HomeMy WebLinkAboutDSHW-2015-007996 - 0901a0688054f8ebOrbital ATK/J
July 29,2015
8200-FY16-025
Mr. Scott T. Anderson, Director v of Waste Management
and Radiation Control Utah Department of Environmental Quality
Division of Waste Management and Radiation Control JUL 2 9 2015
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems Inc., Waste Dock SWMU Investigation Report 2,
Promontory EPA ID #UTD009081357
Dear Mr. Anderson:
On June 24,2015 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. This the second report investigating the waste dock
SWMUs, a similar report was submitted with a June 18th 2015 letter.
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, Inc.
Orbital ATK, Inc. • P.O. Box 707, Brigham City, UT 84302 • 435-863-3511
and Rad'ation Control
JUL 2 9 20)5
ATK Launch Systems Promontory Facility
Waste Dock SWMU Investigation 2
Orbital ATK
ATK Launch Systems
Promontory Facility
July 2015
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 2
July 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). (Please note
that on July 1, 2015 the UDSHW was reorganized into a new Division call the Utah
Division of Waste Management and Radiation Control. The work described in this report
was done under the UDSHW hence this name is used.) 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 June 24, 2015 Jeff Vandel with the UDSHW visited the Promontory Facility to
inspect and investigate a group of 32 Waste Dock SWMUs. The investigation was
similar to the one that took place on May 6, 2015. This report summarizes the findings of
the June 24th inspection 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 June 24, 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 three 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. These are also called 90 day hazardous
waste docks.
3. Satellite accumulation sites that are typically used inside a building and
contain small amounts of waste that are removed daily.
A short listing of SWMUs included in this report that were part of the June 24, 2015
investigation is in Table 1.
Plans are for additional inspections to 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 2
July 2015
Table 1 Waste Dock SWMUs Included in this Report
Investigated on June 24,2015
Building SWMU#
1. M-079 350
2. M-079 563
3. M-191 62
4. M-191 581
5. M-193 582
6. M-193 512
7. M-622 54
8. M-622 87
9. M-621 33
10. M-621 86
11. M-627 98
12. M-629 40
13. M-629 85
14. M-321 514
15. M-572 524
16. M-528 641
17. M-514 523
18. M-590 82
19. M-590 570
20. M-605 97
21. M-605 349
22. M-504 103
23. M-593 584
24. M-705 531
25. M-705 588
26. M-694 61
27. M-693 60
28. M-594/M-595 69
29. M-601 70
30. M-602 71
31. M-603 72
32. M-596/M-597 30
Description
Waste Propellant Dock
90-Day Hazardous Waste Dock
Waste Propellant Dock
90-Day Hazardous Waste Dock
90-Day Hazardous Waste Dock
Waste Propellant Dock
Waste Propellant Dock
Old Hazardous Waste Dock
Waste Propellant Dock
Old Hazardous Waste Dock
Old Hazardous Waste Dock
Waste Propellant Dock
Old Hazardous Waste Dock
90-Day Hazardous Waste Dock
Satellite Accumulation
Waste Propellant Dock
Satellite Accumulation
90-Day Hazardous Waste Dock
Waste Propellant Dock
Satellite Accumulation
Satellite Accumulation
Satellite Accumulation
90-Day Hazardous Waste Dock
90-Day Hazardous Waste Dock (gondola)
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs Building
M-79 350, 563
Description
SWMU 350 is a waste
propellant dock. 563 is
a solvent waste dock.
These are both
contained within one
dock. Operational
dates are 1962 to
present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock is
covered and enclosed on three sides.
There is no history of releases. No
evidence of releases was observed
(small amount of desensitizing oil
staining on floor) during the June 24,
2015 inspection. In the 1990 RFA no
investigation was recommended.
—
• I
M-79 South East Side M-79 East Facing
_
"1
M-79 North West Side M-79 North Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
062, 581
Building
M-191
Description
SWMU 062 is a
propellant waste dock,
581 is a solvent waste
dock. Both are
contained in one dock.
Operational dates are
1962 to present.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock has
concrete floor with containment
and is covered and enclosed on 3
sides. There is no history of
releases. No evidence of releases
was observed during the June 24,
2015 inspection. In the 1990 RFA
no investigation was
recommended.
^
M-191 Dock North Facing M-191 Dock South East Side
M-191 Dock South West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
512, 582
Building
M-193
Description
SWMU 512 is a waste
propellant dock and 582 is a
solvent waste dock. Both
are contained in one dock.
Operational dates are 1962
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
June 24, 2015 inspection. In the
1990 RFA no investigation was
recommended.
_
M-193 Dock Front West Facing
1 is
m
M-193 Dock South West Side
M-193 Dock North West Side M-193 Dock North East Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
54, 87
Building
M-622
Description
SWMU 54 is an old waste
propellant dock; 87 is an old
solvent waste dock. Both we
combined in one dock building
that was removed around 1992.
All that remains is the concrete
slab.
NFA Justification
Weekly inspections as a 90 day hazardous
waste dock. It was sitting on a concrete slab.
There is no history of releases. No evidence of
releases was observed during the June 24,
2015 inspection. In the 1990 RFA no
investigation was recommended.
M-622 Old Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs Building
M-621
Description
SWMU 33 is an old
propellant waste dock
and 86 is an old
solvent waste dock.
Operational dates
were 1962 to 1992.
NFA Justification
Weekly inspections at 90
day hazardous waste
dock. Both docks are
covered and enclosed on
three sides. The solvent
dock has concrete floor.
There is no history of
releases. No evidence of
releases was observed
during June 24, 2015
inspection. In the 1990
RFA no investigation was
recommended.
33, 86
M-621 Solvent Dock East Facing M-621 Propellant Dock North Facing
M-621 waste solvent dock South West sides
M-621 Propellant Dock West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
98
Building
M-627
Description
SWMU 98 was an old
solvent waste dock.
Operational dates are 1962 to
approximately 1992 when it
was removed. All that
remains is an asphalt pad.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock
was sitting on an asphalt pad.
Unsure of the construction but
believe it was similar to other
docks. There is no history of
releases. No evidence of
releases was observed during
the June 24, 2015 inspection. In
the 1990 RFA no investigation
was recommended.
M-6270W Dock location remaining asphalt pad
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
40, 85
Building
M-629
Description
SWMU 40 was an old
propellant waste dock and 85
was an old solvent waste dock.
Both were placed within the
same shed. Shed was removed
around 1992. Operational
dates are 1962 - approx.1992.
Photograph is the area where
the dock was located.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Unsure of
the construction but believe it was
similar to other docks. There is no
history of releases. No evidence
of releases was observed during
the June 24, 2015 inspection. In
the 1990 RFA no investigation
was recommended.
Sf
J-4
*
M-629 Former Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
514
Building
M-321
Description
SWMU 514 is a small
solvent waste dock.
Operational dates are
1962 - present.
NFA Justification
Weekly inspections as a 90
day hazardous waste dock.
Dock is covered and enclosed
on three sides and sitting on a
concrete slab. There is no
history of releases. No
evidence of releases were
observed during the June 24,
2015 inspection. In the 1990
RFA no investigation was
recommended.
M-321 Dock East Facing M-321 Dock North Side
M-32 Dock West Side M-321 Dock South Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs Building
524 M-572
Description
SWMU 524 is an old satellite
accumulation area inside building for
primarily waste rags used in clean-up.
Operational dates are 1962 to
approximately 1992.
NFA Justification
Under control of the operator,
located inside propellant mix
building. Floors were cleaned
and waste removed each day.
There is no history of releases.
No evidence of releases was
observed during the June 24,
2015 inspection. In the 1990
RFA no investigation was
recommended.
m •4
M-572 Satellite Accumulation Area
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs Building Description NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock has a blind
sump for 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 June 24, 2015
inspection. In the 1990 RFA no
investigation was recommended.
M-528 SWMU 641 is a propellant
waste dock; operational dates
are 1962 to approximately
2000. Building and dock are
currently shutdown.
641
M-528 Dock North West Side M-528 Dock North Facin
M-528 Dock West Side M-528 Dock South West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
523
Building
M-514
Description
SWMU 523 was a satellite
accumulation site inside the
building on a table. Waste
consisted mostly of propellant
and rags. Operational dates are
1962 -1995. Currently a
nonoperational building.
NFA Justification
Under control of the operator,
located inside the building.
Floors were cleaned and waste
removed each day. There is no
history of releases. No evidence
of releases was observed during
the June 24, 2015 inspection. In
the 1990 RFA no investigation
was recommended.
M-514 Satellite Accumulation (table)
M-514 Satellite Accumulation (table)
M-514 Satellite Accumulation (table)
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
82, 570
Building
M-590
Description
SWMU 82 is a solvent waste
dock, operational dates are
1962 to present; 570 is an old
waste propellant dock that is
no longer used, the structure
has been removed and only the
concrete base remains.
Operational dates 1962 to
approx. 2000 for propellant
dock, and present for solvent
dock.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Both docks have
containment. Solvent dock is covered
and enclosed by metal on all sides.
There is no history of releases. No
evidence of releases was observed
during the June 24, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
Us i
—
r.
• M-590 Dock South West Corner E-590 Dock West Facing
M-590 Old Propellant Dock location
HHHHWH
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs Building Description
97, 349 M-605 SWMU 97 and 349 are two
satellite accumulation sites
inside the building. Waste
consisted mostly of propellant
and rags. Operational dates are
1962-1995. It is currently a
nonoperational building.
NFA Justification
Under control of the operator, located
inside the building. Floors were cleaned
and waste removed each day. Floor
washed to containment sump. There is
no history of releases. No evidence of
releases was observed during the June
24, 2015 inspection. In the 1990 RFA
no investigation was recommended.
M-605 Satellite Accumulation Site, SWMU 97
M-605 Satellite Accumulation Site, SWMU 349
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs Building Description
103 M-504 SWMU 103 is an old satellite
accumulation site inside the
building. Waste consisted
mostly of propellant and rags.
Operational dates are 1962 -
1995. It is currently a
nonoperational building.
NFA Justification
Under control of the operator, located
inside the building. Floors were cleaned
and waste removed each day. Floor
washed to containment sump. There is
no history of releases. No evidence of
releases was observed during the June
24, 2015 inspection. In the 1990 RFA
no investigation was recommended.
M-504 Old Satellite Accumulation Site
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
531, 588
Building
M-705
Description
SWMU 531 is a gondola waste
dock that contains inert
washout residue from the
reclamation of ammonium
perchlorate. The waste does
not contain EPA waste codes.
588 is a waste propellant dock
used to contain small amounts
of reactive residue from
operation of a sump truck.
Operational dates are 1988 to
present.
NFA Justification
Weekly inspections as 90 day hazardous
waste dock (gondola is actually non-
hazardous). Docks are covered and
enclosed. There is no history of releases.
No evidence of releases was observed
during the June 24, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
Y f
r.
M-705 Gondola Dock
M-705 Dock Propellant Waste
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
61
Building
M-694
Description
SWMU 61 is an old waste
propellant dock. Operational
dates 1962 to 1990s. It is
currently not being used.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock is sitting
on a concrete slab with containment. It
is covered and enclosed on three sides.
There is no history of releases. No
evidence of releases was observed
during the June 24, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
M-694 Dock North facing M-694 Dock West Side
_—
M694 Dock South Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs Building Description
60 M-693 SWMU 32 is an old waste
propellant dock, operations
date were 1962- approximately
1993. Building is currently
shut down. The dock was
removed and all that remains is
an asphalt pad.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Dock was located on
asphalt. There is no history of releases.
No evidence of releases was observed
during the June 24, 2015 inspection. In
the 1990 RFA no investigation was
recommended.
M-693 Dock Former Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
69
Building
M-594/M-595
Description
SWMU 69 is an old propellant
waste dock shared by two
buildings. Operational dates
are 1962-1975. The dock was
removed; all that remains is an
asphalt pad.
NFA Justification
The dock was sitting on an asphalt pad.
Exact location is unknown. There is no
history of releases. No evidence of
releases was observed during the June
24, 2015 inspection. In the 1990 RFA
no investigation was recommended.
M-594/M595 Dock Former Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
70
Building
M-601
Description
SWMU 70 was an old
propellant waste dock at a
currently non-operational
casting building. Operational
dates were approimatlyl962-
1992. The dock was removed
all that remains is the asphalt
pad.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Construction of the dock is
unknown but it is assumed it was similar
to the other docks. It was located on an
asphalt pad. There is no history of
releases. No evidence of releases was
observed during the June 24, 2015
inspection. In the 1990 RFA no
investigation was recommended.
M-601/M-602 Dock Locations
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
30
Building
M-596/M597
Description
SWMU 30 is an old propellant
waste dock shared by two
currently non-operational
casting buildings. The dock is
inactive. Operational dates
were 1962-1988.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. The dock is covered and
enclosed on all sides. There is no history
of releases. No evidence of releases was
observed during the June 24, 2015
inspection. In the 1990 RFA no
investigation was recommended.
mm
M-596/M597 Dock North Facing M-596/M597 Dock South Side
1
mm
M-596/M597 Dock East Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
July 2015
SWMUs
71,72
Building
M-602/M-603
Description
SWMUs 71 and 72 are old
shared propellant waste dock
locations that were located
between two currently non-
operational casting buildings.
Operational dates were
approximatly 1962-1992. The
docks were removed; all that
remains is the asphalt pad.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Construction of the docks
is unknown but it is assumed they were
similar to the other docks. These were
located on an asphalt pad. There is no
history of releases. No evidence of
releases was observed during the June
24, 2015 inspection. In the 1990 RFA
investigation was recommended. no
-T
• * 3». „
_ - Mm
M-602/M-603 Former Dock Locations