DSHW-2013-005473 - 0901a068803bbd7a

ATK
10 rb-oo 54-73 Launch Systems Group
PO Box 707
Bngham City, UT 84302 Division of
Solid and Hazardous Waste
www atk com SEP 1 7 2013
September 12, 2013
8200-FY14-042
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems Inc., EPA ID #UTD009081357, Semi-Annual RFI Progress Report for
March 2013 to September 2013.
Dear Mr. Anderson:
Attached is the ATK Launch Systems Inc. Promontory Facility Semi-Annual RFI Progress Report
for March 2013 to September 2013.
If you have questions regarding this report, 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,
George E. Gooch
Manager, Environmental Services
ATK Launch Systems
cc: Walter L. Baker, Division Director, Utah Division of Water Quality
SEMI-ANNUAL RFI PROGRESS REPORT
1 March 2013 -1 September 2013
ATK Launch Systems Promontory Facility
1. Description Of Work Completed
SWMU Assessment Report Schedule
As required by the Promontory Post-Closure Permit, ATK Launch Systems (ATK) provided
a schedule for submitting SWMU assessment reports or RFI work plans for the SWMUs
listed in Attachment 6 of the permit in to the Division in November 2007. After the Utah
Division of Solid and Hazardous Waste (UDSHW) has approved the schedule, ATK will
proceed with the assessment of the remaining SWMUs.
UDSHW Evaluation of Three SWMU's for Potential Closure
The UDSHW is currently evaluating three SWMUs for potential closure from the
Promontory RCRA RFI report submitted in August 2000. These SWMUS are # 192 -
Hydroflouric Acid Treatment Unit at building M-227, #444 - Dry Well at building M-19A,
and #649 - Strand Burner Exhaust Discharge at building M-585. Through discussion with
the UDSHW, it was determined that additional information on #649 was warranted in order
to establish the valence state of chromium from the total chromium analysis of the soil.
Based on process knowledge, the source of the chromium is the nickel chromium wire used
in the ignition of the propellant strands. When the propellant burns HCL gas is generated
this creates an acidic environment and a Cr (III) valence. Additional information supporting
this process description will be provided to the UDSHW.
U.S. Air Force Installation Restoration Program (IRP) Report
The United States Air Force submitted an IRP report to the UDSHW in 1992 describing the
results of their investigation of the SWMUs at the old Air Force Plant 78 facility. ATK
purchased this facility in 1995. In a December 18, 2012 letter, the UDSHW recommended
additional characterization of three sites. ATK and the Air Force have an agreement to share
costs for additional environmental work at the facility and ATK would need to obtain
concurrence from the Air Force prior to proceeding. However, upon further review of the
IRP report, ATK has determined that the level of additional investigation and clarification
does not warrant pursuing the cost sharing agreement. ATK will arrange a meeting with the
UDSHW to discuss the evaluation of risks and characterization of these SWMUs.
North Plant P Wells Investigation
As part of the corrective action for SWMUs at the North Plant, the UDSHW submitted a
letter on February 3,2012 requesting that an additional well be installed in the same area as
wells P-2, P-6, and P-7. The intent of the new well, P-10, is to more accurately determine
flow direction in the uppermost perched aquifer. ATK submitted a well completion report to
the UDSHW in May 2012.
As discussed in the completion report, during the well development process, the water level
dropped to only 0.5 ft of water remaining in the well. Approximately five days later, the
water level had not changed. There was sufficient water to collect a grab sample on March
27,2012 using a disposable bailer. Results of the sample are contained in the completion
report and included a 1,1- DCE concentration at 6.8 ppb and a TCE concentration at 9.5 ppp.
No perchlorate was detected.
As of June 2013, the water level continues to remain at approximately three inches. It is
believed that due to the tight formation, water does not recharge quickly or because it was
completed in a perched aquifer, the producing zone may be limited. Well P-10 indicates that
the perched zones have a limited northern extent. These are perched aquifers that appear to
be separate, isolated, and laterally discontinuous.
In a site visit on August 2,2012 from Helge Gabert and Jeff Vandel, the decision was made
to wait until the spring of 2013 to see if water recharges back into Well P-10 and then collect
another sample. Based on that result, it will be determined if soil gas sampling will be
required at the site.
Plant 3 Well 3 A Treatment Summary Reports
The treatment system at the Promontory Plant 3 well 3 A has been monitored quarterly
according to the Division approved plan. The plan includes a request that a summary of the
previous year to date monitoring data be included in the September Semi-Annual report.
This summary is found in Table 1. The treatment system continues to remove TCE to below
the 5u7L health based limit with a carbon replacement interval of every 6 + months. Water
usage at Plant 3 has diminished with lower production. Therefore, ATK is finding that TCE
removal extends significantly beyond the standard 6 month carbon replacement interval. In
addition, perchlorate removal in the two septic tanks, M-201 and M-205, continues to be
effective with the all samples reported at non-detect.
2. Summaries of All Findings
No corrective action work on SWMUs has been conducted during this reporting period.
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
No problems were identified.
5. Projected Work for the Next Reporting Period
Monitoring the P wells and the Plant 3 Well 3 A treatment system will be ongoing through the
next reporting period. ATK will pursue resolution of the Air Force cost sharing agreement
for additional characterization of the three IRP SWMUs on the Air Force Plant 78.
Table 1 Plant 3 Well 3A Treatment Summary Reports
Fiscal 2013 Second Quarter Data Summary Well 3A - Post Carbon
Sample Date TCE (ug/L) Perchlorate (ug/L) Flow (gal)1 i j )
9/27/2012 ; U 84 __J 5380 javerage flowjrom: ^^29/2012! J/27/2012|
__: Totalizer reading gallons ^23,627,5001
__i _ : ^ i... ........' iP_a.Y? i 90
Septic Tank Data (ug/L) _ j _ !_ • [
M-201 _ M-205 ±.,, ,. A . _]_ j[ _...!. j
. Perchlorate Perchlorate ' ; ; !
9/27/2012 U U
Influent Data > TCE (ug/L) 1 Perchlorate (ug/L) |
9/27/2012 ' 13.4 88
Fiscal 2013 Third Quarter Data Summary Well 3A - Post Carbon
Sample Date TCE (ug/L)
12/13/2012 ! U
Septic Tank Data (ug/L)
; M-201
Perchlorate
12/13/2012 • U
Perchloratejug/L) i Flow (ga|)!
91 5822 average flow from:
M-205
Perchlorate
U
9/27/2012 12/13/2012
Totalizer reading gallons
'• Days
24,075,800j
77;
Fiscal 2013 Fourth Quarter Data Summary Well 3A - Post Carbon
Sampl e Date \ TCE (ug/L)
3/28/2013 ! 1.7
Septic Tank Data (ug/L)
M-201
Perchjorate
3/28/2013 U
Perchlorate (ug/L) Flow (gal), , j
86 17409 average flow from: • 12/13/2012 3/28/2013
•~ • • ....... .». T ^ ...... ._( ..... ... _j
j _ Totalizer reading gallons j 25,903^700j
Days j 105;
M-205
PercN orate
U
Influent Data TCE (ug/L) Perchlorate (ug/L)
3/28/2013 22.1 83
[ Fiscal 2014 First Quarter Data Summary Well 3A - Post Carbon
Sample Date ! TCE (ug/L) Perchlorate (ug/L) |F[ow (gal)
6/27/2013 1.1
i Se pti c Ta n k JJata (ug/L)
! M-201
: Perchlorate
U
86
M:205
Perchlorate
U
17252 average flow from: 3/28/2013! 6/27/2013:
Totalizer reading gallons
Days
27,473,600!
91;