Internal Letter oi% Rockwell Internationa l

7a " . 2b April 1989

TO - c ,e-- Add,,-,,, FROM .

J . H . Kelle rRocketdyne-SSF L540, 055-T486

89EU-139

S . R . LafflamRocketdyne-SSFL543, 055-T4855705

11"]'';l . Environmental Control Weekly Activity Report

PROBLEMS

Protection of Stratospheric Ozone - On 17 April, the EPA promulgated a nadvanced notice of proposed rulemaking to include 1,1,1-trichloroethane andcarbon tetrachloride into the Montreal Protocol limiting production and usethese remaining chlorinated solvents .

ACHIEVEMENTS - Nothing

INFORMATION

f significance to report .

a

Burn Facility - Misc NAKA explosive wastes and TEA/TEB igniters were disposedof by open burning on designated burn days, April 19-21 Waste pressur ecylinders were also detonated at the facility on 22 April . ProtectiveServices and Environmental were in attendance .

Lion Technology Environmental Workshop - Environmental attended the Lion

Technology Workshop, a comprehensive environmental training on the new rule sand requirements . Corporate sponsored the workshop in Seal Beach .

City of Los Angeles Bureau of Sanitation - The Bureau of Sanitation Quarterl ySelf Monitoring Reports were submitted on schedule .

Aletter was written reaffirming the topics discussed at the 6 April meetin gbetween Rocketdyne and the Bureau of SaniLation regarding the effluen tviolations which recently occurred at the Canoga facility, and Rocketdyn eplans to reduce/eliminate future occurrences .

NPOES Report - The NPDES quarterly monitoring report on waste water dischargesfrom SSFL was submitted to the EPA on schedule .

New aerial photographs - Environmental requested that updated aerialphotographs of SSFL be provided in order to determinethe distance oencroaching homes from the SSFL facility .

Lube/Oil Spill at Bravo Environmental responded to a2-gallon lube/oil spillat Bravo II test stand . The spill was remediated in accordance with standardprocedures . The spill was not reportable .

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Hazardous Material Permit - Work on a renewable hazardous material permit fromVentura County Fire Protection District to store, transport, and use chlorinegas has been initiated .

DOE/Area IV Activities - A "first cut review" of the DOE environmental surveyaction plan was made by Environmental, ETEC, and the DOE San Francisc oOperations Office (DOE/SAN ) . General comments were deemed favorable by theDOE/SAN office . Corrections and comments will be forwarded to DOE/SAN forfinalization . A May 12, 1989 deadline for submittal of the "final" actio nplan to DOE/HQ will be met .

ETEC requested Environmental provide input into the DOE 5-year EnvironmentalRestoration and Waste Management Plan . Issues that were addressed in the planincluded : interaction with regulatory agencies ; compliance strength andweaknesses with air, water, and hazardous waste operations ; identifyingpotential impacts drivers on ETECOperations, etc . Specific activitiesdescribed in the narrative included but not limited to : NOX offsets for theBowl Area, RCRA permits for B/133 and RMDF ; Simi Valley discharges from SCTI,etc . Identified and described in the 5-year Plan for the first time is theAtomics International DeSoto B/104 ground water assessment . Requested fundingis being slotted for FY91 to begin the B/104 characterization .

The Radiation and Nuclear Safety group requested Environmental provideinformation on asbestos containing material in T/055, Area IV SSFL . ACM wasidentified in floor tiles, heater pipe insulation, and ventilation ductmolding . The building will be utilized for HASP office space .

Hazardous Waste Training - Environmental instructed 16 employees of 0/554(DeSoto) and 0/503 (Canoga) facilities in the proper handling of hazardouswaste . As of this date 50 employees have passed the in-house developedtraining class which covers the definitions of hazardous waste, liabilitiesinvolved with improper management , and hazardous waste handling procedures aRocketdyne .

Additional classes will be scheduled for May .

Environmental Coordinator' s Meeting Environmental attended the semi-annualEnvironmental Coordinator' s Meeting held at Seal Beach on 19 April . Major

topics included up and coming state and federal legislation affecting theaerospace industry. Speakers emphasized the importance for Environmental toreview proposed legislation and submit comments to corporate to serve assupport for industry in public hearings .

SARA compliance was discussed for Section 313, Form R reporting which ispublic-accessed data of chemical releases to air , ground , and water .

In addition, Corporate Legal indicated that environmental audits should beconducted at off-site vendors (platers, etc .) that generate hazardous wastewhile performing services for Rocketdyne .

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SSFL Ground Water Program - The three air-stripping tower treatment system s(Alfa, Canyon, and Delta ) continue to decontaminate about 0 .5 million gallon sof ground water per day . A facility power dip tripped the electrical senso rat Alfa and it was down ahalf-day ; the Delta booster pump is leaking and wil lbe repaired by Maintenance . The AR for the upgrade of the other towers (a tBravo and Area I Road) is in the signature loop .

The 1988 Annual Ground Water Monitoring Report for the SSFL facility has beenreceived from Groundwater Resources Consultants, Inc . (GRC) and is bein greviewed .

Other Environmental Activities Environmental Manual Procedure EC 01 .10(Environmental Agency Inspection) has been updated and is in the review cycle .

Post-B/065 Audit Activities - Environmental personnel have investigatedfurther into the history arid disposal practices connected with the concreteholding pit behind the ETEC Lab (B/065) . Chemical analysis of the sumpcontents has revealed the presence of halogenated solvents . A probability ofsoil contamination exists .

Hazardous Material Incidents - Environmental investigated, after beingnotified by Protective Services, that a non-employee working at B/705, CTL IIIhad received an eye injury when he disassembled a pump which apparentlycontained caustic solution under pressure . The employee of Mechanical ProcessCompany received help from Rocketdyne personnel . The small spill was found tocontain 0 .2% potassium hydroxide which had a pH of 14 according to thechemical analysis report . The Environmental technician neutralized the liquidon the ground with Spill-X . After rinsing his eye with water, thenon-employee refused further treatment offered by Health & Safety personnel .This was not a reportable accident .

Support to Advanced Programs D/631 personnel in B/309 along Area I Road havea K-bottle containing 10% fluorine in helium that needs to be vented by4/26/89 so that contractors could work in the area . Environmental advisedthat (a) calculations indicated that 3-pounds of fluorine were present ; (b)venting to the air is not permitted ; ( c) a reportable release would be 10 lbs .of fluorine ; ( d) the material must be captured in their scrubbersystem andthen proceed with permitted hazardous waste disposal routes .

Hazardous Waste Management

On 18 April, 92 drums of hazardous waste were transported to RollinsEnvironmental Service. Inc . in Texas for incineration .

One hundred tons of concrete from the STL IV pond closure and tank removalwas transported to a Class III landfill . Lab analysis showed the concreteto be non-hazardous .

B/204 Underground Gas Tank - The final letter to the Ventura CountyEnvironmental Health Department has been excavated and considered a cleanclosure . Laboratory analysis showed the contamination to be below stateaction levels after excavation .

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INEL Support - Environmental attended a kick-off meeting with INEL managementto discuss needed support for a proposal on remediation activities for ahazardouslmixedlradioactive waste clean-ups in Idaho . Environmental was askedwhether they would be willing to permanently relocate staff to the new INE Loffice .

EC 03 .10 Procedure Rewrite - Environmental Procedure EC 03 .10, Industria lWaste Water Monitoring and Treatment Systems, was updated in a general fashionbut also to relfect the most appropriate sharing of departmenta lresponsibilities to avoid the issuance of NOVs in the future . The newprocedure addresses (1) industrial wastewater flow monitori ng, (2) pHmeasurement and control , and (3) pollutant measurement . A draft of therevised procedure will be distributed to the affected departments to fo rreview and comment , after which the procedure will be finalized and submitte dto management for signature .

B/101 (DeSoto) Waste Water Management System Upgrade - The secured samplingports and a weir and flowmeter have beeninstalled at the B/lOI process are awastewater management system by R . M . Lane Co . with EMSI as subcontractor .The installations were mandated by the Bureau of Sanitation (City of Lo sAngeles ) via NOV No . 45538 . The secured sampling ports will house an Isc ocomposite sampler and a pH meter and will be utilized at the discretion of th eBureau . The flowmeter employs an unusual bubble concept of flow measurementin conjunction with a V-notch weir located in an effluent sampling box . Thesampling box contains about six gallons of waste water allowing for gra bsampling, if the Bureau wishes . The upgrading was completed by the Burea udeadline of 22 April .

EMSI had beenrequested to perform 24-hour composite sampling of the wast ewater effluent at the B/101 process area before final installation of th esampling box and secured sampling ports . A total of 5-days sampling wa sobtained and the samples are currently under analysis . However, preliminaryresults have shown a high level of methylene chloride ( 9 ppm ) in the effluen tstream. Although the source of the contamination is still unde rinvestigation, it is known that solvents are used in nearby fume hoods thathave sinks leading to the waste management system and the sewer .

Bowl Area (SSFL) Navy Valve Test Support A letter has been sent to VAPCDacknowledging the agreement reached between the District and Rocketdyne forthe use of the Rocketdyne lock-box concept for the propane pressure regulatorassociated with the 4 .9 million BTU/hr boiler . The application package forthe authority to construct should thus be considered complete by the District .

ELV Braze Line ( Canoga ) - A meeting was held on 18 April betweenEnvironmental, Health & Safety, and F&PO representatives to discuss the ELVbraze line air emission concerns . Data generated from samplings and analysesperformed by EMSI at the ELV braze line and the 0/544 process area werepresented to the attendees . Significant levels of cadmium and fluoride werefound in the air being withdrawn from the brazing operations and ambient airwarranting suggestions for development of an exhaust system that would meetboth OSHA and Prop 65 requirements . On an interim basis, Health & Safetyrecommended installation of additional fans for the protection of braze lineoperators . F&PO will also work up a design of an exhaust system suitable as along-term solution .

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B/037 (0/502 Process Area) Renovation - Discussions on the B/037 waste wate rsystem upgrading and avoidance of any further NOVs while the upgradin gplanning and installation are underway . Plant Services studied the DI waterregeneration process and determined that the current pH neutralization syste mis marginally adequate for handling the pH burden placed on the clarifier bythe regeneration operation . Additional pumping capacity for the acid bas efeed systems may yet be provided ; however, F&POis very close to installin gthe planned pH neutralizing system upgrade . Facilities engineers ar ereviewing overall 8/037 renovation plans to ensure that upgrade of the pHneutralizing system can proceed without adversely impacting other plans .

SCTIPermit No . 0271 - A letter and 5-0 have been prepared for signature t ocover payment of the $642 .42 in additional renewal fees requested by VAPCD fo rthe SCTI air emissions permit due to the District recalculation of theemission factors based on the recent KVB data . ETEC has reviewed the draftpermit and calculations and has approved the submittal .

D/553 Paint Ordering Support Environmental provided support to D/553,Purchasing, to enable purchase of selected restricted paints and coatings .Word was received by Environmental that a number of vendors would not shippaints with high VOCs or Prop 65 chemicals unless Rocketdyne provided awaiver to them . The impasse was removed upon discussions with the vendorsthat noted the limited use at Rocketdyne of such paints/coatings and theexemption to specific SCAQMD rules as a result .

B/101, D/421 Process Tank Permitting - Applications for permitting (6) processtanks for cleaning and passivating small engine components at DeSoto B/1010/504 are being prepared by Environmental to bring them into compliance withthe new requirements of the SCAQMD Rule 219 .

Environmental Audits - APTF 0/598, B/314, 338 and 383 in Area I were audited =on 11 April for hazardous waste compliance and for cold solvent degreasers .The area was in full compliance relative to hazardous waste containers andlabeling . Asmall unused cold solvent degreaser was found in the shop area ona pallet . 0/598 management said it was to be disposed of .

Peacekeeper Ablative Curing Ovens B/037 Environmental is looking into theprobability of permitting (3) ablative curing ovens in D/502 - B/037 Canoga .the ovens are being used to cure plastics and phenolics .

S . R . <Lafflam, ManagerEnvironmental Uni t

SRL :sj/0007H

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ENVIRONMENTAL UNIT - WEEKLY ACTIVITY REPOR T

DISTRIBUTIO N

cc : T . W . Butler 540, 055-T486M . G . Chavez 031, 055-SS2 5P . C . G . Coulter 091, 055-AB5 7D . C . Gibbs 638, 055-HB1 30 . C . Hunter 564, 055-T486J . A . Kucinskas 014, 055-EA3 5R . H . Lancet 638, 055-HA02K . H . Lynch 541, 055-SS1 3L . E . Lukunich 546, 055-AD06J . Monaghan 598, 055-SS060 . Ploszaj 540, 055-T483R . Reisenweber 870, 001-110, SG05G . M . Richards 574, 055-AB050 . S . Roberson 565, 055-LB05C . J . Rotas 551, 055-CBO 1M . Robertson 539, 055-SS1 2M . C . Shoemaker 539, 055-AC1 0J . Tucker 870, 001-110, SG05J . Uranga Dallas , 407-200E . J . Wooster 564-207, 055-BA7 50 . J . Zwen gEnvironmental Staff

622, 055-T038

MIlD III 11 11BNA0252377 8

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