DSHW-2015-009629 - 0901a0688057a1fd

Orbital ATK
September8, 2015
8200-FY16-032
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
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., Waste Dock SWMU Investigation Report 3,
Promontory EPA ID #UTD009081357
Dear Mr. Anderson:
On August 20,2015 Jeff Vandel from your office visited the Promontory facility to
inspect and investigate a group of 28 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 third report investigating the
waste dock SWMUs, similar reports were submitted previously with a June 18th and July
23,2015 letter.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
3344.
Sincerely,
Manager, Environmental Services
ATK Launch Systems
Div of Waste Management
and Radiation Control
Sfcr - 9 2015
Orbital ATK, Inc. • P.O. Box 707, Brigham City, Utah 84302 • 435-863-3511
Div of Waste Management
and Radiation Control
SEP - 9 2015
ATK Launch Systems Promontory Facility
Waste Dock SWMU Investigation 3
Orbital ATK
ATK Launch Systems
Promontory Facility
September 2015
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 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 (UDWMRC). The work
described in this report was done under the UDWMRC 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. Waste satellite
accumulation areas, typically located in buildings, were also identified as SWMUs.
On August 20, 2015 Jeff Vandel with the UDWMRC visited the Promontory Facility to
inspect and investigate a group of 28 Waste Dock SWMUs. The investigation was
similar to the one that took place on May 6th and June 24th of 2015. This report
summarizes the findings of the August 20th inspection and proposes that these 28
SWMUs be designated as requiring no further action under the RFI and therefore
dropped from the SWMU listing in 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. Propellant waste docks, for safety reasons, have the waste removed
quickly to the treatment locations. Satellite accumulation areas are under the
control of the operator and safety rules require that the waste be removed from
the building each day.
2. Recommendations from the 1990 RFA concluded that no investigation was
needed at these types of SWMUs.
3. There is no record of spills at these sites.
4. During the August 20, 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.
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
A short listing of SWMUs included in this report that were part of the August 20, 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.
Table 1 Waste Dock SWMUs Included in this Report
Investigated on August 20, 2015
Building SWMU# Description
1. M-184 550
2. M-32 51
3. M-32 95
4. M-174 67
5. M-174 601
6. M301 64
7. M-24 336
8. M-20 46
9. M-26 50
10. M-309 64
11. M-34 43
12. M-12 39
13. M-13 35
14. M-120 41
15. M-120 478
16. M120 565
17. M-125/M-126 38
18. M-102 599
19. M-514 523
20. M-519 27
21. M-580 57
22. M-523 28
23. M-524 58
24. M-512 521
25. M-690 76
26. M-573 567
27. M-638 571
28. M-604 73
Two Satellite Accumulation Areas and one
90 Day Hazardous Waste Dock
Waste Propellant Dock
Old Hazardous Waste Dock
Waste Propellant Dock
Satellite Accumulation Area
90-Day Hazardous Waste Dock
Old Hazardous Waste Dock
Old Hazardous Waste Dock
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
Old Hazardous Waste Dock
Waste Propellant Dock
Waste Propellant Dock
Satellite Accumulation Area
90-Hazardous Waste Dock
Waste Propellant Dock
Satellite Accumulation Area
Satellite Accumulation Area
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
Waste Propellant Dock
Satellite Accumulation Area
Waste Propellant Dock
90-Day Hazardous Waste Dock
Waste Propellant Dock
Waste Propellant Dock
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
September 2015
3
SWMUs
550
Building
M-184
Description
SWMU 550 is associated
with 3 satellite
accumulation areas. Two
are located within M-184
and the other is a waste
dock. Operational dates
are 1962- present for
those in the building. For
the waste dock, dates are
1962-2000 as it is no
longer used.
NFA Justification
Under control of the operator,
two located inside building with
waste removed each day. The
other in a waste dock. Dock has
concrete floor and containment.
There is no history of releases.
No evidence of releases was
observed during the August 20,
2015 inspection. In the 1990
RFA no investigation was
recommended for these types of
SWUMUs.
M-184 Satellite Accumulation M-184 Satellite Accumulation
J
_ i
Side 184 Dock North and East M-184 Dock South Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs
51, 95
Buildin
M-32
Description
SWMU 95 is an old propellant
waste dock; 51 is an old
solvent waste dock. Both were
combined in one dock.
Operational dates were 1970-
1990. This dock was primarily
used for solid propellant waste.
Photograph is of the area
where the dock was located.
NFA Justification
Weekly inspections as a 90 day hazardous
waste dock. Waste was mostly solid
propellant that was regularly removed for
safety concerns. Construction was a raised
flat wood platform. There is no history of
releases. No evidence of releases was
observed during the August 20, 2015
inspection. In the 1990 RFA no
investigation was recommended for these
types of SWMUs.
M-32 Old Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs
67, 601
Building
M-174
Description
SWMU 67 and is an old
propellant waste dock and
601 is a satellite
accumulation site in the
building which consist of a
small flip top can. This
location was observed in
the building but due to
photography restrictions it
cannot be included in the
report. Operational dates
for the dock are 1962 to
2012.
NFA Justification
Weekly inspections at 90 day
hazardous waste dock. The
dock is covered and enclosed
on three sides and has a
concrete floor. The satellite
is in the building with waste
removed each day. There is
no history of releases. No
evidence of releases was
observed during August 20,
2015 inspection. In the 1990
RFA no investigation was
recommended.
M-174 Dock South Side M-174 Dock North Facing
V
M-174 Dock East Side M-174 Dock West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs
64
Building Description
M-301 SWMU 64 is a solvent waste dock.
Operational dates are 1962 to
approximately 1994 when it was no
longer used to store hazardous waste.
NFA Justification
Weekly inspections as a 90
day hazardous waste dock.
The dock has concrete
containment, is covered and
enclosed on three sides. There
is no history of releases. No
evidence of releases was
observed during the August
20, 2015 inspection. In the
1990 RFA no investigation
was recommended for these
types of SWMUs.
M-30 Dock South Side M-301 Dock North Facing
r
7^
Mr1
J
f
M-301 Dock West Side M 301 Dock East Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs
336
Building
M-24
Description
SWMU 336 was an old
propellant waste dock.
Operational dates are 1962 -
approx. 1984. Photograph is of
the area where the dock was
located.
NFA Justification
Dock contained solid propellant
waste on an asphalt pad.
Construction was a flat raised
wood platform. There is no
history of releases. No evidence
of releases was observed during
the August 20, 2015 inspection.
In the 1990 RFA no investigation
was recommended for these types
of SWMUs
M-24 Former Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description NFA Justification
SWMU 46 is an old
propellant waste dock.
Photograph is the area
where the dock was
located. Operational
dates are 1962 -
approx. 1984.
Dock contained solid propellant waste on
an asphalt pad. Construction was a flat
raised wood platform. There is no history
of releases. No evidence of releases was
observed during the August 20, 2015
inspection. In the 1990 RFA no
investigation was recommended for these
types of SWMUs.
46 M-20
*' s
M-20 Former Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building
50 M-26
Description
SWMU 50 is an old waste
propellant dock. Operational dates
are 1962 to approximately 1984.
Photograph is the area where the
dock was located.
NFA Justification
Waste was mostly solid propellant
that was regularly removed for safety
concerns. It was covered and
enclosed on three sides. There is no
history of releases. No evidence of
releases was observed during the
August 20, 2015 inspection. In the
1990 RFA no investigation was
recommended for these types of
SWMUs.
7iTI
ha
M-26 Former Waste Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs
64
Description
M-309 SWMU 64 is a propellant
waste dock; operational dates
are 1962 to approximately
2000. The dock including the
concrete pad has been
removed. The photograph is of
the former location of the dock
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock was sitting
on a concrete pad. It was covered and
enclosed on three sides. There is no
history of releases. No evidence of
releases was observed during the August
20, 2015 inspection. In the 1990 RFA
no investigation was recommended for
these types of SWMUs.
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M-309 Former Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
43
Building
M-34
Description
SWMU 43 is an old waste
propellant dock. Operational
dates are 1959 -2000. Dock has
been removed. Photograph is the
area where the dock was located.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock was
on a concrete pad and was
covered and enclosed on three
sides. There is no history of
releases. No evidence of releases
was observed during the August
20, 2015 inspection. In the 1990
RFA no investigation was
recommended for these types of
SWMUs
M-34 Former Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
September 2015
3
SWMUs Building Description
39 M-12 SWMU 39 is an old solvent
waste dock, The structure has
been removed. Operational
dates are approx. 1957 to 1984.
The photograph is the former
location of the dock
NFA Justification
Construction was a flat raised wood
platform on an asphalt pad. There is no
history of releases. No evidence of
releases was observed during the August
20, 2015 inspection. In the 1990 RFA no
investigation was recommended for these
types of SWMUs.
M-12 Former Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
September 2015
3
SWMUs Building Description
035 M-13 SWMU 035 is an old
propellant waste dock.
It was limited to solid wastes,
primarily ammonium
perchlorate. Operational dates
are 1962 to approximately
1995.
NFA Justification
Weekly inspections as a 90 day hazardous
waste dock. Dock is covered and
enclosed on 3 sides. For safety reasons,
propellant wastes were quickly removed.
There is no history of releases. No
evidence of releases was observed during
the August 20th, 2015 inspection. In the
1990 RFA no investigation was
recommended for these types of SWUMs
I
M-13 North Facing Dock M-13 Dock South West Side
s
t
M-13 Dock East Side M-13 Dock South Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation
September 2015
3
SWMUs Building Description
41,478,564 M-120 SWMU 41 is a propellant
waste dock. 564 is a solvent
waste dock. Both of these
share the same dock. 478 is an
old satellite accumulation site
that was locked and outside of
the building and dock.
Operational dates are 1962 -
present for dock, approx. 1990-
2000 for the satellite site.
NFA Justification
Weekly inspections as a 90 day
hazardous waste dock. Dock is covered
and enclosed on 3 sides. Satellite was
locked and under control of the operator.
There is no history of releases. No
evidence of releases was observed during
the August 20, 2015 inspection. In the
1990 RFA no investigation was
recommended for these types of
SWMUs.
M-120 Dock North and West Sides : i^a : ; .
M-120 Dock South and East Sides
M-120 Old Satellite Accumulation Site
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
38 M-125 and SWMU 38 is an old waste
M-126 propellant dock that was used
by the two buildings.
Operational dates are 1969 to
2013.
NFA Justification
Weekly inspections as 90 day hazardous
waste dock. Dock is covered and
enclosed on three sides. There is no
history of releases. (Noticed small
amount of desensitizing oil, a light
mineral oil, staining on wood floor.) No
evidence of releases was observed
during the August 20, 2015 inspection.
In the 1990 RFA no investigation was
recommended for these types of
SWMUs.
2££K?'-OSED
M-125/M-126 Dock West Side B M-125/M-126 Dock East Facin
M-l 25/M-126 Dock South Side M-l25/M-126 Dock North Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
599 M-102 SWMU 599 is an old satellite
accumulation site inside the
building. Operational dates
are 1963 to 2005. Building is
currently not being used.
NFA Justification
Under control of the operator within a
building. Waste was removed each day.
There is no history of releases. No
evidence of releases was observed
during the Aug 20, 2015 inspection. In
the 1990 RFA no investigation was
recommended for these types of
SWMUs.
N
M-102 Old Satelhte Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
523 M-514 SWMU 523 is an old satellite
accumulation site inside the
building. Operational dates
are approx. 1962 to 2000.
Building is currently not being
used.
NFA Justification
Under control of the operator within a
building. Waste was removed each day.
There is no history of releases. No
evidence of releases was observed
during the Aug 20, 2015 inspection. In
the 1990 RFA no investigation was
recommended for these types of
SWMUs.
M-514 Old Satellite Accumulation Site
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
27 M-519 SWMU 27 is an old propellant
waste dock. 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.
Dock was a flat wooden raised platform.
Waste was solid propellant that for
safety reasons was removed quickly.
There is no history of releases. No
evidence of releases was observed
during the August 20, 2015 inspection.
In the 1990 RFA no investigation was
recommended for these types of
SWMUs.
rim*:
M-519 Old Dock Former Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
57 M-580 SWMU 57 was an old
propellant waste dock.
Operational dates were
approximatlyl962-1984. The
dock was removed all that
remains is the gravel pad.
NFA Justification
Construction was a flat raised wooden
platform and used for solid propellant. It
was located on a gravel pad. For safety
reasons waste propellant was removed
quickly. There is no history of releases.
No evidence of releases was observed
during the August 20, 2015 inspection.
In the 1990 RFA no investigation was
recommended.
M-580 Old Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs I Building Description
28 M-523 SWMU 28 is an old propellant
waste dock at a currently non-
operational building. The dock
was removed. Operational
dates were 1962-1985.
NFA Justification
The dock was a flat raised wooden
platform sitting on an asphalt pad.
Waste was solid propellant that for
safety reasons was removed quickly.
There is no history of releases. No
evidence of releases was observed
during the August 20, 2015 inspection.
In the 1990 RFA no investigation was
recommended for these types of
SWMUs.
M-523 Old Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
Building Description NFA Justification
58 M-524 SWMU 58 is an old propellant
waste dock located at a
currently non-operational
building. Operational dates
were approximatly 1962-2005.
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 August
20, 2015 inspection. In the 1990 RFA
no investigation was recommended for
these types of SWMUs.
M-524 Dock North Facing M-524 Dock South Side
M 524 Dock East Side M 524 Dock West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
521 M-512 SWMU 521 is an old satellite
accumulation site inside the
building. Operational dates
are approx. 1962 to 2000.
Building is currently not being
used.
NFA Justification
Under control of the operator within a
building. Waste was removed each day.
There is no history of releases. No
evidence of releases was observed
during the Aug 20, 2015 inspection. In
the 1990 RFA no investigation was
recommended for these types of
SWMUs.
M-512 Satellite Accumulation Site
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
76 M-690 SWMU 76 is an old propellant
waste dock located at currently
non-operational building.
Dock has been removed; all
that remains is the concrete
pad. Operational dates were
approximatly 1962-2000.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Dock was covered and
enclosed on three sides and sat on a
concrete pad. There is no history of
releases. No evidence of releases was
observed during the August 20, 2015
inspection. In the 1990 RFA no
investigation was recommended for
these types of SWMUs.
M-690 Dock Former Location
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
567 M-573 SWMU 567 is an old solvent
waste dock located at currently
non-operational building. The
dock is currently being used by
facility maintenance to store
non-hazardous oil.
Operational dates were
approximatly 1962-2005.
NFA Justification
Weekly inspections as 90 day hazardous
waste docks. Dock is covered and
enclosed on three sides. There is no
history of releases. Small amount of oil
staining was seen in corner. However,
no evidence of releases was observed
during the August 20, 2015 inspection.
In the 1990 RFA no investigation was
recommended for these types of
SWMUs.
m
M-567 Dock East Facing M-567 Dock West Side
m
M-573 Dock South Side M-524 Dock North East Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
571 M-638 SWMU 571 is an old
propellant waste dock located
at currently non-operational
building. Dock is no longer
used. Operational dates were
approximatly 1962-2000.
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 August
20, 2015 inspection. In the 1990 RFA
no investigation was recommended for
these types of SWMUs.
Mi
M-638 Dock North Facing M-638 Dock West Side
ATK Launch Systems
Promontory, Utah
Waste Dock SWMU Investigation 3
September 2015
SWMUs Building Description
73 M-604 SWMU 73 is an old propellant
waste dock located at currently
non-operational casting
building. Dock was removed.
Picture is asphalt pad where
the dock was located.
Operational dates were
approximate 1962-1985.
NFA Justification
Dock was a raised flat wooden structure
on an asphalt pad. It was used for solid
propellant waste that was regularly
removed for safety concerns. There is
no history of releases. No evidence of
releases was observed during the August
20, 2015 inspection. In the 1990 RFA
no investigation was recommended for
these types of SWMUs.
604 Former Dock Location M