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Ank "", PRtI UNITED STATES ENVIRONMENTAL PROTECTION AGENC Y OFFICE OF RADIATION PROGRAMS -LAS VEGAS FACILITY P .O . BOX 9851 7 LAS VEGAS . NEVADA 89193-851 7 (702/798-2476 - FTS 545- 2476 ) NOV 8 198 9 MEMORANDUM SUBJECT : Rocketdyne SSFL Site Sample Analysis Report FROM : Gregg D . Dempsey, Chie f Field Studies Branch 41 I' I TO : Rich Vaille, Assistant Director Toxics and Waste Management Division Attached are the results and my analysis of those results concerning the samples collected at the Rocketdyne Santa Susan a Field Laboratory, July 13, 1989 . There are several outstandin g issues that should be investigated in the future ; those items are discussed in the summary of the report . Acceptance and fundin g of the proposal we first discussed on September 13, 1989, woul d add to the information needed by providing EPA follow up . If youdecide to make a formal press announcement concernin g this report, I would like to be advised and participate, i f possible . A I appreciate the help your staff has given me in preparation of this report . cc : Carmen Santos, Toxics & Waste Management Division Daniel M . Shane, Emergency Response Uni t Michael Bandrowski, Region 9 Robert Dyer (ANR-461) II II BNA00665337 11 II HDMSe00408679
Transcript

Ank

"", PRtI

UNITED STATES ENVIRONMENTAL PROTECTION AGENC YOFFICE OF RADIATION PROGRAMS -LAS VEGAS FACILITY

P .O . BOX 9851 7LAS VEGAS . NEVADA 89193-8517(702/798-2476 - FTS 545- 2476 )

NOV 8 1989

MEMORANDUM

SUBJECT : Rocketdyne SSFL Site Sample Analysis Report

FROM: Gregg D . Dempsey, ChiefField Studies Branch

41 I' I

TO: Rich Vaille, Assistant DirectorToxics and Waste Management Division

Attached are the results and my analysis of those resultsconcerning the samples collected at the Rocketdyne Santa SusanaField Laboratory, July 13, 1989 . There are several outstandingissues that should be investigated in the future ; those items arediscussed in the summary of the report . Acceptance and fundingof the proposal we first discussed on September 13, 1989, woul dadd to the information needed by providing EPA follow up .

If youdecide to make a formal press announcement concerningthis report, I would like to be advised and participate, ifpossible . A

I appreciate the help your staff has given me in preparationof this report .

cc : Carmen Santos, Toxics & Waste Management DivisionDaniel M . Shane, Emergency Response Uni tMichael Bandrowski, Region 9Robert Dyer (ANR-461)

II I IBNA00665337

11 I IHDMSe00408679

I FOREWORD

On July 12 and 13, 1989 , personnel from the U .S .Environmental Protection Agency went to Rockwell International'sSanta Susana Field Laboratory, near Simi Hills , CA to reviewlaboratory operations and collect environmental samples . Thesamples were collected from specific areas onsite where evidenceof radiological or hazardous materials contamination had beenfound .

This report addresses only radiological analyses performedby the contractor used by EPA for this project , Controls forEnvironmental Pollution , Inc. (CEP ) . Samples were collected andshipped with EPA direction by the EPA technical assistance teamcontractor, Ecology and Environment, Inc ,

Delays were encountered during EPA review of CEP databecause it was discovered that CEP had made an error that reducedthe number of radionuclides that were reported . In order toassure validity and quality of data, EPA requested completespectral, radioisotope library, and minimum detectable activitydata on each environmental sample collected . This review processnecessitated that CEP provide additional information and servedto delay this report .

EPA is satisfied with CEP data quality . Reanalysis of anysample is unwarranted .

The transmittal submitted to Region 9 by Gregg Dempsey ofthe Office of Radiation Programs -Las Vegas Facility , dated July28, 1989, should be referenced for further details on the samplelocations discussed in this report .

II . ABBREVIATIONS AND TERMSSeveral abbreviations and terms are used

analyses :n describing the

1 . Gamma Isotopic Analysis - This is an analytical techniquewhich uses a device sensitive to penetrating gamma rays called anintrinsic germanium detector . The sample, be it soil or water, isplaced in a specially calibrated counting container , called acounting geometry , for analysis . Soil samples are often driedprior to placement in the counting geometry . A specializedcomputer is used to record a spectrum of gamma energies which isthem compared with two calibration factors -one is an energycalibration which determines that a "peak" in the spectrum is acertain energy, and the other factor takes into account thecounting geometry and thereby enables the computer to convert aspectrum into a specific analytical result . Results are oftenexpressed in pCi/L (picocuries per liter ) or pCi/g (picocuriesper gram) . The fact that an analysis can be expressed in terms of

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a few picocuries per liter or picocuries per gram often means

in cyclohexane or another low boiling point organic hydrocarbon .

condenses in a special container, where it separatesfro mAs the cyclohexane boils, water is carried in the vapor and

condensed cyclohexane. Simple distillation of the separated wate rusually follows to remove other organic materials which ca ninterfere with analysis .

BNA0066533 9HDMSe0040868 I

detectable activity for nuclides not found in the sample .isotope is sought, a table is often generated to show the minimu mquantifying many isotopes . To aid the analyst if a specifi clisted . The counting system is capable of detecting and

that the sample has only background levels of radioactivity . Inthis report, only gamma emitting isotopes that were detected ar e

2 . Natural Gamma Emitters Just about everything - soil, air ,water, food , and living things (including people) contain som e

thallium, and bismuth . In the report, the specific radium isotoperadioactivity. These are elements like radium , lead , actinium ,origin . Most environmental samples will contain some natura lsmall amount of radioactivity that is natural or terrestrial in

found as thallium-228, abbreviated T1-228, and bismuth is foun dencountered as actinium-228, abbreviated Ac-228 . Thallium is214, they are abbreviated Pb-212 and Pb-214 . Actinium i s

found, radium-226, is abbreviated with the notation Ra-226 . In asimilar fashion , the lead isotopes encountered are lead-212 and

as bismuth-214, or Bi-214 . Perhaps the most widely found isotopeis potassium-40, or K-40 .3 . Cesium-137 - A gamma ray emitting isotope of cesium ,abbreviated Cs-137 . Because of atmospheric testing of nuclea r

only by, man's activities, the concentration varies quite a bittypes of environmental media . Since it has been produced by, an dweapons and other activities, Cs-137 is typically found in mos t

used to analyze samples with weak beta emitters , like tritium .5 . Liquid Scintillation Counting - This is a laboratory techniqu enuclear reactors .by common analytical techniques. Tritium is also be produced inlow in tritium, so low, in fact, that it is difficult to measureamounts . Typically, well water or other protected water is ver yatmosphere and is commonly found in surface water in smal lhydrogen, abbreviated H-3 . It can be produced in the high4 . Tritium - This is the common name for a radioactive isotopefrom place to place .

The sample, after sometimes being purified through azeotropi cdistillation or simple distillation, is placed in a scintillationvial and a counting "cocktail" is added . As a beta particlestrikes a molecule of cocktail, a photon of light proportional t 4the energy of the beta particle is given off . This process is

specific calibration factors .electronically and are converted into activity in pCi/L usingcalled scintillation . These scintillations are counted

6 . Azeotropic Distillation - A method to remove water from soi lor other media . Typically, a soil or other type sample is boiled

III . ENVIRONMENTAL SAMPLE ANALYTICAL RESULT S

Old Sodium Burn Pit

contaminated materials had been dumped at some time in the past .The Old Sodium Burn Pit was an area where radiologically

background levels of radioactivity . The upper pit had moisture ingamma survey instrument indicated what is probably onlyaround the perimeter of the two pits . Walking surveys with aThe area was posted with "Caution - Radioactive Materials" signs

sample was collected in the lower pit for gamma isotopic analysisisotopes and for tritium through azeotropic distillation . Onewas collected in the upper pit to be analyzed forgamma emittingthe soil at its lowest spot . One separate sample plus a duplicate

Results of analyses are below :only since this pit was completely dry .

Upper Pit

Sample Type : Soi lRequested : Gamma Isotopic, Tritium (by Azeotropi c

Gamma Results :K-40 9.76 ± 1 .68 pCi/g

Pb-212 0.54 ± 0 .10Pb-214 0.19 ± 0 .18Ra-226 0 .56 ± 0 .19

Ac-228 0 .79 ± 0 .34Tl-208 0 .81± 0 .22Bi-214 0.28 ± 0 .10

Cs-137 0.90 ± 0 .2 2

Tritium Results :

H-3 0 .59 ± 0 .11 pCi/g soil

II I IIBNA00665340

Distillation)

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Duplicate Sample of Upper Pit

Sample Type : SoilRequested : Gamma Isotopic , Tritium (byAzeotropic Distillation )

Gamma Results :K-4 0

Pb-212Pb-214Ra-226Ac-228T1-228Bi-214Cs-13 7

Tritium Results :

H-3

10 .10 ± 0 .76 pCi/g0 .73 ± 0 .050 .40 ± 0 .100 .38 ± 0 .090 .77 ± 0 .3 30 .76 ± 0 .100 .42 ± 0 .2 80 .94 ± 0 .04

0 .05 ± 0 .02 pCi/g soil

Sample Type : SoilRequested : Gamma Isotopic Only

K-40 28 .81 1 62 pCi/gPb-212 1 .90 0 .11Pb-214 1 .31 0 .27Ra-226 1 .29 0 .1 6Ac-228 1 .62 0 .76

Tl 208 1 .55 0 .19Bi-214 0 .87 ± 0 .62Cs-137 0 .93 ± 0 .06

Analyses from samples collected in the Old Sodium Burn Pitindicatewhat are probably normal or background environmentallevels of radioactivity for this area . The bismuth, lead ,actinium , thallium , radium, and potassium are naturally-occurringradioactive materials . Cesium-137 is found at levels similar towhat would be expected at other locations in the United Statesdue to the atmospheric fallout from nuclear weapons testing . Onemight notice that the Lower Pit gamma levels are roughly twicethe Upper Pit . This is to be expected since the Upper Pit sampleswere counted wet and Lower Pit samples were dry . In addition, thetritium analyses performed on two samples from the upper pit, theoriginal and duplicate , used the azeotropic distillation method .In the case of these two samples , tritium levels are consistentwith what would be present naturally and are thereforeinsignificant.

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Leach Field

The Leach Field is the site of a former sewage leach fieldthat had radioactive materials accidentally dumped into it at onetime . SSFL had initiated a cleanup that removed soil down tobedrock and then restored the land . Walking surveys with a gammasurvey instrument indicated what is probably only backgroundlevels of radioactivity . Results of the analysis of the samplecollected in this area is below :

Sample Type : SoilRequested : Gamma Isotopic Only

K-40 31 .05 ± 1 .27 pCi/gPb-212 1 .88 ± 0 .0 9Pb-214 1 .11 ± 0 .1 8Ra-226 1 .27 ± 0 .1 3Ac-228 2 .15 ± 0 .7 3Tl-208 1 .58 ± 0 .1 7

Bi-214 1 .41 ± 0 .5 3

Cs-137 1 .02 ± 0 .0 5

As in the case of the old Sodium Burn Pit, the isotopelevels encountered are representative of natural background .

Building 59, Former Reactor Building

Building 59 was the location of an old test reactor thatremoved at some time in the past . Walking surveys with a gammainstrument indicated background levels of radiation . Supposedlysand from the area around the building had been contaminated withcobalt-60 and a french drain had been installed in the subfloorto collect infiltrating groundwater . This small quantity of wateris pumped to the surface and analyzed . Two separate samples werecollected for analysis :

Sample Type : WaterRequested : Tritium

H-3 1890 ± 538 pCi/L

Sample Type : WaterRequested : Gamma Isotopic

Reportable Gamma's NOT DETECTED

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There were two findings of interest on these samples . First ,that Co-60 or other gamma emitters were not detected, and second,that tritium was . It is evident that from the drainage system se tup, that Rocketdyne has successfully prevented Co-60 from gettin goutside this building . However, tritium was found in a level farabove what could be called a background amount and might beattributable to this facility . Rocketdyne previously did not tes twater for tritium activity. Although the level encountered isorders of magnitude below what could be described as anenvironmental concern , further study is needed to determine theorigin and spread of tritium on the SSFL site.

Trench Near Building 64, SNM Storage Area

Building 64 was described as a Special Nuclear MaterialsStorage Area . An area around this site was in the process ofbeing cleaned up when samples were collected . This area showedhigher than background gamma readings . Two samples werecollected , an original and a duplicate , and results are below :

Sample Type : SoilRequested : Gamma isotopic only

K-40 29 .33 ± 1 .30 pCi/gPb-212 1 .56 ± 0 .15Pb-214 1 .27 ± 0 .31Ra-226 1 .25 ± 0 .19Ac-228 1 .92 ± 0 .27Tl-208 1.67 ± 0 .26Bi-214 1.49 ± 0 .50Cs-137 331.4 ± 0 . 6

Duplicate of SNM Sample

Sample Type : SoilRequested : Gamma Isotopic Only

K-40 31 . 67 ± 0 .96 pCi/gPb-212 1.57 ± 0 .14Pb-214 1 . 32 ± 0 .32Ra-226 1 .43 ± 0 .18Ac-228 2 .40 ± 1 .41T1-208 1.67 ± 0 .25Bi-214 1.67 ± 0 .25Cs-137 367 .0 ± 0 .6

111HI~HII~Rli II I III I IBNA00665343

HDMSe00408685

In the case of both samples, all gamma emitters arereasonably consistent with background, with the exception o fcesium-137 . This is directly attributable to this spill .Rocketdyne was in the process of cleaning up this area when thissample was collected . Further samples should be collected t overify that this cleanup has been completed .

From the samples collected at SSFL, it is evident that

environmental concern or health risk, the source of this tritiumunaware of the presence of tritium at Building 59 . While not ancontamination has spread offsite . SSFL personnel were apparentlycontamination detected and their location, it is doubtful thatcontamination exists on site property. From the levels of

In the original report documenting the survey and collectionlevels following SSFL cleanup .cesium-137 around Building 64 is brought back to backgroun dneeds to be investigated. It should also be documented that the

that certain types of samples were not collected due to timeof samples on this site, dated July 28, 1989, it was stresse d

be collected and analyzed for tritium . At least a representativefollow-up study, it is first recommended that more water samplescapable of performing those specific analyses required . For aconstraints and difficulty of obtaining a contractor laboratory

vegetation and other media, specifically samples from fera llaboratory must be chosen carefully . It is also recommended tha tdifficult in soil, vegetation, and other media, a contracto remitter whose use is known at the site . Since this analysis i sgroup of samples should be analyzed for strontium-90, a beta

species be collected and analyzed as warranted .The Office of Radiation Programs Las Vegas Facility ha s

presented the Region 9 Office in San Francisco a proposal to

investigation to a close and allay questions that have arisenassist the region and state in their efforts to bring the SSF L

concerning the SSFL environmental program .

BNA00665344HDMSe00408686

1~') SAor

4 Pao

UNITED STATES ENVIRONMENTAL PROTECTION AGENC YOFFICE OF RADIATION PROGRAMS-LAS VEGAS FACILIT Y

P .O BOX 9851 7

Cau 78 1989

MEMORANDUM

LAS VEGAS. NEVADA 89193 .851 7(702/798.2476 - FTS 545-2476 )

SUBJECT : Site Visit to Santa Susana FieldLaboratory Operated by1ckyell/Rocketdyne

FROM : Gre:gg' D . Dempsey, Chief/d Field Studies Branch,ORP

TO : Daniel M . Shane , On-Scene Coordinator,Emergency Response Unit

On July 5, 1989, I reviewed documentation that your office hadassembled on the Rockwell/Rocketdyne Santa Susana Field Laboratory(SSFL) located near Canoga Park , California . The purpose of myconsultation to your office was to help assess the relativemagnitude of health hazards , health risks , past, present, andfuture environmental problems and how Superfund , through youroffice , might address those concerns .

In the two and a half days I spent in your office reviewingthat documentation , I studied previous Rocketdyne EnvironmentalReports, contractor reports on wells and DOE site reviews. As Icommunicated to you during my exit interview , it was my opinionthat Icould not come to a conclusion about conditions relating tothe site without a visit which would include ; discussions withRocketdyne ' s laboratory personnel, my personally makingmeasurements on the various sites identified , and possiblycollecting environmental samples for radiation analysis . Youarranged for your technical assistance team (T .A.T .) contractor,Ecology and Environment, Inc ., to prepare a site safety plan andoutline of measurements and sampling protocol with my inputaccording to your internal procedures . Arrangements were made atthat time and in the following days for a site visit . I also madeassurances to the Ecology and Environment Corporate HealthPhysicist , Jackie Gillings , that I would provide dosimetry and exitpersonnel surveys for T .A .T . personnel working at my direction onthe SSFL site .

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I IH D M Se00408687

On July 12 , 1989, I met with you at SSFL for the purpose o freviewing site and laboratory operations . I spent the afternoonof the 12th reviewing the environmental monitoring laboratoryprocedures and protocols . On July 13, I personally visited thelocations at the SSFL that there were questions about , performedan environmental survey with hand-held radiation survey equipmen tand directed your T .A.T. contractor to collect environmentalsamples in areas where I felt they were warranted . Explaining andcommunicating my concerns and the physics of and analyticalprocesses for environmental radioactivity are difficult to do i na short memorandum. It may be appropriate for me to visit you inthe near future to answer any questions you may have about this ormy future evaluation of the analytical data .

Rocketdyne has had an environmental monitoring program forover 20 years at this site . Many facilities of this type have nothad an environmental program until forced by some legislation orother need . The personnel whom I questioned regarding thelaboratory were most. cooperative . The Manager of Radiation andNuclear Safety, Robert Tuttle, and the Manager of the Radiologica lLaboratory , John Moore , were extremely open and helpful during myreview of their laboratory .

During my review , I questioned Mr . Moore and Mr. Tuttleextensively concerning their procedures and protocols relating tolaboratory equipment and sampling procedures . Laboratory equipmentthat has been provided to this laboratory is state-of-the-art andseems to be in good working order .

However, certain problems exist within this laboratory thatmake me question the validity of some, if not all , of theirenvironmental data . This laboratory apparently has never had athorough review or audit by Rocketdyne or DOE . These reviews areconducted to assess the direction of the environmental program,identify problems in procedures and protocols, and makerecommendations for improvement . Both Mr. Tuttle and Mr. Mooreadmitted thatsuch reviews had not been conducted . It is a commonpractice among good laboratories to conduct peer reviews . Such areview should have revealed many of the problems I will describebelow . DOE apparently conducted a limited audit in February 1989,but the report has not been finalized .

Much of the environmental sampling consists of sampling soilon site and counting it to determine radioactivity . SSFL labpersonnel analyze soil for gross alpha and beta radioactivity .This is not a good method for assessing environmentalradioactivity . In the Rocketdyne procedure , soils are heated in amuffle furnace for 8 hours at 500 °C. Several problems wereidentified : first , this temperature is sufficient to volatilizemost man-made radionuclides of concern , including cesium-137 andstrontium-90 . Second , from the Rocketdyne procedure , soil issieved through a Coors crucible to obtain uniform pa rticle size .

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Mr. Moore told me that approximately 10% of the soil will not pas s

or pebble size is too large . It is common practice that if onethrough the crucible , mainly due to the fact that the sand, clay

machine designed for this purpose . Two grams of soil are used inwishes to obtain a uniform particle size, soil is ground in a

samples are to be counted in a stainless steel planchet , but thecurrent SSFL procedure (Rockwell Document Number N001DWP00000 8

this but it is not adequate . The environmental report states thatvariable results . The procedure attempts to make acorrection fo rbeta radioactivity within the soil, the procedure has highlya planchet for counting. Because of absorption of the alpha and

This also makes a difference in counting and calibration . I askeddated July 9, 1984 ) states that a copper planchet is called for .

know where that documentation might be or if it existed . He alsothat this procedure was worked out a long time ago and he did notvalidity of the procedure used by SSFL . I was told by Mr. Mooredifferent procedure . I asked for documentation or references on theanalysis for americium-241 by alpha spectroscopy , an entirelyshown an EPA procedure that is used to prepare a sample for anMr. Tuttle and Mr. Moore for the basis of the 500 degrees and was

assurance rounds, this procedure for soil is not included . Spikestated that while the SSFL does participate in DOE/EML quality

years experience in preparing and counting samples forprocedure with Dr. Paul Hahn, an EPA radiochemist who has over 3 0procedure to provide internal quality control . I discussed thissamples have apparently never been prepared and run through thi s

radioactivity, and he verified my conclusions . In short, gross

screening method at best and is not an accurate quantitativeconditions present in the environment. This * procedure is aradiation areas on this site, is not a true representation o falpha and beta data on soil , even though it has indicated some

procedure .

Water samples are also collected on the SSFL site. The

for this procedure. Simply, this is a measure of the ability ofproblem . I asked Mr. Moore for a typical beta counting efficiencythat alpha and beta self-absorption is, again, likely to be aalpha and beta radioactivity. I inspected typical samples and foundprocedure is to evaporate the water to dryness and count for gross

analyses as well .similar reasons as stated above , I doubt the validity of thesemassless point source, something a water sample can never be . Fortold that their specifications will only guarantee 45-47% with aminute ) or 50%, I called the manufacturer of this counter and wa stypically 2 dpm/epm (two disintegrations per minute per count perthe counter to detect radiation . Mr . Moore told me that this is

Vegetation samples were collected until 1986 . This wasstopped only two years after an internal SSFL review determinedthat problems existed with alpha and beta counting and changesshould be made . I reviewed the procedure for vegetation counting .It is similar to the soil counting in that the vegetation isessentially ashed before counting and only one gram of ash isanalyzed . The procedure states : "Gently wash the vegetation in the

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container with warm tap water to remove external foreign matter . "

before counting . Or it may be volatilized during ashing at 500°C .instead of being absorbed through the roots, it is washed offcontamination and it settled on the surface of the vegetationIf, past operations at Rocketdyne had produced airborne

Even so, I do not think the reasons were good enough to stopvegetation sampling .

Part of a good environmental program involves checking otherpathways to man through which radionuclides might travel . One ofthese is through meat samples obtained from feral species . Irealize that hunting is probably not permitted in the area aroundSSFL, but I saw abundant evidence of deer (bedding spots ,hoofprints) and squirrel (directly) . These animals are notsampled . A permit to collect these species should be obtained o rSSFL should occasionally examine a road kill . This is not beingdone .

Air samples are collected at SSFL and are examined . I did notsee the procedure for gross alpha and beta counting, but Ithinkit is adequate to measure what it is supposed to from what I sawin the lab . Air flow calibrations on air samplers are necessaryto complete a good program . I did not review these procedures .

Environmental samples are analyzed quarterly for gammaradioactivity . I examined the procedure to calibrate this counterand found that an acceptable , well-documented procedure is used .As an example of this counting, I was given a printout of an airfilter composite that was counting and had finished while I was i nthe lab . I asked how the bag of filters was counted and was toldthat basically the bag was draped over the detector and counted.Later, upon examination of the printout and SSFL procedures, Ifound that the counting time of 10,000 seconds violated the SSFLstated procedure time of "at least 36,000 seconds" . I also foundthat the procedure stated that the sample be counted in a Marinell ibeaker instead of loose in a bag. Statistically, one could defendthe technique and counting time which I was shown , but it violatesSSFL written procedure . One or the other should be changed . TheSSFL lab participates in a quality assurance program and provide sacceptable data for the media tested by gamma spectroscopy .

The lab also provides environmental thermoluminescentdosimetry for the facility and offsite areas. Certain questionablepractices are alluded to in the environmental report . The firstis that data obtained by dosimeters is normalized to a 1000-footaltitude, by using an adjustment factor equal to 15 mR/1000 ft.elevation difference to obtain site averages . I talked to twonationally recognized dosimeter experts and neither had heard ofthis practice . This 15mR/1000 ft. is undocumented by referencein the environmental repo rts . Both experts I spoke to felt thatthis normalization is meaningless . Also , in both the calendar year1987 and the unpublished calendar year 1988 SSFL environmenta lreports, comparisons for the dosimeters placed by the State o fCalifornia and a DOE intercomparison project were "not available"

BNA00665348

for inclusion at the time the report was published . Bill Watsonof the California Department of Health Services , EnvironmentalManagement Branch , assured me that data was available and providedto SSFL. Even if data was unavailable for inclusion in a previousyear's report , it should have be added as an addendum for th efollowing year's report . The unpublished 1988 report does no tcontain information about 1987 omissions . This leads me to thinkthat the SSFL dosimetry program might not compare favorably withthe other groups. Systematic error that might be present indosimetry analyses might make SSFL dosimetry data look comparabl eto itself but still may make these analyses invalid or suspect .A more thorough review needs to be conducted .

Also on July 12, you, your T .A .T . contractor , a representativeof the State of California , Department of Health Services,Charles Myers, and myself met with SSFL staff to determine thecourse of action regarding visiting contaminated or formerlycontaminated locations atSSFL . We reviewed several locations andas a parting question you asked if there were any other locationsthat SSFL personnel could tell us about that were not in theenvironmental reports . The location which was shared with us welater learned was near the Special Nuclear Materials Storage Areaand had involved a liquid spill in the early 1960 ' s . It was agreedthat we would look atthat location along with the others .

On July 13 , I prepared the T.A .T . contractor and myself to goonto these locations . In accordance with arrangements I made withthe Ecology and Environment Corporate Health Physicist , I placed"pocket" or "pencil " type gamma dosimeters on all T .A.T . personnel .I extended that level of protection to both you and myself as well .No dosimeter accrued a measurable exposure during the course of theday although dosimeters worn by Mr. Suter and Mr. Chambers of theT .A .T . did drift off zero in the first two hours after charging .This potential exposure is negligible . I also prepared a LudlumModel 19 Micro-R Gamma Scintillation Counter , an Eberline E-520Geiger-Mueller Counter with both HP-260 and HP-270 Gamma Probes anda Ludlum Model 14C Geiger-Mueller Counter with a "pancake" typegamma probe , all recently calibrated . The Ludlum 14C was used toverify that contamination had not been removed from each location .Each person from EPA and the contractor were surveyed with thisinstrument following exit from each site and none were found to becontaminated. We were escorted through the SSFL site byRandy Ueshiro , at times by Mr . Tuttle , and GaryLavagnino of theDepartment of Energy, ESQA Division .

The first site visited was described as the "Old Sodium BurnPit," an area where radiologically contaminated materials had beendumped at some time in the past . There were " Caution-RadioactiveMaterials" signs around the perimeter of this pit . At one time,a protective dike or berm around this area had washed away andmaterial from this pit was allowed to move off this site in anuncontrolled fashion . The dikes had been rebuilt and a concretegutter had been constructed on the upslope side of the pit to

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prevent rain or wash water from damaging these pits in the future .

for most of the SSFL site was about 20 pR/hr (microroentgens perunremarkable for this area . Background in the immediate area andSurvey instrument readings with the Ludlum Micro-R meter were

the site area for over two hours was about 30 pR/hr in the upperpit near a location SSFL personnel had identified . I also walked

site geology . The highest reading I was able to find in walkingThis 20 pR/hr background at SSFL is normal for that altitude andhour ) . For comparison , in Simi , the background is about 8 pR/hr .

the lack of information concerning the spill at this site, soi laround the area and recorded between 16 and 20 pR/hr. Because o fdown the natural drainage channel about a tenth of a mile and

quality control . In the other pit, a sample was collected to becontractor lab . Duplicate samples were collected at this site fo rwill be analyzed for gamma emitting isotopes and tritium by th eupper pit was collected from mud in this lowest spot. The sampleaccumulate in- these pits would evaporate last . The sample in the

samples were taken in both pits . These pits had areas which wereobviously lowest, that is, where any rainwater that migh t

marked with red surveyor' s flags should additional samples ortubes " were sticking through the surface . Both locations wereanalyzed for gamma emitting isotopes at a spot where old "coolin g

measurements be needed in the future.

SSFL orRoeketdyne has not collected soil or water samples t o

tritium, there was no way in their measurement protocol to detectmaterials accidently dumped at this area and others containedbe analyzed for tritium, a radioactive isotope of hydrogen . if the

tritium will migrate the quickest . The samples collected above mayor waterborne radionuclides are traveling toward the offsite areas ,rapidly distributed in the environment . This means that if groundthrough about two completehalf-lives since this spill and it isnot contain tritium . Tritium , with a 12 year half-life, has goneit . SSFL personnel could not assure me that materials dumped did

verify the absence or presence of tritium .

The second area visited was called the "Leach Field" because

emitting isotopes was collected in this field at a locationoutcroppings in the area . One soil sample to be analyzed for gammaor totally to naturally occurring radioactivity in the roc kpR/hr with about a 30 pR/hr average . This radiation is due largelycontained . Gamma radiation in this area showed between 20 and 3 0a cleanup and it is probable that most of the radioactivity wa smaterials had been accidently dumped into it . SSFL had initiatedit had been used as a sewage leach field at one time . Radioactive

identified by SSFL personnel as having "high beta readings .

The next location surveyed was Building 059, a location wher e

BNA00665350HDMSe00408692

this building and SSFL samples it. Two water samples werearea . There was a pump installed on the French drainage system forthe building itself . Readings were 15-18 µR/hr in the immediateremoved . The site was considered clean, except for some sand ina reactor had once been housed . Contaminated items had been

collected directly from the pump for radioanalysis , one for

specific ' gamma emitting isotopes and one for tritium .

" "Old conservation YardThe was surveyed next . This is an areawhich had recently been cleaned up by SSFL personnel because of"high beta readings ." The area was unremarkable at 13 - 15 µR/hr .No samples were collected from this location for radioanalysis .

We then went to the "New Sodium Burn Pit Area ." It was alsodescribed as having "previously high beta readings" but again wasunremarkable at 18 20 µR/hr. No samples were collected forradioanalysis .

The last site we visited was the site we had beentold aboutonly the day before in the meeting with SSFL officials . It wasdescribed as "Building 064, the Special Nuclear Materials Storag eArea ." An area around this site was in the process of being cleanedup. I spoke to a technician , Mr. Wallace , who was conducting asurvey of this area . He showed me an area of 60 µR/hr. I got ashovel and upon digging at this location in about a foot was ableto increase the surface reading to 200 MR/hr. Mr . Wallace statedthat about 50 pCi/gm of beta radioactivity had been seen at thissite. SSFL personnel were unsure of the nature or time of the spil lat this location but were confident it was in the early 196o's .Apparently SSFL environmental surveys had identified this site .One soil sample to be analyzed for specific gamma emittingradionuclides was collected at this site . A duplicate was alsocollected for quality control of the contractor laboratory .

There are several reasons why I did not collect certai nenvironmental samples . Vegetation both on and off site was ofinterest to me . The majority of grasses in the area were dry an dapparently had been that way for some time . I would have sampledtypical forage on which deer might browse , but SSFL personnelwereunsure about what these might be . Second, it might be necessaryonce the gamma results are obtained from the contractor to go backand get samples analyzed for Sr-89/90 or actually collect newsamples As you are aware, a contract iaDoratory zor Lneradioanalyses was selected without a review of their laboratoryperformance . The Sr-89/90 analysis is extremely difficult andtedious and it will be necessary to verify lab performance beforesamples are analyzed so worthless data is not generated .

It is also important to comment on the audit that wasconducted by the Department of Energy in February 1989 . Thisdocument is in preliminary form and was supplied to me by youroffice to assist in my review . DOE made an attempt to review manyaspects of the SSFL Environmental Program in this document . I echotheir concerns about the well and air sampling at SSFL and offsite .Both of these items, as well as environmental sampling in general,need to be reviewed for adequacy . DOE also identified some problemsin the Radiological Laboratory but did not do an extensive review .The lack of a meteorological tower onsite was also mentioned as aconcern . SSFL uses the EPA code AIRDOS to define dose to affectedoffsite areas . However, the tower information used is from the

11 II I IBNA006653 5 1

HDMSe00408693

Burbank Airport . Better AIRDOS information could be generated wit ha closer-to-site or onsite met tower .

I had nixed feelings about what I saw at SSFL. The staff wasmost cooperative and were very willing to show us everything weneeded to see . They believe they are doing a good job .

The SSFL RadiologicalLab needs updating very badly and thisshould be highly stressed in your report to your superiors . Idon't think analyses of the samples collected by our group onsitewill show a serious radiological health hazard . I will reservecommenting on those analyses until they are complete . However, theSSFL sampling, placement of sample locations, and analyses cannotguarantee that past actions have not caused offsite impacts . Ifthe environmental program stays uncorrected , SSFL cannot guaranteethat unforseenor undetected problems onsite will not impact th eoffsite environment in the future .

It is also clear to me that Rocketdyne does not have a good"handle" on where radiation has been inadvertently or intentionallydumped onsite . Most of the evidence on site spills is incompletelydocumented or anecdotal ., DOE or Rocketdyne should conduct acomplete survey of the site , specifically looking for other spillareas . A good start and a valuable aid for these surveys would becontracting with the EG&G Energy Measurements group in Las Vegas,Nevada for a flyover with their gamma radiation counting equipment .This group is already under contract to DOE/NVO . This survey wouldrapidly identify potential areas of concern . Site aerial readingsare plotted on a site photo in this survey .

I will be in touch with you in the near future to discuss theresults of the samples collected at SSFL . If there are anyquestions about the material above, I will be happy to discuss itwith you .

CC : Mike Bandrowski , Region 9Robert S . Dyer (ANR-461)

I I IBNA00665352

HDMSe00408694

ecology and environment, inc.1 6 0 SPEAR STREET SAN F NR, A CISCO , CALIFORNIA 94105 , TEL . 415 /777-2811

International Specialists in the Environment

SUMMARY REVIEW OPPRELIMINARY ASSESSMENTS/SITE INSPECTIONS OF

ROCKWELL INTERNATIONAL SANTA SUSANA FIELD LABORATORY

SUBMITTED TO :

PREPARED BY:

THROUGH:

DATE:

SITE:

Carolyn Douglas , EPA T-4-7

Karen Johnson , Ecology and Environmen 7 Inc .

Patty Cook, Ecology and Environment, Inc .

July 19, 198 9

Rockwell International Santa Susana Field LabSimi Hills, Ventura County, Californi a

EPA ID# :

TTDI :

PROGRAM ACCOUNT# :

CAD093365435, CA1800090010,

F9-8907-015

FCAZI56SAA

FIT REVIEW/CONCURRENCE:

cc : FIT MasterFile

Tom Mix, EPA -T-4-7Rich Vaille, EPA

INTRODUCTION

CA389009000 1

Previous efforts to assess the hazardous waste disposal activities at theRockwell International Santa Susan Field Laboratory (SSFL) have dealtwith particular areas within the facility, but have never addressed theentire facility as a whole . Some areas within the SSFL belong to thefederal government , while others are owned and operated by RockwellInternational , a private corporation .

In order to determine whether the facility as a whole may be eligible forthe Saperfund National Priorities List, the U .S . Environmental ProtectionAgency (EPA) requested Ecology and Environment , Inca's Fiel dInvestigation Team (FIT) to conduct a review of the availabledocumentation pertaining to hazardous waste activities at the SSFL andevaluate the facility with respect to the Hazard Ranking System set up inthe Comprehensive Environmental Resource Conservation, Liability, andCompensation Act (CERCLA ) of 1980 . EPA's strategy for determination of

further action under CERCLA is based solely on a site ' s potential t o

1

kj/kj/rockwell/sum

recycled paper

11 II 1 1BNA00665353

I IHDMSe00408695

achieve a Hazard Ranking System (HRS) score high enough fo rqualify for inclusion on the National Priorities List (NPL) .

the site t o

In order to present an overview of the entire facility, several reportshave been reviewed and summarized . The primary sources of informatio ntor thisreview included :

0

Groundwater Resources Consultants , Inc ., dated March 3, 1988 .Area II, Rockwell International -Rocketdyne Division, b yPreliminary Assessment Report, Santa Susana Field Laboratory

Rockwell International-Rocketdyne Division , by GroundwaterHydrogeologic Assessment Report , Santa Susana Field Laboratory

Resources Consultants , Inc., dated November 30, 1987 .

Preliminary Assessment of the Former Sodium Burn Pit, RockwellInternational Santa Susana Field Lab, by Karen Johnson, Ecologyand Environment, Inc .

Johnson , Ecology and Environment, Inc .Area, Rockwell International Santa Susana Field Lab, by Kare nPreliminary Assessment of the Construction Materials Landfill

Susana Field Laboratory , Simi Hills, California, by Adam'S .

Preliminary Assessment Summary of Rockwell/Rocketdyne Sant a

. ICF Technology . Inc .` for EPA-FIT, dated December 14, 1987 .Ng ,

9CERCLA Program Phase II Site Characterization, dated May 2Rockwell International-Energy Technology Engineering Center ,

1987 .

Rockwell International -Energy Technology Engineering Center,CERCLA- Program *Phase 3 - Installation Assessment for DOEFacilities at SSFL, dated April 25, 1986 .

Environmental Survey Prelimina ry Report, DOE Activities at SantaSusana Field Laboratories , Ventura County , California , by U .S .Department of Energy , Office of Environmental Audit, datedFebruary 1989 .

SITE DESCRIPTION

The Rockwell International Santa Susana Field Laboratory (SSFL) islocated in the Simi Hills in the southeastern portion of Ventura County,adjacent to the Los Angeles County line (see Figure 1) . It lies on anelevated plateau in rugged terrain south of Simi Valley, California andwest of Chatsworth, California on Woolsey Canyon Road, Simi Hills,California.

The SSFL is divided into four areas designated I, II, III, and IV . Areas

I and III ( CAD093365435 ) are owned and operated by the Rocketdyne

Division of Rockwell International . Area IV is also owned by Rockwell,but is operated under the Atomics International or Energy Systems Group .

kj/kj/ rockwell/sum

11 IIBNA006653 54

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ecology an envkon nent, c .

A 90.26-acre parcel of land in Area IV has been optioned by theDepartment of Energy (DOE), and is the site of DOE's Energy TechnologyEngineering Center (ETEC) (CA3890090001) . Area II (CA1800090010) i sowned by the National Aeronautics and Space Administration (NASA), andhas been operated by Rockwell/Rocketdyne as a product testing facilitysince 1949 ( see Figure 2) .

The operations at the SSFL consist of the research , development, andtesting of rocket engines, lasers , nuclear reactors , coal gasificationand liquifaction processes , and other related technologies . Chemicalsused in these operations include organic solvents , chieflytrichloroethylene (TCE), hydrazine fuels, oxidizers , kerosene-basedfuels, and liquid metals such as sodium and potassium . In addition,asbestos, polychlorinated biphenyls (PCBs), and hydraulic oil have beenused throughout the site . Because of the development and testing ofnuclear reactors in Area IV , radioactive wastes have also been storedon-site.

The largest quantity of wastes generated came from the use of organicsolvents at the large rocket test stands in Areas I and II . Before 1976,TCE was the primary solvent used to wash down equipment and flush engin ethrust chambers . A TCE reclamation system was established around 1960 ,but was, reportedly unreliable (1 )

Rockwell/Rocketdyne manages a contamination control system (also referre dto as the water reclamation system) at the SSFL that consists of 28surface impoundments' designed to collect cooling and rinse water , ' stormrunoff, and accidental spills from Areas 1, 11, and III (see Figure 3) .Some activities in Area IV also discharge to the system through unlinedditches, but no surface impoundments were located in that Area IV .

Eleven of the ponds were designated as hazardous waste facilities underthe Resource Conservation and Recovery . Act . (RCRA) of 197-6 . (2) . ., .Two ofthe ponds, the Engineering Chemistry Lab (ECL) pond in Area III and th eLaser Engineering Test Facility (LETF) pond in Area I, were reportedl ythe only impoundments that were part of the water reclamation system tha tstored and treated hazardous wastes on a routine basis . The ponds wereexcavated in 1984 and the material was sent to a Class I disposalfacility (1) . The constituents of the soil material was not determine dfor this report . The use of the other nine impoundments was discontinuedin 1985 and they are undergoing RCRA closure .

In addition to the surface impoundments , there are at least 17 knownareas where waste materials were stored or treated . Many of these areaslacked the proper containment facilities to prevent a release o fcontaminants to the environment in the event of improper storage o rspills . A summary of all of these potential waste management facilitiesincluding their reported use and wastes handled is provided in Table I .

The SSFL is a large facility and has conducted many different operationsover the years . It was not within the scope of this assessment toidentify the potential existence of additional waste management areasthat have not been addressed by previous investigations .

4

kj/kj/rockwell/sum

l I I IBNA0066535 6

HDMSe00408698

W

SOURCE : Rockwell Internatlonal. CERCLA Phase I-Inslanation Assessment for DOE IU las at F AprN 25, t

TO SUSANA KNOLL S

VENtURA C OS.60V' TACO

_

(NASA)

11 .7AC 10 VAI I I Y CIN(A l Nl V n

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I

2".9 AC AREAA

AREA 11 I PRIVATE 1 BLACK CANYON ROA D

AREA IV I' I0

IN VENTURA COUNTY 166M.WOOLSEY CANYON ROAT)1 (

. . i< IN LA COUNTY: I i sIN VENTURA COUNTY 0 3 4

PUB LI C $TREE T

ROCKWELL 66FFFR 20NE ® WOOLSEY CANYO N1162. 6 AC ROAD IIN LA CITYI 0 43

sUIDIVISIONS

OWNEII JURISDICTION ACRES O ►TIO NROCKWELL Al - 2 . - « 9026nOCKE TOYNE 711 . 1

I IOC KwEll10 UMIll 1142. 6 2217 . 3Ii11VtNNMINI NASA ITORMEAAlpSUI 469 5

NASA ( FORMER APP $41 Ili F Is,

TOTAL ACRES 2661.5

ecology and environment . Inc .

Figure 2 AREAS WITHIN SANTA SUSANA FIELD LAB

SOURCE: Hargis and Associates, 1985

I. CE . AMA

C69A REA HCT It29-

IOM hAMt

Figure 3 CONTAMINATION CONTROL SYSTEMROCKWELL INTERNATIONA LSANTA SUSANA FIELD LAB

sn

R-3O AREA!

24 99NnU Ot tA

uRvtttIDEA

TABLE . 1

WASTE MANAGEMENT FACILITIESSanta Susana Field Laboratory

Rockwell International Corporation .- . Rocketdyne Divisio nSimi Hills, Ventura County, Californi a

FACILITY USE WASTE

AREA I

APTF Ponds2 Cooling water . catchment Kerosene-based fuels (skimmed off )#1 and Emergency Spill Nitric Acid (D002 ) (neutralized )#2 Containment :and Treatment Monomethylhydrazine (P068 ) ( treated wit h

hydrogen peroxide , if spilled )

LETF Pond' Waste Treatment and Storage Corrosive liquids - NaOH , NaF (Held fodisposal in Class I landfill )

Burn Pit Area' Waste Treatment and Storage Solid Propellants and Explosives (burnedand disposed of in Class I or regula rlandfill depending on constitnent s

Potassium Loop Inactive Testing Facility Metallic potassium meal (D003 ) - awaiti nclosure

Perimeter Discharge Pond Water Containment and Storage . Kerosene-base Fuel , Nitric Acid ,Monomethyl Hydrazine , Trichloroethene ,1,1,1-Trichloroethane , Freon, CorrosiveLiquids

R-1 Reservoir Water Storage Kerosene-base Fuel , Nitric Acid ,Monomethyl Hydrazine, Trichloroethene ,1,1,1-Trichloroethane , Freon, CorrosiveLiquid s

CT 1 Active RCRA Facility2 2 Undergoing RCRA Closure -Not Used Since November 198 5

dl eW 3 Und r RCRAA ready Closev_AU)

(D 14-d a/kjlrockvellltb l00007A0

FACILITY USE WASTE

AREA I (con, 0 ,

Bowl Skim Ponds Catchment for Bowl Test Area Kerosene-base Fuel, Trichloroethene ,Emergency Spill Contaiment 1,1,1-Trichloroethane, Freon

Bowl Retention Pond5 Catchment for Bowl Test Area Kerosene -base Fuel, Trichloroethene ,Emergency Spill Contaiment ' 1,1,1-Trichloroethane, Freon

Canyon Retention Ponds Catchment for Bowl Test Area Kerosene-base Fuel , Trichioroethene ,Emergency Spill Contaiment 1,1,1-Trichloroethane, Freon

Canyon Skim Pond5 Catchment for Bowl Test Area Kerosene-base Fuel , Trichloroethene ,Emergency Spill Contaiment 1,1,1-Trichloroethane, Freon

CTL III Skim Pon d#1#2

AREA II

SPA Ponds'# 1#2

Container Rinsate andEmergency SpillContainment and Treatment

1,2-Dimethyl hydrazine (U099), monomethyhydrazine ( P068), nitrogen tetroxide,hydrogen peroxide (hydrazines treatedwith hydrogen peroxide in event of spil l

MMH Pond`(aka : PLF impoundment

Spill Containment and

Treatment

2 Undergoing RCRA Closure--Not used since 19855 Inactive

--- No information availabl e

a/kj/rockvell/tbl

Monomethyl hydrazine nitrogen tetroxide,(hydrogen peroxide used if spilled)

FACILITY USE WASTE

AREA II (con't )

Delta Impoundment2 Rinsate and 'Spill Inhibited Red Fuming Nitric Aci dContainment (oxidizer), cryogenic fluorine an d

hydrogen , kerosene -based fuels ,hydrazines , chlorinated and flourinatedsolvents .

ABSP Pond` Cooling water -;catchment Kerosene-based fuels ( skimmed off) ,and Spill Containment chlorinated solvents , hydraulic oil .

Alfa Tank4 Storage Tank Stores spent TCE until removed forreclamation

PCB Storage Areal Drum Storage PCBs and Hazardous Wastes

Hazardous Waste Storage' Drum storage area Solvents, alcohol , kerosene, oil, paintthinner, turco descalent , and lab packs

Bravo Skim Pond Catchment for Bravo TTest .Area Kerosene-base Fuel , Trichloroethene ,Emergency Spill Contaiment 1,1,1-Trichloroethene, Freon

Alfa Skim Pond Catchment for Alfa Test Area Kerosene-base Fuel , Trichloroethene ,Emergency Spill Contaiment 1,1,1-Trichloroethene , Freon

Alfa Retention Pond Catchment for Alfa Test Area Kerosene-base Fuel , Trichloroethene ,Emergency Spill Contaiment 1,1,1-Trichioroethane , Freon

Coca Skim Pond' Catchment for Coca Test Area Kerosene -base Fuel , Trichloroethene ,Emergency Spill Contaimeht 1,1,1-Trichloroethene , Freon

1 Active RCRA Facility2 Undergoing RCRA Closure-Not Used since 19854 Generator Only5 Inactive

a/kj/rockvell/tb l

w

FACILITY USE

AREA 11 ( con't)

WASTE

R-2A Discharge Pond Water Containment and Storage Kerosene-base Fuel , Isopropyl Alcohol,Trichloroethene , 1,1,1-Trichioroethane,Freon , Hydrogen Peroxide, MonomethylHydrazine

Cd

R-2B Discharge Pond Water Containment and Storage Kerosene- base Fuel , Isopropyl Alcohol,Trichloroethene, 1,1,1-Trichloroethane,Freon, Hydrogen Peroxide, MonomethylHydrazine

CTL II Retension Pond

Flowmeter Catch Pond

AREA III

ECL Pond`' Treatment and Storage Sodium hydroxide , methylene chloride,dimethyl sulfoxide , sodium azide, andother chemicals depending on currentcontract .

STL-IV Ponds' Cooling water catchment Monomethyl hydrazine, nitrogen tetroxide#1 and spill containment chlorinated and flourinated solvent s#2

Compound A Wastewater catchment Hydrofluoric aci d

Silvernale Reservoir Water Storage Kerosene-base Fuel , Nitric Acid,Trichloroethene , 1,1,1-Trichloroethane,Freon, Hydrogen Peroxide , MonomethylHydrazine

Active RCRA FacilityUndergoing RCRA Closure-Not Used Since November 1985Already Closed Under RCR A- No information availabl e

a/kj/rockvell/tbl

CZ

001

PACILITY

AREA IV

Sodium Burn Pi't(B886)

SRE Watershed

SNAP Reactor Bldg.(B059 )

Old Landfil l

RMDFLeachfield

Old ConservationYard

ESADA ChemicalStorage Yar d

Building 100 Trench

S .E . DrumStorage Yard

New ConservationYard

Sodium Burn'Facility (5133 )

Action RCRA Facility

/kj/rockwell/tbl

USE

Treatment and Disposal

Runoff from SRE buildings

Groundwater contaminationfrom Bldg . 059

Drum Storage or disposa l

Accidental release ofcontaminated wastewater

Drum and equipment storage

Drum Storage

Burning and Disposal

Drum Storage

Drum and equipment storage

Equipment Storage

WASTE

Metallic sodium , NaK, kerosene , organicsolvents, diesel fuel, oil and gease,PCBs, PCTs , terphenyls and biphenyls,cesium-137

Asbestos

Cobalt-60, chlorinated solvents

Oil and grease , alcohols , sodium andsodium reaction products , phosphoricacid, and asbestos

Strontium -90 and Yttrium-90

Unknown

Alcohols and unknown others .

Construction debris and possiblyhazardous wastes

Unknown

Unknown

Metallic sodium - high pH soils

3 . HRS FACTORS

3 .1 SRS Summary

The Hazard Ranking System (HRS) was designed to evaluate the relativepotential impact of uncontrolled hazardous substance releases to humanhealth or the environment . The HRS models the potential contaminationmigration pathways of groundwater , surface water, and air . Within eachpathway , the likelihood of release , waste type and quantity , and targe tpopulations are evaluated . Changes in the SRS model have been propose das a result of the Superfund Amendments and Reauthorization Act (SARA )that will address an on-site pathway and extend some of the target radii .This site was primarily evaluated under the original HRS model ; however ,proposed HRS changes were addressed for their effect on this site' seligibility for NPL listing. .

As stated earlier, EPA determines whether further action under CERCLA iswarranted based solely on a site ' s potential to achieve an HRS score highenough to qualify for inclusion on the National Priorities List (NPL) .Because a site ' s HRS score is intended to reflect the magnitude ofpotential risk to human health or the environment , a low potential targetpopulation influences the site's potential to be eligible for NPLlisting .

This is the case .with the SSFL . -Groundwater is not used as a primarysource of drinking water in the area . Most of-the population within athree-mile radius of 'the facility uses water delivered by th eMetropolitan Water District of Southern California from distant surfacewater sources . The local stream channels carry only intermittent surfacewater that is not used for any purpose . Although there are bothconfirmed and potential contaminant releases to the groundwater andsurface water from the SSFL , as this report describes , the site does not-appear . to be eligible foreinclusion on the-NPL due to-the-small potentialdrinking water target population .

3.2 Observed Release

To document an observed release of contaminants to one of the threemigration pathways (groundwater , for instance ), there must be directanalytical data showing that the groundwater in the vicinity of the

facility contains contaminants at a significantly higher concentrationthan background levels . In addition , the contaminant must be attributedto the facility.

There has been an observed release of hazardous substances to groundwater

from the activities at the SSFL . Rockwell began an intensive groundwater

investigation at the SSFL in early 1984 . This investigation showed thatgroundwater beneath the facility was contaminated with organic solvents,predominantlyTCE . TCE has been found in samples from observation wellsaround the facility inconcentrations as high as 5,200 micrograms perliter ( ug/1) (4 ) . Although other volatile organic compounds (VOCs) suchas trans-1 , Z-dichloro- ethylene , vinyl chloride , Freon-113, toluene,

isopropanol , and benzene have also been detected , TCE is considered theprimary contaminant from the site. The VOCs observed in the groundwater

12

kj/kj /rockwell/sum

1 1BNA00665364

I IHDMSe00408706

samples came primarily from the use of solvents at the rocket engine tes tstands . Other suspected sources are the pavement washdown areas ,laboratory solvent use areas , and impoundments that received spills o rdischarges (2) . The groundwater beneath the facility forms a regiona lgroundwater high, so there are no upgradient sources of contaminants an dbackground levels should be zero .

Although VOC contamination has been documented beneath the facility ,existing off-site data does not show that any contamination has migratedoff-site . This may be due to the complex nature of the groundwate rsystem (see 3 . 4 Groundwater ) and the sparce off-site monitoring data .There is believed to be a large cone of depression in the groundwaterbeneath the facility resulting from .long-time withdrawals of groundwaterfor industrial uses that may have prevented the off-site migration ofgroundwater contaminants (4) .

There are two areas of suspected radioactive contamination of groundwaterin Area IV . The subterranean levels of Building 059 formerly housed theSpace Nuclear Auxiliary Power (SNAP) prototype reactor and contain sandand equipment contaminated with cobalt -60 . Groundwater has seeped intothe building and has become radioactively contaminated . A program ofcontrolled groundwater pumpage has lowered the groundwater level beneaththe building . and kept .a water level depression in .the area to prevent themigration `of contaninated--* 'vate'r away from the -building . There has-been.insufficient monitoring -around the area to determine the extent of . .groundwater contamination and whether . any radioactive contamination hasmigrated from the building area (5) .

In the 1970s, there was an accidental spill of radioactively-contaminatedwater .from a tank in the Radioactive Materials Disposal Facility (RMDF)area : while investigating the results of this spill radiation was foundin the soil beneath the RMDF leachfield . It is believed that in theearly 1960s , water containing strontium-90 and yttrium-90 was .,,accidentally released to the sanitary sewer leachfield for the RMDF .After finding this contamination , the soil in the area was excavated andthe joints and fractures in the Chatsworth Formation were sealed withasphalt . However, there is still a high probability that radioactivecontaminants have been released to the groundwater beneath this area .This potential observed release has not been fully investigated (5) .

There has been no observed release of contaminants to surface waterdocumented from the site. Surface runoff contaminated with metals, VOCs,and asbestos has been detected , but there has not been sufficientmonitoring to determine if this contamination has reached any surfacewater bodies . Therefore, an an observed release to surface water has notbeen established ( See Section 3 .5 Surface Water) .

3 .3 Vaste Type and Quantity

Since 1949 , the SSFLhas been the site of a wide variety of research,development , and testing activities . Chemicals used in these operationsinclude organic solvents , chiefly TCE, hydrazine fuels, oxidizers,kerosene-based fuels , and liquid metals, such as sodium and potassium .

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In addition , asbestos , PCBs, and hydraulic oil have been used throughou tthe site. Because of the development and testing of nuclear reactors i nArea IV, radioactive wastes have also been stored on-site .

TheSSFL contamination control system (also referred to as the wate rreclamation system ) consisted of 28 surface impoundments designed t ocollect cooling and rinse water, storm runoff, and accidental spills fromthroughout Areas I, II, and III . Some actiyities in Area IV als odischarge to the system through unlined ditches , but no surfaceimpoundments were located in Area IV .

The Hydrogeologic Assessment Report prepared by Groundwater ResourcesConsultants , Inc . in 1988 in response to the Toxic Pits Cleanup Act of1984 gives a detailed estimate of the types and quantities of wastesreceived by nine of the surface impoundments located in Areas I II anIII . These impoundments were used as cooling water, rinse water, oraccidental spill containment facilities . The wastes collected in theseimpoundments primarily consisted of organic solvents, hydrazine fuels ,oxidizers, and kerosene based fuels . The report estimated tha tapproximately 870 tons of wastes have been deposited in thes eimpoundments over the last 25 years . Many of the impoundments wer eunlined . The concrete lining in the other ponds was not adequatel y'maintained and inspection reports shovd that most of them containedcracks . - No leachate recovery ' systems were installed at the* impoundment s(Z)

The Laser Engineering Test Facility (LETF) pond in Area I and theEngineering Chemistry Laboratory (ECL) pond in Area III were reported tobe the only surface impoundments that stored and treated hazardous wasteson a routine basis within Areas I, II, or III (1) . The LETF pond heldcorrosive liquids, such as sodium hydroxide and sodium fluoride, beforeremoval to a Class I disposal facility . The ECL pond received a widevariety of wastes- depending on-their contracts . Records show that these-wastes included sodium hydroxide, methylene chloride, dimethyl sulfoxide,and sodium azide . Both of these ponds were excavated in 1984 and-thematerials transported to an off-site Class I disposal facility (1) .

In addition to these surface impoundments , there are several drum andequipment storage areas that were not properly regulated or managed forthe containment of spills, and may have released contaminants to theenvironment . The Hazardous Waste Storage Facility in Area II is used tostore drums of nonreactive hazardous wastes generated throughout theSSFL. The facility does not have sufficient impervious paved areas anddiking to properly contain wastes in the event of drum leakage . Thefacility is not roofed and drums of solvents have bulged as a result ofheating by the sun . The area is RCRA permitted and has received several

violations during regulatory inspections . Rockwell is negotiating withNASA to obtain funding to solve the problems at this facility (5) .

A survey of Area IV performed in February 1989 found 35 55-gallon drumsof reactive metal stored near the SNAP facility (Bldg 029) . These drumscontained sodium, potassium, sodium-potassium, zirconium hydride, and

lithium awaiting treatment at the Sodium Burn Facility or removal .

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Eighty-nine drums containing such materials as oils, alcohols, sodium andsodium reaction products , grease , phosphoric acid and asbestos wer eremoved in the early 1980s from an unregulated temporary drum storag earea referred to as the Old Landfill in Area IV (7) . Hydrocarbon an dcesium-137 contamination was detected in the soils at the OldConservation Yard (6) . Aerial photographs showed that hundreds of drum swere stored there in the 1960s and 1970s with no containment structures .There is a RCRA-regulated PCB storage area in . Area II where drums of PCBsand other hazardous wastes are stored . This area is properly enclose dand seems to be in compliance with its RCRA permit .

Although records that document the type or amount of wastes disposed ofat the Old Sodium Burn Pit in Area IV are not available, the amount o fsoil contamination found there during a DOE-CERCLA investigationindicates that the quantity of wastes disposed of was significant . Anarea of approximately 50,000 square feet was found to be contaminate dwith VOCs, metals , oil and grease , PCBs, polychlorinated terphenyls(PCTs), terphenyls , and biphenyls . In addition, radioactive cesium-137was found in soil samples in this area (7) .

Area IV has been the site of the Liquid Metal Breeder Reactor Programsince 1966 . Radioactive wastes from this program consist of bothhigh-activity and low=level wastes . Sigh activity wastes generallycontain .. ac:tavation products such as cobal-t-60 from-fuel--contact.. ' Processoperations ,and cleanup activ.l .ties, generate low-level wastes • contaminatedwith uranium, thorium,: or plutonium. A .small -quantity of .wastes .isgenerated from research programs (5) .

The handling of radioactive wastes , including treatment and storage,takes place at the Radioactive Materials Disposal Facility (RMDF ) . Wastetreatment consists of the solidification and evaporation of low-levelwastes . These wastes are then placed in 55-gallon drums for shipment toan .off-site radioactive waste disposal . facility. . In February 1989, 11 .drums containing low-leveltransuranic (TRU) wastes (by-products ofuranium decay ), were in storage (5) .

High-activity materials such as irradiated fuel elements are not treatedon-site . They are stored in below-grade vaults designed for the storageof fuel elements or high-activity wastes (5) . Existing information doesnot indicate if these wastes are transported off-site for final disposal,or accumulated in the vaults .

There are two areas of suspected radioactive contamination ofgroundwater . The subterranean levels of Building 059 that formerlyhoused the Space Nuclear Auxiliary Power ( SNAP ) prototype reactor containsand and equipment contaminated with cobalt -60 . Groundwater has seepedinto`the building and has become contaminated . A program of controlledgroundwater pumpage has lowered the groundwater level beneath thebuilding and kept a water level depression there to prevent the migrationof contaminated water from the building . There is insufficientmonitoring around the area to determine if the program has beensuccessful (5) .

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Sometime in the early 1960s, radioactively-contaminated water containingstrontium-90 and yttrium-90 was released to the soil in and beneath asanitary sewer leachfield for the RMDF . The soil in the area wasexcavated and the joints and fractures in the Chatsworth Formationsealed with asphalt , but there is still a high probability that

were

contaminants reached the groundwater in this area. This likelihood hasnot been investigated further (5) .

3.4 Groundwater

The principal aquifers at the SSFL are the upper Cretaceous Chatswort hFormation and Quaternary alluvium . The Chatsworth Formation is composedprimarily of veil-consolidated , massively-bedded sandstone with interbedsof siltstone and claystone . The occurrence and movement of groundwate rin the Chatsworth Formation is controlled by a veil-developed system o ffractures and joints. Permeabilities in this formation range fromapproximately 0.01 to 1 ,000 gallons per day per square foot (gpd/ft`) .The wide range in permeability values can be attributed to the fracture dnature of the formation (7) . This fracture system also makes i tdifficult to predict groundwater movement . The depth to groundwater inwells completed in the Chatsworth Formation ranges from a few feet t omore than 300 feet (2) .

Throughout . the -facility, a discontinuous layer of alluvium overlays theChatsworth Formation . This alluvium consists primarily of unconsolidated.sand, silt, and clay that has been ; eroded from--the surrounding Chatsworthand .Martinez Formations . .(The Martinez Formation is not saturatedanywhere-underlying theSSFL, and is 'therefore irrelevant to th egroundwater discussion .) This alluvium or Shallow Zone aquifer is onlysaturated along ephemeral drainages and in the southern part of Burr oFlats. Some portions of the alluvium are saturated only in the ve tseason. The depth to groundwater from Shallow Zone monitor wells rangesfrom four to 33-feet (2) .

Groundwater in the fractures of the Chatsworth Formation occurs underboth confined and unconfined conditions . In some areas of the facility,

the two groundwater systems appear to be hydraulically interconnected .In other areas, however, the Shallow Zone aquifer is separate anddistinct from the Chatsworth Formation groundwater system as evidenced byvastly different water level elevations and contaminant concentrations .In these areas, however, it is still likely that the Shallow Zone

transmits groundwater and contaminants to the underlying fracturedChatsworth Formation (4) .

The groundwater beneath the facility in both the Shallow Zone and the

Chatsworth Formation has been contaminated with volatile organiccompounds . TCE was found in samples from well RD-4 near the Bravo testarea in Area II at concentrations of up to 5,200 ug/l (4) . Groundwatersamples from several areas throughout the facility detected TCE inconcentrations exceeding 1,000 ug/l . Other commonly detectedcontaminants include trans-1,2=dichloroethylenevinyl chloride, and

trichlorotrifluoroethane (Freon 113) . In spite of the long history of

solvent usage at the facility and the high levels of TCE found beneath

the site, no off-site wells have shown groundwater contamination . The16

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pumpage of groundwater from the facility's water supply wells fo rindustrial usage has reportedly created a large cone of depression tha tmay have trapped the contaminants beneath the site (4) . Additionaloff-site monitoring is needed to confirm this assumption .

There is potential radioactive contamination of the groundwater from tw osources in Area IV : the SNAP reactor facility (BLDG 029) and the RMDFleachfield . Additional monitoring in the area of these facilities isneeded to determine the presence and extent of radioactive contamination .

The groundwater in the Chatsworth Formation is not used as a major sourc eof drinking water . The SSFL is provided with bottled water from severallicensed suppliers for use as drinking water . The Metropolitan WaterDistrict of Southern California supplies the local water purveyors wit hdrinking water from imported -surface water. No municipal drinking wateris derived from groundwater. The Southern California Water Company, acommunity water purveyor , has a stand -by well within three miles of th eSSFL, but the well has not been used in at least 10 years (8) .

A preliminary assessment for Area II performed in 1988 identified 400private domestic wells within three miles of the facility ( 9) . A wellcanvass performed for the facility ' s RCRA permitting process in 1984identified 16 wells within one mile of the site, 15 of which were-Inactive- (no operable pump `installed ) .(-1O) . -The sixteenth swell -was onlyused for lawn irrigation . A hydrologist for the .Ventura . CountyDepartment of Water Resources felt that "many"- -of the 400 domesticwellsmay. be inactive . This is based on the current availability of municipalwater supplies and the relatively high salinity of the groundwater .

The mean total dissolved solids concentration found in samples from theChatsworth Formation wells on -site is approximately 670 milligrams perliter (mg/1) (4 ) . The California Recommended Maximum Contaminant Level(MCL)for-total 'dissolved -=solids is 500 mg /1, indicating that the waterfrom the Chatsworth Formation may be more saline than is acceptable fordrinking water usage .

The SSFL has 17 water supply wells that were constructed prior to 1960 .These wells provide about 58 million gallons of water per year forsanitary, cooling, and other industrial uses (2) . The net seasonalprecipitation for the area is about 1.5 inches per year (12) .

3 .5 Surface Water

The SSFL is located on a plateau in the Simi Hills . Ninety percent ofthe facility drains to the southeast through Bell Canyon Creek (7) .Approximately five miles from the site, this creek joins the Los AngelesRiver, which flows through Los Angeles to the Pacific Ocean at Long Beach(13) . The other 10 percent of the site drains north into the Simi Valleythrough ephemeral drainages in Runkle and Meier Canyons . These canyonsmeet up with Arroyo Simi or Conejo Creek about three miles north of thefacility. These streams merge near Camarillo to formCalleguas Creek,which then flows to the Pacific Ocean at Point Magu (2) .

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Surface water drainage from most of the site is regulated by a series o fartificial drainages and impoundments designed to retain and recove rindustrial water, rainfall, and treated sewage treatment plant effluentsfor testing and recycling . Discharges to Bell Canyon Creek areonlymadeafter periods of heavy rainfall . The facility has an NPDES permi tallowing it to discharge up to 160 million gallons of treated wate ryear from two discharge points . However , even in years with heavy

p r

rainfall, the volume of water actually released is much smaller thanpermitted. The facility maintains nearly total compliance with itsdischarge quality requirements (5) .

In 1987, in compliance with Proposition 65, Rockwell conducted a study osurface runoff waters that arenot part of the regulated surface wate rdrainage . Nine sampling locations were identified throughout the SSFL .The samples were compared to the MCLs for drinking water , although therunoff from the site isnot used for that purpose . The MCL for arseni cwas exceeded at seven of the nine locations . The sample collected nearthe old sodium burn pit in Area IV exceeded the MCLs for arsenic ,chromium, and lead . Methylene chloride was detected in two samples a tlevels that exceeded the California Department of Health Service actionlevel of 40 ugfl . The sample from the area behind Building 133 in AreaIV showed levels of asbestos at 4,546 mg/l . The content of chrysolit efibers was 165 million fibers -per liter which is greater than theCalifornia proposed '"significant risk- level"' of 140 -million fibers perliter for ingesting asbestos fibers from drinking water (5) .

Although the runoff from so-me areas of the site did contain significan tamounts of-contaminants , it is not known if these contaminants wer ereleased to any off-site surface water bodies . The drainages to thenorth of the facility only have water in them during periods of heavyrainfall . The runoff from the site may have infiltrated into the soi lbefore reaching a surface water body . The 1-year, 24-hour rainfall fo rthe area -is about -three inches -(12) . '

Due to the ephemeral nature of all of the surface water drainages nearthe site , surface water is not used in this area . During periods of highrainfall , the water that flows through the Arroyo Simi and Los AngelesRiver is sometimes diverted and used for groundwater recharge , but thatoccurs further than three miles from the site (14) .

There are three bird species classified as endangered with geographicranges or habitat preferences that include the Simi Hills : the southernbald eagle, prairie falcon, and American peregrine falcon . There arealso three endangered plant species likely to be found in the Simi Hills :Dudlega cymosa , Dicentra ochroleuca , and Eriogonum crocatum . However,there is no information available to determine whether these sensitiveenvironments can be found within two miles of the site or along theappropriate water ways (15) . A federally listed endangered bird species,the least Bell's vireo has been observed in Arroyo Simi, but this habitatis greater than three miles from the site.

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Air pollution controls and permits at the SSFL are regulated by theVentura County Air Pollution Control District (VCAPCD) . Most of thepermitted facilities are conventional combustion units, with theexception of the coal gasification unit, the sodium heaters, the lo wnitrous and sulfurous oxide combustor, and the sodium burn facility .VCAPCD inspects the facility regularly and has found it in ful lcompliance with its permits (16) .

TCE and other organic chemicals are highly volatile , and with the hig hconcentrations of TCE foundin the groundwater , the potential for arelease of contaminants to the air due to the use of contaminate dgroundwater must be considered . There are two carbon adsorption/ai rstripping towers that operate as part of the on -site groundwaterextraction and treatment program. VCAPCD claims that no detectabl econcentrations of TCE are being released from these towers (16) .

TCE-contaminated groundwater is used to flush rocket engines aftertesting . The flush water is made up of about 15 percent groundwater withan averageTCE concentration of 600 ug/l . The other 85 percent of theflush water is supplied municipal water . Approximately 80 to 300 gallon sof water are used'in a five minute period. for each'test:(16) . Because of "`the low volume of contaminated -water used and, the short duration of the "flush, the amount of =TCE potentially released to the air from theseoperations `isprobably.low .

TCE is also still used as a'solvent flush following rocket engine tests(3) . There is reportedly a TCE capture system in place , but the detailswere not available for this report . It is not known if any TCE i sreleased to the air or the surface water impoundments from these tests .TCE in the surface impoundments would evaporate into the air , the amountdepending on its concentration . Additional information is needed .todetermine if these testing sites and surface impoundments may potentiallyrelease hazardous concentrations of TCE to the air .

In the early days of rocket testing, rocket fuels contained high levelsof beryllium . Particles of beryllium were released to the air andsettled on the soil around the facility . Rockwell states that theberyllium-contaminated soils were removed after the use ofberyllium-containing fuels was discontinued . There is some concern,however , that there may still be concentrations of be ryllium in the soilthat, when picked up by the wind , could pose a threat to human health(17) .

Radionuclides have been emitted from three sources inArea IV of theSSFL: the Radioactive Material Disposal Facility (RMDF),' the NotLaboratory, and the Nuclear Materials Development Facility (NMDF) . TheRMDF consists of several buildings where radioactive wastes aredecontaminated and packaged for off -site disposal . The Hot Laboratory isused principally to examine irradiated fuel and prepare it forreprocessing. It is licensed by the Nuclear Regulatory Commission (NRC)under Special Nuclear Materials License SNM -21 . The Hot Laboratory hasbeen undergoing reconstruction since 1987, and operations involvin g

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radioactive materials have temporarily ceased . The NMDF was constructe dfor research and production work involving highly radioactive fuels . I twas also licensed by the NRC, but the license was rescinded after thefacility was shut down in 1986(5) .

The emissions of radioactive particulates at all three facilities wer eand are controlled by high efficiency particulate air (HEPA) filters .Eight ambient air samplers collect continuous- samples at the SSFL .Radioactive releases are considered low by the DOE . Many of the sample scollected measure near or below detection limits . The totalradioactivity released in 1987 was less than one percent of DO Eguidelines (5) .

PROPOSED REVISED MRS CONSIDERATIONS

Rather than just determining if a release of contaminants to air hasoccurred, the proposed revisedHRS addresses the potential for a releaseof contaminants to the air . Due to the volume and volatility of thehazardous substances used on-site, this factor could possibly increasethe site's eligibility for inclusion on the National Priorities List .

The groundwater targetpopulation should not increase . significantly dueto increasing the radius of-concern from three miles to four . The area

`within ' the'extended radius is'veil developed and•is uses imported surfacewater provided by the Metropolitan Water District of Southern California .

Because the surface water the-distance of concern is increased from onemile to 15 miles from the site under the proposed revised HRS , additional

sensitive environments will be considered . A federally listed endangeredbird species, the least Bell's vireo has been observed in Arroyo Simi,and could potentially be disturbed by contaminant migration from thesite .

The addition of an on-site pathway will not greatly increase thepotential hazard from this site . The SSFL is isolated in rugged terrainand most of the facilities are fenced or guarded to prevent unauthorizedentry . There are approximately 500 employees at the facility but noresident population to be affected by on -site exposure .

5. CONCLUSIONS

The Rockwell International Santa Susana Field Laboratory is divided into

four areas that separate operations performed by Rockwell ' s RocketdyneDivision , the National Aeronautics and Space Administration, and theDepartment of Energy . The facility has been a research , development, andtesting facility for rocket engines, lasers, and nuclear reactors fornearly 40 years . Chemicals used during these operations include organicsolvents, primarily trichloroethylene , hydrazine fuels , oxidizers,kerosene-based fuels , and liquid metals such as sodium and potassium . Inaddition , asbestos , polychlorinated biphenyls , and hydraulic oil have

been used throughout the facility . Because of the development of nuclear

reactors in Area IV, radioactive wastes have also been stored on-site .

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A review of recent reports prepared to assess the hazard potential fro mvarious parts of the facility show that there are several wastemanagement facilities at the site that may have introduced hazardou schemicals into the environment . There are eleven surface impoundment sthat are regulated under the Resource Conservation and Recovery Act o f1976 and are undergoing closure or have been closed . Approximately 870tons of wastes , consisting of organic solvents, hydrazine fuels ,oxidizers , and others , were released to nine of these ponds in 25 year sof use . Most of these ponds had either inadequate or no linings .

In addition to surface impoundments , there were several waste andequipment storage areas where drums of wastes were stored possiblywithout proper spill containment . Two areas have released contamina-tion t9 soil and/or groundwater , and pose a continuing threat to theenvironment . These areas are the Old Sodium Burn Pit and an area nearthe Sodium Burn Facility . Soil near the Burn Pit is contaminated withorganic compounds , metals , polychlorinated biphenyls , metals, cesium-137,and other contaminants . Asbestos was found in a runoff sample takenbehind the Sodium Burn Facility (Building 133) .

Extensive groundwater testing has shown that the groundwater beneath th efacility is contaminated with volatile organic compounds .Trichloroethylene has :been found in .one well at concentrations of a tleast-5 , 200-micrograms per'liter . The maximum contaminant level for,drinking water for trichloroethylene is 5 micrograms per liter . Off-sitewell testing has not shown anygroundwater ` contamination migration away`from the' facility, although this may be due to a lack of effectiveoff-site monitoring . - There is extensive on-site groundwater pumpage thatmay be preventing groundwater flow from leaving the site .

Groundwater is not used as a primary source of drinking water withinthree miles of the site. Most of the area is provided with potable water

.by. water purveyors that receive their water from `the- Metropolitan WaterDistrict of Southern California . The District imports the water fromdistant surface waters . There are potentially 400 private domestic wellswithin a three-mile radius of the site. It is possible , however, thatmany of these wells are inactive due to the current availability ofmunicipal supplies and the relatively high salinity of the groundwater .The facility uses groundwater for sanitation , industrial , and coolingpurposes , but provides bottled water for drinking .

Most of the surface'vater runoff from the site is regulated through thefacility' s water reclamation system . The facility has a discharge permitfor two release locations that are tributary to the Los Angeles River .Surface water runoff from the northern ten percent of the facility maynot be collected ' in the on-site system and drain into canyons leadinginto the Simi Valley . Two areas of soil contamination fall into thisarea and may contaminate runoff with polychlorinated biphenyls , organicsolvents , metals, and asbestos . Surface water is not used for anypurpose except possibly groundwater recharge, and then only in periods ofhigh rainfall . There are no documented sensitive environments within onemile of the site , but a federally endangered species may reside in theArroyo Simi, the drainage channel that site runoff enters three milesfrom the site .

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Most of the air emissions from the site are regulated by the Ven-tura County Air Pollution Control District . The districtbelieves that hazardous emissions are not emanating from thi sfacility . There is not enough information available to determin eif there are uncontrolled releases of trichloroethylene and othe rsolvents from test facilities and surface impoundments to theair . The radionuclide emissions released from the facility ap-pear to be within guidelines established by the Department ofEnergy .

EPA RECOMMENDATION

While an ' abundance of data has been reviewed , additional informa-tion is required before EPA can conclude its evaluation of thefacility under CERCLA . Specifically, analytical data is requiredto determine if uncontrolled releases of trichloroethylene andother solvents via the air pathway are occurring . Once data iscollected, we will determine if the Rockwell International SantaSusana Field Laboratory qualifies for inclusion on the NationalPriorities List .

.The National Aeronautics and ..Space Agency -and the . Department ofEnergy (both Federal Facilities) are requested to .provide EPA

with quantifiable air . analytical data for Area II .and Area IV,respectively . * Each 'agency *is required : to assess the potentialfor-likelihood of release of -contaminants via the air route asoutlined in the proposed revised Hazard Ranking System model

(Federal Register , December 23, 1988) .

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REFERENCES

1 . Hargis and Associates, Phase I Investigation of the HydrogeologicConditions at the Santa Susana Field Laboratory, Ventura County,California, 1985 .

Groundwater Resources Consultants, Inc .,'Hydrogeologic AssessmentReport, Santa Susana Field Laboratory, RockwellInternational-Rocketdyne Division, November 30, 1987 .

Pearson , Florence, California Department of Health Services, ToxicSubstances Control Division, telephone conversation with KarenJohnson, Ecology and Environment, Inc ., July 13, 1989 .

Groundwater Resources Consultants, Inc., Phase II GroundwaterInvestigation, Santa Susan Field Laboratory-Area II, RockwellInternational -Rocketdyne Division , October 29, 1986 .

U.S . Department of Energy , Office of Environmental Audit,Environmental Survey Preliminary Report , DOE Activities at SantaSusana Field Laboratories , Ventura County ,' California , February 1989 .

Lafflam, Steve , Rockwell International , written communication.""Current . ETEC Site Status" to Carmen Santos , Environmental ProtectionAgency, July 11, 1989 .

Rockwell International -Energy Technology Engineering Center, CERCLAProgram Phase II - Site Characterization, May 29, 1987 .

Hooper, Elaine, Southern California Vater Company, telephone

'conversation with Karen Johnson,-Ecology-and Environment ; Inc., July

10, 1989 .

Groundwater Resources Consultants, Inc ., Preliminary AssessmentReport, Santa Susana Field Laboratory-Area II, RockwellInternational -Rocketdyne Division, March 3 1988 .

10 .CERCLIS File, document labeled "Enclosure I to 84RC0-4379", no date .

11 . Hoffman, LaVerne , Ventura County Department of Public 'Works,telephone conversation with Karen Johnson, Ecology and Environment,Inc ., July 5, 1989 .

12 ..Johnson , Karen, Ecology and Environment , Inc ., Preliminary Assessmentof the Former Sodium Burn Pit, Rockwell International Santa SusanaField Lab, no date .

13 . Upper Los Angeles River Area Vatermaster, Watermaster Service in theUpper Los Angeles River Area, Los Angeles County, October 1, 1986September 30, 1987, May 1988.

kjIkj/ rockwell/ref

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Report, Santa Susana Field Laboratory-Area II, Rockwel lInternational -Rocketdyne Division, March 3 1988 .

16 . Danzig, Al, Ventura County Air Pollution Control District , telephone

14 . Townsend , Chip , Venturaconversation with KarenFebruary 9, 1989 .

County Water Works District #8, telephoneJohnson, Ecology and Environment, Inc . ,

15 . Groundwater Resources Consultants, Inc ., Hazard Ranking System

conversation with Karen Johnson, Ecology and Environment, inc ., Juiy

12, 1989 .

Stenberg , Mike, Environmental Protection Agency, telephone conversatiwith Karen Johnson, Ecology and Environment , Inc., July 19, 1989 .

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CONTACT REPORT

AGENCY/AFFILIATION : Ventura Co . Air Pollution Control District

DEPARTMENT

ADDRESS/CITY :

COUNTY/STATE/ZIP:

CONTACT(S) TITLE PHONE

1. Al Danzig (805) 654-2806

2.

B & B PERSON MAKING CONTACT: Karen Johnson DATE : 7/12/89

SUBJECT: Air Emissions

SITE NAME: Rockwell SSFL EPA ID#

Mr . Danzig does not feel there is an airemissions problem at SSFL . Theyregularly monitor-and inspect for compliance and for several years a tleast, the SSFL has been in compliance .

TCE - there are 2 air stripping towers as part oftheir GWdecontamination effort . These towers have charcoal absorbers (?) an demissions from towers have shown no detectable concentrations of TCE .

The fac li-ty also .uses .contaminated water (600. ppb .TCE) in their rocketwash/cool down process . They use 15Z contaminated (600ppb TCE) w/85%fresh water at a volume of 80 to 300 gallons per test . Each test lastsfor about 5 minutes . This test doesn ' t violate any standards and the TC Evolatilized is barely above background .

No actual air monitoring for concentration with respect to background hasbeen done , however, the State Air Resource Control Board will be doingsome monitoring /sampling soon .

In Mr . Danzig ' s opinion, the APCD can say there's no air emissionsproblem because the know the sources , and they are low but no samplinghas been done:

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AGENCY/AFFILIATION: EPA - Air & Toxic Divisio n

DEPARTMENT : Office of Air Toxics& Radiation

ADDRESS/CITY: SF

COUNTY/STATE/ZIP :

CONTACT(S) TITLE PHONE

1. Shelly Rosenbloom 974-7109

2 .

E & B PERSON MAKING CONTACT: Karen Johnson DATE: 7/12/89

SUBJECT: Radiation Air Standard s

SITE NAME: . Rockwell SSFL EPA ID# :

Mr . Rosenbloom is currently awaiting releas eradiation release from SSFL .- it is on hold .

of the DOE report on

DOE emissions standards for air are for individual isotopes, not foralpha & beta .

There are no EPA emissions standards . Radiation NESHAPs (Nat . Em . Stand

for HazAir Polls .) are in dosage figures . AIRDOScomputer modelsconverts, but 'its' not simple.

He doesn't think there is a problem .

7/24/89The standards ( DOE) f?2r plutonium - 239 are 2x10- 14dCi/ml ;strontium - 90 9x10 dCi/ml

These standards are based on recommendations by the InternationalCommission on Radiation Protection .

vp/kj/rockvell/srw-cvm-cr

BNA00665378II III I I

HDMSe00408720

CONTACT REPORT

AGENCY/AFFILIATION:

DEPARTMENT : Air Toxics

ADDRESS/CITY :

CO UNTY/STATE/ZIP :

CONTACT(S) TITLE PHONE

1. Mike Stenbur g

2.

B & E PERSON MAKING CONTACT : DATE:

SUBJECT :

SITE NAMES EPA ID#

There are .10 or more permits issued by the APCD for air emissions . Thereiisno permit for the quenching operation that uses TCE'contaminated GU .

There is some concern about beryllium in the soil being picked up in th ewind . Be was used in rocket propellants until 1968 . Rockwell says thatcontaminated soil has been removed, but Mr . Stenburg questions thethoroughness .

With respect to TCE and Be, there definitely needs to be some airsampling!

BNA00665379HDMSe00408721

CONTACT REPORT

AGENCY/AFFILIATION: EPA

DEPARTMENT : Emergency Response Uni t

ADDRESS/CITY :

COUNTY/STATE/ZIPS

CONTACT(S) TITLE PHONE

1. Dan Shane 974-8361

2.

E & E PERSON MAKING CONTACT : Karen Johnson DATE : 7/18/89

SUBJECT : Recent TAT Site Visi t

SITE NAME: Rockwell SSFL EPA IDI :

The TAT work at SSFL was only at Area IV . They collected soil and watersamples and measured air for radiation .

RS-18 at burn pit contained 275 ppb TCE .

The OVA and HNu showed no readings above background .

wp/kj / rockwell/srw-cwm-cr

BNA006653 80H D M Se00408722

CONTACT REPORT

AGENCY/AFFILIATION : DOHS

DEPARTMENT : TSCD

ADDRESS/CITY :

COUNTY/STATE/ZIP :

CONTACT(S) TITLE PHONE

1 . Florence Pearson Senior Haz Mat Spec . (818)567-3100

2 .

B & 8 PERSON MAKING CONTACT: Karen Johnson DATE :7/13/89

SUBJECT: DOHS feelings about site

SITE NAME : Rockwell SSFL EPA ID# :

current activities to determine if :there are still activities that couldShe said that the DOHS does not know enough about the facility and it s

not thing there are any immediate concerns and the RFA may not be doneThe next step for DOHS is to do an RFA for the entire facility . She does

release contaminants .

right away.

BNA006653 8 1HDMSe00408723

AGENCY/AFFILIATION : DOHS

DEPARTMENT : Radiological Health Branch

ADDRESS/CITY :

COUNTY/STATE/ZIP:

CONTACT(S) TITLE PHONE

1 . Gerard Vong (916) 323-275 9

2.

B & B PERSON MAKING CONTACT: Karen Johnson DATE: 7/12/89

SUBJECT : Radiation Standard s

SITE NAME : _ Rockwell .SSFL EPA IDS :

Appendix .A lists emissions standards for xand z based on isotope .beta radiation . He said .Title 17 discusses radionuclides . Section 3035 5Asked Mr . Wong if there were any concentration standards for alpha and

Be also said that 40 CFR61a list of numbers .

BNA00665382HDMSe00408724

AGENCY/AFFILIATION: Ventura County Water Works District #k 8

DEPARTMENT :

ADDRESS/CITY: Simi Valley

COUNTY/STATE/ZIP: Ventura, CA

CONTACT(S) TITLE paw

1. Chip Townsend Water Supervisor (605) 583-0393

2.

E & E PERSON MAKING CONTACT: Karen Johnson DATE: 2/9/89

SUBJECT : Water use in Simi Valley

SITE NAME : Rockwell SSFL #1 .and #2 SPAID# CAD982399719CAD9823997.7 6

water for the Simi Valley ( including .theRockwell . Facility) . is providedby WWD#8 . They-get the water from HVD from the Colorado River or N . CA .No GW is used at all . Meier Cyn residents also use MVD water (from LasVirgines Water district) . The Arroyo Simi is not used in the Simi Valley .Chip thinks that the water that occasionally flows down to Oxnard is divertedthere and used as recharge for the aquifer beneath the Oxnard Plain .

F123

. . . . . . . . . . .. . . . . . . . ... . . . . . . . . . . . .. . . . . . . . . .

I I IBNA006653 83

HDMSe00408725

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY6%EGION IX

215 Fremont StreetSan 6 ncisco, CA 94. 1 t5

a,-T,xirt,i!2nt of Energysi'o Fr r -ic.'i < :cr ; r&tious Office3 3 ; toadwa

0*18z d =GA 9461 2

!.Mr . Nolan

.los £or your •iafo tion is tie Summary Revie oafveli f-ry Assessments/Site Inspections of Rockwell International'zu,,ta Sena Field Laboratory . A CERCLA site assessment was conductedon the facility to assess its potential to pose a significant threat;to human health and the environment . This report summarizes theavai.lah 1e -data :relative to the hazard ranking system mode.) . .

Additional information is required before we can coflclude ourevaluation•of Rockwell International . Specifically, analytical datais,required to determine if uncontrolled releases oftrich~loroethylene and other solvents from, test facilities and surfaceimpoundments are occurring Via the air route . Oncethis informationhas been received and . reviewed by the Superfund Field OperationsBranch, we, will be able to -determine the . site's eligibility forpotential inclusion on the National Priorities List .

If you have any questions regarding this re rt, w maycontact the or .Carolyn Douglas of my staff at (415r

Sincerely ,

Rich VailleAssistant Dir&._.cvHazardous Waste M-.nagementDivision

S .r .. L :'fflars . (R ack-.aell-Rocketdyn. :Liennis I < ker (TA Ri )Charles Myer s (:i-IS-i S),llen F,,. Air d g . (F'CAPCD)

Thomas Berg (Ve d)Joyce Jatco (NASA)

II I IBNA006653 84

HDMSe00408726

CONTACT REPORT

AGENCY/AFFILIATION : Ventura County Public Works

DEPARTMENT : Flood Control and Water Resources

ADDRESS/CITY :

COUNTY/STATE/ZIP :

CONTACT(S) TITLE PHONE

1. L,a Verne Hoffman Hydrologist (805) 654-2907

2 .

B & B PERSON MAKING CONTACT : Karen Johnson DATE: 7/15/89

SUBJECT : GW Usage

SITE NAME: Rockwell SSFL EPAID#:

there were some wells active. He said that the only way to know for sur e10-12 years ago, he did a well canvass in Section 16 and along Smith Roa dmost of the area is now provided with municipal water . He said that

he knew how many were currently 'active .. He suspected' that at most only .ahandful were still operating . No wells have been drilled recently an d

stating that there are 400 domestic wells within 3 miles . .I asked him i fMr . Hoffman vas cited as part of the reference in the PA for Area II as

would be to go out and canvas the area now.

BNA00665385HDMSe00408727

CONTACT REPORT

AGENCY/AFFILIATION : Southern California Water Company

DEPARTMENT s

ADDRESS/CITY :

COUNTY/STATE/ZIP S

CONTACT(S) TITLE PHONE

1 . Eloise Hooper Service Rep . (805)526-9393

2.

E & E PERSON MAKING CONTACT : Karen Johnson DATE: 7/10/89

SUBJECT: Municipal Well Near SSFL

SITE NAME : Rockwell SSFL EPA ID#: CAD

groundwater recharge injection . If I`want to know more about that, cal l

The municipal well within 3 miles of SSFL is known as their CatherineWell . It is not used to pump out water at all. May be used for

10 years at least , (the length Ms. Hooper has been with the company) allback next 'week when-superintendent returns from vacation . For the last

water supplies have come from MVD and Northern California .

BNA00665386HDMSe00408728


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