DSHW-2015-009810 - 0901a0688057d2b1

Orbital ATK
September 10,2015
8200-FY16-033
Div of Waste Management
and Radiation Control
SEP 1 5 2015 Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality ^ t-j'W *~Z<0 \5 ~~ OO
Division of Waste Management and Radiation Control
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 March 2015 to September 2015.
Dear Mr. Anderson:
Attached is the ATK Launch Systems Inc. Promontory Facility Semi-Annual RFI
Progress Report for March 2015 to September 2015.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
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.
3344
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, UT 84302 • 435-863-3511
SEMI-ANNUAL RFI PROGRESS REPORT
March 1, 2015 - September 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
(now the Utah Division of Waste Management and Radiation Control or the UDWMRC) has
approved the schedule, ATK will proceed with the assessment of the remaining SWMUs.
SWMU Investigations and Closures this Reporting Period
The UDWMRC has recently closed with no further action 64 SWMUs. These SWMUs are
associated with hazardous waste accumulation sites or docks which are 90 day and satellite
locations that are genetically called waste docks. Jeff Vandel with the UDWMRC has
inspected each of these sites for any signs of releases. Photographs, descriptions and other
historical information was provide in reports from ATK to the UDWMRC. Based on this
investigation, a finding of no further action was determined for these waste dock SWMUs.
On August 20th an additional 28 waste dock SWMUs were inspected and a report will be
submitted to UDWMRC with a request to close these with no further action. There are plans
to investigate more waste dock SWMUs in the future.
An investigation was conducted at SWMU # 553 associated with building M-19A and the
historic photographic discharge site into a drainage channel. Previous sampling documented
in the Promontory 2000 RFI Report had indicated that one sample location had shown higher
total chromium levels. Jeff Vandel had proposed that this site be further investigated to
determine if the total chromium levels had a component of chromium (VI) greater than the
current residential standards of 0.29 ppm. A sample was collected from the site and
analyzed for total chromium and chromium (VI). Results showed that the Chromium (VI)
levels were less than a detection limit of 0.214 ppm. This information was provided to the
UDWMRC in a July 29, 2015 letter.
Through approval from the UDWMRC, soil was removed from SWMU #649 - Strand Burner
Exhaust Discharge at building M-585. Testing has demonstrated that the soil is
nonhazardous; however this site has Chromium (VI) values higher than the current EPA
Regional Screening Level of 0.29 ppm. Due to the close proximity to the M-585 building, it
is not advisable to attempt soils removal using a standard back-hoe. Since the contaminated
soil is in a small contained pipe, a digging bar was used to loosen the soil, and a high
powered vacuum used to remove it. This approach worked well at removing over 40 pounds
of soil and rock. Post testing of soil in the excavation indicates that chromium (VI) levels are
still higher than residential standards. ATK will perform additional soil removal using the
same technique. Results for the additional excavation will be provided in the next semi-
annual report.
The P-10 well associated with the M-585 SWMUs remains dry after the initial drilling and
sampling in 2012, indicating that the perched aquifer is not readily recharged.
Plant 3 Well 3A Treatment Summary Reports
The treatment system at the Promontory Plant 3 well 3 A has been monitored quarterly
according to the UDWMRC approved plan. The plan includes a request that a summary of
the previous year to date monitoring data be included in the September Semi-Annual report.
This summary is found in Table 1. The treatment system continues to remove TCE to below
the 5u/L health based limit with a carbon replacement interval of every 6 + months. Water
usage at Plant 3 has diminished with lower production. Therefore, ATK is finding that TCE
removal extends significantly beyond the standard 6 month carbon replacement interval. In
addition, perchlorate removal in the two septic tanks, M-201 and M-205, continues to be
effective with the all samples reported at less than the 4 ppb detection limit.
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 3A treatment system will be ongoing through
the next reporting period. ATK will continue to work to 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 waste docks and other SWMUs currently under review.
Table 1
Plant 3 Well 3A Quarterly Treatment Summary Sept 2014 - June 2015
For Perchlorate (C104.) and Trichloroethylene (TCE)
Well 3A Carbon and Septic Tank Treatment Sampling Data (ug/L)
Date Influent Carbon Effluent Septic Tanks Effluent
(M-201 and
M-205)
Flow (gal)
Totalizer reading
9/29/14 23.1 TCE
84 C104.
3 TCE
84 CIO4-
U CIO4-32,557,800
12/16/14 NS 2.8 TCE
112C104-
U C104. 33,328,800
3/31/15 22.3 TCE
83 CIO4.
2.8 TCE
82 CIO4.
U CIO4-34,290,400
6/29/15 NS 3.1 TCE
98 CIO4-
U ClCv 34,997,300
U = < 4 ppb detection limit
NS= Not Sampled