DSHW-1995-004329 - 0901a06880157ce6

June 15, 1995 QEr^pn/Fr) ^\jf^
jijhi 211995 EarthFax
Mr. A. Frank Walker EarthFax
Environmental Engineer Divisivi Cs SbiitJ & 5:;:.::^!-^-; '^'%„ Engineering Inc,
Thiokol Corporation Utah OepatiiTKnt Oi ["VWutit'iii^ii^i i.'?*^!;-^ Engineers/Scientists
P.O. Box 689 7324 So. Union Park Ave.
Brigham City, Utah 84302-0689
Subject: Certification of M-136 Burn Ground Partial Closure
Dear Mr. Walker:
Suite 100
Midvale, Utah 84047
Telephone [phone]
Fax [phone]
In accordance with the requirements of Federal regulation 40 CFR 265.115 and Utah
regulation R315-7-14,1 have made an independent review of the "Partial Closure Plan, M-136
Burn Grounds" dated November 1992 and the associated document entitled "Partial Closure
of M-136 Burn Ground: Results of Investigative Phase", dated May 1995. Based on my
review, it is my professional opinion that the May 1995 report satisfies the Phase I and Phase
II reporting requirements of the approved closure plan.
Furthermore, it is my professional opinion that the May 1995 report documents that
statistically significant concentrations of contaminants (as compared with background) did not
exist at locations 21, 22, 23, 24, and 25 of the M-136 Burn Ground except in the case of
arsenic, HMX, and selenium. With respect to these constituents, the May 1995 report
documents that:
o Arsenic is not a constituent of the propellants manufactured at Thiokol and is,
therefore, a probable artifact of the local fill material. Furthermore, the
concentrations of arsenic which were discovered are well below accepted risk-
based criteria which would require action, thus negating the need for
remediation.
o HMX is present at concentrations which are well below accepted risk-based
criteria which would require action. Furthermore, HMX is a common ingredient
of propellants which are disposed of at the M-136 Burn Ground, making
cleanup potentially ineffective with continued use of the Burn Ground in the
future. Thus, remediation of the locations with respect to HMX is not
considered necessary.
o Selenium is present in the M-136 Burn Ground at concentrations which are
significantly less than background, thus negating the need for remediation.
The May 1995 report also documents that residue from within and adjacent to the subject
burn trays has been removed and disposed of in accordance with the approved Closure Plan.
Thus, removal of additional soil and implementation of additional closure activities is not
considered necessary.
Mr. A. Frank Walker
June 15, 1995
Page 2
Therefore, based on my review of the above information, I certify that partial closure of the
M-136 Burn Ground which was the subject of the November 1992 Closure Plan has been
completed in accordance with the approved closure plan.
Please be advised that 40 CFR 265.115 also requires similar certification of closure by the
owner or operator. Please contact me if you have any questions.
Sincerely,
^ctjvU% \r:s€^
Richard B. White, P.E.
Principal
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