Help Us, Ensure a Proper Cleanup...

of the Santa Susana Field Laboratory

September of 2012

September 21, 2012

 

Dear Public Participation Group Member:

 

In 2010, the Department of Toxic Substances Control (DTSC) established the Public Participation Group (PPG) in response to feedback from the community.  Many of you expressed a desire for more regular and direct engagement between DTSC and the stakeholders and communities that surround the Santa Susana Field Laboratory (SSFL).  DTSC asked for volunteers to serve on the PPG, and you and others in your community generously offered to serve your neighbors.  Since then, the PPG for the Santa Susana Field Lab has been an important vehicle for public participation. Its members, like you, have demonstrated the power of community service.

On September 12, 2012, DTSC received a petition that meets California’s statutory requirements for a Community Advisory Group (CAG).  Based on our legal responsibilities, DTSC will assist in the formation of a CAG.  Because the roles and goals of a CAG and the PPG are very similar and because DTSC’s resources are limited, DTSC has decided to dissolve the PPG and conclude its work. We encourage you and other members of the PPG to apply for a position on the CAG.  We see the CAG as an important component of focusing community interest as we approach significant milestones in the investigation and cleanup of SSFL.

Why is DTSC taking this step?  Apart from the legal requirement to begin the formation of a CAG, DTSC sees this as an opportunity for the community to tailor its informational needs on its own, rather than having those needs translated by DTSC’s cleanup team.  As you know, the PPG was operated by DTSC and its facilitator. The CAG process gives the community the opportunity to set the agenda for dialogue, while allowing DTSC and other regulatory agencies the opportunity to focus on addressing community questions and considering feedback to our decisions.

A more detailed communication regarding these very important issues will be sent shortly to the SSFL e-mail list.  It will provide more detail on the CAG formation process.  It also will outline various activities - apart from the CAG - that we will use to continue providing the community with site and project information as well as access to our staff and our decision-making process. 

I want to thank you, on behalf of all who work on this project, for your commitment to public involvement and your service on the Public Participation Group. Your participation has given us valuable information, and your dedication to a full cleanup of this site is a gift to future generations who will live and work in the community.

Sincerely,

 

Deborah O. Raphael

Director


Aerospace Contamination Museum of Education ACME
Santa Susana Field Laboratory
Special Update

  

September 21, 2012 


This e-mail will inform you of steps the Department of Toxic Substances Control (DTSC) is taking to address public outreach for the SSFL site.

  

Community interaction and input are a vital component of our work at SSFL. We know that many in the SSFL community have dedicated much of themselves to ensuring that this site is investigated and cleaned up to the most protective standards possible as established in our Administrative Orders of Consent (AOCs) and other agreements with the responsible parties. DTSC would like to thank everyone who has taken the time and made the effort to provide us with their ideas and input and for their patience as we have wrestled with these very important decisions regarding public outreach.

  

Last fall, DTSC Director Debbie Raphael met with a number of community members (both at a meeting of the SSFL Public Participation Group (PPG) and individually) to introduce herself. More importantly, she wanted to better understand your community and your relationship to DTSC and its efforts at SSFL. She was being pressed to make a number of key decisions about DTSC's public participation efforts at SSFL (related to the PPG, the Interagency Workgroup and previous requests for a Community Advisory Group (CAG)). Since then, DTSC has continued to evaluate options to provide your community with information about the project, ways that you have said you'd like to receive that information and methods to provide feedback. While many DTSC outreach and involvement efforts have continued (numerous technical roundtable discussions, monthly email project updates, etc.), neither the PPG nor the Interagency Workgroup have been convened.  DTSC and Director Raphael sincerely appreciate your patience as we have carefully considered all of the information and input we have received.

  

Some recent events have created an opportunity for DTSC to be even more responsive to the many opinions that have been expressed and to allow your community more control over public participation efforts rather than being led and controlled by DTSC.

  

On September 13, 2012 DTSC received a petition to form a CAG. A CAG is a type of community group that is provided for in DTSC's statute. For all sites DTSC oversees, the department is required to provide opportunities for meaningful public participation. There is a particular section of law that allows a community to petition DTSC to form this type of group and requires DTSC, when it receives a petition, to help the community form the CAG. DTSC has determined that the petition meets the statutory requirements. So, in the coming weeks, DTSC will be assisting in the formation of a CAG.

  

DTSC also has decided to dissolve the PPG and conclude its work.

  

Why is DTSC taking this step? Apart from DTSC's legal obligation to help in the creation of a CAG, DTSC sees this as an opportunity for the community to tailor its forum and decide its informational needs on its own, rather than having those needs translated by DTSC's cleanup team. (The PPG was operated by DTSC and its facilitator).

  

The CAG process allows the community the opportunity to set the agenda for dialogue, while allowing DTSC and other regulatory agencies the opportunity to focus on addressing community questions and consider feedback to our decisions. Further, because the roles and goals of a CAG and the PPG are nearly identical and because DTSC's resources are limited, it does not make sense nor is it affordable for DTSC to continue to operate the PPG.

  

We appreciate the members of the community who volunteered their time to serve on the PPG, and to the extent that they would like to continue in a similar capacity on the CAG, encourage them and anyone else who is interested to apply for a CAG position when that opportunity is made available.

  

DTSC has also made a decision about the SSFL Interagency Workgroup. We have received considerable input from community members who want to see the Workgroup continue. We recognize that the Workgroup has served an important role in serving the community for many years. We also recognize that the Workgroup's function and format is different than that of a CAG or the PPG. Based on this input, DTSC has decided to honor the wishes of a large portion of the community to continue the operation of the Interagency Workgroup. There are, however, some fundamental changes that we need to make in in our relationship with the group.

  

Similar to changing our roles and relationships by switching from a DTSC-led PPG to a community-led CAG, DTSC believes there needs to be a similar shift in the Workgroup - from being led by DTSC or another agency to being community-led. DTSC will be meeting with community members who sit on the Workgroup in the next few weeks to discuss the changes that will help us move forward.

  

It is important for everyone in the community to know and understand that DTSC receives feedback and comments through many avenues, and there is no obligation for anyone to participate in these forums in order to have input into DTSC's cleanup decisions. In addition, DTSC does not intend the formation and operation of two different community groups to in any way diminish the role or importance of the other to receive input from the community on site-related issues. DTSC equally values and takes into account input it receives from any person who shares their views with us.  

  

There are many instances in which the public's viewpoints and insights have led us to make changes to investigation or cleanup plans because we've been presented with new or different information that we may not have considered. It is important to note that we value good information that supports our decision making process, no matter where that good information comes from.  

  

We want to remind everyone that while the community forum elements of DTSC's relationship with the public are important, there are myriad other ways that DTSC has been and will continue to provide the community with site-related investigation and cleanup information, and where the community can offer its feedback on plans and reports being presented.

  

The following is a brief listing and description of all of the components of DTSC's public outreach efforts.

  

Public Forums

  • Community Advisory Group
  • Community Workgroup

DTSC Presentations

  • Technical Roundtable Discussions
  • Community Updates/Open Houses

Information posted to the Website

  • Overviews of activities
  • Calendar of events
  • Document Library
  • Public Involvement documents
  • Response to comments

Public comment Periods

  • Public comment periods are held for draft documents for significant milestones of the project
    • Site investigation plans
    • Site cleanup plans
    • Environmental Impact reports

Mail & Email information

  • Community Updates emailed and/or Hard copy mailed to more than 900 community members

Information Placed in local Repositories

  • Technical and community documents are placed in local repositories for review
  • Repositories are located in Simi Valley, Chatsworth (at the DTSC office), Woodland Hills & Northridge

Public Notices

  • Public Notices are printed in the Los Angeles Daily News, Ventura County Star and Simi Valley Acorn

We believe that through all of these opportunities, the community can obtain the information they desire in the form and format that is most comfortable for them. We welcome feedback from the community so that we can make our efforts better and more useful.

  

We hope through these different forums and methods that we are meeting the community's needs and helping everyone to see the tremendous amount of work being done to accomplish those goals.

  

DTSC Staffing of SSFL Project

  

In order to facilitate communication, we are providing you with a list of DTSC contacts. A talented team has been assembled to complete the SSFL project. The team is "housed" in DTSC's Cleanup program, overseen by Deputy Director Stewart Black.


Santa Susana Field Laboratory 

Monthly Status Report 

September 2012 

This monthly update is to inform the community of the Santa Susana Field Laboratory (SSFL) investigation and cleanup activities under the California Department of Toxic Substances Control’s (DTSC) oversight that occurred in September, 2012, as well as activities that are expected to occur in October 2012. An overview summary of The Boeing Company, United States Department of Energy (DOE) and NASA areas at SSFL is included at the end of this report. 

Completed Within the Past 30 Days 

DTSC 

Chemical Soil Background Study 

During the public-review-and-comment period that closed September 4, 2012, DTSC received several stakeholder comments and questions regarding the Study’s draft report. DTSC prepared responses to the comments and took into consideration making several revisions to the draft report to clarify certain statements therein. DTSC will post the responses along with the final report to the SSFL website. 

DTSC received from its independent contractor, Dr. Mark Schilling – California State University, Northridge, draft background threshold values (BTVs) based on combining data for those constituents that were not previously combined in the initial, stratified statistical assessments. 

California Environmental Quality Act (CEQA) 

DTSC worked with the CEQA contractor, AECOM, to plan the overall SSFL CEQA approach. DTSC expects to have the recommended approach posted in early-September. 

DTSC prepared a Notice of Exemption for the Groundwater Interim Measures (GWIM) Work Plan and the notification was filed. 

A CEQA Initial Study is being prepared for the chemical oxidation field test. 

NASA 

In August 2012, NASA completed the first phase of sample collection to complete soil and surficial media chemical characterization at the two SSFL areas under its administration. These areas include the 41-acre NASA portion of Area I (the former Liquid Oxygen (LOX) Plant) and the 409-acre Area II. Samples collected during this nine month program are currently being analyzed and data is being generated for assessment of the extent of remaining chemical data gaps. The second and final phase of sample collection is expected to commence in late spring 2013. 

DOE 

US Environmental Protection Agency (EPA), in coordination with DTSC and DOE, is implementing its second round of sampling efforts to define the nature and extent of radiologic contamination in Area IV. US EPA's round two sampling locations are based upon the validated sampling results they received from their Round 1 sampling. In coordination with DTSC, DOE continues to conduct Phase 3 Soil Chemical Data Gap Investigation sampling in subareas located throughout Area IV. The status of the Phase 3 soil chemical investigation sampling efforts is presented below. 

Northern Buffer Zone (Phase 1 Co-Located and Phase 2 Random Co-Located): 

All field work has been completed. 

All of the analytical results have been received and 50 percent have been validated. 

Deep Borings (Phase 1 Co-Located): 

All field work has been completed. 

All of the analytical results have been received and validated. 

HSA-5A (Phase 3 Data Gap Investigation): 

Addendum No. 4 to Master Field Sampling Plan for Phase 3 Chemical Data Gap Investigation, Subarea 5A approved by DTSC on September 4, 2012. 

Standard Operating Procedure No. 14 (revision 1) Geophysical Survey approved by DTSC on September 24, 2012. 

Geophysical Survey conducted. 

HSA-5B (Phase 3 Data Gap Investigation): 

Approximately 92 percent of the surface and subsurface soil boring sample locations have been completed. 

Approximately 8 percent of sampling locations consist of trenches and test pits that will be completed after the geophysical survey is conducted this fall (2012). 

Six locations were not sampled due to their proximity to archaeological zones. 

All of the analytical results have been received; however, validation has not yet started. 

Geophysical Survey conducted. 

HSA-5C (Phase 3 Data Gap Investigation): 

Approximately 77 percent of surface and subsurface soil boring sample locations have been completed. The remaining 13 percent of sample locations consist of trenches and test pits that will be completed after the geophysical survey to be conducted this fall (2012). 

All of the analytical results have been received; however, validation has not yet started. 

Geophysical Survey conducted. 

Area III Drainage Sediment Sampling (Phase 3 Data Gap Investigation): 

All field work is now complete. 

100 percent of the analytical results have been received; however, validation has not yet started. 

Boeing 

Investigation 

DTSC is continuing to work with Boeing to address DTSC comments and finalize the data quality objective process. The data quality objectives need to be worked out prior to developing the data gap investigation documents. 

Building Demolition 

DTSC requested that Boeing not begin demolition of non-radiological buildings in Area IV pending the resolution of radiological characterization and disposal issues. DTSC is coordinating the radiological characterization issue with the California Department of Public Health and the USEPA. 

DTSC continues to review demolition proposals for two Boeing Area IV Non-Radiological areas. Building 4015 and Potable Water Tanks 812/851. 

Groundwater Characterization and Cleanup 

The groundwater characterization and cleanup program is being conducted by Boeing on behalf of the three parties at the site; Boeing, DOE and NASA. The groundwater characterization and cleanup program consists of: 

o Investigation and characterization of groundwater contamination 

o Ongoing groundwater monitoring of existing wells, 

o Sampling of new groundwater locations, and 

o Treatment of contaminated groundwater with permitted discharge from the Groundwater Extraction and Treatment System. 

Groundwater Investigation 

DTSC has been meeting with Boeing/DOE and NASA to discuss specific recommendations regarding additional sampling to complete the groundwater investigation. Additional seep sampling locations and geophysical work as well as additional well sampling locations have been identified. 

On August 31st a draft work plan for completing the investigation of seeps and springs was submitted. DTSC is reviewing the work plan. 

On September 13th DTSC submitted comments on the Happy Valley pump test work plan. (well RD-10). 

On September 24th a public meeting was held to present an update on the groundwater characterization process. 

Groundwater Monitoring 

Sampling for the 2012 third quarter monitoring event was completed. 

Groundwater Interim Measures 

WS-09A is being pumped to lower the groundwater elevation and reduce the amount of Trichloroethene (TCE) contamination in the groundwater near the southwest corner of 

Area II. This area is located north of the southern buffer zone. 

The public review and comment period on the draft 2009 Groundwater Interim Measures work plan continued through the month of September and closes on October 1st. The project includes the installation and operation of eight source zone groundwater extraction wells, with the water being sent to the existing Groundwater Extraction Treatment System. 

Treatability Studies 

Treatability studies are being conducted on several technologies to be evaluated in the feasibility study. The treatability studies address both soil/bedrock and groundwater contamination. Treatability studies can be either field studies or laboratory studies. 

Four groundwater laboratory studies are being conducted: 

o Chemical oxidation using potassium permanganate, 

o Thermal heating of rock core, 

o Microbial characterization of rock core, pore water, and 

o Bio-Stimulation. 

Status of Treatability Study Testing 

Boeing's contractors are continuing work on the chemical oxidation, microbial characterization, and bio-stimulation laboratory studies. 

Two proposed field tests are in the planning stage: 

o Bedrock Vapor Extraction 

-DTSC, Boeing, DOE and NASA are working through final comments on the work plan addendum. 

o In-situ chemical oxidation (groundwater). 

–On September 24, 2012, DTSC issued an approval of the In-situ chemical oxidation field test work plan and addendum. 

–The next step is to complete the initial study for CEQA, and to post a public notification. 

Interim Source Removal Actions (ISRA) (Note: ISRA activities are conducted under the authority of the Los Angeles Regional Water Quality Control Board (LA-RWQCB)) 

NASA reinitiated ISRA soil excavation activities On September 5, 2012 at Ash Pile/Sewage Treatment Plant (AP/STP) area. The AP/STP ISRA excavation activity is anticipated to remove approximately 4,000 yards of soil and be completed within four weeks, pending acceptable confirmation soil sample results. Excavation and subsequent re-grading are expected to be completed this year before onset of rainy season. 

Boeing received soil sample results and completed delineation ISRA soil removal area IEL-3. Waste characterization planning is ongoing. Excavation and subsequent surface re-grading are expected to be completed this year before onset of rainy season. 

Public Participation 

The GWIM Work Plan is available for review and comment. The Public Comment began on August 31, 2012 and ends on October 1, 2012. All comments and questions should be sent to Roger Paulson, Project Manager, at roger.paulson@dtsc.ca.gov or at 8800 Cal Center Drive, Sacramento, CA, 95826. 

On 9/12/2012 DTSC staff participated in a Congressional Site Tour at SSFL. 

On 9/24/2012 Boeing and DTSC held a public meeting to discuss the Groundwater Investigation and Groundwater data gap activities. At SSFL. 

On September 27, 2012, DOE hosted a Soils Treatability Investigation Group Meeting for community members which included a presentation by Sandia National Laboratory regarding recommendations for soil treatability studies. 

Activities Expected to Occur Within the Next 30 Days: 

DTSC 

Chemical Soil Background Study 

DTSC will continue reviewing and finalizing the draft combined-data BTVs; to be issued as a supplement to the final report. 

DTSC expects to post to the SSFL website the final report, responses to comments, and combined-data BTVs by mid-October. 

California Environmental Quality Act (CEQA) 

DTSC will prepare an SOQ to select a contractor for programmatic CEQA work. 

DTSC will submit a CEQA Initial Study for the chemical oxidation field test. 

Boeing 

DTSC is working with Boeing to address DTSC comments and finalize the data quality objective process. The data quality objectives need to be worked out prior to developing the data gap investigation documents. 

Chemical Oxidation Field Study 

DTSC will approve the construction of monitoring wells to be used in an in-situ chemical oxidation field test. 

An initial study for CEQA will be prepared and the public notification will be made. 

Bedrock Vapor Extraction Field Study 

DTSC will finalize review and responses for bedrock vapor extraction work plan. 

Building Demolition 

DTSC anticipates resolving radiological screening and waste disposal issues for two Boeing Area IV Non-Radiological areas (Building 4015 and Potable Water Tanks 812/851).Pending resolution of the remaining screening and disposal issues, DTSC concurrence with the demolition plans may be provided by October 8, 2012. No other Boeing Area IV demolition proposals have been submitted for review by DTSC. 

Feasibility Study 

DTSC is completing review of the Feasibility Study for site-wide groundwater and bedrock/soils. The Feasibility Study identifies, develops, and evaluates a range of potential technologies that can be used during remediation and disposal activities. Upon completion of this review, the document will be available for public review and comment. 

Interim Source Removal Actions (ISRA) (Note: ISRA activities are conducted under the authority of the Los Angeles Regional Water Quality Control Board (LA-RWQCB)) 

Boeing is planning to conduct ISRA soil removal at a single Area I location in the vicinity of Building 300 after demolition of the building is complete. 

NASA expects to initiate ISRA excavation work in Area II Ash Pile/Sewage Treatment Plant (AP/STP) areas in early September 2012. Excavation and subsequent surface re-grading is expected to be completed this year, before the onset of the rainy season. 

Boeing and NASA are expected to submit the 2011-2012 Rainy Season Summary Report. 

Groundwater Investigation and Cleanup 

DTSC will submit responses to public comments on the Groundwater Remedial Investigation Document. 

Begin RD-10 pump test at Happy Valley. 

Approve and install new groundwater injection and monitoring wells near the former building 300 pad. 

Meet with RPs to plan faults characterization work plan. 

Conduct public meeting on seeps and springs. 

Begin 4th quarter groundwater elevation gauging. 

NASA 

Data Summary Reports for the first phase of the 2011-2012 chemical data gap investigation (Field Sampling Plans (FSPs) 1 through 5) are in preparation for release in 2013. 

A second and final phase of NASA surficial media sampling (FSP-6) will be prepared to account for data gaps remaining from the initial five FSPs implemented in 2011-2012. 

DOE 

Draft Addendum No. 5 to Phase 3 Master Field Sampling and Analysis Plan for Subareas 3 and 6 to be submitted for review/approval. 

Phase 3 soil sampling activities will continue in Area IV. 

Public Outreach 

The Chemical Soil Background Study Report was available for comment in September. The public comment period for this document concluded on 9/4/2012. 

The Groundwater Interim Measures Work plan is available for public review and comment as of October 1, 2012. 

On Monday, September 24, 2012 Boeing, DOE, NASA and DTSC provided an update on the Groundwater Investigation and groundwater data gap activities. 

On September 27, 2012, DOE held a Soil Treatability Investigation Group (STIG) meeting. 

DTSC will continue to provide monthly updates regarding the progress of the site investigation and cleanup process to the community. 

DTSC is in the process of working with the SSFL Community to establish a Community Advisory Group (CAG). As this process progresses additional information will follow via the DTSC/SSFL email list, website and other communication mediums. 

On October 23, 2012, DTSC and Boeing will conduct a community meeting and site visit to discuss the Groundwater and Seeps at SSFL. Additional information can be found on the SSFL calendar at the SSFL website. 

On October 25, 2012, DTSC and DOE will host a technical stakeholder meeting to discuss the proposed Phase 3 chemical data investigation sampling approach for Subareas 3 and 6. The meeting will be held at the SSFL site from 9:30 a.m. until 12:30 p.m. Parties interested in attending should contact Jazmin.bell@emcbc@doe.gov 

Overview 

U.S. Department of Energy (DOE) 

DTSC and U.S. Department of Energy (DOE) are participating in chemical soil sampling efforts in Area IV of the SSFL property where former DOE activities occurred on the Site. Area IV is a 290-acre area located in the northwestern section of the site. DOE owns facilities on a 90-acre site within Area IV. Area IV includes the Energy Technology Engineering Center (ETEC) facility where nuclear research, development, and testing began in the 1950’s. 

The Area IV radiological soil sampling effort is being conducted by the United States Environmental Protection Agency (US EPA). The US EPA approached the investigation by splitting the Area IV and Northern Buffer Zone (NBZ, collectively referred to as the “Site”) investigation into historical site assessment (HSA) subareas. The chemical soil sampling efforts follow the same HSA subarea designations. DOE and DTSC are participating in Area IV and NBZ co-located soil sampling for chemical contaminants. 

The sampling includes three phases, as specified in the December 2010 Administrative Order on Consent for Remedial Action (AOC), signed by DTSC and DOE: 

o Phase 1 - co-located sampling for chemical analysis at US EPA’s first phase of radiological sampling locations in Area IV and the NBZ. 

o Phase 2 sampling is identified as randomly selected sampling locations, and 

o Phase 3 sampling, identified as the Chemical Data Gap Investigation that shall be used to determine the locations at the Site where insufficient chemical data exists and additional chemical investigation is necessary. 

US EPA, in coordination with DTSC and DOE, has implemented its second round of sampling efforts to define the nature and extent of radiologic contamination in Area IV. US EPA’s round two sampling locations are based upon the validated sampling results they received from their Phase 1 sampling. 

Findings of the chemical data gap investigation may not result in sampling at all of the same locations that US EPA identified for additional sampling during the second round. Not all of US EPA’s Round 2 sample locations were sampled for chemical contaminants, and chemical data gap investigation locations may be required where no radiological sampling is needed. The rationale and selection of chemical data gap investigation sampling locations will be provided in the Work Plan for Chemical Data Gap Investigation, Phase 3 Chemical Sampling at Area IV, and discussed with the community. 

NASA 

NASA is currently conducting chemical data gap investigations to complete soil and surficial media characterization at the two SSFL areas under its administration that include the 41.7-acre NASA administered portion of Area I (the former Liquid Oxygen (LOX) Plant), and 409.5-acre Area II. Area II was used primarily for rocket engine testing and includes the Alfa, Bravo, Coca, former Delta Test Stands and support structures. Under the terms of the December 2010 Administrative Order on Consent (AOC), NASA is developing and implementing a series of five Field Sampling Plans (FSPs) to address data gaps in the soil investigations. A sixth NASA surficial media FSP will be prepared in late 2012 to account for any data gaps remaining from the initial five FSPs. 

A summary of the five current NASA surficial media FSPs is provided below: 

FSP-1 (Alfa-Bravo Fuel Farm, Coca-Delta Fuel Farm, Propellant Load Facility) 

o All soil chemical field work completed 

o Data Summary Report anticipated in Summer 2012 

FSP-2 (Incinerator/Ash Pile/Sewage Treatment Plant, Building 204, Storable Propellant Area, and Skyline Road) 

o All soil chemical field work completed 

o Data Summary Report anticipated in late-Summer 2012 

FSP-3 (Alfa Test Stand, Bravo Test Stand) 

o Field sampling completed 

o Data Summary Report anticipated in late Summer 2012 

FSP-4 (Liquid Oxygen Plant, Area 2 Landfill, Expendable Launch Vehicle) 

o Field sampling underway 

o Data Summary Report anticipated in Fall 2012 

FSP-5 (Coca Test Stand, former Delta Stand, R2 Ponds) 

o Field sampling underway 

o Data Summary Report anticipated in Fall 2012 

Boeing 

Boeing owns most of Area I and all of Areas Ill and IV. Areas I and Ill total 791 acres and are operated by Boeing. Boeing also owns the 1143 acre southern buffer zone and 182 acre northern buffer zone. Soils in Area IV and the northern buffer zone are being characterized in the DOE portion of the project. 

Boeing continues to investigate and characterize soils in Area I, Area Ill, and the southern buffer zone. Data Gap Sampling and Analysis Plans (Data Gap SAPs) will be prepared to address data gaps identified in the Resource Conservation and Recovery Act (RCRA) Facility Investigation Reports submitted to date. DTSC anticipates these activities will complete the characterization of the Boeing sites. 

Boeing sites are located in Reporting Groups 1A, 1B, 5, 9 and 10. Boeing intends to prepare the Data Gap SAPs in subgroups identified as Boeing RFI Groups: 

o 1A North, 1A Central, 1A South 

o 1B North, 1B Southwest, 1B Southeast 

o 5/9 North, 5/9 South, and 

o Group 10