DSHW-2016-009699 - 0901a0688062f4ec

Orbital ATK
May 10, 2016
8200-CY16-064
pSHW-2OU-00cl<=£n
Div of Waste Management
and Radiation Control
Mr. Scott T. Anderson, Director MAY 1 0 2016
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 and Dust Collector SWMU Investigation
Report 5, Promontory EPA ID #UTD009081357
Dear Mr. Anderson:
On April 13, 2016 Jeff Vandel from your office visited the Promontory facility to inspect
and investigate a group of 25 waste dock and dust collector Solid Waste Management
Units (SWMUs). The attached report describes the results of that investigation and a
request for no further action on these SWMUs. This is the fifth report investigating the
waste docks with this one also including dust collector SWMUs. Four similar reports
were submitted previously in 2015.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
3344.
Sincerely,
G „
Manager, Environmental Services
ATK Launch Systems, Inc.
Orbital ATK, Inc. • P.O. Box 707, Brigham City, Utah 84302 • 435-863-3511
ATK Launch Systems Promontory Facility
Waste Dock and Dust Collector SWMU
Investigation 5
Orbital ATK
ATK Launch Systems, Inc.
Promontory Facility
May 2016
ATK Launch Systems
Promontory, Utah
Waste Dock & Dust Collector SWMU Investigation 5
May 2016
ATK Launch Systems Waste Dock SWMU Investigation
The ATK Launch Systems, Inc. (ATK) 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.
Additionally, dust collectors used to filter and collect particulates from grit blasting,
grinding and buffing or cutting operations were also designated as SWMUs. These are
typically located outside the facility with the particles collected in particulate capture
drums. All dust collectors are regulated by Clean Air regulations as specified in the
Promontory facility Title 5 Operating Permit.
On April 13, 2016 Jeff Vandel with the UDWMRC visited the Promontory Facility to
inspect and investigate a group of 24 Waste Dock and dust collector SWMUs. The
investigation was similar to the ones that took place on May 6th, June 24th, August 20th,
September 22nd and 29th of 2015. This report summarizes the findings of the April 13,
2016 inspection and proposes that these 24 SWMUs be designated as requiring no further
action under the RFI and therefore be dropped from the SWMU listing in the Post
Closure Permit. There are several reasons for this conclusion:
Waste Docks
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 April 13, 2016 inspection no evidence of releases were seen.
ATK Launch Systems
Promontory, Utah
Waste Dock & Dust Collector SWMU Investigation 5
May 2016
Dust Collectors
1. Dust collectors are regulated by the Clean Air regulations as specified in the
facility permit and inspected on a regular basis looking for leaks and visible
emissions.
2. Inspection reports are maintained at the facility.
3. Particulates are from non-hazardous material operations with the exception of
ammonium perchlorate dust collectors; these filters are either washed and
reused or in the case of paper filters they are managed as reactive wastes and
treated. The drums of ammonium perchlorate particulate are recycled or
treated as hazardous waste.
4. No releases were observed during the April 13, 2016 inspection.
5. There are no known historical releases from these sites.
This report includes a description of each waste dock SWMU or dust collector, photos
and justification for no further action. The description places the waste dock 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 bum 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 April 13, 2016
investigation is in Table 1.
There are plans for additional inspections to be conducted by the UDWMRC on more of
these waste dock SWMUs and dust collectors and other SWMUs; ATK will submit
subsequent reports of these investigations.
ATK Launch Systems
Promontory, Utah
Waste Dock & Dust Collector SWMU Investigation 5
May 2016
Table 1
SWMUs Included in this Report
Investigated on April 13, 2016
BuildinR SWMU#
1. M-016 536
2. M-027 594
3. M-174 480
4. M-103 538
5. M-354 586
6. M-075 34
7. M-508 518
8. M-508 542
9. E-512 499
10. M-508 519
11. E-517 502
12. E-517 501
13. M-585 525
14. M-043 595
15. M-043 453
16. M-005 466
17. M-013 545
18. M-079 537
19. M-179 508
20. M-179 509
21. M-113 476
22. M-113 477
23. M-052 471
24. M-006 468
25. M-008 452
Description
Satellite Accumulation Area
Satellite Accumulation Area
Dust Collector (AP Dust)
Dust and Grit Blast Collector
Waste Propellant Dock (Autoliv)
Waste Propellant Dock (Autoliv)
South Side Dust Collectors
Grit Blast Collector
Dust and Grit Blast Collectors
East Side Dust Collectors
Dust Collectors
North Side Dust Collectors
Dust Collectors
Satellite Accumulation Area
Grit Blast Collectors
Dust Collectors
AP Dust Collection
Dust Collectors
Dust Collectors
Grit Blast Collector
Grit Blast Collector
Dust Collectors
Grit Blast Collector
Dust Collectors
Dust and Grit Blast Collectors
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
536
Building
M-16
Description
SWMU 536 is an old
satellite accumulation
area that is no longer
used. Operational dates
are 1967-2005.
NFA Justification
Satellite under control of the
operator, located inside building;
weekly inspections at 90 day
dock. There is no history of
releases. No evidence of releases
was observed during the April 13,
2016 inspection. In the 1990
RFA no investigation was
recommended for these types of
SWUMUs.
Ui
-16 Old Satellite Accumulation Location
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
594
Building Description
M-27 SWMU 42 is a satellite
accumulation location.
Operational dates are 1985-
present.
NFA Justification
Satellite under control of the operator,
located inside building; weekly inspections
at 90 day dock. There is no history of
releases. No evidence of releases was
observed during the April 13, 2016
inspection. In the 1990 RFA no
investigation was recommended for these
types of SWUMUs._____________________
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M-27 Satellite Accumulation
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
499
Building
E-512
Description
SWMU 499 is associated
with the building dust
collectors used for plastic
grinding and buffing.
Originally there was just
one at the building; the
photos show the original
and newer collector.
Operational dates are
approximately 1962 to
present.________________
NFA Justification
There is no history of
releases. The units are
regulated by the facility Air
Permit including inspections
and record keeping. No
evidence of releases was
observed during April 13,
2016 inspection.
Original Collector
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E-512 Dust Collectors
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building Description NFA Justification
480 M-174 SWMU 480 is an old dust collector
for ammonium perchlorate
grinding. Operational dates are
approximately 1981 to 2012. The
collector is no longer used and
some of the structure has been
removed. It was noted during the
inspection that filters associated
with the old collector were still in
place. These will be reused, if it is
determined they are not reusable
they will be treated as a reactive
waste.
There is no history of releases.
The units are regulated by the
facility Air Permit including
inspections and record keeping.
No evidence of releases was
observed during April 13, 2016
inspection.
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M-174 Old Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
538
Building
M-103
Description
SWMU 538 is an old dust
collector for grit blasting metal
parts. Operational dates are
1962 to approximately 2006.
NFA Justification
There is no history of releases.
The units are regulated by the
facility Air Permit including
inspections and record keeping.
No evidence of releases was
observed during April 13, 2016
inspection.__________________
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M-103 Old Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
586
Building
M-354
Description
SWMU 586 is a
propellant waste dock
that is now located on
property acquired by
Autoliv. Operational
dates for ATK were 1962
to approximately 1992.
NFA Justification
Construction of SWMU 586 is a shed
covered and enclosed on three sides on a
concrete pad. There is no history of
releases. No evidence of releases was
observed during the April 13, 2016
inspection. In the 1990 RFA no
investigation was recommended for these
types of SWMUs._____________________
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M-354 Autolive Dock SWMU
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ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building Description NFA Justification
34 M-75 SWMU 34 is an old propellant
waste dock that is now located on
property acquired by Autoliv. The
structure has been removed and
only the concrete pad remains.
Operational dates for ATK were
1962 to approximately 1992.
Construction of SWMU 586 was a
shed covered and enclosed on three
sides on a concrete pad. There is no
history of releases. No evidence of
releases was observed during the
April 13, 2016 inspection. In the
1990 RFA no investigation was
recommended for these types of
SWMUs.
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M-75 Former Dock Location
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
518
Building
M-508
Description
SWMU 518 is a currently non-
operational dust collector
associated with machining
rubber parts. Located on south
side of the building.
Operational dates are
approximately 1962 to 2006.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during April 13, 2016
inspection.
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M-508 South Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building Description NFA Justification
542 M-508 SWMU 542 is a dust collector
associated with grit blasting
metal parts. Located on the west
side of the building. Operational
dates are approximately 1962 -
Present.
There is no history of releases.
The units are regulated by the
facility Air Permit including
inspections and record keeping.
No evidence of releases was
observed during April 13, 2016
inspection.__________________
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M-508 East Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building Description
519 M-508 SWMU 519 is a dust collector
associated with grit blasting
metal parts and machining
rubber parts. It is located on
the east side of the building.
Operational dates are
approximately 1962 - Present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during April 13, 2016
inspection.
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ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building Description
501 E-517 SWMU 501 is a dust collector
associated with machining
carbon parts. Located on the
north / east side of building.
Operational dates are
approximately 1962 - Present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during April 13, 2016
inspection.___________________________
E-517 Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
502
Building
E-517
Description
SWMU 502 is a dust collector
located on the front side of the
building. It is associated with
machining metal parts.
Operational dates are
approximately 1962 -Present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building Description
525 M-585 SWMU 525 is a dust collector
used for plastic and small
metal parts grit blasting.
Operational dates are 1963 to
present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-585 Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building Description
595 M-43 SWMU 595 is a satellite
accumulation site at M-43.
Operational dates are
approximately 1981 to present.
NFA Justification
Under control of the operator within a
building. Waste is removed each day.
There is no history of releases. In the
1990 RFA no investigation was
recommended for these types of
SWMUs.
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M-43 Satellite Accumulation
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
453
Building
M-43
Description
SWMU 453 is a dust collector
associated with buffing and
abrading rubber and
processing carbon black.
Operational dates are
approximately 1981 to present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-43 Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building
466 M-5
Description
SWMU 466 is associated with
two dust collectors used for
cutting and fabricating carbon
phenolic cloth. Operational
dates are approximately 1981-
present.____________________
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-5 Dust collectors
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
545
Building
M-13
Description
SWMU 545 is an old dust
collector that is no longer
used. It was a closed loop
filter system (contained in the
building) for grinding
ammonium perchlorate.
Operational dates were
approximatlyl 962-2010,
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.
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M-13 Dust Collector System
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
537
Building
M-79
Description
SWMU 537 is an old dust
collector that used to grit blast
metal cases; it was converted
to a ventilation system.
Operational dates were
approximatlyl962 - 1996
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-79 Old Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
Building Description NFA Justification
508 M-179 SWMU 508 is an old dust
collector used for the
machining of plastic parts. It is
no longer used. Operational
dates were approximatlyl962-
1998.
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-179 Old Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs Building Description
509 M-179 SWMU 509 is a dust collector
used in grit blasting plastic
parts. Operational dates are
approx. 1962 to Present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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_____M-179 Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
476
Building
M-113
Description
SWMU 476 is an old dust
collector located on the east
side of the building; used in
grit blasting plastic and metal
parts. It is no longer used.
Operational dates were
approximatlyl 962-2010.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.
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M-113 Old Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
477
Building
M-113
Description
SWMU 477 is a dust collector
on the south end of the
building. It is associated with
machining of phenolic parts.
Operational dates are
approximately 1981-Present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-113 South Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
471
Building
M-52
Description
SWMU 471 is a dust collector
associated with grit blasting
metal parts. It is no longer
used. Operational dates were
approximatlyl 981 -2006.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-52 Old Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
468
Building
M-6
Description
SWMU 468 is a dust collector
associated with a carpenter
shop collecting saw dust.
Operational dates were
approximatlyl 962-present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-6 Dust Collector
ATK Launch Systems
Promontory, Utah
Waste Dock and Dust Collector SWMU Investigation 5
May 2016
SWMUs
452
Building
M-8
Description
SWMU 452 is a dust collector
associated with grit blasting
metal parts. Operational dates
are approximatlyl 981-present.
NFA Justification
There is no history of releases. The units
are regulated by the facility Air Permit
including inspections and record
keeping. No evidence of releases was
observed during the April 13, 2016
inspection.__________________________
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M-8 Dust Collector