DSHW-2018-003325 - 0901a068807ec7d5

Ortita
April 12, 2018
8200-FY17-019
Scott T. Anderson, Director
Department of Environmental Quality
Division of Waste Management and Radiation Control
ATTN: Jeff Vandel
P.O. Box 144880
195 North 1950 West
Salt Lake City, Utah 84114-4880
.1)3014-Z01S - oo33z5
RE: Revised Sampling Results Report and Proposed Corrective Action Solid Waste
Management Unit # 553, ATK Launch Systems Inc. - Promontory Facility, EPA ID#
UTD009081357
Dear Mr. Anderson,
In a March 21, 2018 letter from your office (DSHW-2018-002312), comments were provided on
the Sampling Results Report and Proposed Corrective Action Plan for Solid Waste
Management Unit #553. Included with this letter are responses to those comments and a
revised report.
If you have questions, or need additional information, please contact Paul Hancock at (435)
863-3344.
Sincerely,
Kris H. Blauer, Manager,
Environmental Services
Orbital ATK, Inc. • P.O. Box 707 Brigham City, Utah 84321 • [phone]
ATK Launch Systems Response to Division of Waste Management and Radiation Control
Comments on 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.
Response: The figure has been revised.
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.
Response: The excavated soil with hexavalent chromium exceeding the regional screening
values for residential soil will be sent to an off-site permitted, lined landfill for disposal.
ATK however would like to discuss this as a possible option with the Division in future soil
remediation situations where the soil is not regulated as RCRA hazardous.
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.
Response: This reference has been changed.
Section 4.3 Decontamination Procedures
It is stated in this section that wastewater generated during the filed decontamination will be
collected and disposed of properly. Please describe how wastewater will be properly disposed
of.
Response: The report has been niudified to state that the decontamination wastewater will be
properly disposed by taking it to the on-site wastewater treatment facility M-705.
Orbital ATK, inc. • P.O. Box 707 Brigham City, Utah 84321 • [phone]
rural AM
Sampling Results Report and Proposed
Corrective Action for
Solid Waste Management Unit 553
Promontory Facility
Prepared for:
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
Prepared by:
ATK Launch Systems Inc.
UTD009081357
Revised April 2018
Orbital A SAMPLING RESULTS REPORT
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems

v
TABLE OF CONTENTS
1.0 INTRODUCTION 2
1.1 Background 2
2.0 FIELD SAMPLING ACTIVITY AND CHANGES 2
3.0 SAMPLING RESULTS 3
4.0 PROPOSED CORRECTIVE ACTION 6
4.1 Corrective Action Process 7
4.2 Confirmation Sampling and Analysis 7
4.3 Decontamination Procedures 7
4.4 Sampling Handling and Custody 8
4.6 Quality Control Samples 8
4.6.1 Field Quality Control Samples 8
4.6.2 Laboratory Quality Control Samples 8
4.7 Data Management 9
5.0 DATA VALIDATION AND USABILITY 9
5.1 Data Review, Verification, and Validation 9
FIGURES
FIGURE 1 SWMU #553 Soil Sample Results
FIGURE 2 SWMU #553 Characterization of 50' Location
FIGURE 3 SWMU #553 Proposed Excavation Areas
ATTACHMENTS
Attachment A Analytical Data Sheets
Attachment B XRF Readings
Attachment C Field Notes
1
tal A K SAMPLING RESULTS REPORT
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
1.0 INTRODUCTION
A Sampling and Analysis Plan (SAP) was developed in response to a request by the Utah
Division of Waste Management and Radiation Control (the Division) to resample a Solid Waste
Management Unit (SWMU) designated as #553. This is a historic photographic fixer discharge
area at the Promontory ATK Launch System Inc. (ATK) facility. The Division approved the
plan in an August 6, 2016 letter. The sampling was conducted on September 16, 2016 with
Division representative Jeff Vandel at the site.
1.1 BACKGROUND
The building called M-19A at the ATK facility was historically used to develop X-ray
photographs from the X-ray of solid rocket motors such as Minute Man. The spent photographic
fixer solution was discharged to a dry well which could overflow through a pipe into a storrn
drainage channel designated as SWMU #553.
In October 1993 the storrn drainage channel was sampled using a Division approved plan 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). This sampling is supplemental to information contained in the 2000 RFI
report. Although the 2000 RFI report showed constituent values that were below risk based
levels, the sampling indicated an increasing trend in silver concentrations with distance from the
discharge site. The new sarnpling included greater distances from the discharge point and
greater depths. Additional details can be found in the May 2016 SAP.
2.0 FIELD SAMPLING ACTIVITIES AND CHANGES
The sampling within the strearn channel was completed at the depths and locations specified in
the SAP. However, on the day of sampling, it was noted that a visual difference was seen in the
soil along the west bank of the drainage stream at the first sampling point called the 50 foot
location. This difference was characterized by a dark coloration band. Using the hand held
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SAMPLING RESULTS REPORT
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
XRF it was determined that this narrow zone of soil was highest in silver and chromium values.
With Jeff Vandel's approval, investigation of the stream bank was included with the SAP. An
additional deviation from the SAP at the request of Jeff Vandel was the inclusion of Cr (VI)
analysis of samples that indicated high chromium content when using the XRF. There were two
sampling sites, the 50 ft. and 250 ft. where the XRF indicated high levels for the constituents of
concern. Both of these were along the west bank and associated with the distinctive dark color
band. Other sites along the bank were tested with the XRF and none were found that indicated
higher concentrations, nor were there any visual indications of the darker soil. Due to this
expanded investigation, many XRF readings were taken beyond what was noted in the field
book, therefore the location of some readings in the XRF files are approximate.
Based on the results of the initial sampling more samples were later collected in the two areas
along the bank that indicated higher metals values, specifically for Cr (VI). This sampling
helped to better define the extent of the higher values. These sample results are also included in
this report.
3.0 SAMPLE RESULTS
Figure 1 shows the sample results of both the initial and follow-up sampling events. Only Cr
(VI) was found at concentrations that would exceed residential RSLs. These higher Cr (VI)
values were found at two locations along the west bank of the drainage channel previously
described, at the 50 foot and at 250 feet. The 50 foot West Bank location had the highest values
for all constituents. The higher Cr (VI) values correlated to higher total chromium levels as
would be expected. The duplicate sample to "250", called "250A", was very comparable
indicating good laboratory reproducibility. The background samples matched other 2000 RFI
related background soil levels for metals with the exception of a higher value for silver. Figure 2
shows the sample results of the additional sampling conducted on the west bank at the 50 foot
location. This shows that the high Cr (VI) levels are primarily limited to a narrow band
approximately 1 foot wide and approximately 9 feet in length covered with approximately 2-3
feet of soil overburden. Closer examination of the darker band of soil shows that it appears to
contain ash with burnt twigs and grass. The other Cr (VI) samples in the location were less than
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SAMPLING RESULTS REPORT
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
background. At the 250 -300 foot west bank location the darker band of soil was also visible
although less pronounced, and the Cr (VI) value was lower at 2.6 ppm. The TCLP sample
collected at the 50 foot west bank location with the highest total cadmium, chromium and silver
analytical values were found to be far below TCLP hazardous waste levels. Comparison of the
field XRF data with the actual laboratory analytical results showed that in this situation the XRF
was only qualitative or an indicator of the actual values for the constituents of concern due to
possible interferences or calibration problems. The analytical data sheets are included in
Attachment A. A copy of the excel file with the XRF readings for silver chromium and
cadmium is in Attachment B. A copy of the field notes is found in Attachment C.
Figure 1
SWMU #553, Soil Sample Results, Values in mg/Kg
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Orbital AT'tl>
SAMPLING RESULTS REPORT
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
SI Page
Figure 2
SWMU#553
Characterization of 50 ft. Location -West Bank
Revised April 2018
Orbital Ani}
4.0
SAMPLING RESULTS REPORT
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
PROPOSED CORRECTIVE ACTION
A proposed corrective action for the high levels of Cr (VI) includes excavation of the narrow soil
band from the two areas. The excavated soil will then be placed into a roll off and transported to
a lined solid waste landfill for disposal. This action is allowed since TCLP testing of the highest
metal concentrations found at the site were well below any levels for a hazardous waste
designation. In future similar situations and where it makes economic sense, ATK would
propose further discussions with the Division to conduct mixing of non-hazardous soils. The
two proposed excavation areas are shown in Figure 3.
Figure 3
SWMU 553 Proposed Excavation Areas
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Orbital A K SAMPLING RESULTS REPORT
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems

4.1 CORRECTIVE ACTION PROCESS
The corrective action process would use a backhoe to remove any soil overburden and then
visually remove the higher concentration band of Cr (VI) soil. It is believed that the dark color
characterizing this high level zone of Cr (VI) will be visible as the soil is excavated. Post
excavation confirmation sampling for Cr (VI) will be conducted to assure removal. As the
contaminated soil is removed it will be placed into a steel roll off shipping container.

4.2 CONFIRMATION SAMPLING AND ANALYSIS
Composite samples will be collected from the excavated areas at a depth of two to three inches
using a clean stainless steel scoop.
Soil will be placed into a pre-cleaned polyethylene bowl. Plant material, roots, and large rocks
will be manually removed and the sample will be mixed prior to placing into a 4-oz wide-mouth
glass jar with a Teflon© lined lid.
A11 information collected during the field investigation will be maintained in a field log. Field
documentation will consist of the information provided in the Orbital ATK 2017 QAPP.
The samples will be assigned analysis for Cr (VI) using EPA method 7199. Analysis will be
conducted by ATK Launch Systems Environmental Laboratory at the Promontory facility, a
laboratory certified in the State of Utah.

4.3 DECONTAMINATION PROCEDURES
Prior to and following the collection of each sample, any sampling equipment coming in contact
with the soil will be cleaned with a non-phosphate detergent (e.g., Liquinoxt), rinsed with tap
water, and final rinsed with distilled water. Wastewater generated during field decontamination
will be collected and disposed of properly at the M-705 on-site waste water treatment facility.

4.4 SAMPLE HANDLING AND CUSTODY
Sample containers will consist of glass jars, with Teflon-lined lids. Only decontaminated
stainless steel, polyethylene and/or clean disposable gloves will contact a sample during
placement in a bottle. Disposable gloves will be worn at all times during sample handling to
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Promontory Facility ATK Launch Systems
prevent cross contamination between samples and skin contact with potential contaminants.
Gloves will be disposed of between each sample.
Sample bottles will be placed on ice in waterproof cooler chests for delivery to the analytical
laboratory. Sample labels will be used to identify the samples. These labels will be sufficiently
durable to remain legible when wet and will be marked with indelible ink and affixed to the
sample containers.
A chain-of-custody form will be completed to trace sample possession from the time of
collection through laboratory analysis. One chain-of-custody form will accompany the cooler
container of samples. While the samples are in the custody of the collector, they will not be left
unattended at locations where the samples may be tampered with. The analyses to be performed
will be indicated on the chain-of-custody form, including the quantity and types of containers
that comprise each sample. The shipping container will then be securely closed and delivered to
the analytical laboratory.
All field data will be recorded in a log book. Information to be recorded in the log book will
include the date, time and depth of sample collection, descriptions of the soils encountered at
each sampling location, reasons for field decisions concerning sample intervals, reasons for
departures from prior plans, general observations, etc.
4.5 Field Quality Control Samples
Field QC samples will be analyzed for the same sample constituents as the samples-of-record.
QC samples will consist of collecting field duplicates as a minimum of 10% of the total samples.
4.6 Laboratory Quality Control
Internal laboratory quality control checks will be performed in accordance with the Orbital ATK
March, 2017 QAPP.
4.7 DATA MANAGEMENT
Field data will be recorded in a field log book. These data will be maintained in project files for
future reference. Hard copies of laboratory data will be maintained in project files. Electronic
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Orr tal A It SAMPLING RESULTS REPORT
Solid Waste Management Unit 553 Resample
Promontory Facility ATK Launch Systems
data will be stored indefinitely. Hard-copy data will be maintained for a period of at least 3
years.
5.0 DATA REVIEW, VERIFICATION, AND VALIDATION
Data review, verification, and validation will occur as outlined in the Orbital ATK 2017 QAPP.
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