DSHW-2015-004101 - 0901a06880510aae

Orbital ATK
March 10, 2015 Division of
8200-FY16-004 ancf HazarcJous Waste
MAR 1 8 2015
Mr. Scott T. Anderson, Director 7/)! ^—/^D^i'l r\ I
Utah Department of Environmental Quality ^^il UI
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 2014 to March 2015.
Dear Mr. Anderson:
Attached is the ATK Launch Systems Inc. Promontory Facility Semi-Annual RFI
Progress Report for September 2014 to March 2015.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
3344
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
Orbital ATK, Inc. • P.O. Box 707 Brigham City, Utah 84302 •
SEMI-ANNUAL RFI PROGRESS REPORT
September 1,2014 - March 1,2015
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 Utah Division of Solid and Hazardous Waste
(USDHW) in November 2007. ATK has also informally provided a draft revised schedule to
meet the 2020 EPA goal for SWMU closures for the USDHW review. After the UDSHW
has approved the schedule, ATK will proceed with the assessment of the remaining SWMUs.
SWMU Closures this Reporting Period
The UDSHW has recently closed with no further action SWMU # 192 - Hydraflouric Acid
Treatment Unit at building M-227, and #444 - Dry Well at building M-19A. Building M-40
had two SWMUs #642 and #645, these were closed with no further action based on
investigations that were completed as part of the RFI Phase 1 report.
Soil samples were collected from and #649 - Strand Burner Exhaust Discharge at building
M-585 and analyzed for Chromium (VI). The results reported a value of 0.4 ppm for
chromium (VI) which is slightly above the EPA Regional Screening Level of 0.29 ppm.
These results were provided to the UDSHW in the March 2014 RFI report. The #649
SWMU is a very small site, consisting of a soil filled pipe, approximately 8 inches in
diameter and approximately 2 feet deep. Therefore, it will be a small excavation to remove
the contamination contained within the pipe. Testing of soil in the excavation for chromium
(VI) will be conducted to verify contamination removal. With the approval of the Division,
this removal will take place during the next semi-annual reporting period.
Closure of U.S. Air Force Installation Restoration Program (IRP) Related SWMUs
The RFA contains SWMUs that are associated with the old Air Force Plant 78 IRP sites and
the corresponding IRP report. Information was provided to the UDSHW and additional
samples were collected that resulted in the closure with no further action of 14 of these
SWMUs. These were SWMU numbers 230,235, 279,281,282, 283, 284, 326, 357, 373,
417,419, 503,660.
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 2014, 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 discussions with Helge Gabert and Jeff Vandel, the decision was made that during the
semi-annual spring 2014 groundwater sampling event to place a passive diffusion bag (PDB)
into the 3 inches of water to see if a useful sample could be collected in this way. The results
of the diffusion bag sample indicated much higher VOC levels than originally seen. These
values were reported in a previous report. As a result, there is uncertainty whether this
sampling method can obtain accurate results when the bag is only partially submerged. In
talking with a supplier of PDBs, they confirmed that one would absolutely expect to see
higher VOC values when it is only partially submerged. Other methods of sampling are
being investigated as the well continues to remain essentially dry will just a few inches of
water as of the fall 2014 groundwater sampling event.
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-10 well and the Plant 3 Well 3 A treatment system will be ongoing through
the next reporting period. With the DSHW approval, ATK will remove M-585 dry well soils
with the Cr (VI) concentrations over the current PRG values. ATK will work with UDSHW
in investigating and closing other SWMUs currently under review.