12. Data Management and Documentation Requirements

Describe how analytical data and results will be evaluated , documented and managed , including

development of an analytical database . State the c ri teria that will be used by the project team


13 . The O&M Plan shall specify that the Owner/Operator or Respondent collect and maintain the

following information :


(1) . Work Accomplishments (e .g ., performance levels achieved, hours of treatment

operation, treated and/or excavated volumes, concentration of contaminants intreated and/or excavated volumes, nature and volume of wastes generated, etc .) .

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(2) . Record of significant activities (e .g ., sampling events, inspections, problems

encountered, action taken to rectify problems, etc .) .

b. Monitoring and laboratory data ;

c . Records of operating costs ; and

d. Personnel, maintenance and inspection records .

These data and information should be used to prepare Progress Reports and the CorrectiveMeasure Completion Report .

C. Draft Plans and Specifications

[Note - The Owner/Operator or Respondent may propose or the Department may require thesubmittal of other draft plans and specifications .

1 . The Owner/Operator or Respondent shall prepare draft Plans and Specifications that are based

on the CMI Workplan but include additional design detail . A draft Operation and MaintenancePlan and Construction Workplan shall be submitted to the Department simultaneously with thedraft Plans and Specifications . The draft design package must include drawings andspecifications needed to construct the corrective measure . Depending on the nature of the

corrective measure, many different types of drawings and specifications may be needed. Some

of the elements that may be required are :

General Site PlansProcess Flow DiagramsMechan ical DrawingsElectrical DrawingsStructural DrawingsPiping and Instrumentation DiagramsExcavation and Earthwork DrawingsEquipment ListsSite Preparation and Field Work StandardsPreliminary Specifications for Equipment and Materia l

2. General correlation between drawings and technical specifications is a basic requirement of anyset of working construction plans and specifications . Before submitting the project

specifications to the Department, the Owner/Operator or Respondent shall :

a . Proofread the specifications for accuracy and consistency with the CMI Workplan ; and


HDMSP00118713




D. Final Plans and Specification s

1 The Owner/Operator or Respondent shall prepare final Plans and Specifications that aresufficient to be included in a contract document and be advertised for bid . A final Operation andMaintenance Plan and Construction Workplan shall be submitted to the Departmentsimultaneously with the final Plans and Specifications . The final design package must consist

of the detailed drawings and specifications needed to construct the corrective measure .

Depending on the nature of the corrective measure, many different types of drawings andspecifications may be needed . Some of the elements that may be required are :

General Site PlansProcess Flow DiagramsMechanical DrawingsElectrical DrawingsPiping and Instrumentation DiagramsStructural DrawingsExcavation and Earthwork Drawing sSite Preparation and Field Work StandardsConstruction DrawingsInstallation DrawingsEquipment ListsDetailed Specifications for Equipment and Material

2. General correlation between drawings and technical specifications is a basic requirement of anyset of working construction plans and specifications . Before submitting the final project

specifications to the Department, the Owner/Operator or Respondent shall :

a. Proofread the specifications for accuracy and consistency with the preliminary design ;

and


E. Construction Workplan

The Owner/Operator or Respondent shall prepare a Construction Workplan which documents the overallmanagement strategy, construction quality assurance procedures and schedule for constructing thecorrective measure. A draft Construction Workplan shall be submitted to the Departmentsimultaneously with the draft Plans and Specifications and draft Operation and Maintenance Plan . A

final Construction Workplan shall be submitted to the Department simultaneously with the final Plansand Specifications and final Operation and Maintenance Plan . Upon receipt of written approval from

the Department, the Owner/Operator or Respondent shall commence the construction process andimplement the Construction Workplan in accordance with the schedule and provisions contained therein .

The Construction Workplan must be approved by the Department prior to the start of corrective measure

construction . The Construction Workplan must, at a minimum, include the following elements :

1 . Introduction/Purpose


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Describe the construction management approach including levels of authority and responsibility(include organization chart), lines of communication and the qualifications of key personnel whowill direct the corrective measure construction effort and provide construction qualityassurance/quality control (including contractor personnel) ;

3. Project Schedule

The project schedule must include timing for key elements of the bidding process, timing forinitiation and completion of all major corrective measure construction tasks as specified in theFinal Plans and Specifications, and specify when the Construction Completion Report is to besubmitted to the Department ;

4. Construction Quality Assurance/Quality Control Progra m

The purpose of construction quality assurance is to ensure, with a reasonable degree of certainty,that a completed corrective measure will meet or exceed all design criteria, plans andspecifications . The Construction Workplan must include a complete construction qualityassurance program to be implemented by the Owner/Operator or Respondent .

5. Waste Management Procedures

Describe the wastes generated by construction of the corrective measure and how they will bemanaged.


Sampling and monitoring activities may be needed for construction quality assurance/qualitycontrol and/or other construction related purposes . If sampling activities are necessary, theConstruction Workplan must include a complete sampling and analysis section which specifies

at a minimum the following information :

a. Description and purpose of monitoring tasks ;b. Data quality objectives ;c . Analytical test methods and detection limits ;d. Name of analytical laboratory ;e. Laboratory quality control ( include laboratory QA/QC procedures in appendices)f. Sample collection procedures and equipment ;

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Attachment H - Page 1 0

g. Field quality control procedures :o duplicates (10% of all field samples)o blanks (field, equipment, etc . )o equipment calibration and maintenanceo equipment decontaminationo sample containerso sample preservationo sample holding times (must be specified)o sample packaging and shipmen to sample documentation (field notebooks, sample labeling, etc) ;

o chain of custody

h. Criteria for data acceptance and rejection ; and

i. Schedule of monitoring frequency.

The Owner/Operator or Respondent shall follow all Department and U .S. EPA guidance for

sampling and analysis. The Department may request that the sampling and analysis section be


7 . Construction Contingency Procedures

a. Changes to the design and/or specifications may be needed during construction toaddress unforeseen problems encountered in the field . Procedures to address suchcircumstances, including notification of the Department, must be included in the

Construction Workplan ;

b. The Construction Workplan must specify that, in the event of a construction emergency(e .g ., fire, earthwork failure, etc .), the Owner/Operator or Respondent will orally notifythe Department within 24 hours of the event and will notify the Department in writingwithin 72 hours of the event . The written notification must, at a minimum, specify whathappened, what response action is being taken and/or is planned, and any potentialimpacts on public health and/or the environment ; and

c. Procedures to be implemented if unforeseen events prevent corrective measure

construction . For example, in certain circumstances both a primary and secondarycorrective measure may be selected for the Facility . If the primary corrective measurecould not be constructed, then the secondary would be implemented. This sectionwould thus specify that if the primary corrective measure could not be constructed, thendesign plans would be developed for the secondary measure .

8 . Construction safety procedures should be specified in a separate Health and Safety Plan .

9. Data Management and Documentation Requirement s

Describe how analytical data and results will be evaluated, documented and managed, includingdevelopment of an analytical database . State the criteria that will be used by the project team


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The Construction Workplan shall specify that the Owner/Operator or Respondent collect andmaintain the following information :


(1). Work Accomplishments (e .g., hours of operation, excavated volumes, natureand volume of wastes generated, area of cap completed, length of trench

completed, etc .) .

(2) . Record of significant activities (e .g., sampling events, inspections, problems

encountered, action taken to rectify problems, etc .) .

b. Monitoring and laboratory data;

c . Records of construction costs ; and

d. Personnel , maintenance and inspection records .

This data and information should be used to prepare progress repo rts and the Construction

Completion Report.

10. Cost Estimate/Financial Assurance

If financial assurance for corrective measure construction and operation is required by anenforcement order, facility permit, or through use of Department discretion, the ConstructionWorkplan must include a cost estimate, specify which financial mechanism will be used andwhen the mechanism will be established . The cost estimate shall include both construction and

operation and maintenance costs . An initial cost estimate shall be included in the draftConstruction Workplan and a final cost estimate shall be included in the final Construction

Workplan. The financial assurance mechanism may include a performance or surety bond, atrust fund, a letter of credit, financial test and corporate guarantee equivalent to that in theCalifornia Code of Regulations, Title 22, Section 66264 .143, 66265.143 or any other mechanism

acceptable to the Department.

Financial assurance mechanisms are used to assure the Department that the Owner/Operator orRespondent has adequate financial resources to construct and operate the corrective measure .

F. Construction Completion Report

The Owner/Operator or Respondent shall prepare a Construction Completion Report which documentshow the completed project is consistent with the Final Plans and Specifications . A Construction

Completion Report shall be submitted to the Department when the construction and any operational tests

have been completed. The Construction Completion Report shall, at a minimum, include the following

elements :

1 . Purpose;

2. Synopsis of the corrective measure, design criteria, and certification that the corrective measurewas constructed in accordance with the Final Plans and Specifications ;

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Attachmen t H - Page 1 2

3. Explanation and description of any modifications to the Final Plans and Specifications and whythese were necessary for the project ;

4. Results of any operational testing and/or monitoring, indicating how initial operation of thecorrective measure compares to the design criteria;

5 . Summary of significant activities that occurred during construction . Include a discussion of

problems encountered and how they were addressed;

6. Summary of any inspection findings (include copies of key inspection documents in

appendices) ;

7. As built drawings; and

8. A schedule indicating when any treatment systems will begin full scale operations .

G. Corrective Measure Completion Report

The Owner/Operator or Respondent shall prepare a Corrective Measure Completion Report when theOwner/Operator or Respondent believes that the corrective measure completion criteria have been

satisfied. The purpose of the Corrective Measure Completion Report is to fully document how thecorrective measure completion criteria have been satisfied and to justify why the corrective measure

and/or monitoring may cease. The Corrective Measure Completion Report shall, at a minimum, include

the following elements :

1 . Purpose;

2. Synopsis of the corrective measure ;

3. Corrective Measure Completion Criteri a

Describe the process and criteria for determining when corrective measures, maintenance andmonitoring may cease . Corrective measure completion criteria were given in the final Operationand Maintenance (O&M) Plan ;

4. Demonstration that the completion criteria have been met . Include results of testing and/or

monitoring, indicating how operation of the corrective measure compares to the completion

criteria ;

5 . Summary of work accomplishments (e .g ., performance levels achieved, total hours of treatmentoperation, total treated and/or excavated volumes, nature and volume of wastes generated, etc .) ;

6. Summary of significant activities that occurred during operations . Include a discussion of

problems encountered and how they were addressed ;

7. Summary of inspection findings (include copies of key inspection documents in appendices) ;

and

8. Summary of total operation and maintenance costs .

HDMSP00118718


H. Submittal Summary



The following list provides a summary of when and how key documents should be submi tted to the

Department . The Department may adjust this list to meet site-specific circumstances .

1 . The submittal schedule for the documents listed below should be included in an enforcementorder, permit or otherwise specified by the Department .

a. CMI Workplan

2 . The submittal schedule for the documents listed be low must be specified in the CMI Workpl an .The groupings reflect which documents should be submi tted together .

a. Draft Plans and Specificationsb. Draft Operation and Maintenance Planc. Draft Construction Workpland. Final Plans and Specificationse. Final Operation and Maintenance Planf. Final Construction Workplan

3. The submittal schedule for the document listed below must be specified in the Final

Construction Workplan .

a. Construction Completion Report

4. The submittal schedule for the document listed below is based on when the Owner/Operator or

Respondent believes the completion c riteria have been satisfied .

a. Corrective Measure Completion Report

5 . The submittal schedule for Progress Reports and a Health and Safety Plan shall be specified in

the order or permit .

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ATTACHMENT I

SCOPE OF WORK FOR PROGRESS REPORTS


Attachment I - Page 1

Progress Repo rts shall , at a minimum , include the following information :

1 . A description of significant activities and work completed during the repo rting period ;

2. A summary of any findings made during the reporting period ;

3 . Summaries of all problems or potential problems encountered du ring the repo rting pe riod ;

4. Actions taken and/or planned to rectify problems ;

5. All projected work for the next reporting period;

6. A discussion of any changes in personnel that occurred during the reporting period ;

7 . Summaries of all contacts with representatives of the press , local community or public interest groups

du ring the reporting period;

8. Summary of treatment system effectiveness . Provide a comparison of treatment system operation to

predicted performance levels (applicable only if there is an operating treatment system); and

9 . If requested by the Department of Toxic Substances Control , the results of any sampling tests and/or

other data generated during the reporting period .

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ATTACHMENT J

PERMIT MODIFICATION HISTOR Y

CLASS 2 MODIFICATION -- November 9, 2001Modification Number : MOD-SC3-110901-BPermittee Initiated Modification Request


Attachment J - Page 1

Rerouting Extracted Groundwater between Interim Groundwater Remediation Systems; Reduction of'impling and Inspection Frequency ; SVOC and Perchlorate Sam p

The Class 2 Permit Modification allows the following : :

1) Deactivate the Area I Canyon Air Stripping System and place the system on standby . Reroutethe extracted groundwater from Canyon to the Area I WS-5 UV/Peroxidation system. TheCanyon system can be reactivated if/when additional capacity is desired or needed .

2) Deactivate the Area 1 Road Air Stripping System and place the system on standby . Reroute theextracted groundwater from Area 1 Road to the Area I WS-5/Peroxidation system . TheArea 1 Road system can be reactivated if/when additional capacity is desired or needed .

3) Deactivate the Area II RD-9 UV/Peroxidation System and place the system on standby . Reroutethe extracted groundwater from RD-9 to the Area II Bravo Air Stripping System . The RD-9system can be reactivated if/when additional capacity is desired or needed .

4) Add carbon canisters to the Area II Bravo Air Stripping System for possible capture of semi-volatile organics (SVOCs) . Boeing will test the in fluent to the Bravo system for SVOCsmonthly for 12 consecutive months . At the end of the 12 months , the carbon will be tested foraccumulated semi-volatile organics . If semi-volatile organics are not present at unacceptablelevels, then the canisters may be removed if other evidence does not exist to indicate thatSVOCs may be entering the system

5) Reduce the sampling frequency of the groundwater across all the groundwater remediationfacilities from semi-monthly (twice per month) to monthly .

6) Change the inspection frequency of all groundwater remediation facilities and appurtenancesaccording to the Groundwater Remediation Operation Plan (GROP), generally reduced fromdaily to weekly . DTSC requires Boeing to continue daily visual inspections of the systems to

comply with CCR-22 66264.195(b) and Section VI .F.3 of the post-closure permit.

7) DTSC requires Boeing to begin sampling for perchlorate in the WS-5 UV/P, STL-IV and Deltasystems . Extracted groundwater feeding these three systems were in or near known perchlorate

contamination . DTSC added this requirement to the Class 2 Permit Modification pursuant toCCR-22 Section 66270 .42(b)(6)(A) 1 .

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Attachment J - Page 2

CLASS 1 MODIFICATION -- JUNE 30, 2000Modification Number : MOD-SC3-063000-BPermittee Initiated Modification Reques tName Change Permit C orrections and Permit Updates

In 1995, National Aeronautic & Space Administration (NASA) as the Facility owner and RockwellInternational Corporation as the Facility Operator applied to the California Department of ToxicSubstances Control (Department) for a hazardous waste facility post-closure permit to operate hazardouswaste groundwater extraction, treatment and monitoring systems at the NASA/Rockwell Site, as well

as maintenance of caps at closed surface impoundments . These units are located at the Santa Susana

Field Laboratory, Area II . After issuance of the post-closure permit in 1995, Rockwell InternationalCorporation, Rocketdyne Division was purchased by The Boeing Company to become a wholly owned

subsidiary renamed as Boeing North American . As of January 1, 2000, the name of this Permit wasupdated to The Boeing Company, Rocketdyne Propulsion and Power . Documents indicating the operatorof this facility may be under Rockwell International Corporation, Rocketdyne Division, Boeing North

American Inc., The Boeing Company, or Rocketdyne Propulsion & Power . NASA was and currently

is the owner of the facility . NASA/Boeing is hereinafter referred to as the Owner and/or Operator. This

permit modification changed the name from Rockwell to Boeing throughout the Permit, including the

header .

Shortly after issuance of the Permit on April 7, 1995 (effective May 11, 1995), Rockwell submitted a"Petition for Review" (Appeal) as allowed under the California Code of Regulations, Title 22, Section

66271 .18 . Among the issues was a list of errors made in the Permit. Most of the technical issues were

later resolved and the Appeal was withdrawn by Boeing on February 8, 2000 . This permit modificationcorrects the errors mentioned in Rockwell's Appeal, as well as additional convections, updates andadjustments encountered while reviewing the Permit. These corrections, updates and adjustments didnot altered the operating conditions of the permit .

These modifications -- name change, corrections, updates, adjustments -- met the requirements of a

Class 1 Modification . DTSC deemed these changes to meet the definition of "ministerial" under theCEQA Guidelines 14 CCR Section 15369 and, therefore, exempt under 14 CCR Section 15268 .

HDMSP00118722