DSHW-2015-006810 - 0901a0688053c61a

Orbital ATK
June 18, 2015
8200-FY16-018
2 O\E>-OOb0\O
Divivrr rf
Solid and Ha^ard-.-io* Waste
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., Waste Dock SWMU Investigation Report,
Promontory EPA ID #UTD009081357
Dear Mr. Anderson:
On May 6,2015 Jeff Vandel from your office visited the Promontory facility to inspect
and investigate a group of 32 waste dock Solid Waste Management Units (SWMUs).
The attached report describes the results of that investigation and a request for no further
action on this group of SWMUs.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
3344.
Sincerely,
George E. Gooch
Manager, Environmental Services
ATK Launch Systems
Orbital ATK, Inc. • P.O. Box 707 Brigham City, Utah 84302 •
Division of
Solid and Hazardous Waste
JUN 1 9 2015
/<9l5-oo6ejo
ATK Launch Systems Promontory Facility
Waste Dock SWMU Investigation
Orbital ATK
ATK Launch Systems
Promontory Facility
June 2015
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
ATK Launch Systems Waste Dock SWMU Investigation
The ATK Launch Systems Promontory Post Closure Permit lists the Solid Waste
Management Units (SWMUs) at the Promontory site. This list of SWMUs is part of the
RCRA Facility Investigation (RFI) phase of the facility corrective action. These SWMUs
were initially identified and assessed through the RCRA Facility Assessment (RFA)
conducted by the Utah Division of Solid and Hazardous Waste (UDSHW). The RFA
report was completed by the UDSHW in 1990. The report identified propellant waste
docks and solvent waste docks as SWMUs. These waste docks are typically sheds or
storage structures that are usually open on one side to facilitate adding and removing
waste. The waste docks are managed as 90 hazardous waste sites with weekly
inspections and the other requirements for these regulated units.
On May 6, 2015 Jeff Vandel with the UDSHW visited the Promontory Facility to inspect
and investigate a group of 32 Waste Dock SWMUs. This report summarizes the findings
of that visit and proposes that these 32 SWMUs be designated as requiring no further
action under the RFI and that they be dropped from the SWMU listing on the Post
Closure Permit. There are several reasons for this conclusion:
1. The controls and weekly inspections that are in place by managing these
docks as 90 day hazardous waste units would document and prevent any
releases.
2. Recommendations from the 1990 RFA concluded that no investigation was
needed at these SWMUs.
3. There is no record of spills at these sites.
4. During the May 6, 2015 inspection no evidence of releases were seen.
This report includes a description of each waste dock SWMU, photos and justification for
no further action. The description places these SWMUs into two categories:
1. Propellant waste docks, which includes propellant wastes and reactive
ingredients that are treated at the M-136 or M-225 burn grounds.
2. Solvent waste docks, which includes liquid wastes and solid wastes that are
sent offsite for treatment and disposal.
A short listing of SWMUs included in this report that were part of the May 6, 2015
inspection is in Table 1.
Additional inspections will be conducted by the UDSHW on more of these waste dock
SWMUs and ATK will submit subsequent reports of these investigations.
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
Table 1 Waste Dock SWMUs Included in this Report
Investigated on May 6,2015
Building SWMU#
1. M-lll/M-052 96
2. M-lll/M-052 100,600
3. M-179 92
4. M-53 52
5. M-53 101
6. M-16 48
7. M-16 90
8. M-27 49
9. M-27 565
10. M-320A 490
11. M-43 47
12. M-43 91
13. M-19A 65
14. M-19A 329
15. M-325 583
16. M-628 44
17. M-628 99
18. M-689 63
19. M-689 315
20. M-508 104
21. E-517 106
22. E-512 93
23. E-516 580
24. M-585 029
25. M-585 110
26. M-605 53
27. M-504 32
28. M-512 59
29. M-512 566
30. M-606 36
31. M-623 55
32. M-623 81
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs
096, 100, 600 M-111 / M-52
Description
SWMUs 096 and 100
are solvent waste
docks, SWMU 600 is a
satellite accumulation
site. These are all
within one building.
Operational dates are
1962 to present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock, for satellite
accumulation it is under the control of
the operator and inside building. Dock
has a concrete floor, containment and a
blind sump; it is covered and enclosed
on all sides. There is no history of
releases. No evidence of releases was
observed during the May 6, 2015
inspection. In the 1990 RFA no
investigation was recommended.
M-111 Front - East Side M-111 Inside floor slopes to blind sump
mm
M-111 North West side, high concrete wall
M-111 South side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs
092
Building
M-179
Description
SWMU 092 is a
solvent waste dock.
Operational dates are
1980 to present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock has
concrete floor with containment, it
is covered and enclosed on 3
sides. There is no history of
releases. No evidence of releases
was observed during the May 6,
2015 inspection. In the 1990 RFA
no investigation was
recommended.
M-179 Front - North Facing M-179 Containment and curbing
M-179 South West Corner M-179 South East Corner
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs
052,101
Building
M-53
Description
SWMU 052 is an old waste
propellant dock eliminated in
1990 and 101 is a solvent
waste dock. Operational
dates are 1962 to 1990 for
52, and 1962 to present for
101.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock has
containment and is sitting on a
concrete slab. It is covered and
enclosed on all sides. There is no
history of releases. No evidence of
releases was observed during the
May 6, 2015 inspection. In the 1990
RFA no investigation was
recommended.
r
M-53 Dock Front North Facing M-53 Dock Containment Floor
M 53A
s.
M-53 Dock West Side M-53 Dock South Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs
48, 90
Building
M-16
Description
SWMU 48 is a waste propellant
dock; 90 is a solvent waste dock.
Large dock is used for both
wastes, with a smaller dock used
just for propellant.
Operational dates are 1957 and
1967 respectively, to present.
NFA Justification
Weekly inspections as 90 day hazardous waste
docks. Main dock has containment and is sitting
on a concrete slab. Both docks are covered and
enclosed on three sides. There is no history of
releases. No evidence of releases was observed
during the May 6, 2015 inspection. In the 1990
RFA no investigation was recommended.
M-16 Propellant / Solvent Dock North Facing
Blind sump
location
Within 25 Feet
Unless Loading
or Unloading 3
32
WitWn 25 F„..
Unhnw Loading
or Unloadtno
M-16 Dock South West Side M-16 Dock Small Propellant Shed to East
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs
49, 565
Building
M-27
Description
SWMU 49 is a propellant
waste dock and 565 is a
solvent waste (primarily
rags) dock. Operation
dates 1957 to present.
NFA Justification
Weekly inspections at 90 day
hazardous waste dock. Both docks
are covered and enclosed on three
sides. There is no history of
releases. No evidence of releases
was observed during May 6, 2015
inspection (small desensitation oil
staining on propellant dock floor).
In the 1990 RFA no investigation
was recommended.
•
M-27 Both Docks North Facing M-27 Solvent Dock North Facing
Propellant Dock North Facing M-27 Docks South Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs
490
Building
M-320A
Description
SWMU 490 is propellant
waste dock.
Operational dates are 1962 to
present. Typically, large bulk
propellant containers are
placed in this dock.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock
has a concrete slab floor and is
covered and enclosed on three
sides. There is no history of
releases. No evidence of
releases was observed during
the May 6, 2015 inspection. In
the 1990 RFA no investigation
was recommended.
M-302A Dock North Facing
3
M-320A Dock West and South Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs
47, 91
Building
M-43
Description
SWMU 47 is a propellant
waste dock and 91 is a solvent
waste dock. Both are placed
within the same shed but this
is primarily a propellant dock.
Operational dates are 1981-
present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock is
sitting on a concrete slab and is
covered and enclosed on three
sides. There is no history of
releases. No evidence of releases
was observed during the May 6,
2015 inspection. In the 1990
RFA no investigation was
recommended.
CLASS CLASS
H
M-43 Dock South Side
M-43 Dock North Facing
M-43 Dock South East Corner
...
M-43 Dock West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
Description
SWMU 65 is a propellant
waste dock, 329 is a solvent
waste dock that is no longer
used. Operational dates for 65
are 1962 - present; for 329
they are 1981- approx. 2008.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Docks are
covered and enclosed on three sides**
and sitting on a concrete slab. 329
has containment. There is no historv
of releases. No evidence of releases
were observed during the May 6,
2015 inspection. In the 1990 RFA
no investigation was recommended
M-19A #65 Dock East. South and West Sides
M-19A #65 Dock North Facing
M-19A #329 South West Side M-19A #329 North West side
M-19A #329 Dock East Facing
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building
44, 99 M-628
Description
SWMU 44 is a propellant dock and 99 is
a solvent waste dock; both are combined
within the same shed. Operational dates
are 1962 to present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock is
sitting on asphalt. The dock is
covered and enclosed on three
sides. There is no history of
releases. No evidence of releases
was observed during the May 6,
2015 inspection. In the 1990
RFA no investigation was
recommended.
M-628 Dock North Facing M-628 Dock South East Side
M-628 Dock South West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building
63, 315 M-689
Description
SWMU 63 is a propellant
waste dock; 315 is a solvent
waste dock, both are combined
within the same shed.
Operational dates are 1962 to
present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock has
containment and is sitting on a concrete
slab. It is covered and enclosed on three
sides. There is no history of releases. No
evidence of releases was observed
during the May 6, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
M-689 Dock North Facing
M J
M-689 Dock North West Side
M-689 Dock South West Side
M-689 Dock Showing Containment
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs
104
Building
M-508
Description
SWMU 104 is a solvent waste
dock, there are two sides one
for liquid waste and one for
rags or solids.
Operational dates are 1962 -
present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock has
concrete containment and sump.
The dock is covered and enclosed
on three sides. There is no history
of releases. No evidence of
releases was observed during the
May 6, 2015 inspection. In the
1990 RFA no investigation was
recommended.
M-508 Dock North Facing M-508 Dock Showing Containment
M-508 Dock South Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building Description
106 E-517 SWMU 106 is a solvent waste
dock. Operational dates 1962
to present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock has
concrete containment. Dock is covered
and enclosed on all sides, has sliding
doors. There is no history of releases.
No evidence of releases was observed
during the May 6, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
E-517 Dock South Facing
E-517 Dock West side showing
containment.
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building Description
93 E-512 SWMU 93 is a solvent waste
dock. Has two sides one for
solids (rags) and the other for
liquids. Operational dates are
1962 to present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock has deep
concrete containment. It is covered and
enclosed on three sides. There is no
history of releases. No evidence of
releases was observed during the May 6,
2015 inspection. In the 1990 RFA no
investigation was recommended.
E-512 Dock North Facing
E-512 Dock North West Side
E-512 Dock South Side
HHP
E-512 Dock Showing Containment
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building Description
580 E-516 SWMU 580 is a solvent waste
dock. Operational dates are
believed to be 1962 to present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock is a
wooden tuff shed and enclosed on all
sides with interior containment. There is
no history of releases. No evidence of
releases was observed during the May 6,
2015 inspection. In the 1990 RFA no
investigation was recommended.
Kuardoui Waste MM
! I i
E-516 Dock South Facing
w -
E-516 Dock North West Side
E-512 Dock Showing Containment
MM a ISMHHMB t m •
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building Description
029,110 M-585 SWMU 29 is a propellant
waste dock; 110 includes two
solvent waste docks called
East and South. Operational
dates are 1962 to present.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Main solvent waste dock
called 110 "South" has containment and
is sitting on a concrete slab. Dock 110
"East" is primarily for solid wastes.
Docks are covered and enclosed on
three sides. There is no history of
releases. No evidence of releases was
observed during the May 6, 2015
inspection. In the 1990 RFA no
investigation was recommended.
r
_ M-585 (29)Dock Propellant Waste M-585 (110 South) Dock North and
South East sides Solvent Waste
J-
M-585 (110 East) Dock North, South, West and East sides
and interior.
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building Description
53 M-605 SWMU 53 is an old waste
propellant dock. Operational
dates 1962 to 1990s.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock is sitting
on a concrete slab. It is covered and
enclosed on three sides. There is no
history of releases. No evidence of
releases was observed during the May 6,
2015 inspection. In the 1990 RFA no
investigation was recommended.
M-605 Dock North Facing
M-605 Dock East Side
M-605 Dock South West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building Description
32 M-504 SWMU 32 is a waste
propellant dock, operations
date is 1962-present, however,
building is currently shut
down.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Dock is made up of three
sheds sitting on asphalt. These are
covered and enclosed on three sides.
There is no history of releases. No
evidence of releases was observed
during the May 6, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
3 •
M-504 Dock North Facing M-504 Dock North West Side
PS.
M-504 Dock South East Side M-504 Dock South West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building
59,566 M-512
Description
SWMU 59 is a propellant
waste dock; 566 is a solvent
waste dock. The dock is
divided into two separate areas
for each waste type.
Operational dates are 1962-
present. However, it is
currently not being used.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. The dock has containment
and is sitting on a concrete slab. Docks
are covered and enclosed on three sides.
There is no history of releases. No
evidence of releases was observed
during the May 6, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
i
i
M-512 Dock North Facing
M512 Dock South and South East Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building Description
36 M-606 SWMU 36 is a propellant
waste dock. Operational dates
were 1962-1990. Currently
used for material storage.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Dock is sitting on a
concrete slab and is enclosed on three
sides. There is no history of releases. No
evidence of releases was observed
during the May 6, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
IPPBIIBI HUB
y —"
M-606 Dock North Facing M-606 Dock South Side
M-606 Dock South East Side M-606 Dock South West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
SWMUs Building Description
55,81 M-623 SWMU 55 is a propellant
waste dock; 81 is a solvent
waste dock. Both are enclosed
by one shed. The docks are
inactive. Operational dates
were 1962-1990.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. The dock is covered and
enclosed on three sides. There is no
history of releases. No evidence of
releases was observed during the May 6,
2015 inspection. In the 1990 RFA no
investigation was recommended.
M-623 Dock North Facing M-623 Dock South Side
M-623 Dock East Side M-623 Dock West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
June 2015
583
Building Description
M-325 SWMU 583 is a propellant
waste dock. Operational dates
are 1962 to present.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Dock is covered and
enclosed on three sides. There is no
history of releases. No evidence of
releases was observed during the May 6,
2015 inspection. In the 1990 RFA no
investigation was recommended.
u. LLflrr WASTE
ml * „.!•
M-325 Dock North Facing M-325 Dock East Side
I
j
M-325 Dock South Side M-325 Dock West Side