DSHW-2014-004697 - 0901a0688041094a

Launch Systems Group
P.O. Box 707
Brigham City, UT 84302
Division of
Solid and Hazardous Waste
www.atk.com MAR 1 2 2014
March 12,2014
8200-FY14-080
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
September 2013 to March 2014.
Dear Mr. Anderson:
Attached is the ATK Launch Systems Inc. Promontory Facility Semi-Annual RFI Progress Report
for September 2013 to March 2014.
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
September 1,2013 - March 1,2014
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 ofthe 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 -
Hydraflouric Acid Treatment Unit at building M-227, #444 - Dry Well at building M-19A,
and #649 - Strand Burner Exhaust Discharge at building M-585. Based on a UDSHW
September 10, 2013 site visit and a October 1, 2013 letter, it was determined that #444 could
be closed, but additional information on #649 and #192 was warranted in order to establish
the valence state of chromium from the total chromium analysis of the soil. Soil samples
were collected from these two locations and analyzed for Chromium (VI). These results
were provided to the UDSHW and are also included in Attachment 1. A low detection limit
was required based on the Regional Screening Level (RSL) including a value developed in
New Jersey of 0.29 ppm, which is much lower than what is established in the EPA IRIS data
base. ATK is currently discussing this inconsistency with DSHW in order to determine a
clean-up value.
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. These included Blue Creek, the North Drainage
Ditch (NDD) and the M-585 dry well. ATK has been reviewing these sites and the
associated old risk assessment and discussed these with DSHW. Based on this review the
risks associated with Blue Creek and the NDD do not appear to be valid. A copy of this
review is found in Attachment 2. Additionally, ATK has also investigated the NDD and
submitted the results to UDSHW as SWMU #230, and #282 in the October 2000 RFI report
with a recommendation of no further action. There are a total of 10 ATK SWMUs associated
with the NDD. A figure showing the samples collected in the NDD and the associated
SWMUs is found in Figure 1. The M-585 dry well site investigation is discussed in the
following paragraph on the P Well investigation.
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 ppb.
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 and now 2014 to see if water recharges back into Well P-10
and then collect another sample. Based on that result, it will be determined if additional
investigation will be required at the site.
2. Summaries of All Findings
The summaries of the corrective action work on conducted on SWMUs during this reporting
period are found in section 1 above.
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 3A treatment system will be ongoing through the
next reporting period. ATK will work with UDSHW in investigating and closing the
SWMUs currently under review associated with the 10 IRP related SWMUs and the three
other SWMUs currently under evaluation.
Attachment 1
Analytical Results for Cr (VI) Analysis
In Soils at SWMUs #649 and #192
ALS) Environmental
1310102
Inorganics:
The samples were analyzed following SW-846 procedures for the current revision of the
following SOP and method:
Analvte Method SOP#
Hexavalent chromium 7196A 1122
All acceptance criteria were met.
loflO
ALS Environmental -- FC
Sample Number(s) Cross-Reference Table
OrderNum: 1310102
Client Name: ATK
Client Project Name: Cr(VI) Test SWMUS
Client Project Number:
Client PO Number: ATK-44544
Client Sample
Number
Lab Sample
Number
COC Number Matrix Date
Collected
Time
Collected
SWMU #649 1310102-1 SOLID 30-Sep-13 19:00
SWMU #192 1310102-2 SOLID 30-Sep-13 19:00
V
Page 1 of 1 ALS Environmental - FC Date Printed: Tuesday, October 29,2013
LIMS Version: 6.678
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ALS Environmental
225 Commerce Drtw. Fort CodtK. Colorado 80524
TF. (900) 44&.1511 PH: [phone] FX: (970)4*0-1622
Chain-of-Custody
SAMPLER P Hancock DATE 30-Sep-13
WORKOHOER
pAce
PROJECT NAME CRWh Te>at SWMUS ante Promontory TURNAROUND standard DISPOSAL ffilabj)* Return to Client
PROJECT No. EDO FORMAT
PURCHASE ORDER ATK-44S44
COMPANY NAME ATK WLL TO COMPANY ATK
SEND REPORT TO Paul Hancock INVOKE ATTN TO
ADDRESS PO Box 707 ADDRESS
CfTY 7 •TATE/» Brigham City Ut. 84302-707 CITY/STATE ASP
PHONE [phone] PHONE
FAX -FAX
E-MAIL DauLhancockaatk.com E-MAIL,
Lab ID Field ID Matrix Samel*
Date Sample
Tlnwi
- # Pres. QQ
SWMU # 649 30-Sep-13 01/00/1900
SWMU #192 30-Sep-13 01/00/1900
Time Zone (Circle): EST CST MST PST Matrix: O = o» S'V* NS" non-toil *oM W« weter I--Squtd E - extmO F = filter
For matala or anions, please detail analytes below.
Comments:
Cr (VI) need reporting limit below 0.29 mg/kg
©
QCPAOXAMrtClttCfcealo*)
LEVEL II (! OC)
LEVEL III (8ttJ QC + forma)
LEVEL IV <SWQC*formi
PieeervaHve Key: 1-HCI 2-HN03 3-H2S04 4-NaOH WtaHS04 7-Ottnr «-4 degree* C 9-5036
, RELINQUISHED rt'
RECEIVED BY
REUHQUSHEDBY
. RECEIVED BY
RELMQUISHED BY
RECEIVED BY
PRINTED NAME DATE TIME
ALS Environmental - Fort Collins
CONDITION OF SAMPLE UPON RECEIPT FORM
Client:
Project Manager:
ATK
A.VJ
Workorder No: C5lQ(Q2
Initials: /f^X Pate: lo/d*
>• Does this project require any special handling in addition to standard ALS procedures'?
2< Are custody seals on shipping containers intact?
3 Are Custody seals on sample containers intact?
NONE
« Is there a COC (Chain-of-Custody) present or other representative documents?
s Are the COC and bottle labels complete and legible?
6 Is the COC in agreement with samples received? (IDs, dates, times, no. of samples, no. of
containers, matrix, requested analyses, etc.)
Were airbills / shipping documents present and/or removable?
s. Are all aqueous samples requiring preservation preserved correctly? (excluding volatiles)
Are all aqueous non-preserved samples pH 4-9?
io Is there sufficient sample for the requested analyses?
> Were all samples placed in the proper containers for the requested analyses
iz Are all samples within holding times for the requested analyses?
'3 Were all sample containers received intact? (not broken or leaking, etc.)
14 Are all samples requiring no headspace (VOC, GRO, RSK/MEE, Rx CN/S, radon)
headspace free? Size of bubble: < green pea > green pea
YES NO
am NO
NO YES
NO
YES NO
YE NO
<£YE^ NO DROP OFF
YES NO
YES NO /A
NO
NO
NO
NO
/A YES NO
Amount
NO /A J YES
NO
RAD NO 84
is. Do any water samples contain sediment?
Amount of sediment: dusting moderate heavy
16. Were the samples shipped on ice?
17 Were cooler temperatures measured at 0.1-6.0"C? IR gun used*
DOT Survey/ Acceptance InforfTurllor)
Cooler #:
Temperature (°C):
No. of custody seals on cooler
External uR/hr reading:
Background iiR/hr reading:
Were external uR/hr readings < two times background and within DOT acceptance criteria? NO / NA (If no. see Form 008.)
Additional Information: PROVIDE DETAILS BELOW FOR A NO RESPONSE TO ANY QUESTION ABOVE, EXCEPT #1 AND #16.
tacted? YES/ NO(jfiC^Cmita
'/Date: M
If applicable, was the client contacted? YES / NO (nA j^en^act: Date/Time:
Project Manager Signature i n hp
*IR Gun #2: Oakton, SN 28852500201-0066
Form20lr24.xls (06/04/2012) *IR Gun #4: Oakton, SN 2372220101-0002
Page 1 of |
4 of 10
ORIGIN ID>OGDA <«5> 8G3-S425 SHIPPING ATK LAUNCH SYSTEKS 9160 N HUV B3 BLDG M3
CORINNE• UT 84307 UNITED STATES US
SHIP DATE) 030CT13 ACTMGTi ?.S LB MAN CAOt 01B2408/CAFE2704 DIMS: 12x12*18 IN
BILL SENDER
"AMY WOLF
ALS GLOBAL
225 COMMERCE DRIVE
FORT COLLINS CO 80524
(80714S0-1611 UEF: Mil C/CMM MOP
uiiiiaiiiiiniiiiiiuiuifliifiiiifisuiinituiiiniiia FedEx
Express
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FRI - 04 OCT A
STANDARD OVERNIGH
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131010*
ALS Environmental - FC
Client: ATK
Project: Cr(VI) Test SWMUS
Sample ID: SWMU #649
Legal Location:
Collection Date: 9/30/2013 19:00
HEXAVALENT CHROMIUM
CHROMIUM VI 0.4
SAMPLE SUMMARY REPORT
Date: 29-Oct-li
Work Order: 1310102
Lab ID: 1310102-1
Matrix: SOLID
Percent Moisture: 8.2
Dilution
Factor Date Analyzed
SW7196 Prep Date: 10/8/2013 PrepBy:AJD
0.11 MG/KG 1 10/8/2013
Report
Analyses Result Qual Limit Units
ALS Environmental - FC
LIMS Version: 6.678 AR Page 1 of 4
6 of 10
ALS Environmental - FC
Client: ATK
Project: Cr(VI) Test SWMUS
Sample ID: SWMU #192
Legal Location:
Collection Date: 9/30/2013 19:00
HEXAVALENT CHROMIUM
CHROMIUM VI ND
SAMPLE SUMMARY REPORT
Date: 29-Oct-li
Work Order: 1310102
Lab ID: 1310102-2
Matrix: SOLID
Percent Moisture: 7.0
Dilution
Factor Date Analyzed
SW7196 Prep Date: 10/8/2013 PrepBy.AJD
0.11 MG/KG 1 10/8/2013
Report
Analyses Result Qual Limit Units
ALS Environmental - FC
LIMS Version: 6.678 AR Page 2 of 4
7 of 10
ALS Environmental — FC SAMPLE SUMMARY REPORT
Client: ATK Date: 29-Oct-13
Project: Cr(VI) Test SWMUS Work Order: 1310102
SamplelD: SWMU#192 Lab ID: 1310102-2
Legal Location: Matrix: SOLID
Collection Date: 9/30/2013 19:00 Percent Moisture: 7.0
ReP°rt Dilution
Analyses Result Qual Limit Units Factor DateAnalyzed
Explanation of Qualifiers
Radiochemistry:
U or ND - Result is less than the sample specific UDC.
Y1 - Chemical Yield is in control at 100-110%. Quantitative yield is assumed
Y2 - Chemical Yield outside default limits.
W - DER is greater than Warning Limit of 1.42
* - Aliquot Basis is 'As Received' while the Report Basis is 'Dry Weight'.
# - Aliquot Basis is 'Dry Weight' while the Report Basis is 'As Received'.
G - Sample density differs by more than 15% of LCS density.
D - DER is greater than Control Limit
M - Requested MDC not met.
LT - Result is less than requested MDC but greater than achieved MDC.
Inorganics:
M3 - The requested MDC was not met, but the reported
activity is greater than the reported MDC.
L - LCS Recovery below lower control limit.
H - LCS Recovery above upper control limit.
P - LCS, Matrix Spike Recovery within control limits.
N - Matrix Spike Recovery outside control limits
NC - Not Calculated for duplicate results less than 5 times MDC
B - Analyte concentration greater than MDC.
B3 - Analyte concentration greater than MDC but less than Requested
MDC.
B - Result is less than the requested reporting limit but greater than the instrument method detection limit (MDL)
U or ND - Indicates that the compound was analyzed for but not detected.
E - The reported value is estimated because of the presence of interference An explanatory note may be included in the narrative.
M - Duplicate injection precision was not met.
N - Spiked sample recovery not within control limits. A post spike is analyzed for all ICP analyses when the matrix spike and or spike
duplicate fail and the native sample concentration is less than four times the spike added concentration.
Z - Spiked recovery not within control limits. An explanatory note may be included in the narrative.
* - Duplicate analysis (relative percent difference) not within control limits.
Organics:
U or ND - Indicates that the compound was analyzed for but not detected.
B - Analyte is detected in the associated method blank as well as in the sample. It indicates probable blank contamination and warns the data user.
E - Analyte concentration exceeds the upper level of the calibration range.
J - Estimated value. The result is less than the reporting limit but greater than the instrument method detection limit (MDL)
A - A tentatively identified compound is a suspected aldd-condensation product.
X - The analyte was diluted below an accurate quantitation level.
* - The spike recovery is equal to or outside the control criteria used.
+ - The relative percent difference (RPD) equals or exceeds the control criteria.
Diesel Range Organics:
ALS Environmental - FC
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ALS Environmental - FC SAMPLE SUMMARY REPORT
Client: ATK Date: 29-Oct-13
Project: Cr(VI) Test SWMUS Work Order: 1310102
SamplelD: SWMU #192 Lab ID: 1310102-2
Legal Location: Matrix: SOLID
Collection Date: 9/30/2013 19:00 Percent Moisture: 7.0
Report Dilution
Analyses Result Qual Limit Units Factor DateAnalyzed
G - A pattern resembling gasoline was detected in this sample.
D - A pattern resembling diesel was detected in this sample.
M - A pattern resembling motor oil was detected in this sample
C - A pattern resembling crude oil was detected in this sample
4 - A pattern resembling JP-4 was detected in this sample.
5 - A pattern resembling JP-5 was detected in this sample.
H - Indicates that the fuel pattern was in the heavier end of the retention time window for the analyte cf interest.
L - Indicates that the fuel pattern was in the lighter end of the retention time window for the analyte of interest.
Z - This flag indicates that a significant fraction of the reported result did not resemble the patterns cf any of the following petroleum hydrocarbon products:
- gasoline
- JP-8
- diesel
- mineral spirits
- motor oil
- Stoddard solvent
- bunker C
ALS Environmental - FC
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ALS Environmental ~ FC
Client: ATK
Work Order: 1310102
Project: Cr(VI) Test SWMUS
Date: 10/29/2013 11:5
QC BATCH REPORT
Batch ID: WC131008-1-1 Instrument ID: Spec Method: SW7196
LCS
Client ID:
Analyte
Sample ID: WC131008-1
Run ID: CR131008-1A
Result ReportLimit SPKVal
SPK Ref
Value
Units: MG/KG Analysis Date: 10/8/2013
Prep Date: 10/8/2013 DF: 1
RPD Ref RPD
Value RPD Limit
Control
%REC Limit Qual
CHROMIUM VI 3.01 0.1 100 80-120 20
MB
Client ID:
Analyte
Sample ID: WC131008-1
Run ID: CR131008-1A
Result ReportLimit SPKVal
Units: MG/KG Analysis Date: 10/8/2013
Prep Date: 10/8/2013 DF: 1
SPK Ref Control
Value %REC L'm'*
RPD Ref
Value RPD
RPD
Limit Qual
CHROMIUM VI ND 0.1
MS SamplelD: 1310102-1
Client ID: SWMU #649
Analyte
Run ID: CR131008-1A
Result ReportLimit SPKVal
SPK Ref
Value
Units: MG/KG Analysis Date: 10/8/2013
Prep Date: 10/8/2013 DF: 1
Control
%REC Limit
RPD Ref
Value RPD
RPD
Limit Qual
CHROMIUM VI 1.32 0.109 1.09 0.4 85 75-125 20
MSD SamplelD: 1310102-1
Client ID: SWMU #649
Analyte
Run ID: CR131008-1A
Result ReportLimit SPKVal
Units: MG/KG Analysis Date: 10/8/2013
Prep Date: 10/8/2013 DF: 1
SPK Ref
Value
Control
%REC Limit
RPD Ref
Value RPD
RPD
Limit Qual
CHROMIUM VI 1.39 0.109 1.09 0.4 91 75-125 1.32 20
The following samples were analyzed in this batch: 1310102-1 1310102-2
ALS Environmental - FC
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Attachment 2
ATK Review of the U.S. Air Force Installation
Restoration Program (IRP)
For Former Plant 78, Stage 2
ATK Review of the U.S. Air Force Installation Restoration Program (IRP)
For Former Plant 78, Stage 2
In a December 18, 2012 letter to ATK, the UDSHW commented on the 1992 IRP Stage 2 report
for the former Air Force Plant 78, which is now called ATK Promontory North Plant. The
UDSHW determined that three of the seven areas investigated need additional characterization.
These are Blue Creek, North Drainage Ditch (NDD), and M-585 French Drain Site groundwater
(M-585 is currently being addressed by monitoring of a new well, P-10).
The IRP investigation results were used to perform a human health risk assessment that included
all Plant 78 areas as a whole and calculated a combined risk of 4.6E-6, primarily due to
inhalation pathways at the Blue Creek and NDD sites assuming a continuous lifetime residential
exposure.
Blue Creek
The risks assumed for Blue Creek contributed the greatest amount of risk to the combined risk
assessment. These risks are related to the detections of two compounds, 1,2-DCA and
chloroform, from the December 1988 sampling of surface water and sediment. Of the two, 1,2-
DCA contributes the highest overall risk.
There are several anomalies and conflicting data sets related to the sampling:
• 1,2-DCA was detected at the two background Blue Creek locations north of the Air Force
property indicating an up gradient source.
1,2-DCA was not detected at all of the sample locations along the length of Blue Creek to
the Air Force property boundary (seven out of twelve), and no detections south of that
boundary strongly indicating a noncontinuous source.
• The half-life of 1,2-DCA in surface water was cited in the report from the EPA as 0.005
to 0.2 days.
• 1,2-DCA was only detected in the surface water, not in the sediment, again indicating a
noncontinuous source.
• Previous sampling from 1987 at similar locations did not detect 1,2-DCA or chloroform
in surface water or sediment.
• Repeat sampling conducted in 1990 of the same locations did not detect any 1,2-DCA or
chloroform in surface water or sediment, again indicating this was a onetime,
noncontinuous source or a lab contamination issue.
• Chloroform was only detected once (0.68 ppb) in the twelve Blue Creek samples
indicating this is an outlier or laboratory contamination.
• Chloroform was also detected in the drinking water system (an artifact of chlorination).
• Subsequent samples of Blue Creek and storm water discharges to Blue Creek have not
detected volatile organics. Through a UPDES permit, ongoing monitoring of facility
discharges to Blue Creek, ATK demonstrates compliance with VOCs and other
contaminant limits in the permit.
Risk Assessment Assumptions for Blue Creek
• The risks were summed from all sources. This is very unusual, risk assessments are
calculated from individual sources.
. Only the high detections from the 1988 sampling were used, ignoring the 1987 and 1990
samples that were all nondetects.
• It was assumed that the exposures to 1,2-DCA and chloroform concentrations were
continuous for a lifetime.
• The greatest risk (3.4E-6) was calculated related to inhalation for future residents living
on the banks of Blue Creek and with children swimming in the creek 15 days a month
from May to August.
• When the future risk to residents is removed, the current risk for workers and residents
was calculated at 2.4E-7.
North Drainage Ditch (NDD)
Surface water samples and sediment samples were collected in two locations. The water sample
from one location at the half way point of the ditch indicated several volatile organic
compounds(VOC) with 1,2-DCA and 1,1,1-TCA being detected at 9.9 ppb and 7.5 ppb,
respectively. The other VOC detections were considerably lower. The other sample near the end
of the ditch (west) detected only 1,2-DCA at 4.3 ppb. These samples were collected in December
1988 when there was some water to sample in the ditch. It was noted in the report that discharges
to the ditch had ceased and it was normally dry. Surface sediment samples were also collected;
however, there were no detections of VOCs. Shallow soil borings were also made at seven
locations along the ditch and samples collected at 4 and 8 feet. Only two detections of methlene
chloride at 0.9 ppm and 0.8 ppm were found. Two deep borings were also made. Samples at one
location were collected at 26 feet, 51 feet, 76 feet, and 101 feet, there were no detections. The
other location was at similar depths with only a detection of methylene chloride 4.79 ppm at 36
feet and a trace of a few semi volatile constituents (phalates) and TCE at 171 feet.
Sampling in 1987 (Phase 1) showed trace amounts of TCA, chloroform, and TCE in surface
water and trace amounts of TCE in soil.
When all of the sampling events are reviewed in total, overall there is very little contamination at
this site. These one-time detections were limited to primarily surface water and considering that
the ditch was normally dry, the surface detections would be considered unusual. However, the
risk assessment considered inhalation exposure to surface water and windblown contaminants as
the primary risk.
Under the RFI program, ATK collected samples from seven additional locations along the length
ofthe NDD for SWMUs #230 and #282. These results are included in the August 2000
submittal to the DSHW of the RCRA Facility Investigation Phase 1 Report. The report has a
recommendation of no further action for both of these SWMUs. A figure showing a summary
of the samples collected in the NDD area from both the IRP program and under the RFI program
is included with this document as Figure 1.
Analysis ofthe IRP Analytical QA/QC Data
Scott Fraser, the ATK Environmental Laboratory QA/QC Officer, provided this review of the
IRP laboratory QA/QC Data for the 1988 analysis:
Here are the issues that I would say may call the 1988 Blue Creek surface water data into
question.
• The analysis methods 8010/8020 are gas chromatography techniques that are subject to
nontargel coeluting interferences. Because of this known factor, when compounds are
detected, it is a requirement to confirm them using a secondary column analysis or gas
chromatography/mass spectrometry technique. While there is ''confirmation" data
supplied, it does not always confirm the primary results and it is nol clear that a
secondary column or alternative technique was used. In some cases, the confirmation did
not see the compound. It appears that the confirmation column used the same technique
or column as used in the detection column.
• There is data for a reagent water blank sample that has a detection of 1,2-dichloroethane
at 0.978 ug/L. This is one of the compounds in question and suggests, as indicated above,
that the technique is prone to nontarget coeluting interferences.
• The target compounds present in the Blue Creek surface waters do nol appear with the
common pattern of attendant parent/breakdown products one would expect to find. This
has a serious impact regarding the authenticity ofthe compound identification.
• In light of the fact that a second sampling event did not find any ofthe compounds
reported in the first sampling event suggests further that the earlier reported compounds
may have been a result of nontarget coeluting interferences.
Conclusion
For Blue Creek, the preponderance of data demonstrates that the onetime detections in 1988 of
1,2-DCA and chloroform are not valid for assessing risks at this stream. Since 1989, discharges
to Blue Creek have been regulated by a UPDES permit that includes monitoring for volatile
organic constituents such as 1,2 DCA and chloroform. ATK demonstrates compliance to the
permit through ongoing monitoring. ATK therefore recommends that the risks attributed to
Blue Creek under the IRP be considered invalid with the understanding that the stream is
managed under the UPDES permit, and recommends no further action.
For the NDD, ATK believes that samples taken under the IRP investigation coupled with the
results of the RFI sampling show that there are no unacceptable risks associated with the site and
recommends a designation of no further action.
Figures
Figures from the IRP investigation reports showing sample locations and concentrations for
Blue Creek are included as Appendix 1.
Figure 1 North Drainage Ditch Area Sampling
Air Force
Samples
i
SB
1SW
1SS
2 SB 1SW, 1SW, 3 SW, 2 SS,
2 SB, 1 DB 1 DB 1SS 1SS 1SS, 1SB 1 SB 1SW 1SB 1SB
1SB
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Sewer
Plant Lm; 1SS
Sewage
Evap.
pond
• ••" = ,"| C « 'Jm it 1
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1SB
1SW,
1SS Key:
SS=Soil Sample or Sediment
SW=Surface Water
1SB
Google -
Imagery Date: 9/13/2010 41°43'16.94" N 112025'59.11" W elev 4496 ft eye alt 7957 ft'
Appendix 1
IRP Stage 1 and Stage 2 Sample Locations and Results
for Blue Creek
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M-OCf 0,M* t«A
1,2-OC* 1*0 U«
1.3-OCT 0.62 *«/
;HO<J Mfl M«/I LEGEND f.i.l-TC* 0.304 m9A
UJ-DC* ?.0* uoA
KC »44 wfA
BC-5,$4
*C~3w£8
OCHS fl,4tt y«A
"1,2-0^ 0.2* tttt/l
0.1S w»A TCt 0.07 ug/l
-\ tc-3w>* ClCJi 0.41 ug/l t ,>-0f> 5.?*
•Tc-aoo
KCM-**7
K~«4
swse K-50J CtCW J-74 3-M ueA M-DCA I?.? **A
t,2-0Cr* Utt t»oA
0.7S WtA
*CS 0-3S UQA
O SAMPLING EPISODE 1 (DECEM8ER 1988)
SAMPLING EPISODE 2 (MARCH 1990)
STAGE 1 SAMPLES
STAGE 2 SHALLOW SOIL BORfNG SAMPLES
t.l.t-TC* 4* 0.11J ma/ko
t.t.l-TCA g 0,0« m*A«
Figure 4-38
STAGE 1 AND STAGE 2 SAMPLE
RESULTS, BLUE CREEK NORTH
SOURCE;: est. mi.
INSTALLATION RESTORATION
PROGRAM USAF PLANT 78
4-156
*
M-S23 M-128
5 St./*
te-sss
tC~S»
K3/1C IW114
M-191
LEGEND
Figure E-8
STAGE 1 AND STAGE 2 SAMPLE LOCATIONS
BLUE CREEK, NORTH
INSTALLATION RESTORATION
PROGRAM USAF PLANT 78
A (USC t I
a SUM i MM/M tmta mm win
• tu« t M«I>* wua u««a«
• HUM 2 MUM UJCMBKS
Q »«M t SOU MO/M JU»«ct Mitt SN0US
• nan ! wi« »«/oi rj»«£t mn* s*u»m
"»*tc « wwunoii Muster*
Figure E-9
STAGE 1 AND STAGE 2 SAMPLE LOCATIONS
BLUE CREEK, SOUTH
INSTALLATION RESTORATION
PROGRAM USAF PLANT 78
SOUKCs ISC. !»!,
• 1.1-OCA 0.«l
BC-SW10
am 0.21
A!R FORCE PLANT 78
LEGEND
O SAMPLING EPISODE 1 (DECEMBER 1988)
• SAMPLING EPISODE 2 (MARCH 1990)
«•§- STAGE t SAMPLE
t Sampling Locations at Blue Creek, South,
AFP 78, Brigham City, Utah
Figure 4-2b