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Home My WebLink AboutDSHW-2016-010683 - 0901a0688063f018Div of Waste Management and Radiation Control June 15,2016 8200-CY16-070 JUN 1 5 2016 Orbital ATi DSHW- £oiG-oto683 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 and Dust Collector SWMU Investigation Report 6, Promontory EPA ID #UTD009081357 i—"* Dear Mr. Anderson: On April 13, 2016 Jeff Vandel from your office visited the Promontory facility to inspect and investigate a group of 8 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 sixth report investigating the waste docks with this one also including dust collector SWMUs. Four similar reports were submitted previously in 2015 and one in May of 2016. If you have questions regarding this report, please contact Paul Hancock at (435) 863- 3344. Sincerely, < „ 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 6 rbitalATK ATK Launch Systems, Inc. Promontory Facility June 2016 ATK Launch Systems Promontory, Utah Waste Dock & Dust Collector SWMU Investigation 6 June 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 May 16, 2016 Jeff Vandel with the UDWMRC visited the Promontory Facility to inspect and investigate a group of eight 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, and April 13, 2016. This report summarizes the findings of the May 16, 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 May 16, 2016 inspection no evidence of releases were seen. ATK Launch Systems Promontory, Utah Waste Dock & Dust Collector SWMU Investigation 6 June 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 May 16, 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 May 16, 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 6 June 2016 Table 1 SWMUs Included in this Report Investigated on May 16, 2016 Building SWMU# Description -053 455 -086 458 -210 460 018 330 096 605 097 337 024 495 -066 474 Dust Collector Dust Collector Dust Collector Old Hazardous Waste Dock Satellite Accumulation Areas Satellite Accumulation Areas Satellite Accumulation Areas Grit Blasting Area ATK Launch Systems Promontory, Utah Waste Dock and Dust Collector SWMU Investigation 6 June 2016 SWMUs Building Description NFA Justification 455 M-53 SWMU 455 is associated with the building dust collectors used for processing carbon black and rubber grinding and buffing. It is rarely used. Operational dates are approximately 1967 - 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 the May 16th, 2016 inspection. ATK Launch Systems Promontory, Utah Waste Dock and Dust Collector SWMU Investigation 6 June 2016 SWMUs Building Description NFA Justification 458 M-86 SWMU 458 is a dust collector associated with a small fume hood for mixing rubber liner that contained asbestos. It is rarely used. Operational dates are 1985-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 the May 16th, 2016 inspection. ATK Launch Systems Waste Dock and Dust Collector SWMU Investigation 6 Promontory, Utah June 2016 SWMUs Building Description NFA Justification 460 M-210 SWMU 460 is associated with the building dust collector used for small amounts of ammonium perchlorate weigh up. It is seldom used. Operational dates are approximately 1976 to present. There is no history of releases. The unit is regulated by the facility Air Permit including inspections and record keeping. No evidence of releases was observed during the May 16, 2016 inspection. ATK Launch Systems Promontory, Utah Waste Dock and Dust Collector SWMU Investigation 6 June 2016 SWMUs 474 Building M-66 Description SWMU 474 is an old dust collector used for grit blasting spot on metal rocket motor cases. Operational dates are approximately 1981 to 2005. The collector is no longer used. 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 May 16, 2016 inspection. ATK Launch Systems Promontory, Utah Waste Dock and Dust Collector SWMU Investigation 6 June 2016 SWMUs 330 Buildinu T-18 Description SWMU 330 is an old hazardous waste dock. It was a raised wooden platform that was removed. The photograph is where the dock was located. Operational dates are 1962 to approximately 1986. NFA Justification Waste was removed on a regular basis. There is no history of releases. In the 1990 RFA no investigation was recommended for these types of SWMUs. No evidence of releases was observed during the May 16, 2016 inspection. MU. . ,".JPW| ' ,.v - -,v:: ^r;^j ATK Launch Systems Promontory, Utah Waste Dock and Dust Collector SWMU Investigation 6 June 2016 ATK Launch Systems Promontory, Utah Waste Dock and Dust Collector SWMU Investigation 6 June 2016 SWMUs Building Description NFA Justification 337 T-97 SWMU 337 is a satellite accumulation site. The building at the time of this inspection had restricted access due to preparations for a test fire. However, the site was previously inspected by Jeff Vandel. The photograph is from T- 24 which is very similar. Operational dates are approximately 1988 to present. 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. No evidence of releases was observed during the May 16, 2016 inspection. ATK Launch Systems Promontory, Utah Waste Dock and Dust Collector SWMU Investigation 6 June 2016 SWMUs Building Description 495 T-24 SWMU 495 is a satellite accumulation site. Operational dates are approximately 1962 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. No evidence of releases was observed during the May 16, 2016 inspection.