STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY DEPARTMENT OF TOXIC SUBSTANCES CONTROL In the Matter of: Santa Susana Field Laboratory Simi Hills Ventura County, California CAD093365435 (Boeing) CA1800090010 (NASA) CAD000629972 (Boeing/DOE) CA3890090001 (Boeing/DOE) Docket No. P3-07/08-003 CONSENT ORDER FOR CORRECTIVE ACTION Health and Safety Code Section 25187 The Boeing Company, The National Aeronautics & Space Administration and The U.S. Department of Energy, (Respondents) INTRODUCTION 1.1. Parties. The California Department of Toxic Substances Control (DTSC) and The Boeing Company, a Delaware corporation (Boeing), the National Aeronautics & Space Administration (NASA), a federal agency, and the U.S. Department of Energy (DOE), a federal agency (Respondents) enter into this Consent Order for Corrective Action. 1.2. Permitting Status. Respondents are the owners and/or operators of hazardous waste management units and facilities at the approximately 2850-acre Santa Susana Field Laboratory (SSFL), also defined for corrective action purposes under this Order as "the Facility," located. in the Simi Hills in the southeastern corner of Ventura County, California as shown on Attachment 1. The Simi Hills are bordered on the east by the San Fernando Valley and to the north by the Simi Valley. The site is located about 8 miles south of the San Fernando Valley Freeway (118) and about 10 miles north of the Ventura Freeway (101). The SSFL was established in 1947. Activities at the SSFL have ranged from rocket engine testing to research and development of fuels and propellants, nuclear power and lasers. The SSFL is divided into four (4) administrative areas - Area I, Area II, Area III, Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 and Area IV - and two buffer zones. Areas I and III are operated by The Boeing Company (Boeing), which owns most of Area I and all of Area III. Areas I and III total 791 acres. Boeing also owns a contiguous buffer zone of 1143 acres to the south and a contiguous buffer zone of 182 acres to the north. A 42-acre portion of Area I and all of Area II, which is 404 acres, are owned by the federal government, administered by NASA and operated by Boeing. Area IV, which is 290 acres, is owned and operated by Boeing for the Department of Energy (DOE). DOE owns facilities on a 90-acre site within Area IV. This 90-acre parcel consists primarily of facilities and structures built and owned by DOE and operated by Boeing. The Respondents have engaged in the management of hazardous wastes pursuant to permits and interim status documents issued by DTSC as described in Attachment 2. DTSC issued post closure permits for Areas I, II and ilion May 11, 1995. The postclosure permit for Areas I and III was issued to "The Boeing Company, Rocketdyne Propulsion and Power,,1 as owner and operator. (Permit Number:PC-94/95-3-02), E.P.A. 1.0. Number: CAD093365435) The postclosure permit for Area II was issued to NASA as owner and The Boeing Company, Rocketdyne Propulsion and Power as operator (Permit Number: PC-94/95-3-03, EPA 1.0. Number: CAD180009001 0). The expiration date on both of these permits was May 11, 2005, but Respondents submitted timely and administratively complete applications, which extend the terms of the permits pursuant to the California Code of Regulations, title 22, section 66270.51 (d). The post closure permit for Areas I and III addresses five (5) surface impoundments and five (5) groundwater treatment systems and/or and 1 Rockwell International Corporation, Rocketdyne Division applied to DTSC for a hazardous waste facility post-closure permit to operate hazardous waste groundwater extraction, treatment and monitoring systems at the Rockwell-Rocketdyne Site, and to address maintenance of caps at closed impoundments. After issuance of the post closure permit in 1995, Rockwell International Corporation, Rocketdyne Division was purchased by the Boeing Company and became a wholly owned subsidiary renamed Boeing North American. As of December, 2006, the name on the post closure permits was updated to "The Boeing Company, Rocketdyne Propulsion and Power." Documents may still refer to the Owner and/or Operator of the post closure permits as "Rockwell International Corporation, Rocketdyne Division, Boeing North American Inc., The Boeing Company, or Rocketdyne Propulsion & Power." 2­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 towers. The post closure permit for Area II addresses four (4) surface impoundments and three (3) groundwater treatment systems and/or towers. Until the mid-1980s, the nine surface impoundments in Areas I, II and III were used to contain waste waters related to the testing of rocket engines and engine components. The impoundments received rinse water and waste water that contained traces of fuels, oxidizers and/or solvents. In the mid-1980s, use of the nine surface impoundments was discontinued. The RCRA closure process for these units was initiated in 1985. DTSC accepted closure certification on April 21, 1995. The nine surface impoundments are listed on Attachment 3. In Area IV, the two (2) DOE-owned/Boeing-operated facilities 2 include the Hazardous Waste Management Facility (the HWMF) and the Radioactive Materials Handling Facility (RMHF). DTSC issued a permit for the HWMF in 1993 to DOE as owner and Rockwell International Corporation as " the facility operator (Permit Number: 93-3-TS-002), EPA 1.0. Number: CAD000629972).3 This permit authorized the continued operation of two (2) onsite hazardous waste units in the Energy Technology Engineering Center (ETEC). The units include a treatment unit (the Building 133 sodium burn facility) and a storage unit (the Building 29 sodium storage facility). The HWMF is inactive and remains subject to closure requirements. The RMHF is a mixed waste facility for which Interim Status authority first went into force with the March 22, 1989 Part A submittal to the U.S. Environmental Protection Agency (Interim Status Document EPA 1.0. Number: CA3890090001). In September 1997, DTSC required DOE and Boeing to submit a revised Part A application to clarify the hazardous waste operating units at the RMHF eligible for Interim Status and"to include a closure plan and schedule for closure. A revised Part A application and Closure Plan for the RMHF was submitted 2 DOE owns the facilities, which include structures. Boeing owns the land and operates the facilities. The HWMF permit shows Rockwell International Corporation as the facility operator. Boeing became the current operator through its acquisition of Rockwell International Corporation, Rocketdyne Division after DTSC issued the permit and interim status document. The permit has not been updated to identify Boeing as the current operator. 3 3­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 October 24,1997. DTSC determined the Part A application complied with the administrative requirements for interim status. The RMHF consists of two hazardous waste management storage units (Building 4022, and Building 4621 and its accompanying yard) and a mixed waste treatment unit (Building 4021). Closure of the RMHF is pending. 1.3. Jurisdiction. Jurisdiction exists pursuant to Health and Safety Code section 25187, which authorizes DTSC to issue an Order to require corrective action when DTSC determines that there is or has been a release of hazardous waste or hazardous waste constituents into the environment from a hazardous waste facility. 1.4. Definition of Terms. The terms used in this ,Order are as defined in the California Code of Regulations, title 22, section 66260.10, except as otherwise provided. "Facility" shall mean the entire SSFL site, which is under the ownership and/or control of the Respondents. "Respondent(s)" shall mean one or more of the Respondents identified in Section 1.1 of this Order. 1.5. Attachments. All attachments to this Order are incorporated herein by this reference. 1.6 Right to Hearing. Respondents waive any right to request a hearing on this Order pursuant to Health and Safety Code section 25187 on the matters covered under this Order.:. 1.7· Denial of Liability. By entering into this Order, Respondents do not admit to any fact, fault or liability under any federal or State statute or regulation and this Order shall not constitute a release, waiver, covenant not to sue or limitation on any rights, remedies, powers or authorities that Respondents have under any statutory, regulatory or common law authority. 4­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 FINDINGS OF FACT DTSC hereby finds: 2.1. Region IX of the U.S. Environmental Protection Agency (U.S. EPA) issued an Interim Final RCRA Facility Assessment Report (RFA) in July 1991 that identified 122 areas of the SSFL for designation as Solid Waste Management Units (SWMUs) and Areas of Concern (AOCs). On November 12, 1992, DTSC issued a Stipulated Enforcement Order to Rockwell International Corporation (predecessor to Boeing)4 to impose corrective action requirements at the SSFL based on the 1991 RFA. The 1992 Order required Boeing, among other things, to submit a Current Conditions Report analyzing each area identified in the RFA. The Current Conditions Report was to contain an in-depth investigation of waste generation and release at each area and a determination of necessary further actions for each area, with a basis for each conclusion. The 1992 Order also required Boeing, after submittal of the Current Conditions Report, to submit a draft RCRA Facility Investigation Workplan (RFI Workplan), including plans for each area identified in the Current Conditions Reports as areas appropriate for investigation. The parties contemplated that approval of the RFI Workplan would result, ultimately, in an RFI Report, Corrective Measures Studies and final cleanup of the areas identified in the final Corrective Measures Studies. A Current Conditions Report was prepared by ICF Kaiser Engineers in 1993, on behalf of Boeing. In May 1994, the U.S. EPA finalized the RCRA Facility Assessment Report (RFA). When finalized in 1994, the RFA identified three (3) additional sites for a total of 125 SWMUs and AOCs at the SSFL that either have released or may release hazardous waste or hazardous waste constituents into the environment. During the subsequent RFI phase of Corrective Action, 10 additional AOCs 4 Boeing became subject to the Order through its acquisition of the Rockwell International Corporation, Rocketdyne Division after the Order was issued. 5­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 have been identified at the SSFL. All 135 SWMUs and AOCs are summarized in Attachment 4. They include; all five (5) of the Area I and III closed RCRA surface impoundments; the four (4) Area II closed RCRA surface impoundments; the Area IV HWMF and the Area IV RMHF. Leach fields are typically associated with individual SWMUs and not shown individually except in Area IV where they are independent units. 2.2. Based on the RFA, DTSC concluded that further investigation was needed to determine the nature and extent of any release of hazardous waste or hazardous waste constituents in or from the SWMUsand AOCs listed in Attachment 4. Identified SWMUs and AOCs have been grouped by location for investigation purposes and the groups are called "RFI Sites." A total of 51 RFI Sites have been identified for investigation under the RFI process. The RFI Sites are listed in Attachment 5. The SSFL RCRA Corrective Action program is currently in the RFI Phase which was begun in 1993 following submittal of the original Workplan with the Current Conditions Report. A comprehensive description of tasks performed for the RFI surficial media investigation, RFI scope, workplans prepared, and expansion and changes to the RFI, are described in the RCRA Facility Investigation Program Report, Surficial Operable Unit, Santa Susana Field Laboratory dated July 2004 (Program Report). Laboratory information for samples collected through December 31, 2003 are provided in the Program Report. 2.3. Since the early 1980s, SSFL site characterization has proceeded along two parallel paths, one for groundwater and the other for soils and related surficial media. In 1999, this approach was formalized by defining the groundwater and surficial media as two Operable Units (OUs) for investigation purposes. The OUs at the SSFL are: 6­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 I. The Surficial Media OU comprising saturated and unsaturated soil, sediment, surface water, near-surface groundwater, air, biota, and weathered bedrock. Near-surface groundwater is groundwater that occurs within the alluvium or weathered bedrock. II. The Chatsworth formation OU, comprising the Chatsworth formation aquifer, and both saturated and unsaturated unweathered (competent) bedrock. A discussion of the RFI and OUs is presented in the Program Report. 2.4. As a result of a September 1990 Groundwater Monitoring Evaluation (CME) conducted by DTSC, Respondent Boeing was required to implement a DTSC-approved Site Characterization Plan under the corrective action program. Between 1990 and 2000, several groundwater monitoring wells were installed and sampled, rock core sampling was performed at two locations in the northeast and southeast portions of the site, site fracture data were analyzed, aquifer tests were conducted, and a hydraulic communication study was conducted. The results from these activities were presented in several documents submitted over this period. In September 2000, DTSC approved an investigation of the fractured bedrock and deep groundwater at the SSFL (Workplan for Additional Field Investigations, Chatsworth Formation Operable Unit, Santa Susana Field Laboratory dated October 2000). Further site characterization is intended to provide an understanding of the complex fracturedominated groundwater system at SSFL and the movement of contaminants in the groundwater. As of September 2004, more than 400 shallow and deep wells, and piezometers have been installed on and off the SSFL for the purpose of monitoring and characterizing the groundwater and contaminants. 2.5. Potential human and ecologic exposures to chemicals can occur either onsite or as a result of chemical migration to offsite areas. A generalized conceptual site model (CSM) of potential exposure pathways at SSFL has been developed based on field observations, current and future site use scenarios, and data collected during the investigations at the SSFL. The CSM for SSFL is 7­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket, No, P3-07-08-003 described in the 2005 Standardized Risk Assessment Methodology (SRAM) Work Plan (Rev. 2) approved by DTSC. Attachment 6 provides a list of chemical exposure pathways for human health and ecologic risk assessment at the SSFL. 2.6. Types of chemicals used and waste generated at the SSFL are shown on'Attachment 7. Chemicals of potential concern (COPCs) and chemicals of potential ecological concern (COPECs) for input into, respectively, the Human Health and the Ecologic Risk Assessments shall be determined following methods outlined in the DTSC- approved SRAM. Chemicals of Concern (COCs) and Chemicals of Ecological Concern (COECs) shall be identified in each of the RFI reports as they are prepared. Additionally, a list of COCs has been developed for the nine closed surface impoundments as part of the two postclosure permits for Areas I and III, and Area II. COCs from the Post-Closure Permits are listed in Attachment 8. 2.7. Numerous investigations have been conducted to assess the presence of volatile organic compounds (VOCs) in the groundwater beneath the site. A list of chemicals in groundwater at the SSFL identified as of the issuance of this Order is provided in Attachment 9. 2.8: The SSFL is located in hilly terrain, with approximately 1,100 feet of topographic relief near the crest of the Simi Hills. Approximately 70 percent of the area within a 5-mile radius of the SSFL is undeveloped. Residential development is located about % of a mile to the east of the SSFL on Woolsey Canyon Road and in areas about two miles north of the SSFL. Residential areas located Yz mile south of the SSFL are separated from active portions of the SSFL by an undeveloped buffer zone. 2.9. Surface water from the SSFL drains primarily toward the south into Bell Creek and then eastward to the Los Angeles River with its confluence located in the San Fernando Valley. Surface water in the very north portion of the SSFL drains via various drainages into Meier and Black 8­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 Canyons, which lead to the Arroyo Simi located in Simi Valley. Surface water runoff from Happy Valley on the east flows via Dayton Canyon Creek to Chatsworth Creek and then into Bell Creek. Bell Creek subsequently flows southeast to the Los Angeles River. 2.10. Water supply (drinking water) at the SSFL is provided by the Calleguas Water Company. There are currently no domestic water supply wells in use at the SSFL. 2.11. The SSFL is geologically complex consisting of dipping, fractured sandstone and siltstone with several faults. Releases of hazardous wastes or hazardous waste constituents have migrated offsite through groundwater. Trichloroethene (TCE) has been identified in the groundwater at the SSFL and in groundwater'monitoring wells immediately northeast and offsite of the SSFL. Groundwater characterization activities are ongoing to further assess the nature and extent of groundwater contamination at the SSFL. 2.12. Hazardous wastes or hazardous waste constituents have migrated or may migrate from the Facility into the environment through surface water, air, and groundwater (including seeps and springs) pathways. Potential exposures can occur from direct contact with soils, sediments, weathered bedrock, surface water, air, and groundwater, as well as potential indirect exposure to chemicals in plants following uptake from the soil. WORK TO BE PERFORMED Based on the foregoing Findings of Fact, it is hereby ordered and agreed that: 3.1. Respondents shall perform the work required by this Order in a manner consistent with the DTSC-approved RCRA Facility Investigation Workplans and amendments or additions, Corrective Measures Study Workplan, Corrective Measures Implementation Workplan, and any other DTSC­ 9­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 approved workplans; Health and Safety Code and other applicable State and federal laws and their implementing regulations; and applicable DTSC and U.S. EPA guidance documents. Applicable' guidance documents include, but are not limited to, the "RCRA Facility Investigation (RFI) Guidance" (Interim Final, May 1989, EPA 530/SW-89-031), "RCRA Groundwater Monitoring Technical Enforcement Guidance Document" (OSWER Directive 9950.1, September 1986), "Test Methods For Evaluating Solid Waste" (SW-846), and "Construction Quality Assurance for Hazardous Waste Land Disposal Facilities" (EPA 530/SW-85-031, July 1986). 3.2. Corrective Action Schedule 3.2.1. Within 90 days of the effective date of this Order, Respondents shall submit to DTSC for approval a schedule (with tasks, milestones and timeline) for the following: 1. Remediation of chemically contaminated soils by June 30, 2017 or earlier, utilizing the Standardized Risk Assessment Methodology (SRAM) Workplan (Rev. 2). 2. Completion of construction of DTSC-approved groundwater and unsaturated zone cleanup remedies in the Chatsworth Formation OU by June 30, 2017 or earlier. 3. Completion of construction of DTSC-approved long-term soil cleanup remedy in the Surficial Media OU by June 30, 2017 or earlier. If DTSC disapproves the schedule submitted by Respondents, it shall explain the reasons for its disapproval in writing. 3.2.2. In developing the schedule required by section 3.2.1., Respondents shall consider the possibility of completing the sampling of Area IV for chemical contamination prior to DOE's completion of the Environmental Impact Statement for Area IV. 10­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 3.3 Interim Measures (1M). 3.3.1. Interim measures already completed by Respondents are listed in Attachment 10 (Interim Measures Completed). Respondents shall evaluate available data and assess the need for interim measures in addition to those specifically required by this Order. Interim measures shall be used whenever necessary and appropriate or when directed by OTSC to control or abate immediate threats to human health and/or the environment, and to prevent and/or minimize the spread of contaminants while long-term corrective action alternatives are being evaluated. 3.3.2. Respondents shall submit to OTSC a Workplan for the implementation of Groundwater Interim Measures ("1M Workplan") by August 18, 2007, as directed in OTSC's letter to Boeing dated April 18, 2007. The 1M Workplan is subject to approval by OTSC and shall address remediation and/or containment of contaminants at the test stands and other significant release locations. Specifically, these contaminants include but are not limited to: trichloroethene (TCE) and associated breakdown products; N-nitrosodimethylamine (NOMA); 1,4-dioxane; and perchlorate. The interim measures shall include active remedial technologies applied at source zones(s) to eliminate and/or remediate the contaminant mass flux from the source areas. Remedial technologies to be evaluated by the respondent shall include (but need not necessarily be limited to): TCE Oxidation using Potassium- or Sodium-Permanganate; Nanoscale Zero-Valent Iron Particle Technology; Radio Frequency Heating; Blast-Fractured Enhanced Permeability Remediation; Steam Injection; and Enhanced Bioremediation. Pilot studies shall be conducted, as required by OTSC, to assess the effectiveness of different available remedial approaches If OTSC disapproves of the 1M Workplan, it shall explain the reasons for its disapproval in writing. 11­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 3.3.3. In the event Respondents identify an immediate or potential threat to human health and/or the environment, discover new releases of hazardous waste and/or hazardous waste constituents, or discover new solid waste management units not previously identified, Respondents shall notify DTSC's SSFL Project Director orally within 48 hours of discovery (i.e. this shall include preliminary results from laboratory reports) and notify DTSC in writing within 10 days of discovery summarizing the findings, including the immediacy and magnitude of the potential threat to human health and/or the environment. Respondents shall submit to DTSC an 1M Workplan for approval within the time period specified by DTSC. The 1M Workplan shall include a schedule for submitting to DTSC an 1M Operation and Maintenance Plan and 1M Plans and Specifications. The 1M Workplan, 1M Operation and Maintenance Plan, and 1M Plans and Specifications shall be developed in a manner consistent with the Scope of Work for Interim Measures Implementation approved by DTSC. If DTSC determines that immediate action is required, DTSC may orally authorize the Respondents to act prior to DTSC's receipt of the 1M Workplan. 3.3.4. If DTSC identifies an immediate or potential threat to human health and/or the environment, discovers new releases of hazardous waste and/or hazardous waste constituents, or discovers new solid waste management units not previously identified, DTSC shall notify Respondents in writing. Respondents shall submit to DTSC for approval within the time period specified by DTSC an 1M Workplan that identifies Interim Measures that will mitigate the threat. The 1M Workplan shall include a schedule for submitting to DTSC an 1M Operation and Maintenance Plan and 1M Plans and Specifications. The 1M Workplan, 1M Operation and Maintenance Plan, and 1M Plans and Specifications shall be developed in a manner consistent with the Scope of Work for Interim Measures Implementation approved byDTSC. If DTSC determines that emergency action is required, DTSC may orally authorize Respondents to act prior to receipt of the 1M Workplan. 12­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 3.3.5. All 1M Workplans shall ensure that the Interim Measures are designed to mitigate current or potential threats to human health and/or the environment, and should, to the extent practicable, be consistent with the objectives of, and contribute to the performance of, all final remedies that may be required at the Facility. 3.3.6. Concurrent with the submission of an 1M Workplan, Respondents shall submit to DTSC for approval a Health and Safety Plan. 3.3.7. DTSC shall complete the Public Participation Plan (PPP) following consultation with Respondents and the public. DTSC may periodically update the PPP in consultation with Respondents and the public. 3.4. RCRA Facility Investigation (RFI). 3.4.1. DTSC has reviewed the following work plan-related documents associated with the RCRA Facility Investigation (RFI). a) Current Conditions Report and Draft RCRA Facility Investigation Work Plan, Areas I and III, Santa Susana Field Laboratory, Ventura County, California (ICF Kaiser Engineers, October 1993). b) Current Conditions Report and Draft RCRA Facility Investigation Work Plan, Area II and Area I LOX Plant, Santa Susana Field Laboratory, Ventura County, California (ICF Kaiser Engineers, October 1993). c) Current Conditions Report and Draft RCRA Facility Investigation Work Plan, Area IV, Santa Susana Field Laboratory, Ventura County, California (ICF Kaiser Engineers, October 1993). d) Sampling and Analysis Plan, Hazardous Waste Facility Post-Closure Permit PC-94/95­ 3-02, Area II. Santa Susana Field Laboratory, Rockwell International Corporation, Rocketdyne Division (Groundwater Resources Consultants, Inc., June 1995). e) Sampling and Analysis Plan, Hazardous Waste Facility Post-Closure Permit PC-94/95­ 3-03, Areas I and III. Santa Susana Field Laboratory, Rockwell International Corporation, Rocketdyne Division (Groundwater Resources Consultants, Inc., June 1995). 13­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 f) RCRA Facility Investigation Work Plan Addendum, Santa Susana Field Laboratory, Ventura County, California (Ogden, September 1996). g) RCRA Facility Investigation Metals Sampling and Analysis Plan, Santa Susana Field Laboratory, Ventura County, California (Ogden, September 1996). h) Revised Sodium Reactor Experiment (SRE) RFI Workplan Amendment, Santa Susana Field Laboratory, Ventura County, California (Boeing, December 1998). i) Ecological Validation Sampling and Analysis Plan, Santa Susana Field Laboratory, Ventura County, California (Ogden, May 2000). j) RCRA Facility Investigation Work Plan Addendum Amendment, Santa Susana Field Laboratory, Ventura County, California (Ogden, June 2000); k) RCRA Facility Investigation Shallow Zone Groundwater Investigation Work Plan Final, Santa Susana Field Laboratory, Ventura County, California (Ogden, December 2000). I) Workplan for Additional Field Investigations, Chatsworth Formation Operable Unit, Santa Susana Field Laboratory, Ventura County, California (Montgomery Watson, October 2000) m) Workplan for Additional Field Investigations, Former Sodium Disposal Facility, Chatsworth Formation Operable Unit, Santa Susana Field Laboratory, Ventura County, California (Montgomery Watson, June 2000). n) Work Plan for Additional Field Investigations, Former Sodium Disposal Facility (FSDF), Chatsworth Formation Operable Unit, Santa Susana Field Laboratory, Ventura County, California, Revision 2.2 (Montgomery Watson Harza, December 2001). 0) RCRA Facility Investigation Work Plan Addendum Amendment, Building 56 Landfill (SWMU 7.1) Investigation, Santa Susana Field Laboratory, Ventura County, California (Montgomery Watson Harza, May 2003). p) Happy Valley Interim Measures Work Plan Addendum Amendment, Happy Valley and Building 359 Areas of Concern, Santa Susana Field Laboratory, Ventura County, California (Montgomery Watson Harza , August 2003). q) RCRA Facility Investigation Work Plan Addendum, Area I and Area II Landfills Investigation Work Plan, Revised Final, SWMU 4.2 and SWMU 5.1, Santa Susana Field Laboratory, Ventura County, California (Montgomery Watson Harza, October 2003). r) Perchlorate Characterization Work Plan (Revision 1), Santa Susana Field Laboratory, Ventura County, California (Montgomery Watson Harza, December 2003). 14­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 s) RCRA Facility Investigation Program Report, Surficial Media Operable Unit, Santa Susana Field Laboratory, Ventura County, California (Montgomery Watson Harza Inc., July 2004). t) Proposed Drilling, Construction and Testing of Monitor Wells, Area IV, Santa Susana Field Laboratory, Ventura County, California (Haley & Aldrich, August 2004). u) RCRA Facility Investigation Work Plan Addendum Amendment, Surface Flux and Ambient Air Monitoring, Former Liquid Oxygen (LOX) Plant Site (SWMUs 4.5 and 4.6), Ventura County, California, Revision 1 (MWH Americas, Inc., February 2005). v) Standardized Risk Assessment Methodology (SRAM) Work Plan, Santa Susana Field Laboratory, Ventura County, California, Revision 2- Final (MWH Americas, Inc., September 2005). w) RCRA Facility Investigation Vapor Migration Modeling Validation Study Work Plan, Santa Susana Field Laboratory, Ventura County, California (MWH Americas, Inc., November 2005). x) Vapor Migration Modeling Validation Study Work Plan Amendment, Santa Susana Field Laboratory, Ventura County, California (Boeing,June 2006). 3.4.2. Respondents shall submit to DTSC for approval RFI Reports for the Surficial Media OU in accordance with the schedule stipulated in Section 3.2.1 and approved by DTSC. The SSFL has been divided into 10 Surficial Media OU Group Reporting Areas as listed on Attachment 11 and shown on the map on Attachment 12. An Ecologic Large Home Range report shall also be prepared. The Surficial OU Reports shall be developed in a manner consistent with the approved workplans, workplan amendments, and approved Standardized Risk Assessment Methodology Work Plan (Rev. 2) and future amendments. DTS9 shall review the Surficial OU Reports and notify Respondents in writing of DTSC's approval, conditional approval, or disapproval. 3.4.3. The comprehensive Surficial OU Reports shall summarize the findings from all phases and areas of the SSFL. The Surficial OU Reports shall include all current and historical assessment data collected to date for the vicinity of the unit being investigated in the RFI program. The nine (9) surface impoundments shall also be addressed and included in the Surficial OU Reports. Data 15­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07 -08-003 generated during the investigation and remediation shall be provided to DTSC to allow evaluation of the potential for release of other hazardous constituents. 3.4.4. Each Respondent shall submit with each Surficial OU Group report historical records and documentation, within its possession and control, of all activities associated with each SWMU and AOC in an electronic format. This shall include primary historical records that list or describe any known and/or suspected chemicals stored, handled or released in the study area. Historical information may include (but need not necessarily be limited to) available photographs, drawings, manifests, memoranda, tabulations, lists and any other records regarding the operations conducted in the study area, and the types and sources of chemicals that may have been handled or released in the study areas. 3.4.5. Respondents shall submit in a separate report historical and other documents as described in Section 3.4.4 that are not submitted with individual Surficial OU Group Reports. 3.4.5.1. Within 120 days of the effective date of this Order, Respondent Boeing shall also provide in hard copy transcripts of the deposition testimony of fact witnesses pertaining to SSFL operations and waste management activities from lawsuits involving the SSFL in which Boeing or Rockwell International was a party. 3.4.5.2. If Respondents assert that any document to be submitted pursuant to Section 3.4.4, 3.4.5 or 3.4.5.1 may contain confidential business information, Respondents shall comply with the provisions of California Code of Regulations, title 22, section 66260.2 and the specific text on the page that Respondents consider to be confidential shall be identified. Documents containing confidential business information are to be provided in hard copy to DTSC. All other historical documents are to be submitted in an electronic format with electronic reference list (searchable by key word). 16­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 3.4.5.3. Nothing in Sections 3.4.4, 3.4.5, 3.4.5.1, or 3.4.5.2 of this Order shall require Respondents to provide to DTSC any documents protected from disclosure by applicable legal protections, including without limitation the attorney-client privilege and the attorney-work product doctrine, or shall prevent Respondents from asserting that such applicable legal protections prevent disclosure. 3.4.6. Respondents shall identify and provide to DTSC copies of all available aerial photographs of SSFL taken by Respondents and others operating under contract(s) to Respondents. 3.4.7. Respondents shall demonstrate and certify that they have conducted a reasonable search for the documents required in 3.4.4, 3.4.5 and 3.4.5.1 and include a signed copy of the Signature and Certification stipulated in section 4.4.3 of this Order to certify a reasonable search was completed for each Surficial OU Group Report 3.4.8. Reports prepared by the Respondents or their consultants in support of the Surficial OU RFI shall be submitted in both hard copy and electronically to DTSC. Electronic copies shall be submitted in an electronic format that allows them to be searchable by key word. 3.4.9. Within 120 days of the effective date of this Order, the Respondents shall prepare and submit to DTSC a report summarizing all off-site media sampling and testing data for chemical and radiologic contaminants conducted by the Respondents around SSFL. The summary report shall itemize all separate off-site sampling programs, specify the objectives, summarize the conclusions and summarize results. The report shall include maps and figures of SSFL and surrounding areas showing sample locations, sample results, and sample identification numbers referenced to tables of the analytical results and sample information. The map or maps shall have a key which identifies the sample as to sample media type (air, surface water, soils, groundwater, seeps, and springs). The data table summaries shall be referenced to the original reports. The Respondents shall review the 17­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07 -08-003 data and make conclusions and recommendations as to the completness of the sampling, and recommendations for additional sampling if needed. A bibliography of all original work plans, Health and Safety Plans, Quality Assurance Plans and final reports shall be compiled, and electronic versions of those origi.nal reports shall be included on a CD with the report. 3.4.10. If DTSC determines, based on its evaluation of the report specified in 3.4.9 of this Order, that additional work is required, Respondents shall submit and carry out, by dates to be specified by DTSC, the following workplans: 1. A Workplan to monitor potential presence of airborne chemical and radiologic releases from the SSFL in communities and residential areas surrounding SSFL. 2. A Workplan to sample all'the surface drainages leading offsite from the SSFL property to evaluate potential chemical and radiologic releases into drainages leading away from SSFL. The Workplan shall also identify and include a proposal for sampling seeps and springs in the vicinity of SSFL. 3. A Workplan to collect surface soils and sediment samples in communities surrounding SSFL for chemical and radiologic testing. The Workplan shall include the rationale for selecting the locations of these samples. 3.4.11. Within 180 days of the date of this Order, the Respondents shall proyide to DTSC access to a fully-interactive Geographic Information System (GIS) mapping data base with SSFLrelated chemical and radiologic data (both onsite and offsite) collected by Respondents, georeferenced to SSFL base maps suitable for analyses of data by location, media type, chemical and radiologic analytes, sample identification numbers, and all other sample data parameters. 3.4.12. Respondents shall prepare and submit to DTSC for approval workplans to complete the ongoing Chatsworth Formation groundwater investigation in the northeast (transects) and site­ 18­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07 -08-003 wide groundwater investigation at SSFL. Respondents shall submit these workplans and technical memoranda/reports to DTSC for approval in accordance with the schedule in Attachment 13. These workplans shall include a Phase 2 Groundwater Site Conceptual Model Work Plan (submitted) to drill a series of additional coreholes offsite in the northeast portion of SSFL to assess the extent and migration of TCE and other VOCs in this area, and a Phase 3 Groundwater Site Conceptual Model Work Plan (submitted) that shall collect additional data, including installation of discrete multi-port samplers in wells, spring sampling, and geophysical logging to supplement the Site-wide groundwater investigation. Respondents shall also submit a Site-Wide Groundwater RFI WorkPlan to assess the nature and extent of all COPCs in groundwater and the unsaturated zone sitewide. Respondents shall prepare and submit the following reports/technical memoranda in accordance with the qates specified in Attachment 13: an update to the Conceptual Site Model Technical Memorandum submitted April 2000; 3-D Flow Model Technical Memorandum describing the numerical groundwater model; Phase 2 Northeast Area Groundwater Characterization Technical Memorandum; and the Sitewide Geology Report. The nine (9) surface impoundments shall be addressed and included in the Chatsworth Formation OU Report. 3.4.13. Within 120 days of the date of this Order, the Respondents shall prepare and submit to DTSC for approval a revised Facility-wide Water Quality Sampling and Analysis Plan (WQSAP) that includes the use of low-flow purging and sampling approaches. 3.5. Corrective Measures Study (CMS). 3.5.1. Respondents shall prepare and submit a CMS Workplan to DTSC for the Surficial Media OU and Chatsworth Formation OU (including both groundwater and the unsaturated zone) in accordance with the schedule specified in Section 3.2.1 of this Order. The eMS Work plans for the Surficial Media OU and Chatsworth Formation OU (including both groundwater and the unsaturated 19­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 zone) are subject to approval by DTSC and shall ~e developed in a manner consistent with the Scope of Work for a Corrective Measures Study approved by DTSC. 3.5.2. The CMS work plans shall detail the methodology for developing and evaluating potential corrective measures to remedy chemical contamination at the Facility utilizing the Standardized Risk Assessment Methodology (SRAM) Workplan (Rev. 2). The CMS Workplan shall identify the potential corrective measures, including any innovative technologies that may be used for the containment, treatment, remediation, and/or disposal of contamination. Potential groundwater corrective measures shall evaluate all state.:.of-the-art remedial technologies including but not limited to the following: TCE Oxidation using Potassium- or Sodium-Permanganate; Nanoscale Zero-Valent Iron Particle Technology; Radio Frequency Heating; Blast-Fractured Enhanced Permability Remediation; Steam Injection; and Enhanced Bioremediation. 3.5.3. Respondents shall complete treatability studies for all potential corrective measures that involve treatment except where Respondents can demonstrate to DTSC's satisfaction that treatability studies are not needed. The CMS Work plans shall include, at a minimum, a summary of the proposed treatability studies including conceptual designs, a schedule for submitting treatability study workplans, or Respondents' justifications for not proposing treatability studies. 3.5.4. Respondents shall submit CMS Reports to DTSC for approval in accordance with the DTSC-approved CMS Workplan schedule. DTSC shall review the CMS Reports and notify Respondents in writing of DTSC's approval or disapproval. If DTSC disapproves of the CMS Reports in whole or in part, it shall explain in writing the reason(s) for its disapproval. 3.6. Remedy Selection. 20­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07 -08-003 3.6.1. At a minimum, DTSC shall provide the public with an opportunity to review and comment on the final draft of the CMS Reports, DTSC's proposed corrective measures for the Facility, and DTSC's justification for selection of such corrective measures. DTSC shall conduct a public hearing to obtain comments. 3.6.2. Following the public comment period, DTSC may select final corrective measures or require Respondents to revise the CMS Reports and/or perform additional corrective measures studies. 3.6.3. DTSC shall notify Respondents of the final corrective measures selected by DTSC in the Final Decision and Response to Comments. The notification shall include DTSC's reasons for selecting the corrective measures. 3.7. Corrective Measures Implementation (CMI). 3.7.1. Within 90 days of Respondents' receipt of notification of DTSC's selection of the corrective measures for the Surficial au and Chatsworth Formation au (including both groundwater and the unsaturated zone), Respondents shall submit to DTSC Corrective Measures Implementation (CMI) Workplans. The CMI Workplans are subject to written approval by DTSC. If DTSC disapproves of the CMI Workplans in whole or in part, it shall explain in writing the reason(s) for its disapproval. 3.7.2. Concurrent with the submission of the CMI Workplans, Respondents shall submit to DTSC a Health and Safety Plan. 3.7.3. The CMI program shall be designed to facilitate the design, construction, operation, maintenance, and monitoring of corrective measures at the Facility. In accordance with the schedule contained in the approved CMI Workplan, Respondents shall submit to DTSC the documents listed below. 21­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 • Operation and Maintenance Plan • Draft Plans and Specifications • Final Plans and Specifications • Construction Workplan • Construction Completion Report • Corrective Measures Completion Report 3.7.4. DTSC shall review all required CMI documents and notify Respondents in writing of DTSC's approval or disapproval. If DTSC disapproves of the required CMI documents in whole or in part, it shall explain in writing the reason(s) for its disapproval. 3.7.5. Within 90 days of DTSC's approval of all required CMI documents, Respondents subject to financial assurance requirements shall establish a financial assurance mechanism for Corrective Measures Implementation. The financial assurance mechanisms may include any mechanism described in California Code of Regulations, title 22, sections 66264.143 or 66265.143 as applicable. The parties acknowledge that, pursuant to title 22, sections 66264.140(b)(4) and 66265.140(c), federal agencies are not subject to the financial assurance requirements specified above, and that the purpose of establishing a financial assurance mechanism is to demonstrate that Respondents subject to financial assurance requirements are financially capable of performing the Corrective Measures Implementation and to enable DTSC to undertake Corrective Measures Implementation tasks in the event that Respondents subject to financial assurance requirements are unable or unwilling to undertake the required actions. Respondents subject to financial assurance requirements shall annually adjust the mechanism for inflation in accordance with California Code of Regulations, title 22, sections 66264.142 or 66265.142 as applicable. 22­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 3.8. CEQA. Respondents shall provide all information necessary to facilitate DTSC's preparation of a CEQA analysis, including a Facility-wide Environmental Impact Report (EIR). OTHER REQUIREMENTS AND PROVISIONS 4.1. Project Coordinator. Within 14 days of the effective date of this Order, the Respondents shall each designate a Project Coordinator and shall notify DTSC in writing of the Project Coordinator~ selected. Each Project Coordinator shall be responsible for overseeing the implementation of this Order and for designating a person to act in his/her absence. All communications between Respondents and DTSC, and all documents, report approvals, and other correspondence concerning the activities performed pursuant to this Order shall be directed through their respective Project Coordinators. Each party may change its Project Coordinator with at least seven days prior written notice. DTSC's designated Project Coordinator is Mr. Norman E. Riley, DTSC SSFL Project Director. 4.2. Web Site 4.2.1. Respondents shall establish and maintain a web-based site which shall be used for posting of documents and information related to Corrective Action and cleanup of SSFL. The content of the website shall be solely under the control of DTSC. No changes to the website shall be made without prior DTSC approval. 4.3. DTSC Approval. 4.3.1. Subject to the dispute resolution procedures in Sections 4.19.1.1 through 4.19.1.6, Respondents shall revise any workplan, report, specification, or schedule in accordance with DTSC's 23­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 written comments. Respondents shall submit to DTSC any revised documents by the due date specified by DTSC. Revised submittals are subject to DTSC's written approval or disapproval. If DTSC disapproves of any submittal in whole or in part, it shall explain in writing the reason(s) for its disapproval. 4.3.2. Upon receipt of DTSC's written approval, Respondents shall commence work and implement any approved workplan in accordance with the schedule and provisions contained therein. 4.3.3. Any DTSC approved workplan, report, specification, or schedule required by this Order shall be deemed incorporated into this Order. 4.3.4. Any requests for revision of an approved workplan requirement must be· in writing. Such requests must be timely and provide justification for any proposed workplan revision. DTSC shall approve such proposed revisions absent good cause not to do so. Any approved workplan modification shall be in writing and shall be incorporated by reference into this Order. 4.3.5. Verbal advice, suggestions, or comments given by DTSC representatives shall not constitute an official approval or decision. 4.4. Submittals. 4.4.1. Beginning with the first full month following the effective date of this Order, Respondents shall continue to provide DTSC with quarterly progress reports of corrective action activities conducted pursuant to this Order. Progress reports are due on the last day of the first month following the close of each reporting period. DTSC may adjust the frequency of progress reporting to be consistent with site-specific activities. 4.4.2. Any report or other document submitted by each Respondent pertaining to its activities at the Site pursuant to this Order shall be signed and certified by a responsible corporate officer, or a duly authorized representative. 24­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 4.4.3. The certification required above, shall be in the following form: .1 certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations .. Signature: Name: Title: Date: 4.4.4. Except as provided in Sections 3.4.5.1 and 3.4.5.2, reports and other documents prepared by the Respondents or their consultants in response to this Order shall be submitted in both hard copy and electronically to DTSC. Electronic copies of reports, workplans, technical memoranda, and other documents shall be submitted to DTSC in a format that allows them to be word searchable. Respondents shall provide eight (8) hard_copies and twelve (12) electronic copies of all documents, including but not limited to, workplans, reports, and correspondence of 15 pages or longer to DTSC's Regional office in Sacramento, two (2) hard copies and two (2) electronic copies to DTSC's Regional office in Cypress, one (1) electronic copy to DTSC's Regional office in Berkeley, one (1) electronic copy to the consultant or contractor who maintains the website specified in Section 4.2.1 of this Order, and one (1) hard copy and one (1) electronic copy to DTSC's Administrative File for SSFL (currently DTSC's Regional Office located in Glendale as of the date of this Order). Submittals specifically exempted from this copy requirement are all progress reports and correspondence of less than 15 pages, of which only one (1) copy is required. DTSC may designate that additional hard copies and/or electronic copies (or both) be provided simultaneously to designated repositories. If Respondents assert that any document to be submitted may contain confidential business 25­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 information, Respondents shall comply with the provisions of California Code of Regulations, title 22, section 66260.2 and the specific text on the page that Respondents consider to be confidential shall be identified. Documents containing confidential business information are to be submitted in hard copy to DTSC. 4.4.5. Unless otherwise specified, all reports, correspondence, approvals, disapprovals, notices, or other submissions relating to this Order shall be in writing and shall be sent to the current Project Coordinators. 4.5. Proposed Contractor/Consultant. All work performed pursuant to this Order shall be under the direction and supervision of a professional engineer or registered geologist, registered in California, with expertise in hazardous waste site cleanup. Respondents' contractor or consultant shall have the technical expertise sufficient to fulfill his or her responsibilities. Within 14 days of the effective date of this Order or any contract awarded to implement this Order, Respondents shall notify the DTSC Project Coordinator in writing of the name, title, and qualifications of the professional engineer or registered geologist and of any contractors or consultants and their personnel to be used in carrying out the requirements of this Order. 4.6. Quality Assurance. 4.6.1. All sampling and analyses performed by Respondents under this Order shall follow applicable DTSC and U.S. EPA guidance for sampling and analyses. Workplans shall contain quality assurance/quality control and chain of custody procedures forall sampling, monitoring, and analytical activities. Any deviations from the approved workplans must be approved by DTSC prior to implementation, must be documented, including reasons for the deviations, and must be reported in the applicable report (e.g., RFI Report). 26­ ,-­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 4.6.2. The names, addresses, and telephone numbers of the California State-certified analytical laboratories Respondents propose to use must be specified in the applicable workplans. 4:6.3. All workplans required under this Order shall include data quality objectives for each data collection activity to ensure that data of known and appropriate quality are obtained and that data are sufficient to support their intended uses. 4.6.4. Respondents shall monitor to ensure that high quality data are obtained by its consultant or contract laboratories. Respondents shall ensure that laboratories used by Respondents for analysis perform such analysis according to the latest approved edition of "Test Methods for Evaluating Solid Waste, (SW 846)," or other methods deemed satisfactory to DTSC. If methods other than U.S. EPA methods are to be used, Respondents shall specify all such protocols in the applicable workplan (e.g., RFI Workplan). DTSC may reject any data that do not meet the requirements of the approved workplan, U.S. EPA analytical methods, or quality assurance/quality control procedures, and may require resampling and analysis. 4.6.5. Respondents shall ensure that the California State-certified laboratories used by Respondents for analyses have quality assurance/quality control programs. DTSC may conduct a performance and quality assurance/quality control audit of the laboratories chosen by Respondents before, during, or after sample analyses. Upon request by DTSC, Respondents shall have their selected laboratory perform analyses of samples provided by DTSC to demonstrate laboratory performance. If the audit reveals deficiencies in a laboratory's performance or quality assurance/quality control procedures, resampling and analysis may be required. 4.7. Sampling and Data/Document Availability. 27­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 4.7.1. Respondents shall submit to DTSC upon request the results of all sampling and/or tests or other data generated by its employees, agents, consultants, or contractors pursuant to this Order. Respondents shall follow the same signature and certification requirements of sections 4.4.2 and 4.4.3 above for information submitted pursuant to this section. 4.7.2. Notwithstanding any other provisions of this Order, DTSC retains all of its information gathering and inspection authority and rights, including enforcement actions related thereto, under Health and Safety Code, and any other State or federal statutes or regulations. 4.7.3. Respondents shall notify DTSC in writing at least 7 days prior to beginning each separate phase of field work approved under any workplan required by this Order. If Respondents believe they must commence emergency field ·activities without delay, Respondents may seek emergency telephone authorization from the DTSC Project Coordinator or, if the Project Coordinator is unavailable, his/her designee, to commence such activities immediately. 4.7.4. At the request of DTSC, Respondents shall provide or allow DTSC or its authorized representative to take split or duplicate samples of all samples collected by Respondents pursuant to this Order. Similarly, at the request of Respondents, DTSC shall allow Respondents or their authorized representative(s) to take split or duplicate samples of all samples collected by DTSC under this Order. 4.8. Access. 4.8.1. Subject to the Respondents' security and safety procedures at the Facility, Respondents shall provide DTSC and its representatives access at all reasonable times, following· normal Boeing procedures for access onto the site, to the areas of the Facility under each Respondent's control and any other property to which access is required for implementation of this Order and shall permit such persons to inspect and copy all non-privileged records, files, 28­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07 -08-003 photographs, documents, including all sampling and monitoring data, that pertain to work undertaken . pursuant to this Order and that are within the possession or under the control of Respondents or their contractors or consultants. 4.8.2. To the extent that work being performed pursuant to this Order must be conducted beyond the Facility property boundary, Respondents shall use their best efforts to obtain access agreements necessary to complete work required by this Order from the present owners of such property within 30 days of approval of any workplan for which access is required. "Best efforts" as used in this paragraph shall include, at a minimum, a letter by certified mail from the Respondents to the present owners of such property requesting an agreement to permit Respondents and DTSC and their authorized representatives access to such property. Any such access agreement shall provide for access to DTSC and its representatives. Respondents shall provide DTSC's Project Coordinator with·a copy of any access agreements in their possession. In the event that an agreement for access is not obtained within 30 days of approval of any workplan for which access is required, or of the date that the need for access becomes known to Respondents, Respondents shall notify DTSC in writing within 14 days thereafter regarding both the efforts undertaken to obtain access and the failure to obtain such agreements. DTSC may, at its discretion, assist Respondents in obtaining access. 4.8.3. Nothing in this section limits or otherwise affects DTSC's right of access and entry pursuant to any applicable State or federal law or regulation. 4.8.4. Nothing in this Order shall be construed to limit or otherwise affect Respondents' liability and obligation to perform corrective action including corrective action beyond the Facility boundary. 4.9. Record Preservation. 29­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 4.9.1. Respondents shall retain, during the implementation of this Order and for a minimum of ten (10) years after the Acknowledgement of Satisfaction executed pursuant to Section 6 of this Order, all data, records, and documents that relate to implementation of this Order or to hazardous waste management and/or disposal. Respondents shall notify DTSC in writing 90 days prior to the destruction of any such records, and shall provide DTSC with the opportunity to take possession of any such records. Such written notification shall reference the effective date, caption, and docket number of this Order and shall be addressed to: Mr. Norman E. Riley SSFL Project Director Department of Toxic Substances Control P.O. Box 806 Sacramento, California 95812-0806 4.9.2. If Respondents retain or employ any agent, consultant, or contractor for the purpose of complying with the requirements of this Order, Respondents shall require any such agents, consultants, or contractors to provide Respondents a copy of all documents produced pursuant to this Order. 4.9.3. All documents pertaining to this Order shall be stored in a manner to afford ease of access by DTSC and its representatives. 4.10. Change in Ownership. No change in ownership or corporate or partnership status relating to the Facility shall in any way alter Respondents' responsibility under this Order. No conveyance of title, easement, or other interest in the Facility, or a portion of the Facility, shall affect Respondent's obligations under this Order. Unless DTSC agrees that such obligations may be . transferred to a third party, Respondents shall be responsible for and liable for any failure to carry out all activities required of Respondents by the terms and conditions of this Order, regardless of Respondents' use of employees, agents, contractors, or consultants to perform any such tasks. 30­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 4.11. Notice to Contractors and Successors. Respondents shall provide a copy of this Order to all contractors, laboratories, and consultants retained to conduct or monitor any portion of the work performed pursuant to this Order and shall condition all such contracts on compliance with the terms of this Order. Each Respondent shall give written notice of this Order to any successor in interest prior to transfer of ownership or operation of any portion of the Facility that the Respondents own or operate and shall notify DTSC at least thirty (30) days prior to such transfer. 4.12. Compliance with Applicable Laws and Regulations. All actions taken pursuant to this Order by any of the Parties shall be undertaken in accordance with applicable local, State, and federal laws and regulations Respondents shall obtain or cause their representatives to obtain all permits and approvals necessary under such applicable laws and regulations. 4.13. Costs. Respondents are liable for all costs associated with the implementation of this Order, including all costs incurred by DTSC in overseeing the work required by this Order, to the extent authorized under Health and Safety Code Sections 25269-25269.6, including procedures for dispute resolution. DTSC shall retain all cost records associated with the work performed under this Order as required by State law. DTSC shall make all documents which support the DTSC's cost determination available for inspection upon request, as provided by the Public Records Act 4.14. Endangerment during Implementation. In the event that DTSC determines that any circumstances or activity (whether or not pursued in compliance with this Order) are creating an imminent or substantial endangerment to the health or welfare of people at the Facility or in the surrounding area or to the environment, DTSC may order Respondents to stop further implementation of this Order for such period of time as needed to abate the endangerment. Any deadline in this Order directly affected by an Order to Stop Work under this section shall be extended for the term of the Order to Stop Work. 31­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 4.15. Liability. Nothing in this Order shall constitute or be construed as a satisfaction or release from liability for any conditions or claims arising as a result of past, current, or future operations of Respondents. Notwithstanding compliance with the terms of this Order, Respondents may be required to take further actions as are necessary to protect public health or welfare or the environment. 4.16. Government Liabilities. The State of California shall not be liable for injuries or damages to persons or property resulting from acts or omissions by Respondents or related parties specified in section 4.20 in carrying out activities pursuant to this Order, nor shall the State of California be held as a party to any contract entered into by Respondents or its agents in carrying out activities pursuant to the Order. 4.16.1. Availability of Federal Funds -- DOE and NASA. It is the expectation of DTSC that the federal agencies under this Order shall seek sufficient funding through the federal budgetary process to fulfill the requirements under this Order. It is agreed that if inadequate funds are appropriated for such purposes, the federal agencies shall notify DTSC immediately and develop a plan in writing to secure additional funding to carry out the requirements of this Order. Nothing herein shall be construed as precluding federal agencies from arguing either that the unavailability of appropriated funds constitutes a force majeure, or that no provisions of this Order shall be interpreted to require the obligation or payment of funds in violation of the Anti-Deficiency Act, 31 U.S.C. 1301 or 1341. The Parties agree that in any proceeding to enforce the requirements of this Order, federal agencies may raise as a defense that any failure or delay was caused by the unavailability of appropriated funds. 4.16.2. Limitation of Federal Funds -- Boeing. The Parties acknowledge that some of the work required by this Order will be performed by Respondent Boeing pursuant to separate contracts between Boeing and Respondent DOE or Boeing and Respondent NASA. These contracts are 32­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 subject to federal funds appropriated to DOE or NASA. If arid to the extent that Boeing is required to seek specific funding from a federal agency under such contracts in order to satisfy contractual obligations that comply with this Order and such funding is unavailable, nothing in this Order shall be construed to require Boeing to perform work under this Order that is to be performed in satisfaction of such contractual obligations between DOE and Boeing or NASA and Boeing, or shall prevent Boeing from raising as a defense that any failure or delay under such circumstances constitute a force majeure. 4.17. Reservation of Rights. By issuance of this Order, DTSC does not waive the right to take further enforcement actions. Except as otherwise provided in this Order, Respondents reserve all of their statutory, regulatory and common law rights, defenses and remedies that may pertain to this Order. This Order shall not be construed as a covenant not to sue, release, waiver, or limitation on any rights, remedies, powers, or authorities" civil or criminal, that DTSC or Respondents have under any statutory, regulatory, or common law authority. 4.18. Incorporation of Plans and Reports. All plans, schedules, and reports that require DTSC approval and are submitted by Respondents pursuant to this Order are incorporated in this Order upon approval by DTSC. 4.19. Penalties for Noncompliance. Respondents shall be liable for stipulated penalties in the amount of $15,000 for a material failure to comply with the requirements of this Order, including the making of any false statement or representation in any document submitted for purposes of compliance with this Order. If DTSC can discern that a specific Respondent(s) is responsible for a material failure to comply with the requirements of this Order, DTSC shall proceed only against the responsible Respondent(s) for associated stipulated penalties. "Compliance" by Respondents shall include completion of the activities under this Order or any workplan or other plan approved under 33­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 this Order within the specified time schedules established by and approved pursuant to this Order. All penalties shall begin to accrue on the day after the complete performance is due or the day a violation occurs, and shall continue to accrue through the final day of the correction of the noncompliance or completion of the activity. Nothing herein shall prevent the simultaneous accrual of separate penalties for separate violations of this Order as provided by Health and Safety Code sections 25188,25189 and 25189.2 and other applicable provisions of law. Following DTSC's determination that Respondents have materially failed to comply with a requirement of the Order, DTSC shall give Respondents written notification of the violation and describe the noncompliance. At its sole discretion, DTSC may send Respondents a written notice of noncompliance with an opportunity to cure by a date designated by DTSC in lieu of a written demand for the payment of the penalties. Respondents, individually or collectively, may dispute DTSC's finding of noncompliance by invoking the dispute resolution procedures described in Sections 4.19.1.1 through 4.19.1.6 herein. Penalties shall accrue but need not be paid during the dispute resolution period. If Respondents do not prevail upon resolution, all penalties shall be due to DTSC within thirty (30) days of resolution of the dispute. If Respondents prevail upon resolution, no penalties shall be paid. 4.19.1.1. Dispute Resolution. The parties agree to use their best efforts to resolve all disputes informally. The parties acknowledge that the three (3) Respondents to this Order each have differing ownership and operational responsibilities for various portions of the Facility and the work addressed in this Order. Each Respondent expressly reserves its right to dispute any finding of noncompliance that applies to actions for which it is not responsible or for which it relies in whole or in part on the actions of another Respondent(s). The parties agree that, except as otherwise specifically provided for by Sections 25269.2 and 25269.5 of the Health and Safety Code for cost recovery disputes; the procedures contained in this section are the required administrative procedures for resolving disputes 34­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 arising under this Order. If any Respondent fails to follow the procedures contained in this section, that Respondent shall have waived its rights to further consideration of the disputed issue. Respondents each reserve their respective legal rights to contest or defend against any final decision rendered by DTSC under this Order. 4.19.1.2. If any Respondent disagrees with any written decision by DTSC pursuant to this Order, such Respondent's Project Coordinator shall orally notify DTSC Project Coordinator of the dispute. The Project Coordinators shall attempt to resolve the dispute informally. 4.19.1.3. If the Project Coordinators cannot resolve the dispute informally, the disputing Respondent(s) may pursue the matter by placing an objection in writing. Disputing Respondent's written objection must be forwarded to the DTSC Director or his/her designee, with a copy to DTSC Project Coordinator. The written objection must be mailed to the DTSC Director or his/her designee within fourteen (14) days of the disputing Respondent's receipt of DTSC's written decision. Disputing Respondent's written objection must set forth the specific points of the dispute and the basis for Respondent's position. 4.19.1.4. DTSC and the disputing Respondent(s) shall have fourteen (14) days from DTSC's receipt of each disputing Respondent's written objection to resolve the dispute through formal discussions. This period may be extended by DTSC for good cause. During such period, Respondent(s) may meet or confer with DTSC to discuss the dispute . . 4.19.1.5. After the discussion period, DTSC shall provide the Respondent(s) with its written decision on the dispute, which shall constitute a final agency decision. DTSC's written decision shall reflect any agreements reached during the formal discussion period and be signed by the DTSC Director or his/her designee. 35­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 4.19.1.6. During the pendency of all dispute resolution procedures set forth above, the time periods for completion of work to be performed under this Order that are affected by such dispute shall be extended for a period of time not to exceed the actual time taken to resolve the dispute. The existence of a dispute shall not excuse, toll, or suspend any other compliance obligation or deadline required pursuant to this Order except to the extent that such other compliance obligation or deadline is dependent upon the resolution of the matter which is the subject of Dispute Resolution under this Order, in which case the time periods for completion of such other compliance obligations or deadlines required pursuant to this Order that are affected by such Dispute Resolution shall be extended for a period of time not to exceed the actual time taken to resolve the dispute. 4.19.2. Force Majeure. The Respondents shall cause all work to be performed within the time limits set forth in this Order unless an extension is approved or performance is delayed by events that constitute an event of force majeure. For purposes of this Order, an event of force majeure is an event arising from circumstances beyond the control of the involved Respondents that delays performance of any obligation under this Agreement, provided the involved Respondents have undertaken all appropriate planning and prevention measures to avoid any foreseeable circumstances. Increases in cost of performing the work specified in this Order shall not be considered circumstances beyond the control of the involved Respondents. For purposes of this Order, events which constitute a force majeure shall include, without limitation, events suy b D ocumen t Document WPA (1996) WPAA(2000) DTSC Site Reviews (1997/1998) Area VII Landfill WP (2003) Letter WPs (1997/1998) Totals Proposed for Sampling Total RFI RFI SWMUs/AOCs 64 Sites 34 SWMUs/AOCs 40 Sites 27 6 29 5 6 7 7 52 13 2 5 2 2 2 3 5 3 106 51 106 51 Notes: 1. Sampling plans included in referenced document or as directed during field investigation by DTSC. 2. Because of proximity, Buildings 011 and 008 will be reported together as one RFI site. 3. Only SWMUs and AOCs considered part of each RFI site are listed. No RCRA permitted units or closed USTs are shown, with the exception of tanks for which DTSC has requested additional characterization. All SWMUs and AOCs included in the RFI are listed here and designated in Table 1-3 by "RFI" under "Current Status." 4. Leach Field AOCs originally introduced in the RFA (SAIC 1994). See Acronym List for acronym defmitions 65­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 ATTACHMENT 6 LIST OF SURFICIAL OU AND CHATSWORTH FORMATION OU EXPOSURE PATHWAYS NEAR SURFACE EXPOSURE PATHWAYS AND SOURCE MEDIA Direct Contact • Soil • Sediment • Weathered bedrock • Surface water (secondary medium) • Near-surface groundwater (showering) • Near-surface groundwater (seep/spring) Vapor or Dust Inhalation(a) GROUNDWATER EXPOSURE PATHWAYS AND SOURCE MEDIA Direct Contact • Chatsworth formation groundwater (showering) • Chatsworth formation groundwater (seep/spring) Vapor Inhalation(a) • • • • Soil Near-surface groundwater Ingestion • Soil • Sediment • Weathered bedrock • Surface water • Near-surface groundwater (well drinking water) • Near-surface groundwater (spring/seep) • Plant uptake and vegetation (home garden) Chatsworth Chatsworth Ingestion • Chatsworth • Chatsworth MIGRATION PATHWAYS SURFICIAL OU -7 CFOU • formation groundwater formation unweathered bedrock formation groundwater (well drinking water) formation groundwater (seep/spring) MIGRATION PATHWAYS CFOU -7 SURFICIAL OU Mass transport of chemicals in primary surficial media (soil, sediment, weathered bedrock, and near-surface groundwater) and secondary media (surface water) down to the Chatsworth formation Note: (a) Includes inhalation of ambient vapor as well as intrusion into buildings 66­ • Vapor migration of volatile chemicals from unweathered bedrock or Chatsworth formation groundwater up to the surface • Mass transport of chemicals in Chatsworth formation groundwater to the surface as spring or seep water, or into the weathered bedrock as near-surface groundwater Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 ATTACHMENT 7 SSFL HAZARDOUS WASTE CONSTITUENTS OF CONCERN ASSOCIATED WITH ROCKET TESTING The hazardous waste and hazardous waste constituents of concern at the SSFL associated with rocket engine testing include: Liquid rocket test fuels - RP-1 (high-grade kerosene), JP-4 (a type of jet fuel) monomethyl hydrazine, hydrazine, derivatives, and liquid hydrogen, as well as various by-product of the combustion of these materials, Oxidizers - liquid oxygen and nitrogen tetroxide, and various fluorine compounds and inhibited red fuming nitric acid, Solvents - trichloroethylene, the primary solvent used at SSFL, used to clean engine components before and after testing, The hazardous waste and hazardous waste constituents of concern at the SSFL associated with other research and development activities include the following: Halogenated solvents - 1,1, 1-trichloroethane, tetrachloroethylene, 1, 1-dichloroethane, and chlorofluorocarbons, Caustic solutions - potassium hydroxide and sodium hydroxide, Reactive metals - sodium and other reactive metals, "Green Liquor" wastewater - generated from coal gasification operations, containing organics, sulfur compounds, and ash, Energetic materials - perchlorate, glycidyl azide polymer, hexahydro-1,3,4-trinitro-1,3,5-triazine (RDX), oxtahydro-1,3,5,7 -tetranitro-1,2,5,7 -tetrazocine (HMX), and other ordnance compounds, Polychlorinated biphenyls (PCBs) - transformers and, Various chemicals - used in laboratory operations, such as solvents, acids, and bases Laboratory wastes - from cleaning laboratory instruments, such as waste solvents, acids and bases 67­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 Waste oil - sumps and clarifiers, Construction debris - including concrete, wood, metal and asbestos, Incinerator ash - dioxin and metals, sewage - from onsite sewage treatment plants Radioactive wastes - materials, and fuels - Area IV only; radioactive mixed wastes are not regulated under RCRA and are being evaluated by DOE under a , separate program at the Facility Biocides - cooling tower, water treatment chemicals which include copper and chromium compounds. 68­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 ATTACHMENT 8 CHEMICAL OF CONCERN FROM POST CLOSURE PERMITS SSFL Acetone Carbon Tetrachloride Methylene Chloride Chloroform Flouride Freon 11 Freon 113 Formaldehyde Ammonia Nitrate Methyl Ethyl Ketone Benzene Toluene Xylenes Ethylbenzene PCE TCE Cis-1,2-DCE Trans-1,2-DCE 1,1-DCE Vinyl Chloride 1,1,1-TCA 1,1,2-TCA 1,2-DCA 1,1-DCA 1A-dioxane N-nitosodimethylamine Nitrobenzene 69­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 ATTACHMENT 9 LIST OF CHEMICALS IDENTIFIED IN GROUNDWATER AT SSFL 1,1, I-trichloroethane I,I,2--trichloroethane I,2-dichloroethane I,I-dichloroethane chloroethane I,4-dioxane tetrachloroethylene trichloroethylene cis-I,2-dichloroethylene trans-I,2-dichloroethylene I,I-dichloroethylene vinyl chloride n-nitrosodimethylamine 1,2,3-trichloropropane I,3-dinitrobenzene nitrobenzene nitrate perchlorate petroleum hydrocarbons (various ranges) benzene ethylbenzene :1~~il'~~H48.?:Z9]1&p:'7~( "''''..' '.',...:"",,, ,>" •. acetone ammonia as nitrogen fluoride carbon tetrachloride methylene chloride chloroform chloromethane trichlorotrifluoroethane (Freon 113) trichlorofluoromethane (Freon 11) dichlorodifluoromethane (Freon 12) poly-chlorinated di-benzo dioxins/furans fonnaldehyde cadmium chromium copper lead manganese nickel silver thallium zinc 70­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 ATTACHMENT 10 INTERIM MEASURES COMPLETED DATE 1999-2000 NAME Happy Valley Interim Measure 2000 Former Sodium Disposal Facility (FSDF) 2003 - 2004 Happy Valley Interim Measures 2004 Building 203 Interim Cleanup Measure 71­ ACTION Over 1,600 cubic yards of woil and debris were removed from drainage containing metals/perchorate and geophysical surveys in support of ordnance investigation Over 20,000 cubic yards of material were excavated to remove elevated concentrations of dioxins, PCBs, and mercury. Approximately 8,500 cubic yards of perchlorate impacted soils and surficial weathered bedrock excavated during removal action primarily from the southern Happy Valley Drainage area. Approximately 8,000 cubic yards are undegoing bitotreatment of perchlorate. Interim measures were performed north of Building 203 to remove mercury-impacted soils to prevent migration of mercury in soil downslope. Approximately 3,000 cubic yards of soil and bedrock that contained mercury were excavated. Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 ATTACHMENT 11 RFI GROUP AREA REPORTS FOR SSFL RFI Group Report Area Group 4 - NASA Group 1A - Boeing Group 8 - Boeing & DOE Group 2 - NASA Group 3 - NASA & Boeing Group 1B - Boeing Group 5 - Boeing & DOE Group 9 - Boeing & NASA (DOE contribution) Group 7 - DOE Eco / Large Home Range Note: Group 6 RFI Report submitted October 2006 72­ Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 ATTACHMENT 12 SSFL RFI Group Report Areas --..-...z . . . . . "!;:~~.~ ,J • " ,~,,""'~-<"" \ /' r\" ~ j i , ~h'~rr";;"-~"''''' I"~"~.,j" ' ~l,4:'" .~, ._"_, ~ ./~~"'"."./',,~J7;.,.~ \ ~ . , _ " ' ~ f ; . ' , ~ f t r ' ~ ' " I ' ~.,~.~J f,~i . ' /: ,~,c.""" ' ,,,,,'_ " , "~ ", ' ~ ~"./ I '~ y'~,--",",,, "'~' ~' ~~_~"" ~~ ~.';f". ~~~n..,~'~"'<'" ~~ ~. ,~ ",,'y~ 8~;..4;""" '_1i'I · ~ , :'lID",;.do''''''''fi'' )t!.~ ~ 2!.i "",' "~"_'Pt~;"-;'_' ~,/'; "' '~ ' I' "t~S'"(H'J;~'1\l-;~t"\)¥<~"" r"~t,"'. . :~I',"_: :!'j::",'.="" ~:~:H "'"". ~ ..,.~."...'~ _r . ~ _---'\'" , i'-~""~- -,', b ' ".~ ,._~. ./ ." ",~/~J """",,j? ~9~;"" ~ 1-"­ ~~ ,2... ,_h.'' "....~. 7~+--' .~.,.!~~_' ~"'l~r .'. n" -~""l~ ~" '~' ~," .~ -~' ",~,,, ~/" j:;:-"-.q~,'~if@"~ . ~ r~ ~"~" .~~~'l' ~ \"j'"r ",--r~< . . . , <~4.;'>~-.1-,.~' --'. ".' "~fi:- z,. ~ " ' -,~" ),' ,,-", ""j " ••w.. ....orpoI_.p.ts- ............-...u --'YI~...WO ...­ _b ..... :..__ IOaf!M.. ..-..~ l. ...-,n-' " • . -:.,.• ~ 6 ._.,.... iL,- "-:,,, ; ,., " ..•., 7 . ... " ,,<" .._ ."g' ..t"" ,,_._,"..•"'",;f..i' ... '".•.. . ..!!.;:,_iI!i ,"_ " . ,,iI ".... "._,_;_{. / .. ;:"<> "-:'\'";;J"'I"''':"_"'';':');';.. '"""', .. ':'" (, '''-- ' ' F'-­ \"', '?/­ ,/>,J \,.):d'I, ,( ",-' " ..' •,,"A " " ' ,' ' ,.'__ ' J"" i [' '\: - .' ---,,- ' ,,1\<1 ,... , .,., .".<,-A""l;' ,,/YfCiJii:;"ir.--,' ,-..YA..... ..-. ,,"''}'l'" "., I "'.. . . .' I .."Y __ ... . ,.. .._••"'" ' ' ,,_""'" . " , , , , ' ,. c: ' - r ' --'>'' ' ;ffi , ._<::, ........ _"' , ,/ ',' ..' - .'.' , ,. ,f)' __ ,.,J, ". - " '. '_ ", , '-" I ,.. ," J,;.:;,. :;",..a ,!' ,·'t. , ',.:." • , " .. If"<",' c.:::...J I' '\ " ,'"' """". ". . ."" "o . _ ,,,,--J-"""" ''''''! -r-'/"' ', --" ,"-- "-.- '-- : ," J .'\'-..>1... ,"">,", ... -")1'\. "f,," i 0 '. r=> " ItJil!!lU.. ..... ~.; .. iIr ...." . . ,....I,i_'" ' . '0 ' r;' ' , '" ' -' " "(' J .: : -... . -d...rl' .. -, . ­ "~e v ''-~,;1;~~_~_t:=~1!~~~~~~~~~~"~.,.:E.:~~" "-­ I-' \t-- Q ,~L'" ", ",¥,,,,"," " ''0' k """,. , • _ "",," "-,, I '. " ,- , 1">-·/·: " .. ,'-', ... .!!!"......;<."' ".-' ,-'"11" , t,, " "', ==.._ " 1;,-""".....,'. • , '--_. __ .;--;..' ..,.." ?" ,;j,J' ,,:, , ", , " .. N '., '\ .. "'--', 9 ',,_ " ,'lb" , '" ' _" " .... .. ,--' ....,,. "-<, " I/ "",,,,, --,' - "" LGIimPld=a I::;RU~'l'jllU.·1 Lv [ll!npo"niltl(J:J~; [].'" za f.::J It."" • o 00':: teuiQ [].""',. :.1~:.iI.i-.~~. I" alluNijllt-;tM h'clc.ri: I. h~IJ w....~L'..tzllt.. ;aJ1...~Ul.DIIC". . . I... ~ Z. OC';....I.....: ..-.Jwtd_.,.;L>.a"Ut-p.Io"........................~ ~ M .... d,_"jo ..... LI.I~ttW.lrA..U.:.:iUlwll. .... !II.~A~... Iif""·d.l:i;iJ::ltt-h.U~iJpt-l .... ~ )U'OU.WII• ,..au·u.I".QIo~ e , .. !....,.I!:.........""r~ olr"G:"""..,..,.UIioj,..," Source: RFI Report Group 6, MWH September 2006, 73­ ~~""~"""--' C1.....---~. D­ .•-"'-~ I"lIIl.. a;r r v r.......... t'V­ II Sf L R.FI R.eport GroupIngs -......... II~"" nln... u ~~~- .. ~~- Santa Susana Field Laboratory, Simi Hills, Ventura County, California Consent Order for Corrective Action, Docket No. P3-07-08-003 ATTACHMENT 13 Chatsworth Formation Groundwater Characterization Work Plan and Report Submittal Schedule WORKPLANS Phase 2 Groundwater Site Conceptual Model WorkPlan Phase 3 Groundwater Site Conceptual Model Workplan Site Wide Groundwater RFI WorkPlan DUE DATE June 15, 2007 (submitted) REPORTS/TECHNICAL MEMORANDUMS Conceptual Site Model Update Technical Memorandum and Site-Wide Geology Report 3-D Flow Model Technical Memorandum Phase 2 Northeast Area Groundwater Characterization Technical Memorandum DUE DATE August 31,2007 July 18, 2007 (submitted) January 15, 2008 74­ November 1, 2007 February 1, 2008