DSHW-1997-001493 - 0901a0688013ee81

Michael O. Leavitt
Governor
Diaime R. Nielson, Ph.D. Executive Director
Dennis R. Downs
Director
\ I / '' -t ^^
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF SOLID AND HAZARDOUS WASTE
FILE COPY
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
[phone] Voice
[phone] Fax
(801) 536-M14 T.D.D.
March 18, 1997
Mr. Paul Hancock
Environmental Services
Thiokol Corporation
P.O. Box 689
Brigham City, UT 84302-0689
RE: Closure plan for the old open burning sites at M-225
Dear Mr. Hancock:
The "Closure Plan for Old Open Buming Sites at the M-225 OB/OD Facility" submitted by Thiokol
to the Division of Solid and Hazardous Waste (the Division) has been reviewed. A number of
questions and concems were generated by the review, and are addressed in the list of comments that
is enclosed. The comments are organized by the sections that appear in the Closure Plan. Once you
have had the opportunity to review the comments, the Division recommends that a meeting be
scheduled to resolve the issues and move forward with the closure.
To schedule a meeting, or if you have any questions regarding this letter or the enclosed comments,
please contact Jeff Vandel at 538-9413.
Sincerely,
)ennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board
DRDUCVMl
Enclosures
c: John C. Bailey, M.D., M.S.P.H., Health Officer/Dept. Director, Bear River Health Dept.
F;\SHVAHWB\JVANDEL\WP\THIOKOL\M-225.CL
File: Thiokol
COMIMENTS ON THE M-225 OB/OD FACILITY OLD
BURN SITES CLOSURE PLAN
1.0 Introduction
A minor correction is needed in the last paragraph ofthis section. Please replace "Utah
Sohd and Hazardous Wastes Committee" with Utah Solid and Hazardous Waste Control
Board.
1.4 Waste Characterization
In this section it is stated that the possible hazardous contaminants, from previous
activities at the M-225 facihty, are listed in Table 1.4. It appears that this list is
incomplete. Compounds that were reported to be burned at M-225, but do not appear in
the Ust include RDX, beryUium, cadmium, aluminum, molybdenum and sUver. Please add
these compounds to Table 1.4, or provide a justification for why they should not be
included in the table.
2.1 Closure Performance Standard
As in section 1.0, "Utah SoUd and Hazardous Wastes Committee" needs to be replaced
with Utah SoUd and Hazardous Waste Control Board.
2.2 Decision Matrix
According to the Decision Matrix shown in Figure 2.2, if it is determined that extensive
contamination exists at M-225, the site will be closed with the contamination in place and
post-closure activities would ensue. This matrix doesn't include the possibiUty that
corrective action may be required based on the level of risk present at the site. The level
of risk which requires corrective action is outUned in R315-101-6(e).
4.1 Previous Investigation
In the second sentence ofthe second paragraph ofthis section, it is stated that the old
units were sampled and found not to contain significant levels of hazardous constituents.
The Division disagrees with this statement because the previous investigation did not
adequately demonstrate the nature and extent of the contamination. This is the objective
of the additional sampling. Please either revise or remove the statement referred to above.
In addition, it appears that approval ofthe azide pit excavation was given in order to
faciUtate the investigation ofthe extent of contamination.
4.2.1 ShaUow Boring Program
It is stated in this section that the location ofthe proposed background bore hole is shown
in Figure 4.2.1. The proposed location of the bore hole is not shown in this figure.
It is also stated in this section that each boring wiU be advanced to a depth of 20 feet.
This depth was selected, it is reported, because any contamination present is expected to
be found within this interval (based on soil characteristics and other factors). The burial
of the old units with M material during the upgrade of the facility is not addressed. A
bore hole depth of 20 feet beneath the old ground surface (prior to filling) should be
adequate. However, since the depth of fiU material is not addressed, the depth of
characterization provided by 20 foot bore holes is unknown. In addition, the depth of the
azide pit excavation needs to be addressed for the same reason.
It is reported that the bore hole soil samples wiU be analyzed for the constituents Usted in
Table 4.2.1. Based on the information that Thiokol has provided on the materials that
were burned at the old units, it appears that there are some constituents that should be
added to this list. The constituents that should be added are: RDX, beryUium, cadmium,
and sUver. In addition, the pH of the soU samples should be measured in order to fuUy
characterize the samples.
WiU the soil sarrples be analyzed on-site at Thiokol's analytical laboratory? If so, is
the laboratory certified for aU of these constituents?
In the second to last sentence ofthis section, it is stated that the locations ofthe soil
borings wiU be determined by using a random number generator and the grids on Figure
4.2.1. If the old burn units can stiU be accurately located, it is the Division's opinion that
off-setting the previous bore holes at each unit would be a more effective method for
characterizing the site. If, however, the old units can not be accurately located, randomly
selecting the bore hole locations as proposed would be appropriate.
In regard to the grids in Figure 4.2.1 that may be used to select random locations for the
bore holes; there is no scale on the figure. Please provide a scale for the figure or report
what the distance will be between the proposed grid lines.
Based on the information that the Division currently has, it appears that additional
characterization ofthe azide pit may not be necessary. Additional data from the previous
invesfigafion and corrective action is needed, however, before a risk-based closure with no
further action could be approved. The data needed includes: the depth of the azide pit
excavation, aU of the volatile organic compound (VOC) data for the azide pit bore hole
samples (we're missing trichloroethene among others), pyridine data from the bore hole
samples, and VOC and metal data from the confirmation samples (if it exists). If it is
determined that additional sampUng ofthe azide pit is not necessary, the Division would
suggest utUizmg the 2 bore holes planned for the pit somewhere else (the detonation pit
for example).
4.2.2 Statistical Methods
Due to the possibiUty that the soU below one of the old burn units (the composite pit for
example) is contaminated while the soU under the other units is clean, pooUng the data
coUected from the same stratum at each unit would not be appropriate. Each unit wiU
have to be compared to the background data separately. Since samples from different
units can not be pooled to make comparisons with background data, the number of
samples available for comparisons is reduced to two per stratum per unit (unless the
previous bore hole samples are used). In addition, under the proposed closure plan, only
one sample per stratum would be avaUable to use as background data (again unless the
previous background data is used). If the ANOVA technique is going to be used, more
samples are needed in order to make meaningful comparisons. If the previously coUected
background data were used, and possibly the previous data coUected from each unit, and
the four strata are pooled together (from each unit and the background holes) the
ANOVA technique could be used on the pooled data.
Based on the previous analytical data, it appears there's a good chance that at least 50%
of the sample results wiU be non-detect. Please include in your response an outline of the
procedures that wiU be foUowed if the test of proporfions or control chart (including the
type) statistical methods are used.
4.2.3 Risk Assessment
There is a typographical error in this section. Please replace R315-105 with R315-101 in
the first and second sentences.
4.2.4 Reporting Data
Thiokol is proposing that the results of Phase I, the investigative phase, be submitted
in the Closure Report after Phase II, Closure Action, is complete. The Division
recommends that the bore hole data be submitted for review before a closure action (or no
action) is taken.
It appears that there are a few parameters and methods that should be added to Table
4.2.2 in this section. The parameters are: RDX and HMX (suggested method 8330); lead,
beryUium, cadmium, and sUver (suggested method 6010, TCLP would not be
appropriate); pyridine (suggested method 8260) and sodium azide (method may vary). If
the burn units at M-225 are closed in accordance with the risk-based closure standards,
the Division recommends that Thiokol ensures that the method detection Umits are
adequate (low enough) for aU ofthe analytes before the analysis is done. This must be
done so it can be shown that the levels detected do not present a risk to human health or
the environment.
4.3 Phase II Closure
In paragraph 1 of this section it is stated "if no statisticaUy significant hazardous waste
constituents above background are detected or constituents below risk-based levels are
detected in the soU, then the site will be closed with no further actions." What land use
scenario wUl these levels be based on? WiU standard default parameters for residential
land use be used?
In paragraphs 2 and 3 "R315-105" should be replaced with R315-101.
4.3.1 Closure With No Continued Action
As mentioned in section 4.2.2 above, an ANOVA may not be appropriate for the data
generated from sampling the separate units at M-225. Therefore, the use of "statisticaUy
significant" results may not apply.
4.3.2 Closure by Excavation of Wastes
It is stated in the third paragraph that the location ofthe background bore hole is identified
in Figure 4.2.1. The location ofthe bore hole is not shown on this figure.
4.3.3.4 Groundwater Monitoring WeU InstaUation
If groundwater monitoring is necessary, Thiokol's proposal to use weU X-4 and the
down gradient springs wiU have to be evaluated.
4.3.4 Post Closure
It is stated in this section that the post-closure plan, if necessary, wiU comply with the
requirements that apply to surface impoundments. The post-closure plan may need to
comply with the post-closure requirements that apply to landfills if hazardous waste or
waste constituents are left in place above risk-based levels, and it is shown that
groundwater has been impacted by past activites at M-225.
5.3 SoU SampUng and Analysis
It is stated in this section that fifty two samples and one field blank wiU be analyzed. The
Division generaUy suggests 1 trip blank and 1 dupUcate sample be analyzed for every 10 to
20 samples to ensure QA/QC. The cost estimate may need to be revised to account for
additional dupUcate and field blank samples.