DSHW-2018-004121 - 0901a06880813c53

Orbital ATK
April 30, 2018
8200-FY18-015
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 N. 1950 W.
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Div of \Nate Manaprnent
and Radiation Control
MAY -8 2818
7)14/20/0-001HZ(
Re: ATK Launch Systems-Promontory EPA ID number UTD009081357
Soil Monitoring Plan, Groundwater Monitoring Plan Response to Comments
Dear Mr. Anderson:
Enclosed are updated Soil and Groundwater Monitoring Plans and responses to the "Divisions"
comments that ATK Launch Systems received in March 2018. These documents are in support
of the Human Health Risk Assessment (HHRA) for the Open Burning and Open Detonation
Treatment Units at the ATK Launch Systems Promontory Facility.
Please contact me if you have any questions concerning this report. My telephone number is
[phone] or you can contact Blair Palmer at [phone].
Sincerely
Kris H. Blauer
Manager, Environmental Services
ATK Launch Systems Inc.
cc: Jeff Vandel
Orbital ATK, inc. • 9160 N. Hwy 83, Promontory, UT 84307 • 435-863-3511
Geosyntecl>
consultants
engineers 1 scientists 1 innovators
RESPONSE TO COMMENTS
OrbitalATK
Promontory Facility
Brigham City, UT
Prepared by
Geosyntec Consultants, Inc.
1376 Miners Dr. Suite 108
Lafayette, CO 80026
Project Number DE0188
April 2018
e
Soil and Groundwater Monitoring Plans Response to Comments
OrbitalATK Promontory
model has predicted to be the maximum deposition area. Please revise the SMP as needed if
sampling of this area is added.
Response to Comment 3: Since onsite receptors evaluated in the OB/OD HHRA are only
exposed through the inhalation pathway, the Lakes model did not estimate soil concentrations for
on-site areas, and there is no complete exposure pathway for ingestion of soil on-site. Without a
complete exposure pathway, there is no reason to collect on-site soil samples.
The modeled soil concentrations for the point of maximum deposition off-site were presented in
the SMP and they represent the highest soil concentrations of all of the off-site receptors. This
scenario represents the highest exposure to a future potential farmer even though the point of
maximum deposition is not considered a likely location for a future resident to build a home. The
SMP will be revised to better explain this issue.
4. 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 RSLo/F = RSL2,3,7,8-TCDD X TEO .c.congener
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.
Response to Comment 4: The factor used was the TEF (toxicity equivalence factor) for
developing the EPA RSL values for the Dioxinifuran compounds. However, the footnote for
Table 2 incorrectly stated that the factor was multiplied by the RSL for 2,3,7,8-TCDD, and it
incorrectly included the TEQ. The correct equation is as follows:
RSL 2,3,7,8 TCDD
TEFcongener
The text in Section 5 of the SMP will be revised to include the above equation and a discussion
of how the congener-specific RSLs were calculated. Table 2 will be revised to include the
congener-specific TEF factors used to derive the final RSL values.
Response to DSHW-2018-Comments SLGW Monitoring Plan.docx Page 2
J
RSLcongener =
ATK — Promontory Groundwater Monitoring Plan for the Assessment of
Potential Impacts from Open Burning Operations
Division Comments:
Section 4.2.1 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.
ATK Response:
The latest data set from M-136 wells is being reviewed by the modeler at Earth Fax Engineering.
Additional samples have were collected in 2017 since the plan was submitted in December 2016 with
more sampling planned for 2018. It is believed that additional samples will be beneficial in the modeling
effort.
Section 4.4 Monitoring Frequency and Reporting
Is it 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).
ATK Response:
Currently we believe that additional time to provide more data to improve the modeling projections is
warranted. ATK plans to use data from the 2018 and 2019 groundwater sampling events for the model.
This would then be a submittal in March of 2020 of the 2019 Semi-annual Groundwater Monitoring
report. If this changes ATK will provide an update to the Division in the 2018 Semi Annual Report.
Orbital ATI(
Soil Monitoring Plan
Hazardous Waste Storage and Subpart X Treatment Permit
SOIL MONITORING PLAN
Promontory Hazardous Waste Storage and
Subpart X Treatment Permit
Prepared for:
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
Prepared by:
OrbitalATK Launch Systems Inc.
April 2018
Orbita AM
Soil Monitoring Plan
Hazardous Waste Storage and Subpart X Treatment Permit
TABLE OF CONTENTS
Table of Contents
1.o INTRODUCTION 1
1.1 General Description 1
1.2 Human Health Risk Assessment 2
1.3 SMP Priorities 4
2.0 DATA QUALITY OBJECTIVES 5
3.0 SOIL MONITORING LOCATIONS, NUMBER AND ANALYTES 7
3.1 Sample Locations and Number' 7
3.2 Sampling Frequency 8
3.3 Background Soil Sampling 8
3.3.1 Metals Data — Chromium and Nickel 9
3.3.2 PAH Data 9
3.3.3 Dioxin/Furan Data 9
3.4 Creation of Doxins/Furans from Anthropogenic Sources 9
4.0 TECHNICAL SAMPLING AND ANALYSIS PLAN 11
4.1 Sampling Locations 11
4.2 Soil Sampling Methods 11
4.3 Sampling Handling Methods 11
• 4.4 Equipment Decontamination 12
4.5 Analytical Methods and Procedures3 13
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4.6 Quality Control/Quality Assurance Samples 13

4.6.1 Field Quality Control Samples 13

4.6.2 Laboratory Quality Control 14
5.0 DECISION STATEMENT — BACKGROUND AND REGIONAL SCREENING LEVELS 15
6.0 REFERENCES 17
TABLES
Table 1. Risk Drivers for the Adult Farmer at the Location of Maximum Risk 19
Table 2. Laboratory Detection Limits and Regional Screening Levels for the Soil Analytes 20
Table 3. Background Metals in Soil - 2016 Sampling Event 21
FIGURES
Figure 1 — Location of Burning Grounds and Maximum Off-Site Risk
Figure 2 — Proposed Soil Sampling Locations
Figure 3 — 2016 Background Soil Sample Locations
APPENDICES
Appendix A — ProUCL Output
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LIST OF ACRONYMS AND ABBREVIATIONS
95UCL 95% Upper Confidence Limit
AERMOD American Meteorological Society Gaussian Air Dispersion Modeling
COPC Chemical of Potential Concern
• Cr(VI) Hexavalent chromium
D/F Dioxins/Furans
DQO Data Quality Objectives
EPA Environmental Protection Agency
ERA Ecological Risk Assessment
HHRA Human Health Risk Assessment
HHRAP Human Health Risk Assessment Protocol Guidance for Incineration
ISC-3 Industrial Source Complex-3
mg/kg Milligrams per kilogram
NAAQS National Ambient Air Quality Standard
OB Open Burning
OD Open Detonation
OBODM Open Burn/Open Detonation Model
PAHs Polynuclear Aromatic Hydrocarbons
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QA Quality Assurance
QC Quality Control
RCRA Resource Conservation and Recovery Act
RSLs Regional Screening Levels
SIM Selective Ion Monitoring
SMP Soil Monitoring Plan
TEF Toxic Equivalency Factor
TSLs Toxic Screening Levels
UDWMRC Utah Division of Waste Management and Radiation Control
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1.0 INTRODUCTION
This Soil Monitoring Plan (SMP) has been developed to comply with Module IV.K.1 of the
Hazardous Waste Storage and Subpart X Permit ("the Permit") issued to OrbitalATK Launch
Systems Inc. (OrbitalATK). The Permit is issued for thermal treatment operations conducted on the
Promontory site, which is owned by OrbitalATK. The Promontory facility has a Subpart X thermal
treatment unit that is operated as an open burn / open detonation facility (OBOD).
This SMP provides a plan to monitor the potential impacts of the Promontory Burning Grounds
operations on soils within and beyond the Promontory facility, as identified by the air dispersion and
deposition model of the Human Health Risk Assessment (HHRA). Risks to human health are
evaluated using the data generated out of the air quality modeling for the HHRA, and an application
for an Ecological Risk Assessment (ERA) Waiver has been submitted to the Utah Division of Waste
Management and Radiation Control (UDWMRC). These risk assessments will be supported by data
collected under this SMP.
1.1 GENERAL DESCRIPTION
The Burning Grounds are located as shown on Figure 1. M-136 is situated between the Northern
Manufacturing Building and the Administrative Buildings and Central Manufacturing Building,
while M-225 is located in an up-land area south and east of the Central manufacturing area.
M-136 consists of 14 burn stations. Burn stations 1 through 12 are clustered within 100 meters of
each other. Six of the 12 stations are located closest to the western property line and six are further
from the boundary. M-225 consists of 4 burn stations. Burn Stations 1 through 4 are clustered within
100 meters, the OD pit is located in the center of the 4 burn stations.
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OrbitalATK processes both Class 1.1 and Class 1.3 propellant waste. A maximum of 10,065,000
pounds of reactive waste may be burned in one year. Under the permit, OBOD operations are
constrained to burn between the hours of 9:00 am and 6:00 prn Mountain Time, and only when the
surface wind speed is greater than three miles per hour and less than 15 miles per hour. In addition
the Clearing Index rnust be greater than 500, unless approved by agreement with Utah Division of
Air Quality, Box Elder County and the Director.
1.2 HUMAN HEALTH RISK ASSESSMENT
A HHRA was conducted in support of the Promontory Subpart X permit (Geosyntec, 2016) and
approved by the UDWMRC in June 2016. A number of different receptors were evaluated in this
HHRA process, including an on-site worker, off-site residents and off-site farmer families. All
chemicals measured (detected and not detected) from emissions tests conducted with Class 1.1 and
1.3 propellant wastes were evaluated in the HHRA. 209 chemicals were considered quantitatively
in the HHRA for the burning grounds at Promontory. The risks evaluated included acute (short-
term) inhalation hazards and risks, and chronic (long-term) risks and hazards for a range of exposure
pathways.
CB&I conducted the air quality modeling for the Promontory treatment units in August 2014. The
air quality model was developed by them based on some initial air quality modeling conducted by
TetraTech and combined an OBOD Model (OBODM) with the Industrial Source Complex (ISC-3)
American Meteorological Society Gaussian Air Dispersion Modeling (AERMOD) to produce an
improved OBODM/AERMOD hybrid model that is believed to more accurately predict air chemical
transport and dispersion for this type of facility. The output files from this model became the source
files for a Human Health Risk Assessment model developed by Lakes Environmental and based on
the USEPA's Human Health Risk Assessment Guidance for Incineration. The HHRA software
calculated risks and hazards for both short-term and long-term exposure hazard and risk calculations.
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The model provides short-term ambient air concentration data. The highest air concentrations for
the National Ambient Air Quality Standard (NAAQS) compounds from one source are used to
evaluate ATK's air concentrations compared with the NAAQSs, which are not exceeded by ATK.
These concentrations were also compared with Utah Toxic Screening Levels (TSLs), and these were
not exceeded.
The air quality model was approved by the Utah Department of Environmental Quality and estimated
both air dispersion to provide ambient air COPC concentrations and particle deposition onto soil.
The Lakes model also estimated soil COPC concentrations based on deposition over time, and soil
mixing. Deposition was calculated at grid nodes across the site and the soil concentrations were
modeled at the point of maximum deposition, as shown in Table 2 and Figure 2. The air and risk
modeling were conducted assuming burning grounds M-136 and M-225 were simultaneously active.
Therefore, there is not a separate soil sampling location for each of the burning grounds. The point
of maximum off-site impact represents a location with deposition from both M-136 and M-225.
Separate models were not prepared for M-136 and M-225, however, M-136 processes a higher mass
of material than M-225 and M-136 is therefore likely to contribute more to the point of off-site
deposition and the current proposed sampling location would represent the best location for
evaluating potential deposition onto soil.
The exposure pathways included in the HHRA were inhalation, the inadvertent ingestion of soil, the
ingestion of produce, beef, and milk; and ingestion of human milk by infants. The residential
receptors were assumed to reside at the location of maximum off-site impact. This location
represents the highest risks to a future potential receptor with a complete exposure pathway for soil
exposure pathways. On-site receptors are only exposed via inhalation, and therefore do not have a
complete exposure pathway for soil exposure. Subsistence farmer scenarios were evaluated
assuming the food was grown in the areas of maximum deposition, which is located on a steep
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hillside where agricultural use of this type would not be possible. When all exposure pathways for
the subsistence farmer were added together, the summed risk was less than one in one million ( l x 10-
6). Non-cancer hazards for all receptors were less than the target hazard index of one (1.0).
The constituents exhibiting a combination of the highest bioaccumulative potential and the highest
toxicity were those that resulted in the highest risk, namely hexavalent chromium (Cr(VI)),
dibenzodioxins/dibenzofurans (D/Fs) and polynuclear aromatic hydrocarbons (PAHs). Table 1
summarizes the risk drivers and the calculated chronic risk associated with the hypothetical adult
farmer scenario at the location of maximum risk. Based on the calculated risk of the constituents,
Cr(VI), selected D/Fs and selected PAHs were established as the contaminants of potential concern
(COPC) that would drive the HHRA.
1.3 SMP PRIORITIES
This SMP was developed based on the information from the HHRA including:
• The source locations and volumes processed,
• The by-products identified in the test-burn process from the materials being processed,
• The air quality model,
• The deposition of particulates under site-specific conditions and
• Soil mixing calculations
The HHRA process and associated risk drivers identify the off-site receptor locations where
potential soil COPC concentrations would be at their highest and these locations are selected to
represent locations where for soil sampling/monitoring would capture the highest risks.
The HHRA process predicated that soil concentrations would be very low, and selecting the location
where the model predicts they would be the highest provides the greatest possibility of detecting
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COPCs in the environment that might be derived from the burning grounds, although this SMP will
show that, 1) even though the locations where the highest predicated COPCs are being sampled, the
HHRA predicts the COPC concentrations will be below the method detection limits for these
chemicals in soil, and 2) the concentrations of predicted COPCs are at or below concentrations found
in background soil samples collected from the area.
PAHs and D/Fs are by-products of all combustion processes, and may be derived not only from
OrbitalATK but from anthropogenic sources including:
• Historical combustion from existing communities,
• Historical combustion from recent residential communities,
• Historical combustion from agricultural burning (crops waste and barrel burning),
• Historical and current combustion processes (automobiles, wood burning fires, other
industrial combustion sources, etc.).
Nickel and Cr(VI) are also present in background soil and may confound the data related to current
releases from the Promontory burning grounds and natural background.
These factors should be taken into consideration when reviewing the results from this SMP.
2.0 DATA QUALITY OBJECTIVES
Throughout the SMP, superscripts are placed to associate certain portions with the EPA Data Quality
Objective Process (DQO), EPA QA/G4, 2006. There are seven steps in the DQO process, of which
five are generally applicable to the SMP at this time.
I. Define the problem that necessitates the study. Describe the problem, develop a conceptual
model of the environmental hazard to be investigated, and identify the general type of data
needed.
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2. Identify the goals of the study; identify the key questions that the study attempts to address,
along with alternative actions or outcomes that may result to develop a decision statement.
3. Identify the information inputs to determine the types and sources of information needed
to resolve the decision statement or produce the desired estimates; whether new data
collection is necessary; and whether appropriate sampling and analysis methodology exists
to properly measure environmental characteristics for addressing the problem.
4. Define the boundaries of the study by defining the sampling unit as an area, volume, or
mass that may be selected from the target population. When defining sampling units, you
should ensure that the sampling units are mutually exclusive (i.e., they do not overlap), and
are collectively exhaustive (i.e., the sum of all sampling units covers the entire target
• population). Practical constraints that could interfere with sampling should also be
identified in this step. A practical constraint is any hindrance or obstacle (such as fences,
property access, water bodies) that may interfere with collecting a complete data set.
5. Develop an approach to guide how to analyze the study results, draw conclusions from
the data, and develop a decision rule.
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3.0 SOIL MONITORING LOCATIONS, NUMBER AND ANALYTES
The objective of this SMP is to collect soil data that might be used to support the results of the
Promontory HHRA, and to provide additional background data.' [Superscripts correspond to the
steps associated with the EPA Data Quality Objectives. These steps are summarized in Section 2.0].
The data collected during this SMP will be evaluated and compared first to the modeled maximum
soil concentrations resulting from the HHRA, for the point of maximum risk.2 This will be
accomplished through the collection of surface soil samples in the area of highest predicted particle
deposition predicted by the HHRA air quality model, and at background locations.
The collection of surface soil samples will be based on the assumption that aerial deposition would
occur over the specified area at Promontory based on the approved HHRA and the permitted
operation of M-136 and M-225.
3.1 SAMPLE LOCATIONS AND NUMBER4
Figure 1 shows the off-site location of maximum risk identified in the HHRA. It is located west of
M-136 on a hill that has difficult access. The model used in the HHRA was based on a 100-meter
grid spacing within the first 3 kilometers. The soil samples will be collected using 100-meter spacing
to provide coverage across the area of the location of maximum risk, as shown in Figure 2. The
collection of nine soil samples is proposed and should be adequate to allow for the calculation of
statistics such as a 95 percent upper confidence limit (95UCL), as described in Section 5.0.
The proposed soil samples from this area will be analyzed for the COPCs that are attributed to the
chronic risk estimates, as shown in Table 1. The results will lend additional information using data
in an effort to establish that the acceptable risk to human health is not exceeded. The risk drivers
are Cr(VI), select D/Fs and select PAHs.
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In addition to Cr(VI), soil samples will also be analyzed from total chromium and nickel. Total
chromium is not a risk driver, but these results will provide a more complete understanding of the
chromium content in soil. As shown in Table 1, the chronic risks associated with nickel are two
orders of magnitude lower than those associated with Cr(VI), however, nickel was a driver for the
acute inhalation hazards, and these analyses will provide a better understanding of the nickel content
in soils near the site.

3.2 SAMPLING FREQUENCY
OrbitalATK is proposing to collect nine samples from a square grid measuring 200 meters on each
side, centered at the point of maximum deposition, as shown in Figure 2. Each sample will be 100
meters away from the next sample. These nine samples will be used to establish baseline conditions
and summary statistics for these samples will be compared to the summary statistics on the new
background samples.

3.3 BACKGROUND SOIL SAMPLING
Background soil data exist from 1994 and samples were collected in the area west of the
manufacturing building at depths ranging from the ground surface down to 15 feet below ground
surface. Analyses included metals (including total chromium), volatile and semi-volatile organic
compounds, which were largely non-detects. Since there were no background data available for
Cr(VI), additional soil samples were collected in November 2016 from the locations shown in Figure
3. The most recent samples were analyzed for total chromium, hexavalent chromium and nickel and
the results are summarized in Table 3.
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3.3.1 Metals Data — Chromium and Nickel
Total chromium data exist from both the 1994 and 2016 sampling events. The concentrations are
similar and indicate that total chromium concentrations in the 2016 sampling event range from 6.6
— 14 mg/kg and the 95UCL is 13 mg/kg (Table 3). Cr(VI) concentrations from the 2016 sampling
event range from 0.13 — 0.21 mg/kg in the detected samples and the 95UCL is 0.19 mg/kg. Nickel
concentrations range from 4.3 — 13.3 mg/kg and the 95UCL is 11.6 mg/kg. The 95UCLs were
calculated using ProUCL, and the output is included as Appendix A.
3.3.2 PAH Data
Background data for PAHs are very limited. New data will be collected under this SMP from the
seven background locations shown in Figure 3. The analyses will be limited to benzo(a)anthracene
and benzo(k)fluoranthene, the two detected risk drivers shown in Table 2.
3.3.3 Dioxin/Furan Data
Dioxin/furan data will be collected under this SMP from the seven background locations shown in
Figure 3. The analyses will be limited to the individual congeners that are the detected risk drivers,
as shown in Table 2.
3.4 CREATION OF DOXINS/FURANS FROM ANTHROPOGENIC SOURCES
Dioxins and furans are formed during combustion, especially low temperature burning and
smoldering conditions (EPA, 2006). Historically, the major identified sources of environmental
releases of dioxin-like compounds are grouped into six categories: combustion sources, metals
smelting, refining and process sources, chemicals manufacturing sources, natural sources and
environmental reservoirs. In 1987 and 1995, municipal waste combustors were the leading source
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of dioxin emissions. By the year 2000, municipal waste combustion had dropped to fourth, largely
due to the fact that modern combustors are designed to burn waste efficiently at high temperatures
and to minimize the conditions know to promote the formation of these byproducts. Burning of
domestic trash in backyard burn barrels is now the major source of dioxins to the environment (EPA,
2006). Backyard barrel burning takes place at lower temperatures, and the trash can often smolder
for long periods of time. For similar reasons, burning of stubble in agricultural fields produces
dioxins. There are limited data available indicating that backyard barrel burning can result in a
variety of dioxin/furan congener profiles, depending on the type of trash that is burned and the
associated wet or dry conditions of the trash during burning (EPA, 2006). OrbitalATK anticipates
evaluating the dioxin/furan data in soils as they become available and conducting a comparison of
the new data to established data related to backyard barrel burning and agricultural burning that
could be occurring in the Promontory area.
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4.0 TECHNICAL SAMPLING AND ANALYSIS PLAN
The purpose of this section of the SMP is to present the sampling protocols, analytical methods, and
the data validation methods for the soil monitoring pr0gram3.

4.1 SAMPLING LOCATIONS
Surface soil samples will be collected at the nine locations shown in Figure 2. The locations are
based on the hypothetical farmer scenario at the location of maximum risk, as determined by the
modeling in the HHRA.

4.2 SOIL SAMPLING METHODS
The intent of the sampling program is to collect actual field data based on, and in support of, the
completed HHRA. Samples will be collected using a pre-cleaned stainless-steel spoon. Soil will be
sampled to a depth from surface to approximately three inches and placed into a pre-cleaned
stainless-steel bowl. This depth was selected to be consistent with the Human Health Risk
Assessment Work Plan (HHRAP) Combustion Guidance which recommends a soil mixing depth
ranging from 2 — 20 centimeters (approximately 1 - 8 inches) and the default value of 2 centimeters
that was utilized in the HHRA Lakes model. Plant material, roots, and rocks will be manually
removed. The soil will be lightly mixed before being placed into 4-oz wide-mouth glass jars with
Teflon© lined lids and will be properly preserved. The number of jars and type of preservative will
depend on the analytes of concern and quality assurance / quality control (QA/QC) requirements.

4.3 SAMPLING HANDLING METHODS
The jars will be labeled, logged into the field log book, placed in a sealed plastic bag, and placed
into an iced cooler. A chain-of-custody form will be completed as soon as possible to trace sample
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possession from the time of collection through laboratory analysis. One chain-of-custody form will
accompany each shipping 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, including the quantity and types
of containers that comprise each sample. The completed chain-of-custody will be sealed in a
resealable plastic bag and placed inside the shipping container. 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,
at a minimum, the date, time, location and depth of each sample collected, descriptions of the soils
encountered at each sampling location, recording of field decisions concerning sample locations,
and the basis for departures from prior plans and general observations.
4.4 EQUIPMENT DECONTAMINATION
Prior to the collection of each sample, any non-dedicated sampling equipment coming in contact
with the soil will be cleaned with a non-phosphate detergent (e.g., Liquinox®), rinsed with tap water,
and a final rinse using distilled water. Wastewaters generated during field decontamination will be
collected and properly disposed.
Only decontaminated stainless-steel or Teflon sampling equipment and clean, disposable gloves will
contact the samples during placement in the container. Disposable gloves will be worn at all times
during sample handling to prevent cross contamination between samples and skin contact with
potential contaminants. Gloves will be changed between each sample.
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4.5 ANALYTICAI, METHODS AND PROCEDURES3
Samples will be analyzed for the COPCs presented in Table 2. The D/F samples will be analyzed
using EPA Method 8290, by high-resolution GC/MS. Method 8290 is normally used in conjunction
with RCRA regulatory action in support of remediation activities and is able to report lower method
detection limits than Method 8280. Analyses are expected to be conducted by ALS/Columbia
Laboratories, in Houston Texas, a Utah-certified laboratory for D/Fs; or an equivalent Utah-certified
laboratory.
The semi-volatile analytes consist of two PAHs and will be analyzed using EPA 8270-SIM
(Selective Ion Monitoring). SIM has been selected over the Standard Method 8270 because it
provides an order of magnitude better quantitation results. The metals will be analyzed under
Method 6010, with the exception of hexavalent chromium which will be analyzed under Method
7199. Semi-volatile and metal samples will be analyzed by the ATK Promontory laboratory, a Utah-
certified laboratory, or an equivalent Utah-certified laboratory.
4.6 QUALITY CONTROL/QUALITY ASSURANCE SAMPLES
QA/QC samples will be analyzed for the analytes discussed above. QA/QC samples will consist of
blind duplicates.
4.6.1 Field Quality Control Samples
Blind duplicates are used to evaluate the laboratory accuracy where analytical results of two samples
collected from the same location are compared. A minimum number of blind duplicates will be
collected to represent at least 10% of the total samples sent for analysis. The duplicate samples will
be given a unique designation that will differentiate the duplicate from the original sample-of-record.
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All blind duplicate samples will be delivered to the laboratory under chain-of-custody as outlined
previously.
4.6.2 Laboratory Quality Control
Internal laboratory quality control checks will be performed in accordance with the OrbitalATK
Quality Assurance Project Plan (QAPP) (OrbitalATK 2017).
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5.0 DECISION STATEMENT — BACKGROUND AND REGIONAL SCREENING
LEVELS
In accordance with Module IV.K of the Permit, the decision rule for this program will involve
evaluating actual soil data based on the modeling conducted during the OBOD HHRA5. The HHRA
model is inherently conservative based on potential risks to human health, even in the absence of
hard analytical data. The data collected during this SMP will be evaluated and compared first to the
• modeled maximum soil concentrations resulting from the HHRA, for the point of maximum risk.2
Then the data will be compared to the USEPA Regional Screening Levels (RSLs) and the site-
specific background concentrations, using the statistics described below.
The RSLs for the D/Fs were calculated in accordance with EPA guidance (EPA 2010) using the EPA
RSL for 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) and the toxic equivalence factors
(TEFs) for each congener as shown below:
• RSL f or 2,3,7,8 TCDD
RSLcongener = TEFcongener
The resulting RSLs for each congener are presented in Table 2.
Either a 95UCL or maximum concentration will be provided for each COPC shown in Table 2.
ProUCL will calculate a 95% UCL as long as there are a minimum of four data points, however nine
data points will provide a more robust data set, with decreased variability. No maximum
concentration will be reported for sample sets without any detects. For D/Fs, the ProUCL model
will be used to calculate the 95UCL as long as at least 5 dioxin or furan congeners are detected in
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Orbital AM
Soil Monitoring Plan
Hazardous Waste Storage and Subpart X Treatment Permit
each of the nine sampling locations. Non-detects will be considered as described in ProUCL
guidance.
A comparison of the 95UCL for each of the detected risk drivers to both the background
concentrations and USEPA RSLs will be prepared.5 While the HHRA model assumes a complete
pathway from particle deposition to ingestion/bioaccumulation in an adult, comparison to the RSLs
will indicate whether the soil concentrations have accumulated to levels that would warrant
• additional investigation. If the results exceed either background or the RSLs, further comparisons
will be conducted to determine whether a COPC is present due to anthropogenic activities, such as
barrel burning and crop burning in the case of D/Fs, or whether it could be due to site-related
activities. Future actions taken will depend on these results, and additional samples would only be
• taken after the results of the first sampling round have been thoroughly evaluated. OrbitalATK
anticipates resampling five years after the initial sampling round, at the point of maximum risk (one
• sample). Frequency of sampling will be controlled by the Promontory Part B permit.
•
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Soil Monitoring Plan
Hazardous Waste Storage and Subpart X Treatment Permit
6.0 REFERENCES
EPA, 2006 An Inventory of Sources and Environmental Releases of Dioxin-Like Compounds in
• the United States for the Years 1987, 1995, and 2000. National Center for Environmental
Assessment. Office of Research and Development. U.S. Environmental Protection Agency.
EPA/600/P-03/002F. November 2006.
• EPA, 2010 Recommended Toxicity Equivalence Factors (TEFs) for Human Health Risk
Assessments of 2,3,7,8-Tetrachlorodibenzo-p-dioxin and Dioxin-Like Compounds.
EPA/100/R-10/005 December.
• Geosyntec, 2016. Open Burn Open Detonation Human Health Risk Assessment. ATK Launch
Systems, Promontory, Utah. June 2016.
OrbitalATK 2017. Quality Assurance Project Plan •
• •
•
Page l 17
e
•
Orbital AT
Soil Monitoring Plan
Hazardous Waste Storage and Subpart X Treatment Permit
• • • TABLES
. • •
•
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Orbital ATI(
Soil Monitoring Plan
Hazardous Waste Storage and Subpart X Treatment Permit
Table 1. Risk Drivers for the Adult Farmer at the Location of Maximum Risk
COPC Chronic Risk Percent of Risk
Detected in
Emissions
Tests?
Chromium, hexavalent 4.9E-07 50.0% yes
Dibenz(a,h)anthracene 1.3E-07 13.7% no
PentaCDF, 2,3,4,7,8- 1.2E-07 11.9% yes
2-Naphthylamine 3.9E-08 4.0% no
4-Aminobyphenyl 3.8E-08 3.8% no
Benzo(a)pyrene 2.5E-08 2.5% no
n-Nitrosodiethylamine 1.6E-08 1.6% no
Pentachlorophenol 1.5E-08 1.5% no
PentaCDD, 1,2,3,7,8- 1.2E-08 1.2% yes
TetraCDF, 2,3,7,8- 1.1E-08 1.1% yes
HexaCDF, 1,2,3,4,7,8- 1.0E-08 1.1% yes
HexaCDF, 1,2,3,7,8,9- 8.8E-09 0.9% yes
HexaCDF, 2,3,4,6,7,8- 8.5E-09 0.9% yes
HexaCDF, 1,2,3,6,7,8- 6.8E-09 0.7% yes
PentaCDF, 1,2,3,7,8- 6.0E-09 0.6% yes
Benzo(k)fluoranthene 5.7E-09 0.6% yes
n-Nitrosodimethylamine 5.3E-09 0.5% no
Benzo(a)anthracene 5.1E-09 0.5% yes
TetraCDD, 2,3,7,8- 5.0E-09 0.5% yes
Nickel 4.6E-09 0.5% yes
Notes:
COPCs shown in bold will be retained as analytes for the Soil Monitoring Plan
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Orbital ATK
Soil Monitoring Plan
Hazardous Waste Storage and Subpart X Treatment Permit
Table 2. Laboratory Detection Limits and Regional Screening Levels for the Soil Analytes
•
* *
*
*
COPC
Modeled Soil
Concentration
(mg/kg)
MDL
(mg/kg)
EQL
(mg/kg)
TEF (Toxicity
Equivalence
Factor')
EPA RSL
(mg/kg)
Metals (Method 7199)
Chromium, hexavalent 1.16E-07 0.08 0.4 0.3
Metals (Method 6010)
Chromium, Total 1.40E-07 1 5 1.2E+05
Nickel 2.23E-10 0.5 2.5 1.5E+03
SVOC/PANs (Method 8270-SIM)
Benzo(a)anthracene 5.67E-09 2.00E-04 7.0E-03 0.16
Benzo(k)fluoranthene 3.93E-08 2.00E-04 7.0E-03 0.16
Dioxins/Furans1 (Method 8280/8290)
TetraCDD, 2 3,7,8- 1.30E-13 TBD 1.0E-06 1 4.8E-06
PentaCDD, 1,2,3,7,8- 6.15E-13 TBD 5.0E-06 1 4.8E-06
HexaCDF, 1,2,3,4,7,8- 2.50E-11 TBD 5.0E-06 0.1 4.8E-05
HexaCDF, 1,2,3,6,7,8- 1.54E-11 TBD 5.0E-06 0.1 4.8E-05
HexaCDF, 1,2,3,7,8,9- 1.13E-11 TBD 5.0E-06 0.1 4.8E-05
HexaCDF, 2,3,4,6,7,8- 1.82E-11 TBD 5.0E-06 0.1 4.8E-05
PentaCDF, 1,2,3,7,8- 6.66E-12 TBD 5.0E-06 0.03 1.6E-04
PentaCDF, 2,3,4,7,8- 1.37E-11 TBD 5.0E-06 0.3 1.6E-05
TetraCDF, 2,3,7,8- 2.06E-12 TBD 1.0E-06 0.1 4.8E-05
Notes:
MDL - Method Detection
Limit
EQL - Estimated Quantitation
Limit
RSL - Regional Screening
Level
aEPA 2010 The RSLs for the dioxins/furans were developed by dividing the RSL for 2,3,7,8-TCDD by the TEFs
for the individual congeners
Page l 20
•
Soil Monitoring Plan
*
13rbital ATK
* *
* Hazardous Waste Storage and Subpart X Treatment Permit
*

* *
Table 3. Background Metals in Soil - 2016 Sampling Event
Sample ID
Total
Chromium
(mg/kg)
Hexavalent
Chromium
(mg/kg)
Nickel
(mg/kg)
Background 1 13.5 0.161 10.5
Background 2 13.2 0.14 .1 9.6
Background 3 11.3 0.131 9.7
Background 4 6.6 0.211 13.3
Background 5 8.6 0.2 J 4.3
Background 6 9 < 0.08 8.3
Background 7 14 0.161 11.2
95 UCLs 13 0.19 11.6
•
* *
0 Page l 21
Orbital AM
Soil Monitoring Plan
* • *
Hazardous Waste Storage and Subpart X Treatment Permit
FIGURES
*
* *
*
Page l 22
•
Figure 1 Ccosracc'-
Maximum Off-site Risk M-139 1
1
,
ATK Launch
Systems Facility
acihty Boundary
M-225
ATK Launch Systems
Promontory, Utah
Location of Burning Grounds and Maximum Off-site Risk -
Soil Monitoring Plan
DE-01236
Dec 2016
Yol.S.rrystrearNnVI taamtv 01/10111, 11.
Legend
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2
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0001 o I
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1
Proposed Soil Sample Locations - Sod Monitoring Plan
_4 .445ene.,,,X.,..,
III 40 • • • ID II ID Ilk 4? • IP II • • • 0 • •
Background 3 Cr
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C Background 1
Background 6 0
C Background 4
I
1 Facildy Boundary I
ATK Launch s, Systems Facility /
tt
Legend tr•
2016 Background Soil
Sample Location
Background 7 b.,
• •
ATK Launch Systems
Promontory, Utah
2016 ackground Soil Sample
Locations - Soil Monitoring Plan
Background 5 C
Figure 3 Dec 2016
DE-0188
tr,rrvr,11,1,. hy -rod NM •
2
kites
1/•••••••••••••••••••••••••••••••••••••••••••
Div of Waste Mdnagement
and Radiation Control
MAY - 8 2018
7;514W -2Ce-M412.4 Orbital ATK
Thermal Treatment Units M-136 and M-225
Groundwater Monitoring Plan
ATK Launch Systems
Promontory Facility
Prepared for:
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
Prepared by:
ATK Launch Systems Inc.
UTD009081357
April 2018
Orbital ATK3
ATK Launch Systems Promontory Facility
Thermal Treatment Operations
Groundwater Monitoring Plan
April 2018
TABLE OF CONTENTS
1.0 INTRODUCTION 1
2.0 Current Montoring Operations 1
3.0 Monitoring Plan Purpose and Applicability 1
4.0 Groundwater Monitoring Plan Elements 2
4.1 Ongoing Statistical Evaluations and Groundwater Modeling 2
4.2 Preveously Conducted Studies 2
4.3 Proposed Additional Studies 2
4.3.1 Additional Groundwater Modeling 3
4.4 Monitoring Frequency and Reporting 3
ATTACHMENTS
ATTACHMENT 1 Description of the M-136 Groundwater System
•
Orbital ATIO ATK Launch Systems Promontory Facility
Thermal Treatment Operations
Groundwater Monitoring Plan
April 2018
ATK Launch Systems Thermal Treatment Operations Groundwater Monitoring Plan
1.0 Introduction
As required by Module IV.K.4 and Appendix 11 .10.1 of the ATK Launch Systems part B
permit, a groundwater monitoring plan has been developed for the M-136 and M-225 treatment
units. The Permit is issued for thermal treatment operations conducted on the Promontory site,
which is owned by OrbitalATK. The Promontory facility has these two Subpart X thermal
treatment units that are operated as open burn / open detonation facilities (OBOD).
2.0 Current Monitoring Operations
A groundwater monitoring program has been in place at the facility since 1986 to monitor
contaminants that were released from past disposal practices. This monitoring plan is currently
regulated by the ATK Launch Systems Promontory Facility Post Closure Permit. The Post
Closure permit covers the closure of the M-136 Liquid Thermal Treatment Areas (LTTAs)
which are within the M-136 treatment area. Therefore the Post Closure Permit monitoring plan
monitors the same groundwater aquifer throughout the facility. It also includes monitoring of
the M-225 area along with the remainder of the Promontory facility and off site locations.
This permit establishes the sampling methods, constituents of concern, data quality objectives,
sampling frequency, sampling results and analytical methods for groundwater at the facility. A
summary report of these groundwater related items are submitted semi-annually to the Utah
Division of Waste Management and Radiation Control (DWMRC).
The groundwater monitoring program addresses the following concerns:
• The hydrologic and geologic characteristics of the unit and the surrounding area
• The existing quality of groundwater, including other sources of contamination and
their cumulative impact on the groundwater;
• The quantity and direction of groundwater flow; and
• The proximity to and withdrawal rates of current and potential groundwater users.
3.0 Monitoring Plan Purpose and Applicability
Along with the information already generated by the Post Closure Permit, the thermal treatment
operations groundwater monitoring plan will focus on developing a strategy to evaluate the
impact of ongoing thermal treatment operations on facility groundwater within the M-136 area
and if groundwater contamination is increasing. The M-225 area is a small unit that treats small
amounts waste. Previous investigations of soil and groundwater at M-225 indicate that depth to
groundwater is in excess of 600 feet, and that even with the historic treatment of waste in
earthen trenches, contamination does not extend beyond 8 feet of soil depth. This information
is detailed in the M-225 Old Burn Sites Closure Plan Report and the Utah Division of Solid and
Hazardous Waste closure approval letter, April 3, 2012. Therefore it is proposed that the
current groundwater monitoring plan contained in the post closure permit is sufficient to address
1
Orbital ATKI73 ATK Launch Systems Promontory Facility
Thermal Treatment Operations
Groundwater Monitoring Plan
April MK
the M-225 thermal treatment unit and that the additional elements contained in this plan apply
to the M-136 treatment area.
4.0 Groundwater Monitoring Plan Elements
4.1 Ongoing Statistical Evaluations, and Modeling.
The monitoring plan proposes two potential ways to evaluate the monitoring data from
wells at M-136, statistical evaluation of individual wells, and groundwater modeling.
Vadose zone modeling may also be used to help answer questions of contaminant
movement to groundwater.
4.2 Previously Conducted Statistical Studies
A data set has been developed to statistically look at individual wells within the M-136
burn grounds to determine if there is an increase or decrease in contamination
concentrations. The statistical methods used were trend analysis using Mann Kendall
and Sens Slope. This evaluation specifically looked at perchlorate as it is the most
mobile contaminant and is currently used as an ingredient of the waste that is treated.
Based on this evaluation it was found that two wells show a statistically significant
upward trend and five other wells show either no trend or a decrease. A report was
submitted to the UDWMRC on December 3, 2013 with this evaluation. Additionally,
vadose zone modeling was conducted using the HYDRUS model to determine if
precipitation could reach groundwater at M-136 under current conditions. Based on the
HYDRUS results it was found that even with using conservative assumptions,
precipitation would not reach groundwater. In discussion with the UDWMRC it was
concluded that additional monitoring of the wells within the M-136 burn ground would
continue on a regular basis. It was also discussed that there are ongoing upward and
downward contaminant fluctuations in most of the M-136 wells making it difficult to
determine if these trends actually reflect an increase in contamination mass in the
aquafer or movement of existing contamination. Additionally, with the existing high
perchlorate concentrations it is difficult to determine what a represents a significant
change.
4.3 Proposed Additional Studies
The statistical studies conducted to date looked at individual wells and then made
assumptions of increasing and decreasing contaminant concentrations. These ongoing
statistical evaluations will continue, however, this may not be the best way to evaluate
the impact to groundwater of ongoing treatment operations in the thermal treatment
areas. Earth Fax Engineering (EFE) developed the approved groundwater model for the
Promontory Facility. A description of the groundwater system at M-136 has been
provided by EFE and is included as Attachment 1. Based on this description, the
groundwater at M-136 has some unique characteristics that form a basin with high
hydraulic conductivities but with little to no gradient due to surrounding flow barriers.
Using this evaluation it is assumed that contaminant movement is slowed by the lack of
gradient and may be characterized more by slug flow (i.e, movement of contaminant
mass in a high or low concentration slug). Looking at the M-136 groundwater as a basin
2
Orbital ATIO ATK Launch Systems Promontory Facility
Thermal Treatment Operations Groundwater Monitoring Plan
April 2018
system may make the statistical evaluation of individual wells less useful. In a recent
discussion with UDWMRC, it was determined that additional groundwater modeling
may be a more effective way to evaluate if contamination is entering the groundwater
and if it is related to current operations or if it is due to movement of existing
contamination.
4.3.1 Additional Groundwater Modeling
To evaluate the possibility that the upward statistical trend seen in some M-136 wells
reflects movement from historic source areas with high concentrations to areas of lower
concentration, additional modeling was proposed. This modeling would use the existing
groundwater model calibrated to a transient state and use 10 years of analytical data.
The model would use the first 5 years of analytical data as a baseline and then run it to
simulate approximately 5 years of contaminant movement between wells. The results
would be compared to current conditions and determine if there is a similar pattern
showing a predicted increase in the last 5 years in the downgradient or lower
concentration wells. In order to conduct this modeling additional monitoring data from
the M-136 wells may be needed. This modeling will be conducted by Earth Fax
Engineering. They are currently determining if this modeling can be conducted with the
existing data set. If more data is needed the modeling will be conducted when sufficient
data is collected.
4.4 Monitoring Frequency and Reporting
Monitoring of the M-136 groundwater system wells will be conducted at least semi-
annually using the Post Closure Permit monitoring plan until sufficient data is obtained.
It is currently anticipated that a report of the groundwater modeling of the M-136 wells
will be provided in the March M-136 2020 Post Closure Permit Semi-annual
groundwater report which will include monitoring data from 2018 and 2019. Additional
modeling will be reported each following year as applicable. If the proposed modeling
is not feasible then a statistical trend analysis will be provided each year in the same
report.
3
13rbital ATIO ATK Launch Systems Promontory Facility
Thermal Treatment Operations
Groundwater Monitoring Plan
April 2018
Attachment 1
Description of the M-136 Groundwater System
Description of the M-136 Groundwater System
The slope of the potentiometric surface in the vicinity of the M-136 Burning Grounds
(between wells C-6/C-8) is significantly less than that in adjacent areas immediately up and
downgradient. This decrease in slope is likely caused by a combination of a local increase in
the hydraulic conductivity (due to an extremely fractured fault zone or solution cavities) and the
presence of a downgradient groundwater flow barrier. Chen-Northern (1992a, 1992b, and
1992c) and Bolke and Price (1972) suggest that an up-faulted ridge of limestone on the
downgradient edge of this area, trending northeast to southwest across Blue Creek Valley, acts
as a low-conductivity barrier. However, as found during groundwater modeling efforts at the site,
the hydraulic gradient does not increase until groundwater flows back into the unconsolidated
materials at and downgradient from wells F-1 and E-9. A review of hydraulic conductivity data
obtained from site monitoring wells indicates that this steepening of the potentiometric surface
occurs in an area of lower conductivity alluvial deposits. Furthermore, the hydraulic gradient
between wells B-3 and 8-4, on either side of the up-faulted ridge of limestone, is nearly flat.
Hence, the apparent downgradient "barrier" to groundwater flow is actually an area of lower
conductivity sediments rather than the up-faulted ridge of limestone proposed by others.
The groundwater gradient at the M-136 Burning Grounds is found to be very flat with little
change over long distances. For example, a 1000 foot distance from A-9 to D-4 remains at an
elevation of near 4291'. The potentiometric surface at the Burning Grounds generally resembles
a basin in some areas due to the lack of groundwater gradient. Based on this it would be
expected that contaminant migration out of the area would be slow.
a