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Home My WebLink AboutDSHW-2016-007576 - 0901a0688061648eDiv of Waste Management and Radiation Control MAR - 9 2016MAR Orbital ATK March 7,2016 8200-FY16-056 D5RW- 20lfc-OOl57C 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 S'Re: ATK Launch Systems Inc., EPA ID #UTD009081357, Semi-Annual RFI Progress Report for September 2015 to March 2016. Dear Mr. Anderson: Attached is the ATK Launch Systems Inc. Promontory Facility Semi-Annual RFI Progress Report for September 2015 to March 2016. 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. t£--------—__i George E. (jooch Manager, Environmental Services ATK Launch Systems cc: Walter L. Baker, Division Director, Utah Division of Water Quality 3344 Sincerely, Orbital ATK, Inc. • P.O. Box 707, Brigham City, UT 84302 • 435-863-3511 SEMI-ANNUAL RFI PROGRESS REPORT September 1,2015 - March 1,2016 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 In a December 2,2015 letter the UDWMRC closed with no further action 86 SWMUs. These SWMUs are associated with hazardous waste accumulation sites or docks which are 90 day and satellite locations that are generically called waste docks. Jeff Vandel with the UDWMRC has inspected each of these sites for any signs of releases. These inspections were conducted on August 20th, September 22nd, and September 29th. Photographs, descriptions and other historical information were provided in reports from ATK to the UDWMRC. Based on this investigation, a finding of no further action was determined for these waste dock SWMUs. Through approval from the UDWMRC, soil was removed from SWMU #649 - Strand Burner Exhaust Discharge drywell 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 12 inch diameter 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 indicated that chromium (VI) levels were still higher than residential standards. ATK performed additional soil removal using the same technique. A thick white clay layer was encountered as the soil removal continued. It is believed that this clay would limit Cr (VI) migration. A sample of the clay was collected (see Figure 1). However, the results were surprisingly still over the RSL limit. Plans are to conduct more soil removal during 2016 and additional analysis along with a background sample. These results will be discussed in the next progress report. p a I1 / Figure 1 M-585 Strand Burn Drywell Clay Layer Sampling The P-10 well associated with the M-585 SWMUs continues to remain dry after the initial drilling and sampling in 2012, indicating that the perched aquifer is not readily recharged. 2. Summaries of All Findings The summaries of the corrective action work 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 SWMU #649 M-585 dry well soils with the Cr (VI) concentrations over the current PRG values. Additional sampling work on SWMU #553 at building M-19A will be conducted. There will be continuing work with UDWMRC in investigating and closing waste docks, dust collectors and other SWMUs currently under review.