DSHW-2016-012910 - 0901a06880669235

Orbital ATK/j
Div of WaswWanagemam
and Radiation Control
September 15, 2016
8200-CY16-080 SEP \ 5 2016
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195North 1950 West PSHW' 2016'0 1 2. ^ I 0P.O. Box 144880 * 1
Salt Lake City, Utah 84114-4880
yRe: ATK Launch Systems, Inc., EPA ID #UTD009081357, Semi-Annual RFI
Progress Report for March 2016 to September 2016.
Dear Mr. Anderson:
Attached is the ATK Launch Systems, Inc. Promontory Facility Semi-Annual RFI
Progress Report for March 2016 to September 2016.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
3344
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.
Sincerely,
--------George Gooch
Manager, Environmental Services
ATK Launch Systems
cc: Walter L. Baker, Division Director, Utah Division of Water Quality
Orbital ATK, Inc.P.O. Box 707, Brigham City, UT 84302 • 435-863-3511
SEMI-ANNUAL RFI PROGRESS REPORT
March 1, 2016 - September 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, Inc. (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 an August 18, 2016 letter the UDWMRC closed with no further action 33 SWMUs. These
SWMUs are associated with dust and grit blast collectors and 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 April 13th, and May 16th. 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 dust
collector and waste dock SWMUs.
On July 12, 2016, Jeff Vandel conducted inspections of 24 SWMUs. Most of these had
been previously investigated as historic surface water discharges from various buildings at
the facility and were part of the October 2000 RFI report submittal to the Division. A report
of this inspection was submitted to the Division on July 26, 2016.
In discussions with the Division it was determined that SWMU 553 required additional
investigation to more fully characterize the site. This SWMU is related to a former
photographic X-ray development process at building M-19A that historically discharged
photographic fixer waste water to a storm drainage channel. ATK proposed an investigation
plan that was approved by the Division in an August 12, 2016 letter. Plans are to conduct
this additional investigation during the month of September 2016. The Division will be
notified of the dates.
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
residential Regional Screening Level (RSL) of 0.29 ppm. Due to the close proximity to the
M-585 building footings, it is not advisable to attempt soils removal using a standard back-
hoe. Since the contaminated soil is in a 12 inch diameter pipe, in 2015 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 RSL 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, however, the results were
surprisingly still over the RSL limit. Plans were to conduct more soil removal during 2016
with additional analysis. Due to the inherent difficulty in removing significant amounts of
soil though the small opening around the cement footing, a method to potentially treat the
Cr(VI) in situ was researched. Calcium Polysulfide (CPS) liquid has been found to be
effective in reducing agent in several published studies with soil to convert Cr (VI) into Cr
(III). The CPS is not regulated by EPA and has a minor health concern related to possible
skin and eye irritation. The CPS creates a reducing environment regardless of the substrate
pH, and is stable for long periods of time. Information shows it would require low
concentrations to quickly reduce the Cr (VI) in the M-585 soil. ATK is in the process of
doing some bench tests of the CPS using the M-585 soil. If these tests demonstrate the CPS
is effective, we will propose to the Division that it be used as an in situ treatment of the Cr
(VI) in place of excavation that can be potentially damaging the building. These bench test
results will be discussed in the next progress report.
Plant 3 Well 3A Treatment Summary Reports
The treatment system at the Promontory Plant 3 well 3A has been monitored quarterly
according to the UDWMRC approved plan. The plan includes a request that a summary of
the previous year to date monitoring data be included in the September Semi-Annual report.
This summary is found in Table 1. The treatment system removes TCE to below the 5p/L
health based limit with a carbon replacement interval of every 6 + months. A slight
breakthrough was noted in the December 2015 sample and the carbon was replaced.
Interestingly, the septic tank samples from the same December sample showed TCE was
below detection limits. Water usage at Plant 3 has diminished with lower production.
Therefore, ATK is finding that TCE removal extends significantly beyond the initial 6 month
carbon replacement interval. In addition, perchlorate removal in the two septic tanks, M-201
and M-205, continues to be effective, however two samples showed perchlorate detections in
M-201 or M-205 that appear to be independent of the of each other. These samples are
collected from the septic tanks where treatment is taking place and in the subsequent sample
from M-201 it showed that it was treated in the process to less than the detection limit. This
demonstrates the perchlorate removal and reducing capacity of the tanks at higher levels. The
unusual detect in M-205 is being resampled to confirm treatment. Both of these locations
are only connected to hand washing sinks and a toilet, additionally M-201 has a shower and a
washing machine. While the source of the higher perchlorate levels remains unknown it is
likely related to some minor residue on personnel.
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 on 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 closing other SWMUs currently under review.
Table 1
Plant 3 Well 3A Quarterly Treatment Summary Sept 2015 - June 2016
For Perchlorate (CIO4.) and Trichloroethylene (TCE)
Well 3A Carbon and Septic Tank Treatment Sampling Data (ug/L)
Date Influent Carbon Effluent Septic Tanks (M-201
and M-205)
Flow (gal)
Totalizer reading
9/29/15 25.5 TCE
85 C104.
4.5 TCE
83 C104.
M-205 U CIO4-
M-201 327 CIO4-
35,811,500
12/16/15 NS 7 TCE
75 C104.
U CIO4-
U TCE
37,000,200
3/31/16 28.1 TCE
71 C104.
U TCE
U CIO4-
U CIO4-38,209,000
6/29/15 NS U TCE
101 C104.
M-201 U CIO4-
M-205 16.4 CIO4-
38,209,000 *
U = < 4 ppb detection limit
NS= Not Sampled
*Totalizer being repaired