DSHW-2018-001304 - 0901a068807b90fb

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DSHW-2018-001304 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
February 26, 2018
Kris Blauer, Manager
Environmental Services ATK Launch Systems – Promontory P.O. Box 707 Brigham City, UT 84302-0707
RE: Soil and Groundwater Monitoring Plans for Evaluating the M-136 and M-225 Thermal Treatment Units ATK Launch Systems – Promontory Facility UTD009081357
Dear Mr. Blauer:
The Division of Waste Management and Radiation Control has completed its review of ATK’s Soil and Groundwater Monitoring Plans for evaluating the impacts from operations at the M-136 and M-225 Thermal Treatment Units. These plans were submitted to the Division in December 2016 in accordance
with Permit Conditions IV.K.1. and IV.K.4. Enclosed are comments and questions regarding the Soil and Groundwater Monitoring Plans. Please address these issues and submit revised plans within 60 days of receipt of this letter in accordance with Permit Condition IV.K.2.

If you have any questions, please call Jeff Vandel at [phone]. Sincerely,

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

(Over)

STA/JV/km
Enclosure: Comments on the Soil Monitoring Plan for the Assessment of Potential Impacts
from Open Burning Operations c: Blair Palmer, ATK Launch Systems Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Department
Amy Hensley, USEPA, Region 8

Page 1 of 2
Division of Waste Management and Radiation Control Comments ATK – Promontory Soil Monitoring Plan for the Assessment of Potential Impacts from Open Burning Operations Section 1.2 Human Health Risk Assessment The point of maximum deposition associated with the M-136 Burning Grounds is discussed in this section. It appears that the Soil Monitoring Plan (SMP) doesn’t include monitoring of the M-225
Burning Grounds. If so, please explain in the SMP why ATK does not plan on monitoring at M-225.
Section 4.6.2 Laboratory Quality Control Would the March, 2017 QAPP apply to the soil samples that will be collected? If so, please change the reference in this Section from the 1993 RFI QAPP to the March, 2017 QAPP.
Section 5.0 Decision Statement – Background and Regional Screening Levels It is stated in the first sentence of this Section that, in accordance with Module IV.K., the decision rule for the soil monitoring program will involve evaluating soil data based on the modeling conducted during the HHRA.

Based on the Summary of Air Dispersion Factors in Attachment 5 of the July, 2014 Air Dispersion Modeling Report Addendum, it appears that deposition of particulate and gas is expected to be greater at the on-site maximum impact area than the off-site maximum impact area. The Division agrees that the off-site maximum impact area should be sampled as proposed. However, please consider sampling the on-site maximum impact area as well to see what kind of impact, if any, the M-136 Burn Ground
operations have had at the area the model has predicted to be the maximum deposition area. Please revise the SMP as needed if sampling of this area is added. Table 2. Laboratory Detection Limits and Regional Screening Levels for the Soil Analytes
It is stated at the bottom of Table 2 that the “RSLs for Dioxin/Furans were developed by multiplying the
RSL for 2,3,7,8-TCDD by the TEQs for the individual congeners.”
EPA RSLD/F = RSL2,3,7,8-TCDD x TEQcongener
Please clarify whether the multiplying factor used is TEQ (toxicity equivalence) or TEF (toxicity equivalence factor). If the multiplying factor is TEF rather than TEQ, please revise Table 2 to include
the appropriate congener TEF used and the corrected developed EPA RSL values.
If the procedure used in the development of the RSLs for dioxins/furans is not correctly stated as above, please clarify the procedure used to develop the RSLs for the dioxins/furans in Table 2 and provide a sample calculation.

Page 2 of 2
ATK – Promontory Groundwater Monitoring Plan for the Assessment of Potential Impacts from Open Burning Operations
Section 4.3.1 Additional Groundwater Modeling It is stated in this section that additional monitoring data from the M-136 wells may be needed to conduct the groundwater modeling that has been proposed. Has it been determined if sufficient data
exists for this area? Please revise this section as appropriate. Section 4.4 Monitoring Frequency and Reporting It is stated in this section that a report of the proposed groundwater modeling for the M-136 wells will
be provided in the March 2018 Semi-annual Groundwater Monitoring Report. Please revise the
monitoring plan to propose a new date for the submittal of the report (due to our delay in reviewing the
Groundwater Monitoring Plan).