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Home My WebLink AboutDSHW-2012-010201 - 0901a0688030c9f8ATK Division of Solid and Hazardous Waste SEP 2 5 2012 2D\Z-DlbZO\ 25 Sept 2012 8200-FY13-037 Scott T. Anderson, Director Utah Department of Environmental Quality Division of Solid and Hazardous Waste P.O. Box 144880 195 North 1950 West Salt Lake City, Utah 84114-4880 Subject: ATK Launch Systems Promontory Facility, Response to Utah Division of Solid and Hazardous Waste Comments Regarding the New SWMU Assessment Report, Promontory EPA ID #UTD009081357 Dear Mr. Anderson: On August 31, 2012, your office submitted a letter with comments in response to the ATK New SWMU Assessment Report for SWMU #680. It should be noted that your staff has agreed to a renumbering of this new Solid Waste Management Unit (SWMU) associated with M-705 as SWMU #681. ATK's responses to these comments are included with this letter. If you have questions regarding these comments, please contact Paul Hancock at (435) 863-3344. Sincerely, Robert Ingersoll Director Environmental Services Launch Systems Group P.O. Box 707 Brigham City, UT 84302 www.atk.com Responses to Comments from the Utah Division of Solid and Hazardous Waste (UDSHW) on the ATK Launch Systems Promontory New SWMU #680 Assessment Report ATK General Response: ATK has been in recent contact with the Utah Division of Solid and Hazardous Waste regarding the numbering of the Promontory SWMUs. It was agreed that this new SWMU associated with M-705 should actually be designated as SWMU #681. In the future, this SWMU will be designated as #681. USDHW comment: At the beginning of the section, it was stated that during the inspection of a concrete trench at building M-705, a crack in the trench was observed. How often are the trenches at M-705 inspected? ATK Response: The M-705 trench is inspected once per month. USDSHW comment: Please provide the complete output including the transient time steps of the Hydrus Model that was run to investigate the potential for the release from M-705 to reach groundwater. ATK Response: The transient time steps of the Hydrus Model run were a minimum of 26 minutes and a maximum of 5 days. The complete output files from the Hydrus Model run used in this simulation are included with this submittal as Attachment 1. USDSHW comment: The 30-year travel time for the transport ofperchlorate from M-705 to well J-7 seems like a long time for this distance and apparent potentiometric surface gradient from M-705 to the west. Is there any additional information available to support this time frame? Is there any data available for the TCC8 or TCC8a wells that were drilled? ATK Response: The reason for the slow travel velocity from M-705 to the west is due to the low conductivity of the aquifer found in this area. The conductivity for this flow region is only 0.75 to 1 ft/day. ATK has data on Well TCC8a including a location. This information is included below in another response. Groundwater modeling was completed on the travel time from M-705 to Well TCC8a showing 5400 days (14.8 years). USDSHW comment: At the end of the first paragraph in this section, it is stated that there are three monitoring wells (J-1, J-7 and J-8) that could be considered immediately down gradient of M-705. Based on the fall 2010 potentiometric surface map that was submitted to the Division by ATK. well J-1 appears to be up-gradient from M-705. ATK Response: ATK agrees with Well J-l being up-gradient of M-705, which is why only wells J-7 and J-8 were modeled. USDSHW comment: The second page of the EarthFax document states "since well J-1 is located east of M-705, the model results in few contaminants reaching J-1." As pointed out above, the potentiometric surface data for the M-705, well J-1 area indicates that groundwater flow is to the west. Based on this data, no contaminants released from M- 705 should reach well J-1. ATK Response: ATK concurs with the UDSHW statement, the word "few" should have been stated as "no". USDHW comment: Please submit a blown-up version of the particle trace map that was submitted so the M-705 to the well J-7 and J-8 may be seen in more detail. ATK Response: A larger particle trace map is included with this submittal as Attachment 2. UDSHW comment: What is the status ofthe old wells TCC8 and TCC8a? Are well casings still in place? Based on their apparent location, it would be very useful if potentiometric and/or analytical data could be collected from one of these wells. ATK Response: As noted above, ATK has information on wells TCC8 and TCC8a. A well log indicates Well TCC8 was drilled with a 4 %-inch casing to a depth of 458 feet. However, there is no indication it was completed. Well TCC8a was drilled in the same general area of TCC8. It was drilled to a depth of 610 feet with a 10-inch casing to 438 feet and an 8-inch casing from 438 to 610 feet. The casing was perforated at depths of 400 to 410, 430 to 450, 480 to 510, and 530 to 590 feet. A search of the area located only one well with an intact 10-inch casing so it is assumed to be Well TCC8a. The well will be sampled for VOCs and perchlorate and results will be reported in the Fall 2012 semiannual groundwater report. Attachment 1 Hydrus Model Output Files Attachment 2 ATK Building M-705 Particle Track Map Attachment 1 Hydrus Model Output Files ATK M-705 HYDRUS Model Output Files Water Flow Boundary Conditions Upper Boundary Condition (• Constant Pressure Head C Constant Flux P Atmospheric BC with Surface Layer C Atmospheric BC with Surface Run Off C Variable Pressure Head C Variable Pressure Head/Flux E3 Lower Boundary Condition C Constant Pressure Head C Constant Flux H Variable Pressure Head C Variable Flux (* Free Drainage '" Deep Drainage C Seepage Face; h = f~" Horizontal Drains OK Cancel Previous Next Help Initial Condition (• In Pressure Heads ,:" In Water Contents Main Processes Heading: Welcome to HYDRUS-1D Simulate P Water Flow I-" Vapor Flow r~ Snow Hydrology f~ Solute Transport (* General Solute Transport « Major Ion Chemistry C HP1 (PHREEOC) V Heat Transport F Root Water Uptake I Root Growth V C02 Transport l~~ Inverse Solution ? OK Cancel Next. Help Geometry Information Length Units C mm <"* cm ff m £3 14 Number of Soil Materials Number of Layers for Mass Balances jl Decline from Vertical Axes |35 Depth of the Soil Profile Iteration Criteria Iteration Criteria 10 Maximum Number of Iterations 0.001 Water Content Tolerance 10.01 Pressure Head Tolerance Time Step Control 3 w Lower Optimal Iteration Range Upper Optimal Iteration Range Lower Time Step Multiplication Factor Upper Time Step Multiplication Factor Internal Interpolation Tables 1e-008 fToo Lower Limit of the Tension Interval Upper Limit of the Tension Interval OK Cancel Previous. Next.. Help 22 OK Cancel Previous. Next. Help ATK Response to Comments New SWMU 680 ATK M-705 HYDRUS Model Output Files Print Information SS Print Options W T-Level Information Every n time steps: I Print at Regular Time Interval p— fi* Screen Output Print Fluxes (instead of Temp) for Observation Nodes W Hit Enter at End? OK Cancel Previous. Next... Help Print Times Number of Print Times: JTo Select Print Times... Water Flow Parameters Qs Alpha Ks 046 0.36 0 38 0 38 1.6 0.5 2.7 0 8 1 37 1 09 1 23 1 09 0.06 0.0048 0.0288 0.048 0.5 0.5 0.5 0.5 Soil Catalog ) Silt • I Neural Network Prediction j V Temperature Dependence OK Cancel Previous... Next. Help Soil Hydraulic Model Hydraulic Model Single Porosity Models l* van Genuchten - Mualem With Air-Entry Value of-2 cm ( Modified van Genuchten Brooks-Corey f" Kosugi (log-noimal) Dud-Porosrty/Dual-Permeabilrty Models '"' Dual-porosity (Durner, dual van Genuchten - Mualem] i Dual-porosity (mobile-immobile, water c. mass transfer) <~ Dual-porosity (mobile-immobile, head mass transfer) — Models below are recommended only for experienced users = C" Dual-permeability (Kinematic wave equation) C Dual-permeability (Gerke and van Genuchten, 1993) C Look-up Tables OK Cancel Previous. Next... Help Hysteresis P No hysteresis r Hysteresis in retention curve Hysteresis in retention curve and conductivity t' Hysteresis in retention curve (no pumping. Bob Lenhard] C Initially drying curve Initially wetting curve ATK Response to Comments New SWMU 680 2 ATK Response to Comments New SWMU 680 ATK M-705 HYDRUS Model Output Files Soil Profile Summary 10 11 12 15 Root Axz Dxz 0 0399009 0.0959374 0168109 0.256417 0.36086 0.481438 0 618152 0.771001 0.939986 1.12511 132636 1.54375 177728 2.02694 0 -154975 -3.7262 -6.52934 -9 95922 -14.0158 -18.699 -24 009 -29.9456 -36.509 -43.6992 -51.5157 -59.9591 -69 0294 -78.7262 •K Cancel Previous Next Help Time Information Time Units— C Seconds f Minutes C Hours & Days C Years Time Discretization Initial Time Final Time 3G5 0.001 Initial Time Step M inimum T ime S tep j 1 e-005 M aximum T ime S tep (499899 OK Cancel Previous. Next... Help Time-Variable Boundary Conditions V Time-Variable Boundary Conditions JO Number of Time-Variable Boundary Records (e.g.. Precipitation) r~ Daily Variations of Transpiration During Day Generated by HYDRUS V Sinusoidal Variations of Precipitation Generated by HYDRUS. Meteorological Data I- Meteorological Data |0 Number of Meteorological Records (e.g.. Radiation) (* Penman-Montheith Equation f Hargreaves Formula C Energy Balance Boundary Condition |"~ Daily Variations of Meteo Data During Day Generated by HYDRUS S3 ATK Response to Comments New SWMU 680 4 Profile Information: Pressure Head -10 - -15 - E a. -25 -30 - -35 -120 -100 -80 -60 -40 —l — -20 20 h[m] Attachment 2 ATK Building M-705 Particle Track Map Oversized Drawings/Maps associated with this document are located elsewhere in the DSHW files. For assistance, please contact the GRAMA Coordinator.