DSHW-2017-009334 - 0901a06880773862

Orbital ATK
Oct 27, 2017
8200-FY17-032
Mr. Scott T. Anderson, Director
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
Div of Waste Management
and Radiation Control
OCT 3 0 2017
Re:ATK Launch Systems Inc., Surface Water Discharge£WMU Investigation
Report 2, Promontory EPA ID #UTD009081357
Dear Mr. Anderson:
On May 3rd and October 4th of 2017 Jeff Vandel from your office visited the Promontory
facility to inspect and investigate a group of 22 Solid Waste Management Units
(SWMUs) primarily related to surface water discharges. 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.
Kris H. Blauer
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 Facility
Surface Water Discharge SWMUs
Investigation 2
rbitalATK
ATK Launch Systems, Inc.
Promontory Facility
October 2017
ATK Launch Systems
Investigation 2
Promontory, Utah
Surface Water Discharge SWMUs
October 2017
ATK Launch Systems Surface Water Discharge SWMUs Investigation 2
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 and subsurface water
discharges from various buildings. The 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. The subsurface discharges
were usually domestic septic drain fields mixed with industrial flows. In 1995 all of these
types of building discharges were connected to two biological waste water treatment
facilities.
On May 3, 2017 and October 4, 2017 Jeff Vandel with the UDWMRC visited the
Promontory Facility to inspect a group of 22 SWMUs that were primarily these building
water discharges. This report summarizes the findings of that investigation and inspection.
It proposes that these 22 SWMUs be designated as requiring no further action under the
RFI and therefore be dropped from the SWMU listing in the Post Closure Pennit. There
are several reasons for this conclusion which include:
1. The RFI 2000 report concluded that these surface water discharge SWMUs
required no further investigation as constituents were below risk based levels or
represented background levels. Comparison of these detected constitute
concentrations to the current (June 2017) Regional Screening Levels for
residential exposure showed that values are also below these screening
standards.
2. All building flows of this type were connected to waste water treatment
facilities in 1995. During the inspections no evidence of any releases from the
buildings were seen.
3. One SWMU investigated was an old open burning site where the investigation
demonstrated that no risk based screening levels were exceeded.
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 May 3 rd and October 4th
investigation is in Table 1.
Surface Water Discharge SWMUsATK Launch Systems
Investigation 2
Promontory, Utah October 2017
Table 1 SWMUs Included in this Report
Investigated on May 3rd and October 4th 2017
SWMU Building
1.660 North Plant
2.658 E-534
3.659,E-512
4.208 E-512
5.195 M-174
6.625 M-153
7.626 M-002-2
8.465 M-002
9.609 M-009-NE
10.621 M-055-W
11.627 M-002-3
12.615 M-057
13.234 I-010-S
14.630 M-072
15.483 M-197
16.673 M-120
16.628 M-019A
17.254 M-117
18.527 M-606
19.632 M-193-N
20.631 M-191-S
21.560 A-002
22.451 A-002
Description
Buildings Surface Discharge to Drainage Site
Sanitary Sewer Discharge Pond
Building Surface Discharge
Building Surface Discharge
Old Open Burning Site
Septic Drain field
Septic Drain field
Septic Drain field
Surface Discharge to Dry Well
Building Surface Discharge
Septic Drain field
Building Surface Discharge
Surface Discharge to Dry Well
Septic Drain field
Building Surface Discharge
Building Surface Discharge
Septic Drain field
Surface Discharge to Dry Well
Building Surface Discharge
Septic Drain field
Septic Drain field
Building Surface Discharge
Building Surface Discharge
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs
658
Building
E-534
Description
SWMU 658 is a historic
sanitary sewer discharge pond
on the North Plant. Operational
dates are 1965- 1995. It
received some industrial flows.
It was initially investigated as
part of the Air Force IRP and
dropped from further
investigation. It was
investigated again by ATK and
reported in the 2000 RFI
NFA Justification
There is no history of releases. Both the
IRP and the RFI investigation showed only
trace detections of constituents of concern
and recommended no further action. The
figure below shows the sampling locations.
The photo is from the April 12th, 2017
inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs
659, 208
Building
E-512
... f.
Building E-512 Surface
Water Discharge SWMUs
Description
SWMU 659 and 280 are
associated with a building
wastewater discharges from
the south west side of
building E-512. 280 was
the actual discharge and 659
is the ditch where the
discharged flowed to the
southwest. This was
investigated and reported in
the 1992 Air Force IRP
report.
NFA Justification
The RFI investigation did
not detect any hazardous
levels of constituents. The
attached figure shows the
IRP sample locations. Only
trace contamination was
detected in the surface water,
all soil was non-detect; NFA
was recommended. This
site was viewed during the
April 12, 2017 inspection.
Approx. Sampling Locations
Borings to 8 feet A
Soil and / or Surface water a
Google Earth
■
ffySM
Deep Boring
converted to
5
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWIM Us Building Description NFA Justification
195 M-174 SWMU 195 is an old open burning
area for reactive wastes. Use at the
site was sporadic and short term.
The area was graded and is now
near the large motor casting pits.
The RFI investigation as
reported in the 2000 RFI
Report, did not find constituents
above risk based levels and no
further action was
recommended. This site was
visited during the May 3, 2017
inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWIMUs Building Description NFA Justification
625 M-153 SWMU 625 is an old septic The RFI investigation as reported
drain field system consisting of in the 2000 RFI Report, analyzed
three fields used for that for volatile organics, semi-volatile
serviced a large portion of the organics and metals. No
main plant administration and constituents were above risk
manufacturing area.based levels and no further action
Operational dates are 1975 to was recommended. This site was
approximately 1995.visited during the Oct 4, 2017
inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs
626
Building
M-002-2
Description
SWMU 626 is second of
three septic drain fields
associated with the
laundry facility.
Operational dates are
approximately 1975 to
1989.
NFA Justification
The RFI investigation as reported in the
2000 RFI Report demonstrated no
constituents were above risk based levels
and no further action was recommended.
Contents of the tank were removed and
sent offsite for disposal. This site was
visited during the Oct 4, 2017 inspection.
■■■
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________SWMU 626, M-2 Laundry drain field
:;
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs Building Description NFA Justification
465 M-2 SWMU 465 is the first of three
drain fields associated with the
laundry facility. Operational dates
are 1962 to 1975. In 1975 the drain
field was switched to a new drain
field SWMU 626.
The RFI investigation as reported in
the 2000 RFI Report demonstrated no
constituents were above risk based
levels and no further action was
recommended. Contents of the tank
were removed and sent offsite for
disposal. This site was visited during
the Oct 4, 2017 inspection._________
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
swrvuis Building Description NFA Justification
627 M-2 SWMU 627 is the third of
three drain fields associated
with the laundry facility.
Operational dates are 1989 to
1995.
The RFI investigation as reported in the
2000 RFI Report demonstrated no
constituents were above risk based levels
and no further action was recommended.
Contents of the tank were removed and
sent offsite for disposal. This site was
visited during the Oct 4, 2017
inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWIM Us Building Description NFA Justification
615 M-57 SWMU 615 is a surface The RFI investigation as reported in the
building discharge generated 2000 RFI Report demonstrated that
by boiler condensate. It constituents were below risk based
flowed into the ditch in the levels and no further action was
photograph. Operational dates recommended. This site was visited
are approx. 1970 to 1995.during the Oct 4, 2017 inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs Building Description NFA Justification
234 1-10 South SWMU 234 is the location of a The RFI investigation as reported in the
former dry well. The flow was 2000 RFI Report. The excavation
from sinks in the building used removed constitutes to background
in washing glassware and levels. No further action was
equipment. In 1997 the drywell recommended. Contents of the dry well
was removed through a DSHW were sent offsite for disposal. This site
approved plan. Operational was visited during the Oct 4, 2017
dates are 1962 to 1995.inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs Building Description NFA Justification
630 M-72 SWMU 630 is the location of
an old septic drain field. It
received both domestic and
industrial flows. Operational
dates are 1962 to 1995.
The RFI investigation as reported in the
2000 RFI Report demonstrated that
constituents were within background
levels and no further action was
recommended. Contents of the tank were
removed and sent offsite for disposal.
This site was visited during the Oct 4,
2017 inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs Building Description NFA Justification
483 M-197 SWMU 483 was a small The RFI investigation as reported in the
surface discharge associated 2000 RFI Report demonstrated that
with cooling water from a constituents were within background
BAG. Operational dates are levels and no further action was
approximately 1989 to 1995.recommended. This site was visited
during the Oct 4, 2017 inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs Building Description NFA Justification
673 M-120 SWMU 483 was a small The RFI investigation as reported in the
surface discharge associated 2000 RFI Report demonstrated that
with cooling tower bleed off constituents were below risk based
water from building M-120.values and no further action was
Operational dates are recommended. This site was visited
approximately the 1960s to during the Oct 4, 2017 inspection.
1995.
ATK Launch Systems
Promontory, Utah
Water Discharge SWMU Investigation 7
October 2017
SWMIJs Buildiniz
628
Description
M-19A SWMU 628 is the location of
an old septic drain field. It
received both domestic and
industrial flows from floor
drains. Operational dates are
1962 to 1995.
NFA Justification
The RFI investigation as reported in the
2000 RFI Report demonstrated that
constituents were within background
levels and no further action was
recommended. Contents of the tank were
removed and sent offsite for disposal.
This site was visited during the Oct 4,
2017 inspection._____________________
l
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs Building Description NFA Justification
254 M-117 SWMU 254 is the location of The RFI investigation as reported in the
an old dry well associated with 2000 RFI Report demonstrated the
a boiler. It received boiler constituents were within background
blowdown, condensate flows.levels and no further action was
Operational dates are 1962 to recommended. This site was visited
1988.during the Oct 4, 2017 inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs Building Description NFA Justification
527 M-606 SWMU 527 is the location of
a former discharge from BAG
cooling units to a small ditch.
Operational dates are 1962 to
1995.
The RFI investigation as reported in the
2000 RFI Report demonstrated the
constituents were within background
levels and no further action was
recommended. This site was visited
during the Oct 4, 2017 inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs
631
BuildimI Description NFA Justification
M-191-S SWMU 631 is the location of
an old septic drain field. It
received both domestic and
industrial flows from the
building. Operational dates
are 1987 to 1995.
The RJFI investigation as reported in the
2000 RFI Report demonstrated that
constituents were within background
levels and no further action was
recommended. Contents of the tank
were removed and sent offsite for
disposal. This site was visited during
the Oct 4, 2017 inspection.
ATK Launch Systems Water Discharge SWMU Investigation 7
Promontory, Utah October 2017
SWMUs Building Description
451,590 A-2 SWMU 451 and 590 are the
location of two wastewater
flows that comingled in a
drainage ditch. 451 was a
handwashing sink in the
printing, copying area and 590
was rinse and developer
wastewater from a small
photo laboratory. Operational
dates are approx. 1970s to
1995.
NFA Justification
The RFI investigation as reported in the
2000 RFI Report demonstrated the
constituents were within background
levels and no further action was
recommended. The spent photo fixer at
this site was captured for silver
recycling. This site was visited during
the Oct 4, 2017 inspection.
mm
SWMU 451, 590 at A-2 historic flows to drainage ditch