DSHW-2013-005479 - 0901a068803bbd06

State
Department of
Environmental Quality
Amanda Smith
Ereculire Director
DIVISION OF SOT-ID AND
HAZARDOUS WASTE
Scott T. Anderson
Director
Solid and Hazsrdous \yrst€ Control Boerd
Kevin Munay, Crarr
Dennis Riding, t',ce-Crair
Eug€ne Cole, DrPH
JclICoombs. MPH, LFHS
Mark Franc
Brelt Mickelson
Amanda Smith
Shane Whitney
Drr a)'ne Wooller
Scott T. Arderson
Executive Secrelary
GARY HERBERT
Governor
GREC BEI,L
Lieutehanl Governor
October l, 2013
George Gooch, Manager
Environmental Services
ATK Launch Systems - Promontory
P.O. Box 707
Brigham City, Utah 84302-0707
RE: RFI Report, SWMUs #192,#444,and#649
uTD00908l 357
Dear Mr. Cooch:
The Division of Solid and Hazardous Waste has completed its review of the RFI Report,
phase I SWMUs for SWMU numbers 192,444 and 649. Division staffmember Jeff Vandel
also inspected these SWMUs during a site visit on September 10,2013. Our responses to the
RFI Report findings and recommendations are given below lor each SWMU.
SWMU #192 - Hydrofluoric Acid Treatment Unit at M-227
Based on the RFI Report, ATK recommended that no further action be taken at this SWMU.
Due to the issues outlined below, the Division believes that this recommendation is not
appropriate.
. concentrations of cadmium, chromium and lead exceed ATK background levels at
the "neutralization pit."
. The EPA Regional Screening t,evels (RSL) for hexavalent chromium in residential
(0.29 mg/kg) and industrial (5.6 mgikg) soil are based on valent-specific IRIS
toxicity values. Therefore, ATK needs to demonstrate that concentrations of
chromium that exceed background do not exceed the RSL lor hexavalent chromium.
The RFI Report did not include analyical data, or other information, indicating what
portion of the total chromium that was detected (maximum of 89.8 mg/kg) is
hexavalent chromium.
As outlined in Section VI.F of ATK's Post-closure Permit, a recommendation for no further
action must be based on information that demonstrates that hazardous constituents were not
detected; or hazardous constituents are below background concentrations; or hazardous
constituents have been detected, but do not pose a threat to human health or the environment
195 Nonh 1950 West ' Sak Lake City' UT
MailingAddress P.O. Box 144880'Salt Lake Citv, UT 841144880
Telephone (8Ol) 536-0200'Fax [phone] ' T D D [phone]
lLtluut. de q. i Iah. g(ro
Printed on 1007o recycled Paper
DSHW-2013-00s479
Division of Solid and Hazardous Waste
Page 2
based on the results of a screening level risk assessment conducted in accordance with R315-
l0l-5.2(bxl) ofthe Utah Administrative Code.
Based on a discussion on the chromium valence issue during a meeting that was held at ATK
Promontory on September 19,2013, ATK has agreed to collect a sample for hexavalent
chromium analysis from the location where the maximum total chromium concentration was
detected. A decision on whether to conduct further work or a screening level risk assessment
will be made based on the results ofthe hexavalent chromium analvsis.
SWMU #444 - Drv Well at M-l9A
Conective action was conducted at this site from September 1997 to November 1998 and
excavated soils were treated onsite as part ofthe CAMU that was in July 1997. Based on the
results of confirmation samples collected after the third and final excavation at the site and
the CAMU treatment results, the RFI Report is hereby approved. The Division concurs that
no further action is needed at this SWMU. No land use restrictions apply to this specific site.
SWMU #649 - Strand Bumer Exhaust Discharee at M-585
Based on the investigation of this SWMU, ATK has recommended that corective action be
taken at the site. Soil sample results indicate that chromium and mercury were detected at
concentrations that exceed ATK background levels. As stated above, ATK needs to
demonstrate that concentrations of chromium that exceed background do not exceed the EPA
Regional Screening Level (RSL) for hexavalent chromium. In addition, HMX was detected
at 18.7 mg/kg.
Based on a discussion on the chromium valence issue during a meeting that was held at ATK
Promontory on September 19,2013, ATK has decided to collect a sample for hexavalent
chromium analysis from the same location where the total chromium sample, which
exceeded background, was collected. A decision on whether to conduct further work or a
screening level risk assessment will be made based on the results ofthe hexavalent chromium
analysis.
lfyou have any questions, please call JeffVandel at [phone].
Scott T. Anderson, Director
Division of Solid and Hazardous Waste
STA/JViKK
c: Paul Hancock, ATK Launch Systems
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Nancy Morlock, Region 8 EpA
File !o: AI K Launch Systems Pronronlory