DSHW-2012-001891 - 0901a068802b41af

Launch Systems Group
P.O. Box 707
Brigham City, UT 84302
www.atk.com
29 February 2012
8200-FY12-068
RECEIVED
MAR 0 2 2012
UTAH DIViSlUN UF
SOLID & HAZARDOUS WASTE
20IZ.00^4^
Scott T Anderson
Executive Secretary,
c/o UDEQ Division of Solid and Hazardous Waste
PO Box 144880
SALT LAKE CITY UT 84114-4880
Subject: ATK Launch Systems Promontory Facility, Semi-Annual RFI Progress Report for
September 2011 - March 2012, Promontory EPA ID #UTD009081357
Dear Mr. Anderson
Attached, please find the ATK Launch Systems Promontory Facility Semi-Annual Progress Report
for September 2011 - March 2012. If you have questions regarding these comments, please contact
Paul Hancock at [phone].
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fine and imprisonment for knowing violations.
Sincerely,
Paul V. Hancock, Manager
Environmental Services
Co : Walter L. Baker, Division Director, Utah Division of Water Quality
SEMI-ANNUAL RFI PROGRESS REPORT
1 September 2011-1 March 2012
ATK Launch Systems Promontory Facility
1. Description Of Work Completed
SWMU Assessment Report Schedule
As required in the ATK Launch Systems, September 20, 2007 Promontory Post-Closure
Permit, ATK submitted a schedule for submitting SWMU Assessment Reports or RFI work
plans for the SWMUs listed in Attachment 6 of the permit. Upon Utah DSHW approval of
the schedule, ATK will proceed with the assessment of the remaining SWMUs.
North Plant "P Wells" Investigation
As part of the Corrective Action for SWMUs in the North Plant, the DSHW submitted a
letter on February 3, 2012 requesting that an additional well be installed in the same location
as wells P-6 and P-7. The intent of the new well is to more accurately determine flow
direction in the uppermost perched aquifer. ATK submitted a well installation plan on
February 24, 2012, which the DSHW has approved. The installation of this new well called
P-10 is now in progress.
New Solid Waste Management Unit
A new Solid Waste Management Unit has been identified and designated as SWMU # 680.
On January 23, 2012, an inspection of a concrete trench in building M-705 at the Promontory
facility showed that there was a crack approximately two inches wide. This trench routinely
receives perchlorate water with a concentration in the hundreds to thousands of parts per
million as part of the treatment processes in the building. Small amounts of volatile organics
such as acetone may also be in the waste water. Processes discharging waste water to the
trench were stopped and a repair was made by the following day. The remainder of the
trenches were inspected and found to be in good condition. What caused the crack, how long
it existed,and what quantity of perchlorate was released is uncertain.
Since the release is underneath an operating building no material was recovered. Down
gradient monitoring wells J-1, J-7, and J-8 are in place to monitor any increases in
groundwater perchlorate or volatile organic levels if sufficient water was released to reach
groundwater.
The location is designated as SWMU # 680. A SWMU assessment report will be submitted
within the time specified in the Promontory Post Closure Permit.
Vegetable Oil Injection Pilot Testing
The DSHW gave approval for a pilot test of vegetable oil injection at the source areas in the
M-136 bum grounds. This injection was completed in September 2007. Summaries of the
interim testing results have been provided in previous progress reports. A final report was
submitted to the Division on June 7, 2010. The conclusion of the report was that using
vegetable oil as a substrate to stimulate biological degradation is a viable way to treat volatile
organic compounds and perchlorate at M-136. Further, that a broader application would be
successful. ATK submitted responses to the Divisions most recent comments on 25 July,
2011. Samples continue to be collected to assess the long term effects of the treatment.
2. Summaries of all flndings
Summaries are in section I above.
3. Summaries of all problems or potential problems encountered during the reporting
period
There were no significant problems encountered during the reporting period.
4. Actions taken to rectify problems
ATK continues to review all available information and pursue all avenues
to resolve any uncertainty associated with the solid waste management units.
5. Projected work for the next reporting period
Efforts for the next reporting period will include installation of new monitoring well P-10,
receiving approval for voluntary corrective measures, investigating additional solid waste
management units, and SWMU Assessment report preparation. Monitoring at the vegetable
oil injection wells, and the Plant 3 treatment system monitoring will be ongoing through the
next reporting period.