DSHW-2018-002303 - 0901a068807cac43

Div of Waste Management
and Radiation Control
Re:
MAR052018 A
orhitatAflKP
March 5,2018
8200-FY18-007
Mr. Scott T. Anderson, Director
Utah Deparfnent of Environmental Quality
Division of Waste Management and Radiation Confrol
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84l14-4880
ATK Launch Systems Inc., EPA ID #urD009081357, semi-Arurual RFI progress
Report for September 2017 to March 2018.
Dear Mr. Anderson:
Attached is the ATK Launch Systems Inc. Promontory Facility Semi-Annual RFI
Progress Report for Septernber 2017 to March 2018.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
3344
I certifu under penalty of law that this document and all attachments were prepared under my
direction or superuision 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 systern, or those persons directly responsibll foigaitreri"g tie
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.
George E. Gooch
Manager, Environmental Services
ATK Launch Systerns
cc: Erica Gaddis, Division Director, Utah Division of Water Quality
OrbitalATK, lnc. o P.O. Box707, Brigham City, UT 84302 . 435-863-3511
SEMI-AI\NUAL RFI PROGRESS REPORT
September 1,2017 - March 1,2018
ATK Launch Systems Promontory Facilify
1. Description Of Work Completed
SWMU Investigations and Closures this Reporting Period
In a September 22,2017 letter the UDWMRC closed with no further action 8 SWMUs.
These SWMUs are associated with water discharge sites. 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 Launch Systerns (ATK) to the UDWMRC. In May 3d and
October 4h of 2Ol7 Jeff Vandel inspected a total of 23 more SWMUs. ATK submitted a
report in October 2017 withmore information on these SWMUs which were historic surface
water discharges. This additional information supported a no further action disposition for
these SWMUs.
SWMU 208
The Septernber 2017 Semi-annual report contained detailed information on SWMU# 208.
This is located at M-136 and was a shallow depression that was used to dispose of waste oils.
This pit was designated as SWMU #208.
In May 2017, with Division of Waste Managernent and Radiation Control representative Jeff
Vandel present, a back*roe was used to locate the SWMU by pulling back the soil until the
visible dark surface soil layer was found and the pit boundary was determined. Two
preliminary soil samples were collected at that time of an approximately 3 inch wide dark
soil layer from two locations and submitted for VOC and semi-volatile analysis. These
results show that in an assumed worst case by sampling the dark surface 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. The intent is to submit to UDWMRC a sampling
and analysis plan and investigate deeper locations in the pit
After this initial sampling a small plastic bag containing what appeared to be propellant was
found in the excavated surface soil. It was later determined to be inert. It is believed that it
was material rernaining from previous burning of the pit. However, an internal safety concern
was raised. As a safety precaution additional digging at the site was stopped until a protocol
could be developed to account for the possibility of live material being present. Although
this is unlikely, the project has been delayed until this can be resolved.
SWMU 553
The September 2017 Semi-annual report contained detailed information on the investigation
and results of SWMU# 553. This SWMU is related to a former photographic X-ray
development process at building M-l9A that historically discharged photographic fixer waste
water to a storm drainage channel. A separate report has been submitted to UDWMRC with
additional details and a request to conduct soil removal of low levels of Cr (VI) at a couple of
locations along the bank. Pending approval from the UDWMRC this remediation efflort will
be conducted. Figure 1 shows the results and location of the Cr (VI) soil sites along the
banks of the drainage channel.
Figure I
SWMU 553 Analytical Results
Values in ppm unless noted
Wetl P-10
The P-10 well associated with the M-585 SWMUs that previously has been dry was found to
contain water and was sampled in the spring and fall of 2017 semiannual event. However the
water level remains significantly lower than when the well was originally drilled. Results are
included in the Septernber groundwater 2077 semiannual report. This continues to support
the understanding that groundwater contamination related to these historic SWMUs is found
in perched aquafers in this area that have little or no corlmunication and that regional flow is
to the south west.
2.
3.
4.
5.
Summaries of All Findings
The summaries of the corrective action work conducted on SWMUs during this reporting
period are found in section 1 above.
Summaries of AII Problems or Potential Problems Encountered During the Reporting
Period
There were no significant problems encountered during the reporting period.
Actions Taken to Rectify Problems
No problerns were identified.
Projected Work for the Next Reporting Period
Monitoring the P-l0 well and the Plant 3 Well 3A treatment systern will be ongoing through
the next reporting period. Additional work at SWMU #553 atbuilding M-l9A and SWMU
#208 at M-l36 will be conducted. There will be continuing work with UDWMRC in
investigating and closing other SWMUs currently under review. A proposal to investigate 40
additional SWMUs during 2018 has been submitted to the UDWMRC.