DSHW-2018-008821 - 0901a068808cde06

NORTHROP GRUMMAN
Div of Waste Management
and Radiation Control
September 12, 2018
8200-FY18-021 SEP 1 2 2O18
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Dsi-014-2DIci -008 sZ
Re: ATK Launch Systems Inc., EPA ID #UTD009081357, Semi-Annual RFI Progress
Report for March 2018 to September 2018.
Dear Mr. Anderson:
Attached is the ATK Launch Systems Inc. Promontory Facility Semi-Annual RFI
Progress Report for March 2018 to September 2018.
If you have questions regarding this report, please contact Paul Hancock at (435) 863-
3344
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision 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 system, or those persons directly responsible for gathering the
information, 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.
Kris H Blauer
Manager, Environmental Services
ATK Launch Systems
cc: Erica Gaddis, Division Director, Utah Division of Water Quality
ATK Launch Systems, Inc. • P.O. Box 707, Brigham City, UT 84302 • 435-863-3511
SEMI-ANNUAL RFI PROGRESS REPORT
March 1, 2018 - September 1, 2018
ATK Launch Systems Promontory Facility
1. Description Of Work Completed
SWMU 208
The September 2017 and March 2018 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.
As mentioned previously 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 remaining 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. This safety concern continues to be in place until a safe way to excavate is
determined.
Plant 3 Well 3A Treatment Summary Reports
The treatment system at the Promontory Plant 3 well 3A has been monitored quarterly
according to the UDWMRC approved plan. The plan includes a request that a summary of
the previous year to date monitoring data be included in the September Semi-Annual report.
This summary is found in Table 1. The treatment system removes TCE to below the 51i/L
health based limit with a carbon replacement interval of every 6 + months. Water usage at
Plant 3 has diminished with lower production. Therefore, ATK is finding that TCE removal
extends significantly beyond the initial 6 month carbon replacement interval. In addition,
perchlorate removal in the two septic tanks, M-201 and M-205, is being monitored for
effectiveness. Samples showed some perchlorate detections in M-201 or M-205. These
samples are collected from the septic tanks where biological treatment is in process and
where conditions are present to remove perchlorate. The detections and subsequent non-
detects demonstrate treatment is taking place.
Table 1
Plant 3 Well 3A Quarterly Treatment Summary Sept 2017 — June 2018
For Perchlorate (C104-) and Trichloroethylene (TCE)
Well 3A Carbon and Septic Tank Treatment Sampling Data (ug/L)
Date Influent Carbon Effluent Septic Tanks Flow gal ( flow is average
for period)*
M-201
CLa4
M-205
CLa4
9/28/17 30.4 TCE
84 C104_
0.4 TCE
83 C104_
U U 1,589,595
12/14/17 N S U TCE
89 C104_
121 15 1,071,560
3/30/18 13.6 TCE
100 C104_
U TCE
94 C104_
U U 1,595,689
6/27/18 NS U TCE
80 C104_
U 55 2,468,711
U = < 4 ppb detection limit
NS= Not Sampled
* Totalizer meter appears clogged due to carbon, under repair, the flow is averaged based on
pump times for the period.
SWMU 553
2. In a May 23, 2018 letter the Division approved the corrective action plan for the removal of
Cr (VI) contaminated soil at SWMU 553. Removal of the soil was first attempted on July
18, 2018 by hand due to the difficulty in accessing the location in the deep runoff channel
Approximately 1 yard of soil was removed from each of the two locations. Follow-up sample
analysis showed that there was contamination remaining. A large track-hoe that could reach
into the deep storm channel was then used for soil removal on August 29, 2018. From
observations it appeared that the grey colored soil that indicated contamination went back
another one foot into the bank at each location. The track-hoe over excavated the site
removing approximately 3 feet of the bank. Approximately 15 yards of soil were removed.
Photographs of the work are in Figure 1. The soil was placed into a roll off bin for shipping
to an offsite Subtitle C landfill. Confirmation samples were collected. Once laboratory
results are obtained a report will be submitted.
Figure 1
3. Summaries of All Findings
The summaries of the corrective action work conducted on SWMUs during this reporting
period are found in sections above.
3. Summaries of All Problems or Potential Problems Encountered During the Reporting
Period
There were no significant problems encountered during the reporting period.
4. Actions Taken to Rectify Problems
No problems were identified.
5. Projected Work for the Next Reporting Period
Plant 3 Well 3A treatment system will be ongoing through the next reporting period.
Finalizing the report for SWMU #553 at building M-19A will be completed. There will be
continuing work with UDWMRC closing other SWMUs currently under review and
investigating additional SWMUs.