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DSHW-2018-002312 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4284
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 21, 2018 Kris Blauer, Manager
Environmental Services
ATK Launch Systems – Promontory P.O. Box 707 Brigham City, UT 84302-0707
RE: Sampling Results Report and Proposed Corrective Action for SWMU #553
UTD009081357 Dear Mr. Blauer:
The Division of Waste Management and Radiation Control has completed its review of ATK’s
Sampling Results Report and Proposed Corrective Action for contaminated soil at SWMU #553 (photographic fixer discharge from Building M-19A). Review comments are enclosed. Please address the Division’s comments and submit a revised Report at your earliest convenience.
If you have any questions, please call Jeff Vandel at (801) 536-0257.
Sincerely,
Scott T. Anderson, Director Division of Waste Management and Radiation Control STA/JV/km
Enclosure: Comments on Sampling Results Report and Proposed Corrective Action for SWMU #553 c: Lloyd Berentzen, MBA, Health Officer, Bear River Health Department Grant Koford, EHS, Environmental Health Director, Bear River Health Department Amy Hensley, USEPA, Region 8
Paul Hancock, ATK Launch Systems
Division of Waste Management and Radiation Control Comments ATK – Promontory Sampling Results Report and Proposed Corrective Action for SWMU #553 Figure 1 SWMU #553 Soil Sample Results
The results of the TCLP sample that are shown in the figure are reported in units of ppb. Please revise the figure to show the results in units of mg/L so it is clear that they are TCLP results. Section 4.0 Proposed Corrective Action
The proposal to dilute contaminated soil excavated from the SWMU #553 site with clean soil until concentrations of hexavalent chromium do not exceed Regional Screening Levels for residential soil is not an acceptable method under RCRA. The Division recommends that ATK send the excavated soil off-site to
a permitted, lined solid waste landfill for disposal. Section 4.2 Confirmation Sampling and Analysis Please change the reference to the RFI Work Plan QAPP to the more recent March, 2017 QAPP in this
section and Sections 4.6 and 5.0. Section 4.3 Decontamination Procedures
It is stated in this section that wastewater generated during field decontamination will be collected and disposed of properly. Please describe how wastewater will be properly disposed of.