DSHW-2018-011583 - 0901a068809412d0

DSHW-2018-011583 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
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
December 5, 2018
Kris Blauer, Manager
Environmental Services ATK Launch Systems – Promontory P.O. Box 707 Brigham City, Utah 84302-0707

RE: Surface Water Discharge Solid Waste Management Unit (SWMU) Investigation Report #2 ATK Launch Systems – Promontory Facility UTD009081357
Dear Mr. Blauer:
The Division of Waste Management and Radiation Control has completed its review of 12 of the 23 SWMUs included in the Surface Water Discharge SWMU Investigation Report #2 dated October 27, 2017. The SWMUs that are included in the report were initially identified during the
RCRA Facility Assessment (RFA) and were investigated during the Phase I RCRA Facility
Investigation (RFI). On-site inspections were conducted at all of the SWMUs that were reviewed. Based on the information presented in the Surface Water Discharge SWMU Investigation Report #2, the Phase I RFI Report, the
Installation Restoration Program Report – Phase II (for SWMUs #280, #659 and #660), and the
inspections that were conducted at each SWMU, ATK’s request for no further action is hereby approved for 5 of the 12 SWMUs reviewed as indicated in Table 1 below. Please update Table 6-B of ATK’s Post-Closure Permit for the SWMUs approved for NFA in accordance with Condition VI.A.2. The Division has comments on the information supporting the other seven SWMUs. The comments are
enclosed. Please provide responses to the comments on the other SWMUs at your earliest convenience.
(Over)

If you have any questions, please call Jeff Vandel at [phone].
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/JV/km Enclosures: Table 1. Status of Surface Water Discharge SWMUs Investigation 2
Comments on the SWMUs
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

Table 1. Status of Surface Water Discharge SWMUs Investigation 2
SWMU # Building Description Comments NFA
1. 660 Faust Valley Drainage Surface drainage course NFA is appropriate based on RFI and IRP, sample results. yes
2. 658 E-534 Septic sludge disposal pond NFA is appropriate based on RFI, sample results. yes
3. 659 E-512 E-512 Drainage Ditch NFA is appropriate based on IRP, sample results. yes
4. 280 E-512 Building surface discharge NFA is appropriate based on IRP, sample results. yes
5. 195 M-174 Old burn ground west of M-174 Are samples representative? The burn pit may not have been
sampled since its exact location was unknown.
no
6. 625 M-153 Septic drain field* Although random sampling was used, the drain field area was
pretty well represented.
no
7. 626 M-002-2 Laundry drain field* Are samples representative? Random sampling not ideal for the site.
no
8. 465 M-002-1 Septic drain field* Are samples representative? Random sampling not ideal - drain field area not very well sampled.
no
9. 609 M-009-NE Surface discharge to dry well Drywell was removed years prior to sampling. Borings were
located based on facility maps and interviews with building personnel to represent the center
and outer limit of the well.
yes
10. 621 M-055-W Building surface discharge Comments on analytical results. no
11. 627 M-002-3 Septic drain field* Are samples representative? Location of drain field is described as approximate in the RFI Report.
no
12. 628 M-019A Septic drain field* Should ClO4 and VOCs have been included as COPCs? Random sampling adequate?
no
*drain fields

General Comments on the Drain Field SWMUs Based on EPA Guidance (Guidance on Choosing a Sampling Design for Environmental Data Collection, December 2002), judgmental sampling (as opposed to simple random) is appropriate for situations where there is “reliable historical and physical knowledge about the feature under
investigation.” Furthermore, judgmental sampling is appropriate if “the objective of the investigation is
to screen an area (or SWMU) for the presence or absence of contamination at levels of concern, such as risk-based screening levels.” The Division is concerned that the random sampling that was conducted at the drain field SWMUs,
particularly SWMUs #465 and #627, may not be adequate for determining the presence or absence of
contamination. According to Figure 465-1 (or Drawing No. M2-1) of the August, 2000 Phase I RFI Report, the sampling grid laid out for SWMU #465 was over 500 feet long and 200 feet wide with the random samples all being collected along the eastern edge of the grid and Figure 627-1 indicates that the location of the SWMU #627 drain field is approximate.

Was the random sampling of the drain field SWMUs representative and adequate for determining the presence or absence of contamination? Does ATK have any additional information regarding the location and size of the drain fields at SWMUs #465 and #627? Could sample locations be reliably selected that are more likely to represent the drain field discharges?
Comments on the Surface Water Discharge SWMU Investigation Report 2
1. SWMU 195 - Building M-174 - Old Open Burning Site
Although the analytical results appear to indicate that contamination at the SWMU isn’t a concern, it is unknown if the old burn trenches were actually sampled. The RFI Report indicates that the area was graded prior to sampling and the sampling grid was laid out over the approximate location of the burn trenches. In addition, sample locations were selected randomly.

How was the sampling grid located? Does ATK have any additional information on the number of burn trenches, their size and location? A no further action determination is not appropriate at this time since it is unknown if the burn trenches were actually sampled.
2. SWMU 625 - Building M-153 - Septic Drain Fields A, B &C
Are the random samples that were collected adequate for determining the presence or absence of contamination? Could sample locations be reliably selected that are more likely to represent the drain field discharges?
3. SWMU 626 - Building M-002-2 - Laundry Drain Field
Are the random samples that were collected adequate for determining the presence or absence of contamination? Could sample locations be reliably selected that are more likely to represent the drain field discharges?
4. SWMU 465 - Building M-002-1 - Septic Drain Field
The Division is concerned that the random sampling that was conducted at SWMU 465 is not adequate for determining the presence or absence of contamination. Based on Figure 465-1 (or Drawing No. M2-1), the sampling grid laid out was over 500 feet long and 200 feet wide with the random samples all being collected along the eastern edge of the grid.

Does ATK have any additional information regarding the location and size of the drain field at
SWMU 465? What do the rectangles and lines shown within the sampling grid on Figure 465-1
represent? Could sample locations be reliably selected that are more likely to represent discharge from the drain field? 5. SWMU 621 - Building M-055-W – Building Surface Discharge
The units for the semi-volatile organics laboratory data for the two-foot depth samples at the
point of discharge and 25 feet down-gradient are reported as ug/L, but in the RFI Report text (Table 621-1) the units are shown as mg/kg. The report discusses collecting soil samples, but not water samples.
Bis(2-ethylhexyl)phthalate was reported at 3600 ug/L in the point of discharge, two-foot sample
and 8040 ug/L in the 25 feet down-gradient, two-foot sample. Both of these results were also qualified with the letter “B.” This compound was identified as a COPC for the SWMU apparently based on sampling of the wastewater discharge.
It appears that the compound was detected in a blank, but data for the blank isn’t included in the
report and the “B” flag is not discussed in the text. Please clarify these results. Chromium was also identified as a COPC in the RFI Report, but there are no results for chromium included with the data. Were the soil samples analyzed for chromium?

6. SWMU 627 – Building M-002-3 – Septic Drain Field Based on Figure 627-1 of the Phase I RFI Report (August, 2000), the location of the drain field at SWMU #627 is approximate. Are the random samples that were collected adequate for determining the presence or absence of contamination? Could sample locations be reliably
selected that are more likely to represent the drain field discharges?
7. SWMU 628 – Building M-019A – Septic Drain Field What is the suspected source of the high perchlorate concentrations that have been detected in the nearby monitoring well M39B1? The RFI Report states that COPCs for the SWMU were
identified based on the results of samples of the waste water from the building that were
collected during a sampling event in 1988. Were VOCs or perchlorate detected in the samples? Are the random samples that were collected adequate for determining the presence or absence of contamination? Could sample locations be reliably selected that are more likely to represent the drain field discharges?