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HomeMy WebLinkAboutDSHW-2004-008763 - 0901a06880197108ATK ALLIANT TECHSYSTEMS 25 October 2004 8200-FY04:ST047 Mr. Dennis R. Downs, Executive Secretary State of Utah Department of Environmental Quality Division of Solid and Hazardous Waste 288 N. 1460 W. P.O. Box 144880 Salt Lake City, Utah 84114-4880 ATK Thiokol Propulsion RO. Box 707 Brigham City. UT 84302-0707 Tel 435 863-3511 Fax 435 863-2234 I ^ OCT 2 9 2004 : I Ufah DivlsEon of Solid | [end Hazardous Waste i Dear Mr. Downs ATTENTION: Jeff Vandell Subject: Semi-Annual RFI Progress Report As required by Section VHH of Thiokol Corporation's Post Closure Permit, the following semi- annual RFI progress report is submitted for your review. The reporting period covered by this report is 1 March 2004 - 1 September 2004. Included is information on a new Solid Waste Management Unit # 676, a floor drain in an equipment room located at M-397. If you have any questions regarding this report, please direct them to myself at (435) 863-3344. Sincerely Paul V Hancock, Manager Environmental Remediation c: Don Ostler, Director, Division of Water Quality SEMI-ANNUAL RFI PROGRESS REPORT 1 March 2004 - 1 September 2004 ATK Thiokol Promontory Facility 1. Description and estimation of the percentage of the RCRA Facilities Investigation completed A new SWMU was identified in March 2004 at building M-397 and designated as #676 This IS a final assembly building for the Space Shuttle While excavating west of M-397 an open pipe was discovered It was traced back to a floor drain in the equipment room Approximately 1 quart of oil drained out when the pipe was exposed followed by approximately 20 gallons of water The water and oil were cleaned up and removed A tank was placed to receive future water and oil from the pipe The equipment room holds vacuum pumps and generates water by once through cooling water, a dnnking fountain and a sink No hazardous constituents are anticipated In 2003, Thiokol received permission from the Division of Solid and Hazardous Waste to conduct Passive Soil Gas Survey work at Solid Waste Management Units #202, #551 and #625 These units had been previously investigated with a series of soil samples, but no definitive results were obtained The report of these results IS included in the August 2000 Thiokol Propulsion RCRA Facility Investigation Source and Contamination Characterization Phase 1 SWMUs report These sites are still suspected of being significant contamination sources for VOCs One hundred total soil gas modules were installed at these sites according to the approved plan There was no indication of contamination at the Solid Waste Management Unite sites #202 and #625 At SWMU site #551, indications of contamination were found in the upper quadrant of the grid These results were reported in the previous semi-annual progress report for 1 September 2003 - 1 March 2004 As a result of this survey, Thiokol has installed additional soil gas modules at SWMU #551 and #625 and at other locations that may be contamination sources in the Plant 3 area Summaries of all findings Results of the analysis of the soil gas modules will be included in a future submittal to the DSHW 2 Summaries of all changes made in the RCRA Facility Investigation during the reporting period As descnbed above Passive Soil Gas survey is an additional tool that is being tested at Solid Waste Management Units to determine if it is effective at delineating volatile organic contamination source areas 4 Summaries of all contact with representatives of the local community, public interest groups or State Government during the reporting period Correspondence regarding RFI activities has been limited to the Division of Solid and Hazardous Waste and the Division of Water quality 5 Summaries of all problems or potential problems encountered during the reporting period There were no significant problems encountered dunng the reporting penod Actions taken to rectify problems Thiokol continues to review all available information and pursue all avenues to resolve any uncertainty associated with the solid waste management units Changes in personnel during the reporting period There are no changes in personnel The existing environmental staff will continue to conduct the sampling when possible Contractors will be used when specialized equipment is required Projected work for the next reporting period Efforts for the next reporting period will focus on receiving approval for voluntary corrective measures, investigating additional solid waste management units, and report preparation The results of the soil gas work, at this time appear to be positive in helping to delineate possible source areas Pending additional approval from the Utah Division of Solid and Hazardous Waste, additional sites are now being surveyed with this method Copies of daily reports, inspection reports, laboratory and monitoring data A descnption of the new SWMU #676 is attached SWMU 676 DISCHARGE FROM BUILDING M-397 Source Characterization Unit/Disposal Area Characteristics This solid waste management unit is the location of an industrial wastewater discharge from Building M- 397 in Thiokol's Administration and Manufacturing Area The discharge consisted of a floor dram in the equipment room Wastewater could be compnsed of vacuum pump once-through cooling water, a drinking fountain and a sink There is a potential for hydraulic oil releases from leaks in the equipment The discharge was to a previously unknown location through a buried pipe that deadened in the soil During excavation in March of 2004 this pipe was located When the pipe end was uncovered, approximately one quart of hydraulic oil was released along with approximately 20 gallons of water This water and oil containing soil were cleaned-up and removed from the site In 1995, Thiokol completed the construction of two biological wastewater treatment facilities and associated wastewater collection systems At that time, all wastewater flows were collected and piped to the new wastewater treatment facilities This particular flow from M-397was unknown and not connected The water is now being collected in a tank that is periodically pumped and taken to the wastewater treatment facility Physical Setting M-397 IS located on the western flank of the Blue Springs Hills This is a horst and graben block fault system with two major fault trends north 15 degrees east and east-west The Blue Springs Hills at this location consists of Paleozoic carbonate units covered with a thin veneer of Quaternary alluvium The valley is filled with Tertiary and Quaternary sediments which include older fluvial and lacustrine sediments, alluvial fan deposits, Lake Bonneville sediments, and recent alluvium M-397 is sited on the gentle slope of a moderately large alluvial fan Sediments consist of unconsolidated gravels, sands, and clays of colluvial (debris flow), fluvial, and alluvial depositional environments Within the valley-fill, ground water occurs in unconfined conditions The valley-fill sediments consist of sands and gravels interbedded with silts and clays Generally, the coarser materials are found along the margins of the valley and as basal sediments above the bedrock The silts and clays act as confining units interbedded within the coarser materials Within consolidated sediments, ground water occurs in fault zones and solution cavities in the limestones The regional aquifer is found in unconsolidated alluvial material within the Blue Spnngs Valley and in fractured bedrock along the flanks of the range There does not appear to be a distinct low permeability barrier beneath the entire site, although discontinuous zones are ubiquitous The thickness of the aquifer IS unknown, but it is expected to be greater than 500 feet All of the wells installed to date have been drilled to less than the bottom of the aquifer The deepest wells drilled into the saturated zone are Thiokol exploratory water wells TCC8 and TCC8A, completed in 1960 and 1962, west of UDLV Well TCCBA was drilled 610 feet deep, penetrating 460 feet of saturated material Monitoring wells E-3, E-4, E-5, and E-6 are located between 2000 and 2400 feet from this site along State Highway 83 The wells were installed in 1990 to depths of 126 51,132 06, 121 60, and 89 16 feet Thiokol Propulsion RCRA Facility Investigation respectively The depth to ground water in E-3 was 108 29 feet, 93 97 feet in E-4, 80 01 in E-5, and 67 79 feet in Junel 999 Ground water movement at this site appears to be in an east to southeasterly direction Waste Characteristics The discharge consisted of wastewater comprised of once-though cooling water for vacuum pumps, drinking water, hand sink water and small leaks of hydraulic fluid When the end of the pipe was uncovered, a small amount of oil along with approximately 20 gallons of water drained out No analytical data is available for this specific discharge However, functions at this equipment room in building M-397are similar to building M-67 (SWMU 261) for which analytical data is available The wastewater discharge from M-67 was sampled for characterization dunng sampling events in 1987 and 1988, and submitted to the Division of Water Quality in a report titled Thiokol Corporation Ground Water Quality Protection Report, September 1991 Thiokol conducted an assessment of the potential impact to the environment from this discharge by comparing the analytical results from this characterization to applicable regulatory regulations (i e , MCLs, Secondary Dnnking Water Standards, EPA Health Advisories, or Ground Water Quality Standards, and proposed Action Levels for Solid Waste Management Units) The discharge was further compared to surface water (Blue Creek) entering Thiokol property and to ground water quality from momtonng wells at Thiokol considered to be background wells The constituents of concern for this site were identified through this assessment process The contaminants of potential concern (CQPC) for this M-67 site were identified as lead and pH The investigation of the South Dispersion Area (SWMU 634), which ultimately received the industrial wastewater from this site, included an expanded list of laboratory parameters Samples of the water discharge are being collected to characterize the need for further efforts at the site Processes do not indicate that hazardous constituents would be present Soil Characterization The USGS has classified this soil as Hupp Silt Loam or Silty Clay Loam (HpD) The Hupp series soils consist of well drained soil on alluvial fans They formed in very gravelly and cobbiy alluvium derived mainly from limestone, sandstone, and quartizite parent rocks The surface layer is grayish-brown and brown gravelly silt loam The subsoil and substratum are pale-brown gravelly silt loam The surface layer IS generally mildly alkaline and slightly calcareous in the lower part The subsoil and substratum are moderately alkaline and moderately calcareous Contamination Characterization The M-67 discharge location soils were sampled during the RFI process as a discharge that was charactenstic of other surface water discharge sites at Thiokol Table M67-1 is a summary of the constituents detected in at least one sample during the investigation for this site This table also shows the range of concentrations for each constituent Minimum concentration values preceded by a less-than sign (<) indicate the laboratory reported the chemical was not detected and the value shown represents the detection limit If the laboratory reported a metal undetected in a sample, but that metal was detected in other samples, the minimum concentration shown is one-half the reported detection limit Thiokol Propulsion RCRA Facility Investigation Due to the limited number of samples collected at this site, a 95 percent upper confidence limit (UCL95) was not calculated Risk assessment guidelines recognize that when too few samples are collected, the upper confidence limit on the average concentration will be high, even above the maximum detected value In these cases, the accepted approach is to use the maximum detected value to estimate exposure concentrations TABLE M67-1 CONSTITUENT CONCENTRATION RANGE CONSTITUENT MINIMUM CONCENTRATION (mg/Kg) MAXIMUM CONCENTRATION (mg/Kg) LEAD 5 04 12 30 pH 8 05 11 02 Comparison to Background Concentrations Table M67-2 is a summary of the corresponding background concentrations for those constituents detected and summarized in Table M67-1 Included are the results of background samples taken from areas at Thiokol believed to be representative of naturally occurring levels of chemicals in the soil Minimum concentration values preceded by a less-than sign (<) indicate the laboratory reported the chemical was not detected and the value shown represents the detection limit TABLE M-67-2 BACKGROUND CONCENTRATIONS CONSTITUENT MINIMUM CONCENTRATION (mg/Kg) MAXIMUM CONCENTRATION (mg/Kg) LEAD 0 75 32 50 pH 6 98 8 43 Upon inspection of Table M67-3, it can be seen that lead concentrations were within the range found in Thiokol background soil The maximum pH value in the soil did exceed the maximum value in background samples Comparison to Risk-Based Levels Table M67-3 is a tabular comparison of the maximum concentration levels for the constituents of concern to the respective maximum Thiokol background level, USGS background levels. Preliminary Remediation Goals (PRG), RCRA Corrective Action Levels, and EPA Soil Screening Levels Thiokol Propulsion RCRA Facility Investigation The PRG values shown in Table M67-3 are chemical concentrations that correspond to fixed levels of risk (i e , either a one-in-one-million [10®] cancer risk, or a noncarcinogenic hazard quotient of 1) The RCRA Corrective Action Levels represent proposed values which, if found in the environment in excess of this level, could trigger the need for further analysis Soil Screening Levels (SSL) are concentrations of contaminants in soil that are designed to be protective of exposures in a residential setting The SSL represent the concentration of a contaminant, which, if present at a site at or below this concentration, would be considered protective of ground water The values shown were developed using a dilution attenuation factor (DAF) of 20 to account for natural processes that reduce contaminant concentrations in the subsurface As shown in Table M67-1, lead concentrations at this site are below the EPA's Preliminary Remediation Goals for residential settings Conclusions The investigation conducted at this site did not reveal the presence of lead at concentrations which exceeded Thiokol background nor did the concentrations exceed the EPA's Preliminary Remediation Goal for residential settings Qne sample collected from this site did exhibit a higher pH but the value appears to be a single point outlier with all other samples at or near background levels Recommendations for Additional Work Based on the findings of the investigation conducted of the soils at the M67 discharge site dunng the RFI, ATK Thiokol believes that further action at the M-397 site is not likely warranted Planned sampling of the discharge will provide additional indications of any contaminates of concern Thiokol Propulsion RCRA Facility Investigation TABLE M67-3 COMPARISON TO BACKGROUND AND RISK- BASED CONCENTRATIONS MAXIMUM REPORTED RFI CONCENTRATIONS (mg/Kg) PRELIMINARY REMEDIATION ' GOALS (mg/Kg) RCRA CORRECTIVE ACTION LEVELS ^ (ppmw) EPA SOIL SCREENING LEVELS DAF 20 (mg/Kg) CONSTITUENT AREA OF CONCERN THIOKOL BACKGROUND RESIDENTIAL INDUSTRIAL RCRA CORRECTIVE ACTION LEVELS ^ (ppmw) EPA SOIL SCREENING LEVELS DAF 20 (mg/Kg) Lead 12 30 32 50 400 00 1000 00 pH 11 02 8 43 EPA Region 9 Preliminary Remediation Goals (11/1/1999) • EPA proposed RCRA Corrective Action Rule (55 FR 30798 July 27 1990) ^ EPA Region 111 Risk Based Concentrations (October 22 1997) " USGS Background Concentrations of Elements in Soils (1984) Thiokol Propulsion RCRA Facility Investigation