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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