DSHW-2007-001974 - 0901a0688013c18c

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RCRA O&M INSPECTION REPORT
Date of Inspection:
Facility:
Facility Contact:
Notification:
Applicable Regulations:
Type of Inspection:
Participants:
Timeof Arrival:
Time ofDeparture:
Report Prepared by:
March 15, 2005
ATK Launch Systems - Promontory
P.O. Box 707
Brigham City, UT 84302-0707
David P. Gosen, P.E.
Director, Environmental Services
[phone]
UTD009081357 Generator, TSD
RCRA Permit, UAC R315
Operation & Maintenance (O&M)
JeffVandel(TL),DSHW
Helge Gabert, DSHW
John Holladay, ATK
Paul Hancock, ATK
David Covington, ATK
March 15, 2005: 9:30 AM
March 15, 2005: 4:00 PM
Jeff Vandel
Facilitv Description
The ATK Launch Systems - Promontory (ATK) facility is located in Box Elder County,
approximately 30 miles northwest of Brigham City, Utah. The 20,000 acre plant site is
situated in Blue Creek Valley, north ofthe Great Salt Lake, along State Highway 83.
Blue Creek Valley is a remote area that opens to the south onto mudflats and wetlands.
The closest inhabitants to the facility live approximately one mile to the west ofthe
administration area on a cattle ranch. The Bear River Migratory Bird Refuge is located
approximately seven miles south ofthe ATK plant site.
The ATK plant is divided into four major areas designated as: Defense and Launch
Vehicle (DLV), Administrative and Manufacturing Area (or Space), Test Area, and High
Performance Propellant Development Area (or Plant III). There are approximately 675
buildings located on the four areas that comprise the ATK plant. Since operations began
in 1956, ATK has been primarily involved in the production ahd testing of rocket motor
propellants. These activities have included the production and testing of motors for the
Space Shuttle, the wash-out and reloading of Minuteman ICBMs, and many other
projects for the Department of Defense (DOD).
In June of 1986, ATK was issued a Notice of Violation for operating surface
impoundments without interim status or an approved plan. ATK was disposing of
wastewaters and solvents contaminated with propellant in unlined pits at the M-136 Open
Bum Grounds. ATK has estimated that approximately 175,000 gallons of wastewater
was disposed ofat the M-136 Bum Grounds per month fi-om 1962 to 1986. This practice
resulted in the contamination ofthe regional groundwater aquifer.
Requirements to address violations associated with these pits, or land disposal units, were
established in a 1987 Consent Order. ATK closed these units, in accordance with its
approved Closure Plan, in May of 1992. A Post-Closure Permit (the Permit) was issued
by the Executive Secretary ofthe Utah Solid and Hazardous Waste Control Board on
September 1, 1992 to direct monitoring and corrective acfion for the contaminated
aquifer. An updated version ofthe Post-Closure Permit is scheduled to be issued in
September, 2007. The post-closure care period for the M-136 Bum Grounds is 30 years
from the effective date ofthe Permit.
Groundwater Monitoring
ATK has been conducting semiannual groundwater monitoring at the Promontory facility
since 1987. The groundwater protection standard established in the Permit has been
exceeded in the compliance wells and contaminants have migrated down-gradient beyond
the facility boundary. The prirnary contaminants that have been detected in groundwater
are: TCE, TCA (and their daughter products) and perchlorate. ATK has installed
approximately 75 wells since 1987 in order to define the extent of contamination.
Groundwater monitoring has shown that at least two contaminant plumes, in addition to
the primary regional plume, exist at the facility. Groundwater contamination has also
been detected in a perched aquifer zone east ofthe primary plume in the regional aquifer.
In October, 2000 the Division of Solid and Hazardous Waste (the Division) completed a
Comprehensive Groundwater Monitoring Evaluation (CME) ofthe ATK groundwater
monitoring program. In December, 2001 the Division completed a review ofthe ATK
Corrective Action Plan (CAP), which consisted of a groundwater flow and transport
model and a human-health risk assessment. Based on the results ofthe CME and CAP
review, it was determined that ATK needed to install additional monitoring wells to
define the extent of contaminant plumes in five different areas at the facility. In addition,
it was requested that ATK submit a revised groundwater model and risk assessment after
the extent ofgroundwater contamination was defined. Upon approval ofthe risk
assessment, a CAP based on its findings will be submitted by ATK.
The five areas at the facility where it was determined by the Division that more data was
needed to define the extent ofthe contaminant plumes are described below (see attached
map):
1. South/Southwest of well EW-6
2. West of wells F-l and E-l
3. East of wells E-10 and E-9
4. South of Pipe, Shotgun and Horse Springs
5. East/Southeast of well X-4
In May of 2002, ATK submitted a work plan for the installafion often monitoring wells
(the H-series wells) that would provide data for areas one, two and four as identified
above. In addition, the Work Plan proposed investigation activities at three suspected
source areas. In June, 2002, representatives ofthe Division (Jeff Vandel and Helge
Gabert) met with ATK to discuss monitoring well locations and other plans for defining
the extent of groundwater contamination. The proposal for monitoring well installation
was approved by the Division in July, 2002. The installafion of well H-9 was observed
by Jeff Vandel on August 7, 2003 (see attached photos). Based on this observation, it
appeared that the H-wells were installed in accordance with the approved work plan.
An O&M Inspecfion was conducted by the Division on July 23, 2002. This inspection
focused on the maintenance and the condition ofthe closed impoimdment caps and the
existing groundwater monitoring system. None ofthe new monitoring wells had been
completed at that time. Three issues were identified as a result ofthe inspection. ATK
was nofified ofthese issues in a letter dated September 3, 2002. ATK replied to the letter
on September 20, 2002 and the issues were resolved.
On August 7'*' and 18'^ 2003, Jeff Vandel and Helge Gabert met with ATK
representatives to discuss the need for additional monitoring wells to help define the
extent of contamination at area three, as idenfified above. On August 22, 2003, ATK
submitted a proposal for the number (six) and locations of these additional wells (J-series
wells). The Division approved this proposal on September 11, 2003.
The August, 2003 plan was amended in August, 2004, when ATK proposed to add two
more wells (wells J-7 and J-8) to help define the northem contaminant plume. The
source ofthis plume is the M-508 drain-field, which was also included in the 1987
Consent Order and will be incorporated into the reissued Post-Closure Permit. The plan
to install two additional wells was approved by the Division on September 17, 2004.
Additional Work
Other progress on corrective action for contaminated groundwater at ATK since the 2002
O&M Inspection includes the submittal of a groundwater flow and contaminant transport
model and Risk Assessment Work Plan. In addition, ATK is currently conducting two
pilot tests at the facility to assess possible treatment methods for contaminated
groundwater.
The final Groundwater Model Work Plan was submitted by ATK on August 25, 2004 and
approved by the Division on October 14, 2004. The Groimdwater Model was submitted
to the Division on February 8, 2006. After reviewing the model, the Division provided
comments on it (July 19, 2006) and met with ATK to discuss them. The model is
currently being revised by ATK and their contractor.
A Groundwater Risk Assessment Work Plan was submitted to the Division on May 23,
2005. This plan was reviewed and comments were provided to ATK on September 21,
2005. A revised work plan was submitted by ATK in December, 2005. This work plan
was approved by the Division on April 12, 2006. The human health risk assessment is
scheduled to be submitted within six months ofthe Division's approval ofthe
groundwater model. The ecological risk assessment is due within one year ofthe
approval ofthe groimdwater model. Corrective Action will be required based on the
results ofthe risk assessments.
Inspection
ATK completed the installation ofthe J-series wells in January, 2005. Well J-4 was
installed to determine ifthe regional aquifer and contaminant plimie extended east
beneath the perched aquifer in the area of well Ml 14B1. After drilling well J-4 through
the local perched aquifer and down to an elevation below where the regional aquifer was
expected, ATK believed the hole didn't penetrate the regional aquifer as it appeared to be
dry. However, the hole was checked again later and water was observed at
approximately the elevation that was expected for the regional aquifer. Despite
observing water in the well, ATK was doubtfiil that the regional aquifer extended as far
to the east as well J-4. It was speculated that the well wasn't completely sealed off in the
perched zone and water was leaking through to the bottom ofthe hole, or that drilling
water remained in the hole.
The O&M Inspection, conducted on March 15, 2005, was focused on resolving the
regional aquifer issue at well J-4, inspecting the J-series wells installed, and discussing
the implications ofthe analytical data that had been obtained for the wells by January,
2005. The specific issues that were addressed during the inspection are discussed below.
1. At the time ofthe inspection, well J-4 had not been developed since ATK was
unsure ifthe regional aquifer had been penetrated. An M-scope (water level
probe) was lowered into the well casing during the inspection to determine the
potentiometric surface. The water level was measured at an elevation of 4,269
feet - an elevation that corresponds well with the regional aquifer in the area.
ATK had also recently received analytical data from well J-4, from when it was
sampled with a bailer on.January 13, 2005. TCE was detected in the sample at
2,540 |ig/L and perchlorate was detected at 14 |ig/L. The TCE concentration was
higher than what would be expected, based on concentrations observed in the
regional aquifer in the area, but the perchlorate concentration detected was quite
similar. Based on this evidence, the Division and ATK agreed that the well
needed to be properly developed and constructed.
ATK developed well J-4 and completed its construction shortly after the O&M
Inspection in March, 2005. Data collected since then (see Table 1.) show
significantly increasing levels of TCE. The cause ofthis trend is currently
unknown, although ATK has speculated that a previously unknown source may be
responsible. The trend in TCE concentrations will continue to be monitored and
will be further evaluated in the 2008 O&M Inspection..
2. Analytical results obtained for wells J-7 and J-8 in January, 2005 indicated that
the TCE and perchlorate plumes extended south towards monitoring wells
installed for the solid waste landfill. During the inspection, ATK proposed to
monitor the landfill wells and possibly install additional wells at a later date as
needed.
Both TCE and perchlorate have been detected in landfdl well #1 (LF-1), however
the concentrations detected have remained steady since 2000. Based on the
available data, it doesn 't appear that landfdl wells #2 and #3 have been
impacted. The concentrations of TCE and perchlorate that have been seen in
LF-I are greater than those seen upgradient in wells J-7 and J-8, therefore it
appears that the landfill could be the source ofthe contaminants observed in
LF-1. Monitoring ofthese wells will continue and this issue will be evaluated
further in 2008. In conclusion, it appears that the installation of wells J-7 and J-8
has adequately defined the northern plume at this time.
3. Analytical results obtained prior to the inspection for wells J-5 and J-6, installed
north of Pipe and Shotgun Springs, didn't match up well with surface water
concentrations that have been observed in the springs - which are located
approximately 1,000 feet dovm-gradient. As ATK's contractor had begun work
on the groundwater model, it appeared that more data was needed for this area.
Since groundwater flow to the springs appears to be stmcturally controlled, ATK
proposed conducting a VLF survey in the area to see if it would help understand
how stmctures control groundwater flow in the area.
A TK's contractor completed the VLF survey in the Fall of 2005. The data appear
to indicate that a significant, north/south trending structural feature does exist in
the area between the springs and wells J-5 and J-6. This helps confirm that flow
to the springs is structurally controlled, and suggests that it consists of conf ned
flow through fractures that probably are not connected to wells J-5 or J-6.
4. During the inspection, the recently completed J-wells were inspected. It was
observed that wells J-5 and J-6 didn't have caps on the PVC casing. Other than
this problem, it appeared that the wells were completed in accordance with the
well installation plan and the Post-Closure Permit.
Based on conversations with A TK personnel, well caps were ordered and
installed shortly after the inspection was conducted. All ofthe J-series wells are
now properly completed.
5. The need for an additional monitoring well to provide data for the last area
identified, area five, was discussed with ATK during the inspection. ATK was in
agreement with the need for a well and indicated that one would be installed at a
future date.
On June 13, 2006 the location for the well (X-5) was discussed in the field by Jeff
Vandel, Helge Gabert and ATK personnel. A site for the well was selected at that
time. The boring for this well (X-5) was completed in early February, 2007. The
well is currently being developed.
Sigiiahlt^ Date
Table 1. TCE Results (jig/L) for the J-Series Wells,
Spring (S) 2003 to Fall (F) 2006
:#ell.L^
Jl
J2
J3
J4
J5
J6
J7
J8
262
NS
NS
NS
NS
NS
NS .
NS
'^M'
373
NS
6.2 J
NS
NS
NS
NS
NS
•'iiK'#
221
1.2 J
<1
NS
5.4 J
3.8 J
12.5
43.9
i-s^i
261
<1
10.4
2540
4.9 J
3.8 J
35.8
8.7 J
96.8
<1
10.7
938
4.9 J
7.9 J
33.6
9.7 J
508
<1
<1
6930
4.2 J
2.4 J
38.1
7.3 J
|^;,,F06i^^>L,
697
<1
13.9
9070
7.2 J
S.OJ
26.1
<1
NS - no sample
J - analytical result below the estimated quantitation limit (EQL)
Table 2. Perchlorate Results (^ig/L) for the J-Series Wells,
Spring (S) 2003 to Fall (F) 2006
^pWeu'-:^
Jl
J2
J3
J4
J5
J6
J7
J8
iTdslf
597
NS
NS
NS
NS
NS
NS
NS
^:-p'-,;
726
NS
<4
NS
NS
NS •
NS
NS
.^04,,:::
495
7.1
<1
NS
6.7
10.4
182
58.3
585
14.0
<1
14.0
10.0
14.5
407
15.0
"^^W^''
778
93.3
<4
10.5
14.0
11.3
389
<1
,.4^K - ,.,'••
1250
73.2
<4
82.4
12.2
17.4
524
<4
iWgF;
1240
102
<4
69.9
12.4
12.3
471
40.5
NS - no sample
J - analytical result below the estimated quantitation limit (EQL)
ATK Launch Systems - Promontory
Installation of Monitoring WeU H-9, August 7, 2003
state of Utah
Department
of
Environmental Quality
ATK Launch Systems
Promontory Facility
O&M Inspection Report 2005
New Wells Installed in Areas 1-5
Perchlorate Groundwater
Plumes
Legend
Perchlorate Plume Concentrations
(As of Fall 2004)
Perched Aquifers Regional Aquifer
5 ug/L
100 ug/L
1000 ug/L
10000 ug/L C^
L^j-" Facility
# l\/lonitoring Wells
Private Land
State & Federal Lands
* The contamination plunnes are generalized.
** Sources for land ownership: Box Elder County Recorders Office,
State of Utah School and Institutional Trust Lands Administration,
and Screening Level Endangerment Assessment Thiokol
Propulsion, Norttiem UT, WalstJ, 2001.
Aerial Photograph: USGS Projection: UTM Nad 27 Zone 12
0 0.5 1
Miles