DSHW-2012-013196 - 0901a0688032ad83

State ofUtah
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
December 11, 2012
Robert Ingersoll, Director
Environmental Services
A TK Launch Systems -Promontory
P.O. Box 707
Brigham City, UT 84302-0707
RE: Compliance Evaluation Inspection
UTD009081357
Dear Mr. Ingersoll:
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
Brett Mickelson
Brad Mertz
Gary Mossor
Dennis Riding
Dwayne Woolley
Amanda Smith
Scott T. Anderson
Executive Secretarv
Representatives of the Division of Solid and Hazardous Waste conducted a compliance evaluation
inspection (CEI) at the ATK Promontory facility on September 25 and 26, 2012. The CEI was
conducted to evaluate ATK's compliance with the State ofUtah Hazardous Waste Management
Rules (R315 of the Utah Administrative Code), and the Hazardous Waste Permit. Based on
findings documented during the inspection, A TK appeared to be in compliance with its permit and
the Hazardous Waste Management Rules.
With respect to the practice of disposing post-bum ash and debris from the M-136 and M-225
Bum Grounds in the on-site, solid waste landfill, analytical results for perchlorate in ash or
residue samples collected after the treatment of reactive waste were requested. Based on the
analytical results provided by A TK of the bum ash and filter cake samples that were collected on
March 16, 2012 (Lab Sample ID 1203017-01 and 1203017-02), it appears that perchlorate
occasionally remains in the ash or residue following an open bum and is then disposed in the
unlined landfill.
In addition, A TK recently completed a statistical assessment of perchlorate concentrations that
have been observed in groundwater monitoring samples collected from wells in the M-136 area.
The assessment confirmed that, of the six wells that were evaluated, two ofthem (wells D-4 and
C-1) have increasing trends in perchlorate concentrations. It is unknown if ash containing
perchlorate that is disposed of in the M-136 landfill is contributing to the groundwater
contamination. R315-101-3 (Principle ofNon-degradation) states, "when closing or managing a
contaminated site, the responsible party shall not allow levels of contamination in
DSHW-2012-011452
195 North 1950 West Salt Lake City, UT
Mailing Address: P.O. Box 144880 ·Salt Lake City, UT 84114-4880
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groundwater ... to increase beyond the existing levels of contamination at a site when site
management commences."
ATK currently ships bum ground ash and debris off-site for disposal at the Bacchus facility. The
Division recognizes that the Promontory bum grounds ash is non-hazardous and may be disposed
in the on-site solid waste permitted landfill. However, to ensure that groundwater contamination
at Promontory does not increase beyond existing levels, the Division recommends that ATK adopt
the practice of shipping bum ground ash (and filter cake as applicable) off-site for ?isposal.
This letter will serve to close out the 2012 CEI. The Division appreciates the cooperative efforts
of your staff during the CEI. If you have any questions, please contact Jeff Vandel at (80 1) 536-
0257.
Sincerely,
Scott T. Anderson, Director
Division of Solid and Hazardous Waste
STA/JV/tjm
c: George Gooch, ATK, email
Blair Palmer, A TK, email
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
David Duster, Region 8 EPA
DSHW-2012-011452 2