DSHW-2012-012431 - 0901a068802eaafb

State ofUtah
GARY HERBERT
Governor
GREG BELL
Lieutenant Governor
David Gosen, P .E.
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF SOLID AND
HAZARDOUS WASTE
Scott T. Anderson
Director
February 3, 2012
Director, Environmental Services
A TK Launch Systems Inc.
P.O. Box 707
Brigham City, Utah 84302
Re: Corrective Action for Installation Restoration Program (IRP)
Former U.S. Air Force Plant 78, Stage 2
ATK Launch Systems, Promontory Facility, Brigham City, Utah
UTD009081357
Dear Mr. Gosen:
Solid and Hazardous Waste Control Board
Kevin Murray, Chair
Kory Coleman, Vice-Chair
Brian E. Brower
Scott Bruce
Jeff Coombs, MPH, LEHS
R. Ryan Dupont, Ph.D.
Larry A. Ellertson
Bnitt Mickelson
Brad Mertz
GaryMossor
Dennis Riding
Dwayne Woolley
Amanda Smith
Scott T. Anderson
Executive Secretary
The Division of Solid and Hazardous Waste has completed its review of the subject document. Of
the seven areas of concern investigated, Building M-585 (French Drain Site) appears to be the
only site where soil and groundwater contamination from past waste management practices has
not yet been sufficiently characterized. Our comments are two-fold:
1) The local groundwater flow direction at Building M-585 has not been defined. Three
piezometers were installed at the site (P-2, P-6, and P-7). However, it appears that
piezometer P-2 taps into a different, deeper, confined groundwater bearing zone than
piezometers P-6 and P-7 (which tap into the uppermost perched zone). Therefore, in order
to accurately determine groundwater flow direction in the uppermost perched zone, at least
one additional piezometer will have to be installed, preferably in a location which
maximizes a triangular area with respect to piezometers P-6 and P-7.
2) The soil vapor study, conducted in two phases to the southwest of Building M-585, is
based on the PETREX, ion flux, indicator method. It appears that quantitative soil vapor
concentration estimates are non-existent. Therefore, in order to model potential indoor air
concentrations to receptors in this area, which, since the perched aquifer is less than 100
feet below grade, is required as part of the human health risk assessment, a supplemental
soil vapor study consisting of a mixture of passive and active soil vapor probes is
TN201200285
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.goo
Printed on I 000/o recycled paper
warranted. This study, which will fill potential soil gas data gaps, should be conducted in
the area in direction of groundwater flow (determined as mentioned above). ,
Please respond to these comments by February 29, 2012, or, alternatively, if you are in agreement
with our comments, please submit a work plan to address these issues by March 30,2012. Once
the risks of soil and groundwater contamination around Building M-585 have been adequately
characterized, we can make a close-out determination according to Utah Administrative Rule
R315-101-6. Thank you for your cooperation. Ifyou have any questions, please call Helge
Gabert or JeffVandel at [phone].
cs~ E2)
Scott T. Anderson, Director
Division of Solid and Hazardous Waste
STAIHG/tjm
c: Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Department
Nancy Morlock, USEPA Region VIII
Paul Hancock, ATK
AI Lee,ATK
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