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Home My WebLink AboutDSHW-2016-011719 - 0901a0688065364cOrbital ATK July 26, 2016 8200-CY16-074 Div of Waste Management and Radiation Control JUL 2 7 2016 Mr. Scott T. Anderson, Director Utah Department of Environmental Quality Division of Waste Management and Radiation Control 195 North 1950 West dsmw- zoi^-oimn P.O. Box 144880 Salt Lake City, Utah 84114-4880 Re:ATK Launch Systems Inc., Surface Water SWMU Investigation Report 1, Promontory EPA ID #UTD009081357 Dear Mr. Anderson: On July 16, 2016 Jeff Vandel from your office visited the Promontory facility to inspect and investigate a group of 24 Solid Waste Management Units (SWMUs) that are primarily past surface water discharges from various buildings. The attached report describes the results of that investigation and a request for no further action on these SWMUs. If you have questions regarding this report, please contact Paul Hancock at (435) 863- 3344. Sincerely, George Gooch 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, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 255 M-179N These SWMUs are The 2000 RFI report describes 256 M-179-SE associated with building two sampling locations, one at the 268 M-8 process water surface discharge point and 25 feet down 269 M-10 discharges including gradient with depths at surface 409 M-10 cooling water and boiler and two feet. All constituents 472 M-52 blowdown. This water were found to be below 611 M-9 co-mingled in underground pipes and daylighted at one location in a storm drainage channel. Operational dates are approximately 1967- 1995. background concentrations or well below risk based levels. These values are also below current 2016 residential soil RSLs. SWMU 256 was not part of the 2000 RFI report, however, during this investigation it was concluded that this discharge was part of these comingled discharges investigated in the RFI report and is therefore included with this group. ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 257 M-14N These SWMUs are associated The 2000 RFI report describes two 270 M-14S with a boiler house (M-14) and sampling locations within the pond with 345 M-14 the boiler blowdown, condensate and water softening waste water. These flows were piped to a nearby collection pond for evaporation. Operational dates are approximately 1967-1995. depths at surface, five and ten feet. All constituents were found to be below background concentrations and risk based levels. These values are also below current 2016 residential soil RSLs. ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 258 413 M-33B M-33C These SWMUs are associated with a boiler house (M-33) boiler blowdown and condensate. The flows were piped to a discharge location west of the building. Operational dates are approximately 1967 to 1995. Later construction has modified the discharge area. The 2000 RFI report describes two sampling locations, one at the discharge point and 25 feet down gradient with depths at surface and two feet. All constituents were found to be below background concentrations or well below risk based levels. These values are also well below current 2016 residential soil RSLs. SWMUs 258, 413, M-33 Boiler Old Discharge location ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 259 M-53 SWMU 259 is associated with an old building discharge from the east side of M-53. It consisted of once through cooling water, parts rinse water and building wash down. Operational dates are approximately 1981 to 1995. The 2000 RFI report describes two sampling locations, one at the discharge point and 25 feet down gradient with depths at surface and two feet. All constituents were found to be well below risk based levels. These values are also well below current 2016 residential soil RSLs. SWMU 259, M-53 Old Surface Water Discharge ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs 261, 433 Building M-67 RF1 Description SWMUs 261 and 433 are surface water discharges associated with BAG cooling, once through cooling, boiler condensate and ultrasonic coupling. Operational dates are approximately 1962 to 1995. Later NFA Justification The 2000 RFI report describes two sampling locations, one at the discharge point and 25 feet down gradient with depths at surface and two feet. All constituents were found to be well below risk based levels. These values are also well below current 2016 residential soil RSLs. construction has modified the original contours. SWMUs 261, 433, M-67 Old Surface Water Discharge Location ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 263 M-72 SWMU 263 was a surface water discharge associated with BAG cooling, boiler blowdown, boiler condensate and water softener waste water. Operational dates are approximately 1962 to 1995. The 2000 RFI report describes two sampling locations, one at the discharge point and 195 feet down gradient with depths at surface and two feet. All constituents were found to be well below risk based levels. These values are also well below current 2016 residential soil RSLs. SWMU 263, M-72 Old Surface Water Discharge Location ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 264 M-641 SWMU 264 was a surface water discharge associated with once through cooling, and boiler condensate. Operational dates are approximately 1962 to 1995. The 2000 RFI report describes two sampling locations, one at the discharge point and 25 feet down gradient with depths at surface and two feet. All constituents were found to be below risk based levels. These values are also below current 2016 residential soil RSLs. SMMU 264, M-641 Old Surface Discharge Location ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 267 A-9 SWMU 267 was a surface water discharge associated with boiler blowdown, boiler condensate, BAG cooling and water softening waste water. Operational dates are approximately 1962 to 1995. The 2000 RFI report describes two sampling locations, one at the discharge point and 318 feet down gradient with depths at surface and two feet. All constituents were found to be below risk based levels. These values are also below current 2016 residential soil RSLs. SMMU 267, A-9 Old Surface Discharge Location ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 273 M-585 SWMU 273 was a surface water discharge associated with laboratory operations and once through cooling. Operational dates are approximately 1962 to 1995. The 2000 RFI report describes two sampling locations, one at the discharge point and 25 feet down gradient with depths at surface and two feet. All constituents were found to be below risk based levels. These values are also below current 2016 residential soil RSLs. SMMU 273, M-585 Old Surface Discharge Location ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 SWMUs Building RFI Description NFA Justification 274 M-593 SWMU 274 was a surface water discharge associated with BAG cooling, boiler condensate and casting pit wash water. Operational dates are approximately 1962 to 1995. The 2000 RFI report describes two sampling locations, one at the discharge point and 25 feet down gradient with depths at surface and two feet. All constituents were found to be below risk based levels. These values are also below current 2016 residential soil RSLs. ATK Launch Systems Promontory, Utah Surface Discharge SWMU Investigation 1 July 2016 ATK Launch Systems Promontory Facility Surface Water Discharge SWMUs Investigation 1 rbitalATK ATK Launch Systems, Inc. Promontory Facility July 2016 ATK Launch Systems Promontory, Utah Surface Water Discharge SWMUs Investigation 1 July 2016 ATK Launch Systems Surface Water Discharge SWMUs 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) now called the Utah Division of Waste Management and Radiation Control (UDWMRC). The RFA report was completed by the UDSHW in 1990. A RCRA Facility Investigation (RFI) was conducted by ATK under approval of the UDSHW and a subsequent report submitted in August 2000. The report describes the investigation, results and conclusions associated with many SWMUS at ATK including a group of surface water discharges from various buildings. These surface water discharges were predominantly characterized as boiler blowdown, boiler condensate, Baltimore Aircoil cooling towers (BAC) and once through non-contact cooling. These discharges typically went to the building drainage systems that included storm water runoff. In 1995 all of these types of building discharges were connected to two biological waste water treatment facilities. On July 12, 2016 Jeff Vandel with the UDWMRC visited the Promontory Facility to inspect a group of 24 SWMUs that were primarily these building surface water discharges. This report summarizes the findings of that investigation and inspection. It 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: 1. The RFI 2000 report concluded that these surface water discharge SWMUs required no further investigation as all constituents were below risk based levels or represented background levels. Comparison of these detected constitute concentrations to the current (May 2016) Regional Screening Levels for residential exposure showed that they are also below these screening standards. 2. All building flows of this type were connected to waste water treatment facilities in 1995. During the July 12, 2016 inspection no evidence of any releases from the buildings were seen. 3. Two other SWMUs investigated were historic mining prospects that predate ATK ownership or activity. These were not investigated as part of the RFI 2000 report. During this inspection no evidence of ore processing or mining activity was found at these sites. There were no risks identified and it was determined that no additional investigation was needed. This report includes a brief description of each of the SWMUs, including photos and justification for no further action. Additional details for the surface water discharge SWMUs are found in the August 2000 RFI report. A listing of SWMUs included in this report that were part of the July 12th, 2016 investigation is in Table 1. ATK Launch Systems Surface Water Discharge SWMUs Investigation 1 Promontory, Utah July 2016 Table 1 SWMUs Included in this Report Building Investigated on July 12, 2016 SWMU# Description 1.M-179N 255 Surface Building Discharge 2.M-008 268 Surface Building Discharge 3.M-010 269 Surface Building Discharge 4.M-010 409 Surface Building Discharge 5.M-052 472 Surface Building Discharge 6.M-009 611 Surface Building Discharge 7.M-179SE 256 Cooling Water Discharge 8.M-014N 257 Surface Building Discharge 9.M-014S 270 Surface Building Discharge 10.M-014 345 Building Discharge Collection Pond (m-omn&s) 11.A-009 267 Boiler Discharge 12.M-033B 258 Surface Building Discharge 13.M-033C 413 Surface Building Discharge 14.M-053E 259 Surface Building Discharge 15.M-053-BP 260 Dry Well Sump 16.M-072 263 Surface Building Discharge 17.M-067 261 Surface Building Discharge 18.M-067 433 Surface Building Discharge 19.NEl/4, SW1/4 Sec. 20 225 Old Prospect 20.NEl/4, SW1/4 Sec. 20 226 Old Prospect 21.S-501 266 Boiler Discharge 22.M-641 264 Building Discharge 23.M-593 274 Building Discharge 24.M-585 & M-585N 273 Surface Building Discharge