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Home My WebLink AboutDSHW-2011-008338 - 0901a06880274a95 (5)January 20, 2011 David P. Gosen, P.E. Director, Environmental Services ATK Launch Systems – Promontory P.O. Box 707 Brigham City, UT 84302-0707 RE: Review of Corrective Measure Pilot Test Reports Ex-Situ Soil and In-Situ Groundwater ATK Launch Systems - Promontory Facility UTD009081357 Dear Mr. Gosen: The Division of Solid and Hazardous Waste has completed its review of the report titled “Evaluation of the Enhanced Bioremediation Pilot Test” and the report titled “Corrective Measure Pilot Test to Evaluate Ex-Situ Remediation of Perchlorate Contaminated Soil.” ATK submitted these reports to the Division on June 15, 2010 and July 27, 2009 respectively. It appears that the remediation method that was tested for treating soil contaminated with perchlorate was quite successful and the enhanced bioremediation method has potential for in-situ treatment of contaminated groundwater. However, the Division requests that ATK provide some more information on a few issues regarding these pilot tests. Our comments and questions are enclosed with this letter. Please submit your responses at your earliest convenience. If you have any questions, please contact Jeff Vandel at (801) 536-0257. Sincerely, ORIGINAL DOCUMENT SIGNED BY SCOTT T. ANDERSON ON 1/20/2011 Scott T. Anderson, Director Division of Solid and Hazardous Waste STA\JV\tjm Enclosure Page 2 c: Paul Hancock, ATK Launch Systems Jason Wells, ATK Launch Systems Nancy Morlock, Region 8, USEPA Lloyd Berentzen, MBA, Health Officer, Bear River Health Department Corrective Measure Pilot Test to Evaluate Ex-Situ Remediation of Perchlorate Contaminated Soil 1) Page 2. The text states that the effluent is primarily water with residual volatile organic acids. However, the exact nature and concentration of the volatile organics is not discussed in the text. Please elaborate and indicate whether there is reason to believe that the volatile organics could present a risk to down-gradient receptors, if this test is to be scaled up to full production in the future. 2) Page 3. The text states that saturation was only achieved in the center of the mounds, but that the outer areas of the mounds did not display any discernible reduction in perchlorate concentrations, because these areas did not receive enough effluent. It is unclear why this geometry was selected at the beginning of the test. Furthermore, it is unclear why the mound configuration was not changed once it became apparent that the design of the mounds was inadequate to provide for treatment of all soils. Was untreated soil from both the manure test and the bioreactor effluent test used in the final procedure using roll-off dumpsters? Please elaborate. 3) Page 8. Does ATK plan on conducting any further work on evaluating this remediation technique? Evaluation of the In-Situ Enhanced Bioremediation Pilot Test for Contaminated Groundwater 4) Page 2. The text states that, in the vicinity of the M-136 burning grounds, the groundwater potentiometric surface is substantially reduced, and caused, in part, by locally elevated hydraulic conductivities. Please explain how a reduced potentiometric slope can be caused by elevated conductivities beneath the burning grounds. A review of the 2010 site-wide potentiometric surface map reveals that a reduced slope is perhaps discernible to the south of the burning grounds, but not at the burning grounds proper. 5) Page 7. The text states that Figures 2 and 3 display the point decay rates for perchlorate at wells C-2 and A-5. While we agree that the decay rates at well C-2 appear to have different slopes, we are not sure if the decay rate at well A-5 is indeed significantly different for pre- and post-treatment times. Did ATK perform any statistical tests regarding significant differences of the respective slopes? 6) Page 8. The text states that the decay rate of well T-2 is larger than that of well D-2, which, in turn, is smaller than that of well C-2, which proves that this test demonstrates the efficient degradation of perchlorate in groundwater. However, it appears that the slope of decay in well D-2 is positive, which contradicts the above line of reasoning. Please elaborate. We also question whether the above statement is perhaps not well founded, as it appears to be based on three wells only, and a determination of statistical significance of the respective decay slopes is missing here as well. 7) Page 9. The text states that vinyl chloride (VC) was observed one year after the test began, at a concentration of 4.1 ug/l in injection well A-1. While VC, classified as a mutagen, and as a known human carcinogen, is indeed short-lived, once it has the opportunity to volatilize, please be aware that, for a carcinogenic target risk level of 1E-6, the EPA regional screening level for ingestion is 0.017 ug/l, well below the concentration displayed in well A-1. We are concerned that this in-situ test, if scaled up to full production, would not account adequately for the generation and dispersion of VC into the groundwater system. Please comment. 8) Figure 1. The North arrow appears to point to a wrong direction. Please correct in any future submittals that utilize this figure. 9) Page 10. Does ATK plan on conducting any further work or monitoring to evaluate this remediation technique? TN201100045 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4414 www.deq.utah.gov TN201100045 Printed on 100% recycled paper Solid and Hazardous Waste Control Board John D Newman, Chair Michael D. Brehm, P.E., Vice-Chair Scott Bruce Carlton Christensen Kory Coleman Jeff Combs, MPH, LEHS R. Ryan Dupont, Ph.D. Larry A. Ellertson Brad Mertz Gary Mossor Kevin Murray Dennis Riding Amanda Smith Scott T. Anderson Executive Secretary State of Utah GARY HERBERT Governor GREG BELL Lieutenant Governor Department of Environmental Quality Amanda Smith Executive Director DIVISION OF SOLID AND HAZARDOUS WASTE Scott T. Anderson Director