DSHW-2017-000316 - 0901a0688069d831

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January 12, 2017
8200-CY17-002
Div of Waste Management
and Radiation Control
Scott T. Anderson
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
PO Box 144880
Salt Lake City, Utah 84114-4880
Jan, i 2 2017
DSHW-ZOI7- 00031C
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Subject: ATK Launch Systems- Promontory Facility; EPA ID Number UTD009081357; M-590
Spill Report; Cleanup Recommendation
Dear Mr. Anderson:
In our November 19, 2015 correspondence ATK Launch Systems, Inc. (ATK) reported that no
cleanup had been initiated for material under the building and asphalt pad pending further
discussion with the Division to evaluate cleanup options. Based on that discussion we are
proposing the following recommendation. These recommendations were originally proposed
and discussed with the Division in December 2015, this letter formalizes those discussions.
Cleanup Recommendation
It is recommended that no action be taken based on these factors:
• The release is in the soil underneath the building’s containment and around the building's
footings.
• Based on the Cal/EPA Office of Environmental Health Hazard Assessment, sodium
hydroxide in soil reacts with water and organic materials and will neutralize naturally
without any corrective action.
• The building is surrounded by asphalt which prevents the potential for precipitation to
infiltrate.
• Removing contaminated soil would require demolishing the facility.
• It is also recommended that the site not be classified as a solid waste management unit
(SWMU) since no remediation value has been established for sodium hydroxide in the
EPA Regional Screening Level Table (June 2015).
Basis for Recommendation
The cleanup criteria for this spill involve soil that has absorbed high pH sodium hydroxide liquid
based on these factors:
• Sodium Hydroxide released to the soil does not meet the 40 CFR 261.22 definition for
the characteristic of corrosivity. The corrosivity characteristic determinations under the
EPA require that the waste be aqueous with a pH 2< or > 12.5 as measured by a pH meter
using method 9040. There is an EPA method for measuring the pH of a solid, method
9045; however, the EPA has clarified that “Method 9045 is not (to be) used for
corrosivity characteristic determinations” (April 4, 1995; 60 FR 17003).
OrbhalAm
Decembor 8, 7015
Mr. Scott T. Anderson, Director
Utah Division of Waste Management and
Radiation Control
• Sodium hydroxide is a unique constituent in that there are no actual cleanup standards or
■. screening levels that apply to soil and groundwater found in the ERA Regional Screening
■' level Table (June 2015).
• The California Office of Environmental Health Hazard Assessment (OEHHA) has
published a reference called Technical Support Document: Toxicology Clandestine Drug
Labs: Methamphetamine, Volume 1, Number 7, and Sodium Hydroxide. It discusses the
hazards and cleanup of sodium hydroxide used in illegal drug labs. In the section on soil,
the document states “Sodium hydroxide would be expected to react with water and
organic materials in soil, thereby becoming neutralized.” In the section on groundwater, it
states “Sodium hydroxide is highly reactive and is rapidly neutralized by organic
chemicals in soil. For this reason, it is not expected to migrate downward through soil to
groundwater.”
• Based on groundwater wells in the spill location, it appears that this is an area where
perched aquifers may exist at an estimated depth of 80 feet. The regional aquifer is
estimated to be around 200 feet deep. The potential for the sodium hydroxide to reach
groundwater is low, especially due to the fact that the release is under a building
suiTOunded by asphalt with no potential for precipitation to infiltrate.
ATK believes that taking no action is protective of human health and the enviromnent. We are
taking corrective actions to prevent future releases which include an engineering review of
containments areas, a requirement to verify tank integrity prior to use, a requirement for building
owners to develop planning to transfer liquids in the event a tank fails, and a requirement to
evaluate the materials and design of tanks and fittings.
We appreciate the time spent by Jeff Vandel and Jon Parry discussing this topic. Please refer
questions on this topic to Paul Hancock, [phone].
/ 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 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 offine and imprisonment for knowing violations.
Sincerely,
George Gooch
Manager, Environmental Services
c: Jeff Vandel, DSHW
Jason Wells, Orbital ATK