Cal/EPA

Department ofToxic SubstancesContro l

1011 N. Grandview Ave .Glendale, CA 9120 1

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July 16, 199 8

Mr. Steve Lafflam

Division Director

Safety, Health & Environmental Affairs

Rocketdyne Propulsion & PowerBoeing North American, Inc .

6633 Canoga Avenue

P . O. Box 7922

Canoga Park, CA 91309-7922

Dear Mr. Lafflam :

TECHNICAL REVIEW OF DRAFT INTERIM MEASURES WORKPLANFOR THE FORMER SODIUM DISPOSAL FACILITY (FSDF),DEPARTMENT OF ENERGY, BOEING NORTH AMERICAN, INC .,SANTA SUSANA FIELD LABORATORY, SIMI HILLS, CALIFORNI A

The Department of Toxic Substances Control (DTSC) has reviewed the

draft Interim Measures (IM) Workplan for the Former Sodium Disposal Facility

(FSDF) received May 18, 1998, provided several sets of comments to the

Department of Energy (DOE) and Boeing North American, Inc . (Boeing) on

June 11, 1998 and June 30, 1998, and have met with representatives of DOE and

Boeing on July 1, 1998 and July 8, 1998, to resolve technical issues . Most

technical issues have been resolved with the only significant exception being the

issue of acceptance criteria for backfill to be placed in the FSDF excavation.

Due to the urgency expressed by DOE and Boeing to complete the IM

before the 1998/1999 rainy season commences and for DOE to encumber funds

before the end of the 1998 federal fiscal year, this IM needs to move forward.

Therefore, the remaining issue is made a condition of technical acceptance by

DTSC of the IM Workplan . DTSC is herein indicating that its review of the draft

FSDF IM Workplan is complete and that subject to the agreed-upon revisions

being made, the comments on the Transportation Plan (enclosed) being

incorporated, and the following specific condition concerning backfill acceptance

criteria, the draft FSDF IM Workplan is determined to be technically acceptable

such that it may be public noticed.

00 4"7 39 PC 07 20-98x11 :04 RCVi ;

Pete WilsonGoverno r

Peter M. RooneySecretary

for EnvironmentalProtectio n

HDMSe00162873

Mr. Steve Lafflam

July 16, 1998

Page 2

The backfill acceptance cri te ria shall be :

The Wilcoxon Rank Sum test would be used to determine if the

data sets (on-site and import soil) are the same or different for

inorganic constituents only . If there is no difference between the

two data sets, then the soil would be acceptable for use as backfill .

If DOE/Boeing is unable to locate backfill that passes the

Wilcoxon Rank Sum Test for on-site soils, then the soil could be

used as backfill only if the following conditions were met :

1) metals concentrations do not exceed localbackground levels ; local background levels to beapproved by DTSC prior to Wilcoxon Rank SumTest determination ;

2) PCB and VOC concentrations are non-detect ;

• 3) TPH (speciate the hydrocarbon using EPA Method8015 modified) for gasoline and diesel are non-detect; and motor oil at concentrations less than 100ppm;

4) dioxin concentrations - TEQ- less than 10 parts per

trillion; and

5) Other organic constituents are non-detect .

DTSC is in the process of preparing the Initial Study on the basis of the

draft FSDF IM Workplan, agreed-upon revisions and the above mentioned

condition for this project pursuant to requirements in the California

Environmental Quality Act (CEQA) . When the revised draft FSDF IM Workplan

is provided to DTSC, the technically accepted draft FSDF IM Workplan and

CEQA documents will be public noticed for thirty days to invite public comment .

• Mr. Steve Lafflam

July 16, 1998

Page 3

If you have any questions, contact Penny Nakashima at (818) 551-2900 .

Philip. ChandlerSupervising Hazardous Subst ancesEnginee ring Geologis tSouthern California Permitting Br anchGlendale Offic e

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Enclosure

cc: Mr. Jim Davis

U. S. Department of EnergyOakland Operations Office1301 Clay Street, 700NOakland, California 94612-520 8

Dr. Michael Sullivan

Rocketdyne Propulsion & Power

Boeing North American, Inc .

6633 Canoga Avenu e

P . O. Box 7922

Canoga Park, California 91309-792 2

Ms . Majelle Le eETEC Program ManagerBoeing No rth Ame rican , Inc .6633 Canoga Avenu eP . O. Box 7922Canoga Park, Califo rn ia 91309-7922

Mr. Tom KellyU. S . Environmental Protection Agency

75 Hawthorne Stree t

San Francisco, California 94105

HDMSe00162875

S Mr. Steve LafflamJuly 16, 1998Page 4

cc: Mr. Robert SamsDepartment of Toxic Substances Control1011 N. Grandview AvenueGlendale, California 9120 1

Dr. T.R. HathawayDr. Debbie OudizDepartment of Toxic Substances Control301 Capitol Mall, 1st Floo rSacramento, California 9581 4

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COMMENTS ON APPENDIX D - TRANSPORTATION PLANINTERIM MEASURES WORKPLAN FOR THE FSDF

Section 4.0 Destination of Waste

• Waste Fate - Clarify that if pretreatment of hazardous waste is necessary,

then this treatment would be performed at the disposal facility . The

current phrasing is ambiguous .

Section 7.0 Traffic Control and Loading Procedure s

• Diverting trucks arriving earlier than planned to a staging area on De Soto

Boulevard needs to be included under the heading entitled "Staging Area" .

• The Transportation Plan (TP) addresses a 10 minute interval between

empty trucks traveling to the site . Mention is made earlier in the TP that

the primary route was selected to pose the least inconvenience to the

residents along the route . To be consistent with this goal, monitoring of

loaded and empty trucks on the local two-lane roads needs to be included .

Section 8 .0 Record Keepin g

Plan Distribution - The documents listed need to be kept in the cab of the

truck with the driver.

Section 9 .0 Health and Safety Pla n

• Specific Instructions, page 22 - The first bullet states that the driver willnot leave his seat during loading . The second bullet states that the driverwill leave the cab and observe the loading while standing outside theexclusion zone. To avoid confusion, clarify under what circumstances thetwo scenarios will apply For example, if the truck driver arrives at the sitewhen loading is in progress, then the driver will remain in the cab withwindows closed.

• The third bullet addresses suspect non-hazardous waste loads entering thedecontamination area . Mention of suspect hazardous waste loads needs tobe included .

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HDMSe00162877

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Section 10.0 Contingency Pla n

• Chemical Hazard, 2nd bullet - The impact to the environment does not

include risk form airborne contaminants . The risk is potentially high .

• Physical Hazard discusses a large spill but does not address small spills .

• Spill Response Plan/Cleanup Plan

- during cleanup efforts, measures to suppress dust need to be

included .

- small spill cleanup and containerization need to be addressed .

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