DSHW-2013-002344 - 0901a06880358de3

Department of
Environmental Quality
State of Utah
Amanda Smith
Executive Director
GARY HERBERT
Governor
DIVISION OF SOLID AND
HAZARDOUS WASTE
GREG BELL
Lieutenant Governor
Scott T. Anderson
Director
March 14,2013
Robert Ingersoll, Director
Environmental Services
ATK Launch Systems-Promontory
P.O. Box 707
Brigham City, UT 84302-0707
RE: Assessment Report for SWMU #681
UTD009081357
Dear Mr. Ingersoll:
The Division of Solid and Hazardous Waste has completed its review of ATK's responses to
Division comments on the New SWMU Notification and Assessment Report for the new SWMU
#681.
Enclosed are a few additional comments in reply to your responses. Please provide a response to
these comments within 60 days of the date ofthis letter.
If you have any questions, please call JeffVandel at [phone].
~2)
Scott T. Anderson, Director
Division of Solid and Hazardous Waste
STA/JV/tjm
Enclosure
c: Paul Hancock, A TK, email
Blair Palmer, ATK, email
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Nancy Morlock, Region 8 EPA
DSHW -2013-002344
I95 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.gov
Printed on 1 00"/o recycled paper
Division of Solid and Hazardous Waste Additional Comments on
ATK Launch Systems-Promontory Facility's Response to Comments
New SWMU Notification and Assessment Report for SWMU #681
Original DSHW 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 of26 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.
Additional DSHW Comment:
The Division is concerned that the answer to the question of whether groundwater may be
impacted by the release from Building M-705 is based solely on the Hydrus Model that has been
run without any specific subsurface data. We believe that a more rigorous assessment of the
potential for an impact to groundwater from the release is warranted. The installation of a new
monitoring well down-gradient of M-705 could provide the most definitive answer to this
question.
Original DSHW Comment:
Please provide a blown-up version of the particle trace map that was submitted so the path from
the M-705 building to wells 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.
Additional DSHW Comment:
Thank you for providing the blown-up version of the particle trace map. Based on the map, it
appears that the particle trace from M-705 is to the west beneath Blue Creek and then pretty much
straight south until near well H-8 where it turns to the southwest. It appears that if contamination
from the release at M-705 were to reach groundwater, a contaminant plume may not be seen at
wells J-7 or J-8.
In addition, at approximately well H-1, the particle trace contiimes due south to the mudflats as
opposed to turning toward the east and Shotgun and Pipe Springs. Is this consistent with the
solute transport model?
DSHW-2013-002344 1
Original DSHW Comment:
What is the status of the 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 ...
Additional DSHW Comment:
ATK has indicated that well TCC8a was sampled last fall and that no contaminants were detected.
Is the potentiometric surface data for the well consistent with the groundwater flow model? Is
there any data available that may be used to calculate a hydraulic conductivity for the well? It
was also indicated in the meeting held at our office on March 6, 2013 that A TK may recalibrate
the groundwater flow model. Please ensure that applicable data from well TCC8a (i.e., head data
and concentration) is used when the model is recalibrated.
DSHW-2013-002344 2