DSHW-2016-010443 - 0901a0688063b7b5

Div of Waste Management
and Radiation Control
JUN - 8 2016
OrbtoalATK
June 6, 2016
8200-CY16-067
DSH-K/-Z016- Oio^t-b
Scott T. Anderson, Director
Department of Environmental Quality
Division of Waste Management and Radiation Control
ATTN: Jeff Vandel
P.O. Box 144880
195 North 1950 West
Salt Lake City, Utah 84114-4880
RE: Additional Investigation, Solid Waste Management Unit # 553, Sampling and Analysis Plan,
ATK Launch Systems Inc. - Promontory Facility, EPA ID# UTD0090813571—'
Dear Mr. Anderson,
In a February 19, 2016 letter from your office (DSHW-2016-004925), a request was made to conduct
additional sampling at SWMU #553 and that a sampling plan be submitted. A sampling and analysis
plan is included with this letter for SWMU #553.
If you have questions, or need additional information, please contact Paul Hancock at [phone].
Sincerely,
( ^ »ch, Manager,
Environmental Services
Orbital ATK, Inc.P.O. Box 707 Brigham City, Utah 84321 o (801 )250-5911
rbitalATK
SAMPLING AND ANALYSIS PLAN
Solid Waste Management Unit 553 Resample
Promontory Facility
Prepared for:
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
Prepared by:
ATK Launch Systems Inc.
UTD009081357
May 2016
Orbital ATK
SAMPLING AND ANALYSIS PLAN
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
TABLE OF CONTENTS
1.0 INTRODUCTION..............................................................................................................2
1.1 Background.............................................................................................................2
1.2 Studies at Other Photgraphic Sites...........................................................................2
1.3 Previous Sampling..................................................................................................3
1.3 Purpose of Sampling.................................................................................................6
2.0 FACILITY DESCRIPTION...............................................................................................6
3.0 SAMPLING RATIONALE....................................................................................... 6
4.0 DATA GENERATION.......................................................................................................6
4.1 Sampling Process Design........................................................................................7
4.2 Sampling Methods..................................................................................................7
4.3 Decontamination Procedures..................................................................................8
4.4 Sampling Handling and Custody............................................................................8
4.5 Analytical Methods.................................................................................................9
4.6 Quality Control Samples.........................................................................................9
4.6.1 Field Quality Control Samples....................................................................9
4.6.2 Laboratory Quality Control Samples.........................................................10
4.7 Data Management.................................................................................................10
4.8 Site Survey Control................................................................................................10
5.0 DATA VALIDATION AND USABILITY.......................................................................11
5.1 Data Review, Verification, and Validation.............................................................11
FIGURES
FIGURE 1 SWMU #553 Sample Locations
TABLES
TABLE 1 SWMU #553 Soil Sampling Results Oct. 1993
TABLE 2 Analytical List
1
BrhitalATi
SAMPLING AND ANALYSIS PLAN
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
1.0 INTRODUCTION
This Sampling and Analysis Plan (SAP) has been developed in response to a request by the Utah
Division of Waste Management and Radiation Control (the Division) to resample a Solid Waste
Management Unit (SWMU) designated as #553, a historic photographic fixer discharge area at
the Promontory ATK Launch System Inc. (ATK) facility. The Division recommended that ATK
submit a plan for additional sampling at the site.
1.1 BACKGROUND
The building called M-19A at the ATK facility was historically used to develop X-ray
photographs from the X-ray of solid rocket motors such as Minute Man. The spent photographic
fixer solution was discharged to a dry well which could overflow through a pipe into a storm
drainage channel designated as SWMU #553.
In October 1993 the storm drainage channel was sampled as part of the site RFI program. A
report of the investigation was included in Thiokol Propulsion RCRA Facility Investigation
Source and Contamination Characterization Phase 1 SWMUs , August 2000 (2000 RFI report).
This sampling plan is supplemental to information contained in the 2000 RFI report. A table
summarizing the sample locations and results collected at SWMU #553 is found in Table 1.
1.2 STUDIES AT OTHER PHOTOGRAPHIC WASTE SITES
Additional photographic waste water discharge sites have been investigated and RCRA closed at
the Promontory facility. These include M-39, M-l 14, M-636 and M-508. An understanding of
the studies at these sites conducted along with the clean-up is helpful in determining how the
metals associated with these discharges behave in soils at ATK and how to investigate them at
this site. ATK commissioned Utah State University to conduct a comprehensive study of the
soils at M-39 and M-l 14. The report of this work, Soils Study of Space Operations Facilities
(M-39, M-l 14) Photographic Developer Waste Discharge Sites, and detailed summaries have
been submitted previously to the Division in reports associated with those site closure plans.
2|Page May2016
Orbital AT Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
SAMPLING AND ANALYSIS PLAN
Briefly, the study involved soil physical and chemical properties testing, extraction of metals and
taken at each of the sites. Site M-39 is especially applicable to SWMU #553 as it is
approximately 550 feet away and would have similar soil characteristics. It was found that silver
concentrations at the M-39 site decreased rapidly with depth, indicating that high silver levels
remained at the 0 to 1 foot range and were not mobile in the soil. Similar non-mobile
characteristics for chromium and lead were also determined, along with the understanding that
background levels of these constituents are present in the soil. Cadmium was found to be more
mobile, however concentrations were low and below levels of concern. The remediation process
at the sites also involved shallow excavations to remove the contamination. Based on this
information the constituents of interest would remain in the shallow zones of the soil within the
storm channel. Further, the silver levels appear to be associated with the other constituents of
interest.
1.3 PREVIOUS SAMPLING
Figure 1 shows the locations of the previous sampling sites within the storm drainage channel
along with potential sampling locations. In the 1993 sampling event, 5 locations were selected
down gradient relative to the discharge point, 25 feet, 50 feet, 75 feet, 100 feet and 250 feet. At
each of these locations soils samples were collected at the surface and at a depth of two feet.
As can be seen in in Table 1, the results show that silver concentrations were typically higher
than background, but do not exceed the U.S. EPA Regional Screening Level of 390 mg/Kg. The
250 foot location sample collected at an interval of 1 to 2 feet showed the highest value for silver
at 135.8 ppm. This higher value indicates that silver concentrations may be higher at distance
and at depth within the storm channel possibly due to storm water flushing sediment past the
original contamination zone. The other metal constituents were determined to be below levels of
concern or similar to background with the exception of one chromium sample at the 50 foot
location.
In 2014, after discussions with the Division, an additional sample was collected to characterize
3|Page May2016
column studies. The vertical distribution of total metals was determined in samples from cores
Orbital ATK
SAMPLING AND ANALYSIS PLAN
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
the Cr (VI) values at the 50 foot sample location which had shown the highest total chromium
level at a depth of 2 feet. Analytical results showed that Cr (VI) levels were below PRGs.
Table 1
SWMU #553, Soil Sample Results (pg/g), Oct. 1993
coc Depth Source 25'50'75'100'250'Background
Cd surface U U U 0.6 0.6 U
2'U U 8.2 3.7 1.4 U
Cr (total) surface 11.0 10.9 18.8 19.5 19.3 19.3
2'16.0 26.3 506.8
19.0*
41.3 20.0 26.4
Cr VI surface
2'<2.1*
Pb surface 9.4 7.6 12.8 12.6 14.3 14.5
2'12.1 16.0 20.3 13.3 20.9 13.7
Ni surface 11.2 10.6 14.6 14.2 16.0 18.2
2'32.4 22.3 18.0 12.9 28.0 18.4
Ag surface U U 1.5 2.9 31.1 1' to 2'
135.8
U
2'U U 96.3
93.1*
46.2 104.0 U
* sample results dated August, 2014, Cr (VI) values are in pg/Kg
2 0 14 | P a g e May 6
5

|
P

a

g

e

May
2
0
1
6
OrhitaBATK
SAMPLING AND ANALYSIS PLAN
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
1.4 PURPOSE OF STUDY
In the 2000 RFI report sampling, there was an indication that silver concentrations at SWMU
553 were higher in the storm channel at greater depths and greater down gradient distances from
the discharge location. The purpose of this SAP is to conduct additional sampling in order to
better characterize the concentrations of silver at greater depths and downgradient distances than
conducted in the previous sampling.
2.0 FACILITY DESCRIPTION
Please refer to the 2000 RFI report for a facility description.
3.0 SAMPLING RATIONALE
Since previous sampling has shown that all areas sampled are below the RSLs, this sampling will
determine if the concentrations of silver increase with either distance or depth from the previous
locations. An iterative approach will be used which includes the use of a hand held X-ray
fluorescence (XRF) to screen soil samples as they are excavated. Using this approach it will
possible to screen out areas that are low in silver concentrations and move on the other locations
or if they are high to continue going deeper or a greater distance. The hand held XRF has a
lower detection limit of around 40 ppm for silver in soil, this is very adequate as the RSL for
silver is 360 pmm. Silver detections should also act as a good indicator as it is associated with
other constituents of concern which are present in background concentrations.
4.0 DATA GENERATION
4.1 SAMPLING PROCESS DESIGN
The objective of site sampling will be to assess the silver concentrations at greater depths and
distances than the previously conducted sampling. Samples will first be collected at the 50 foot,
150 foot, 250 foot location at a depth interval of surface, 1- 2 feet and then at a depth interval of
6|Page May2016
Orbital AT Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
SAMPLING AND ANALYSIS PLAN
2.5 to 3 feet. Using the XRF these samples will be screened for silver at 200 ppm, if samples are
higher than 200 ppm at these sites, samples will be collected at a depth interval of 3.5 to 4 feet
and again screened for silver using the XRF. Additional depth intervals of 0.5 to 1 foot will be
sampled until it is determined that silver is below a 200 ppm screening level. This approach will
be used to determine if silver concentrations increase at depth. Additionally, samples will be
collected at distances of 300, 350 and 500 foot locations within the channel starting at a depth of
surface, 1 foot, then a depth interval of 1.5 to 2 feet, one final sample will be collected at a depth
interval of 2.5 to 3 feet. If silver concentrations are below the 200 ppm screening and not
increasing, then no additional samples will be collected. If concentrations are increasing at
depth or at distance additional samples will be collected using a protocol of 50 foot distances and
0.5 to 1 foot depths until the contamination has been determined to be properly bounded. Based
on what is found during the screening process changes may be made in the field to these
prescribed depths and distances in order to better characterize the site.
4.2 SAMPLING METHODS
Due to the large amount of large rock and gravel found in the storm drainage channel, sample
depth intervals will be achieved using a backhoe or a pick and shovel.
Samples will be collected at the prescribed depth either from the backhoe bucket or from the hole
using a pre-cleaned stainless steel spoon. Soil will be placed into a pre-cleaned polyethylene
bowl. Plant material, roots, and rocks will be manually removed. The soil will be lightly mixed,
and screened using the XRF. The sample at each location with the highest silver concentration
as screened by the XRF will be analyzed at the ATK Environmental Laboratory as a
confirmation sample. Confirmation samples will be placed into a 4-oz wide-mouth glass jar with
a Teflon® lined lid, and securely tightened.
All information collected during the field investigation will be maintained in a field log. XRF
analytical data will be kept in an Excel spreadsheet file and will be included in the report. Field
documentation will consist of the information provided in the RFI Work Plan QAAP.
7|Page May2016
Orbital AT,Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
SAMPLING AND ANALYSIS PLAN
The soil sample numbering sequence will show the distance and depth designation. Sample
numbers will be recorded in the field log book and on the chain-of-custody form submitted with
the sample to the analytical laboratory. The confirmation sample containers will be immediately
place in a cooler on ice. The samples will be assigned analysis for silver, chromium and
cadmium using the methods outlined in Section 4.5 of this SAP.
4.3 DECONTAMINATION PROCEDURES
Prior to and following the collection of each sample, any sampling equipment coming in contact
with the soil will be cleaned with a non-phosphate detergent (e.g., Liquinox®), rinsed with tap
water, and final rinsed with distilled water. Wastewater generated during field decontamination
will be collected and disposed of properly. The excavated soil will remain within the area of
sampling activity.
4.4 SAMPLE HANDLING AND CUSTODY
Sample containers will consist of glass jars, with Teflon-lined lids. Only decontaminated
stainless steel, polyethylene and/or clean disposable gloves will contact a sample during
placement in a bottle. Disposable gloves will be worn at all times during sample handling to
prevent cross contamination between samples and skin contact with potential contaminants.
Gloves will be disposed of between each sample.
Sample bottles will be placed on ice in waterproof cooler chests for delivery to the analytical
laboratory. Sample labels will be used to identify the samples. These labels will be sufficiently
durable to remain legible when wet and will be marked with indelible ink and affixed to the
sample containers.
A chain-of-custody form will be completed to trace sample possession from the time of
collection through laboratory analysis. One chain-of-custody form will accompany the cooler
container of samples. While the samples are in the custody of the collector, they will not be left
unattended at locations where the samples may be tampered with. The analyses to be performed
will be indicated on the chain-of-custody form, including the quantity and types of containers
8 | P a g e May 2016
Orbital AT Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
SAMPLING AND ANALYSIS PLAN
that comprise each sample. The shipping container will then be securely closed and delivered to
the analytical laboratory.
include the date, time and depth of sample collection, descriptions of the soils encountered at
each sampling location, reasons for field decisions concerning sample intervals, reasons for
departures from prior plans, general observations, etc.
4.5 ANALYTICAL METHODS
Soil samples will be analyzed in accordance with EPA Methods 601 OB (total priority pollutant
metals) for silver, chromium and cadmium. Table 2 includes anticipated method detection limits
and estimated quantitation limits. Unless interferences preclude attainment of the detection
limits, the detection limits are sufficiently low to meet the concentrations for a residential
scenario Regional Screening Levels for Contaminants of Concern at Superfund Sites, December
2015, now used by USEPA Region 9 (RSLs). Constituents will be reported on a dry-weight
basis.
Priority pollutant metals analysis will be conducted by ATK Launch Systems Environmental
Laboratory at the Promontory facility, a laboratory certified in the State of Utah.
4.6 QUALITY CONTROL SAMPLES
Quality Control (QC) soil samples will be analyzed for the constituents listed in Table 2, except
as noted below.
4.6.1 Field Quality Control Samples
Field QC samples will be analyzed for the same sample constituents as the samples-of-record.
QC samples will consist of field duplicates and background samples.
Field Duplicate samples are analyzed to check the reproducibility of sampling and analytical
results of two samples collected from same location. Field duplicates (representing about 10%
of the total samples sent for analysis) will be collected at randomly-selected locations during the
sampling program. A subsurface sample selected for duplication will be obtained by removing
All field data will be recorded in a log book. Information to be recorded in the log book will
May 2 0 169 | P a g e
Orbital AT
SAMPLING AND ANALYSIS PLAN
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
half of the sample following mixing. The duplicate sample will be given a designation that will
laboratory for analyses of the same constituents as the sample-of-record. All field duplicates will
be delivered to the laboratory under chain-of-custody as outlined above.
Background Samples are collected to demonstrate that the concentrations of contaminates of
concern are naturally present at the site. They also function as a check on analytical
interferences both positive and negative that may influence the analytical results. The
background location will be determined during the day of sampling and noted in the field log
book.
4.6.2 Laboratory Quality Control
Internal laboratory quality control checks will be performed in accordance with the RFI Work
Plan QAPP.
4.7 DATA MANAGEMENT
Field data (e.g., XRF readings, visual observations, lithologic information, etc.) will be recorded
in a field log book. These data will be maintained in project files for future reference. Hard
copies of laboratory data will be maintained in project files and will be entered into a Microsoft-
based spreadsheet and/or database to aid in evaluation. Electronic data will be stored
indefinitely. Hard-copy data will be maintained for a period of at least 3 years.
4.8 SITE SURVEY CONTROL
Following collection of the soil samples, each sample location will be surveyed using a sub­
meter GPS unit or standard survey equipment and recorded in the field logbook. This will allow
sample sites to be re-accessed in the future if necessary.
10|Page May2016
differentiate the duplicate from the original sample. The field duplicates will be submitted to the
Orbital ATK
SAMPLING AND ANALYSIS PLAN
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
Soil
MDL MRL
Priority
Pollutant
Metals
(601 OB)
Residential
RSLs (mg/kg)(mg/kg)(mg/kg)
Chromium —0.07 0.500
Silver 390 0.100 0.500
Cadmium 70 0.100 0.500
5.0 DATA VALIDATION AND USABILITY
5.1 DATA REVIEW, VERIFICATION, AND VALIDATION
Data review, verification, and validation will occur as outlined in the RFI Work Plan QAPP.
11 | P age May 2016