DSHW-2017-007853 - 0901a068807570b2

Orbital ATK
September 13, 2017
8200-CY17-028 Biv of Waste Management
and Radiation Control
Mr. Scott T. Anderson, Director SEP 1 5 2017
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
P&HW-'2017-007353
Re: ATK Launch Systems Inc., EPA ID #UTD009081357, Semi-Annual RFI Progress
Report for March 2017 to September 2017.
Dear Mr. Anderson:
Attached is the ATK Launch Systems Inc. Promontory Facility Semi-Annual RFI
Progress Report for March 2017 to September 2017.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
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
infonnation, 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.
3344
S:
Kris H Blauer
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, 2017 - September 1, 2017
ATK Launch Systems Promontory Facility
1. Description Of Work Completed
SWMU Investigations and Closures this Reporting Period
In a March 10, 2017 letter the UDWMRC closed with no further action 15 SWMUs. These
SWMUs are associated with water discharge sites and old mining prospects. Jeff Vandel
with the UDWMRC has reviewed the RFI reports and inspected each of these sites. These
inspections were conducted in July of 2016. Photographs, descriptions and other historical
information were provided in reports from ATK to the UDWMRC. The letter also had
additional questions on 9 other SWMUs that had been investigated. ATK submitted more
information and responses to these questions in a May 1st 2017 letter. This additional
information supports a no further action disposition for these SWMUs.
SWMU 208
The area called M-136 at the ATK facility was historically used to dispose of waste materials
and is currently permitted to treat reactive wastes. One of the locations at M-136 was a
shallow depression called a pit that was used to dispose of waste oils. This pit was
designated as SWMU #208. The operation of the pit was approximately from the early
1960s to the early 1970s. The pit was also periodically burned as was customary for the
time period.
In August 1994 the oil pit was sampled as part of the site RFI program. A report of the
investigation was included in Thiokol Propulsion RCRA Facility Investigation Source and
Contamination Characterization Phase 1 SWMUs, August 2000 (2000 RFI report). The
conclusions of the study were that additional investigation was warranted.
In May 2017, after discussions with the Division, an effort was made to precisely locate the
pit that had been previously covered with about a foot of soil. With Division of Waste
Management and Radiation Control representative Jeff Vandel present, a backhoe was used
to pull back the soil until the visible dark surface soil layer was found and the pit boundary
was determined. Two soil samples were collected at that time of the approximately 3 inch
wide dark soil layer from two locations and submitted for VOC and semi-volatile analysis.
The results from these samples is found in Table 1. These results show that in this assumed
worst case dark layer of soil that there are two primary hazardous constituents,
hexachlorobutadiene and trichloroethylene. Of these two only hexachlorobutadiene had a
value that exceeds a residential RSL. Hexachlorobutadiene is a known constituent of
hydraulic oil and according to an ATSDR reference is readily broken down in soil.
Table 1
SWMU #208, Soil Sample Results (pg/Kg), May 2017
Constituents Center of Pit West end of Pit Residential RSLs and Notes
Hexachlorobutadiene 947 / 6100 3.2 1,200 ppb RSL
Trichloroethene 426 109 940 ppb RSL
Tetrachloroethene 31.8 3.4 J 24,000 ppb RSL
Benzo^.H.Operylene ND 810 J Combustion product
No RSL
Chrysene ND 530 J Combustion product
16,000 ppb RSL (110)
Chloroform 6.8 ND 320 ppb RSL
Benzene ND ND 1,200 ppb RSL
A sampling and analysis plan is being prepared to conduct an additional investigation of the
SWMU.
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. 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. During this
sampling period the M-53 environmental laboratory experienced breakdowns of the gas
chromatograph and the March sample went out of hold time. Samples were resent sent to
Chemtech Ford for VOC analysis however a labeling error resulted in no value being
reported for TCE from the second quarter sampling. The third quarter VOC sampling was
collected earlier in May to avoid similar issues. In addition, perchlorate removal in the two
septic tanks, M-201 and M-205, is being monitored for effectiveness. Samples showed some
perchlorate detections in M-201 or M-205. These samples are collected from the septic tanks
where biological treatment is in process and where conditions are present to remove
perchlorate. The detections and subsequent non-detects demonstrate treatment is taking
place. However, ATK is reevaluating the sampling rational and would like to discuss options
with UDWMRC. Ways to optimize removal conditions in the septic tanks are also being
determined.
Table 1
Plant 3 Well 3A Quarterly Treatment Summary Sept 2016 - June 2017
For Perchlorate (CIO4-) and Trichloroethylene (TCE)
Well 3A Carbon and Septic Tank Treatment Sampling Data (ug/L)
Date Influent Carbon Effluent Septic Tanks Flow (gal)
Totalizer reading
M-201 M-205
9/30/16 23.6 TCE
97 CIO4-
U TCE
93 CIO4-
102 27 38,209,000
12/14/16 NS U TCE
85 CIO4-
285 U 2,217*
3/31/17 29.2 TCE
81 CIO4-
NA TCE,
88 CIO4-
U 33 13,418
5/9/17 NS 0.4 TCE 15,478**
6/29/17 NS 86 CIO4-199 59
U = < 4 ppb detection limit
NS= Not Sampled
1 Laboratory Gas Chromatograph broke during hold time for TCE samples
^Totalizer was replaced - new meter installed
** Totalizer meter appears not be working due to carbon clogging, under repair
SWMU 553
In discussions with the Division it was detennined that SWMIJ 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. Using an approved plan from
the UDWMRC and with Jeff Vandel at the site, soil samples were collected within the
drainage channel. Samples were collected from the surface to three feet in depth and
screened in the field with an XRF. The highest values were then analyzed using standard
EPA laboratory methods. These samples showed that the values within the drainage channel
were below the EPA Regional Screening Level (RSLs) for residential exposure. The
constituents of concern were silver, cadmium, chromium and Cr (VI). However a change to
the sampling plan was made in the field and samples were also collected along the banks of
the channel which showed that two locations had higher concentrations of Cr (VI).
Additional samples were later collected to characterize these two sites. Based on these
results some soil removal will be needed at the two locations. A separate report has been
submitted to UDWMRC with additional details and a request to conduct the removal.
Figure 1 shows the results of the sampling at SWMU 553.
Figure 1
SWMU 553 Analytical Results
Values in ppm unless noted
i
Analysis Result
Background,Sample ^ '
Analysis Result
Analysts Result
Cd 0.7
Cr 78.5
Ag 204
C'(V!) ^2.6
Analysis Result
(dup)
Well P-10
The P-10 well associated with the M-585 SWMUs was found to contain water and was
sampled in the spring 2017 semiannual event. Results will be included in the September
groundwater 2017 semiannual report.
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. Additional work at SWMU #553 at building M-19A and SWMU
#201 at M-136 will be conducted. There will be continuing work with UDWMRC in
investigating and closing other SWMUs currently under review.