DSHW-2017-001896 - 0901a068806c86b5

DSHW-2017-001896 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality

Alan Matheson
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director

March 10, 2017

George Gooch, Manager
Environmental Services
ATK Launch Systems – Promontory
P.O. Box 707
Brigham City, UT 84302-0707

RE: Surface Water Discharge Solid Waste Management Unit (SWMU) Investigation Report
UTD009081357

Dear Mr. Gooch:

The Division of Waste Management and Radiation Control has completed its review of the Surface
Water Discharge SWMU Investigation Report dated July 27, 2016. The 24 SWMUs that are included in
the report were initially identified during the RCRA Facility Assessment (RFA) and were investigated
during the Phase I RCRA Facility Investigation except for two SWMUS that pre-date operations at the
ATK facility. These two SWMUs appear to be old mine prospects or small quarries.

All of the SWMUs included in the Surface Water Discharge SWMU Report were inspected on
July 12, 2016. Based on the information presented in this report, the Phase I RFI Report and the
inspections that were conducted at each SWMU, ATK’s request for no further action is hereby approved
for the 15 SWMUs listed in the enclosed table. Please see the comments below regarding the other 9
SWMUs.

The SWMUs approved for no further action are also currently listed in Attachment 6 of ATK’s Post-
Closure Permit. Attachment 6 should be modified to indicate that the listed SWMUs have achieved no
further action status.

(Over)

Please respond to the comments on the other SWMUs at your earliest convenience. If you have any
questions, please call Jeff Vandel at [phone].

Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control

STA/JV/jr

Enclosures: Division of Waste Management and Radiation Control Comments Investigation of
Surface Water Discharge SWMUs
Surface Water Discharge and Mine Prospect SWMUs Approved For No Further Action

c: Lloyd Berentzen, MBA, Health Officer, Bear River Health Department
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Moye Lin, USEPA Region 8
Paul Hancock, ATK Launch Systems

Division of Waste Management and Radiation Control Comments
Investigation of Surface Water Discharge SWMUs

1. SWMU Group 255, 256, 268, 269, 409, 472 and 611

Drawing Number M8-1, which is included in the RFI Phase I Report (August, 2000) for this
SWMU Group, shows a culvert that cuts diagonally beneath the road just south of the soil
sample locations. Were the discharges from Buildings M-179N, M-179SE, M-8, M-10, M-52
and M-9 all hard-piped to this culvert?

The 1990 RFA Report contains two photos associated with this group of SWMUs. One photo
shows the ends of two large culverts where surface water is discharged and the other photo
shows the end of one smaller culvert where surface water is discharged. Is there an additional
location that hasn’t been sampled where wastewater from this SWMU group was discharged
from the end of a culvert?

2. SWMU 260

Based on the RFI Phase I Report, Laboratory Data Appendix (August, 2000), it appears that
there were three different sampling events associated with this SWMU: March, 1994,
September, 1996 and February, 1997. Three of the soil samples collected in February 1997
exceed the residential soil Regional Screening Level for Aroclor 1254.

These laboratory results aren’t discussed in the text of the RFI Phase I Report or Surface Water
Discharge SWMU Investigation Report. Do these samples represent the old dry well at building
M-53? Has any action been taken based on the detections of Aroclor 1254 (the samples are
described as Bldg. M-53, SWMU #260, point of discharge surface, 15 feet down-gradient
surface and 26 Feb-M53-1)?

3. SWMU 273

The four soil sample results reported in the RFI Phase I Report appear to indicate that soil
contamination associated with the surface water discharge isn’t a concern. However, analytical
results for the wastewater discharge associated with the SWMU (RFI Phase I Report, Volume 2,
Appendix 7.1) showed chloroform was detected at 193 ug/l. In addition, chloroform, perchlorate
and chlorinated solvents have been detected in the perched groundwater plume adjacent to
building M-585.

The soil gas surveys that were conducted west of building M-585 during the IRP investigation of
the french drain (SWMU #227) appear to be located in the same area as SWMU #273. These
surveys also indicated the presence of chlorinated solvents and chloroform. The Division
reviewed the IRP Investigation of the M-585 french drain site in 2012 and concluded that the site
had not been sufficiently characterized.

Is there information that demonstrates that the french drain and not the surface water discharge is
the source of the contamination detected in this area? How is the historical use of the two units
different? Should perchlorate be considered a Contaminant of Concern (COC) at SWMU 273?

SURFACE WATER DISCHARGE AND MINE PROSPECT SWMUs APPROVED
FOR NO FURTHER ACTION

Building SWMU# Description
1. M-14N 257 Surface Water Discharge
2. M-14S 270 Surface Water Discharge
3. M-14 345 Surface Water Discharge
4. M-33B 258 Surface Water Discharge
5. M-33C 413 Surface Water Discharge
6. M-53 259 Surface Water Discharge
7. M-67 261 Surface Water Discharge
8. M-67 433 Surface Water Discharge
9. M-72 263 Surface Water Discharge
10. M-641 264 Surface Water Discharge
11. S-501 266 Surface Water Discharge
12. A-9 267 Surface Water Discharge
13. M-593 274 Surface Water Discharge
14. Near M-46 225 Old Mine Prospect
15. Near M-46 226 Old Mine Prospect