DSHW-2018-012402 - 0901a068809649c8

DSHW-2018-012402 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 28, 2018
Kris Blauer, Manager
Environmental Services ATK Launch Systems – Promontory P.O. Box 707 Brigham City, Utah 84302-0707
RE: Review of the Surface Water Discharge SWMU Investigation Report #2, Group 2 ATK Launch Systems – Promontory Facility UTD009081357
Dear Mr. Blauer: The Division of Waste Management and Radiation Control has completed its review of the 11 remaining SWMUs from the 23 SWMUs that were 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 and the inspections that were conducted at each SWMU, ATK’s request for no further action is hereby approved for 4 of the 11 SWMUs reviewed as indicated in the enclosed Table. Please see the comments that are also enclosed regarding the other 7 SWMUs and submit responses to them at your earliest convenience.
In addition, please update Table 6-B of ATK’s Post-Closure Permit for the SWMUs approved for NFA in accordance with Condition VI.A.2. If you have any questions, please call Jeff Vandel at [phone].
Sincerely,
Scott T. Anderson, Director Division of Waste Management and Radiation Control (Over)
STA/JV/km Enclosure: Comments on the Surface Water Discharge SWMU Investigation Report #2 Table 2. Status of Surface Water Discharge SWMUs Investigation #2
c: Grant Koford, EHS, Environmental Health Director, Bear River Health Department Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Department Amy Hensley, USEPA, Region 8 Paul Hancock, ATK Launch Systems

Table 2. Status of Surface Water Discharge SWMUs Investigation #2
SWMU # Building Description Comments NFA
1. 615 M-057 Building surface discharge NFA is appropriate based on sampling of waste water discharge
and soil.
yes
2. 234 I-010-S Surface discharge to
dry well
NFA is appropriate based on
confirmation sample results after two excavations.
yes
3. 630 M-072 Septic drain field Missing data for soil sample collected at Grid #31, 10 ft. depth. Arsenic detected exceeds background. Random sampling.
comments
4. 483 M-197 Building surface discharge Comments on discrepancies in the analytical data and absence of VOC results.
comments
5. 673 M-120 Building surface discharge Comments regarding sampling locations. comments
6. 254 M-117 Surface discharge to dry well NFA is appropriate based on soil sample results from 1995 and 1999 and surface water discharge
sample results.
yes
7. 527 M-606 Building surface discharge NFA is appropriate based on soil sample results and general BAC cooling discharge sample analyses
yes
8. 632 M-193-N Septic drain field Random sampling. Source for arsenic? Perchlorate a COPC? comment
9. 631 M-191-S Septic drain field Random sampling. Perchlorate a
COPC?
comment
10. 560 A-002 Building surface
discharge
Comment on the soil samples that
were collected
comment
11. 451 A-002 Building surface
discharge
Comment on the soil samples that
were collected
comment

General Comment 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.”
As we commented previously, the Division is concerned that the random sampling of the drain field SWMUs that was conducted may not be adequate for determining the presence or absence of contamination. Jeff Vandel recently discussed this issue with Paul Hancock and Blair Palmer and they agreed to take a closer look at the drain field SWMUs which, in this correspondence, include #630, #631 and #632.

Comments on the Surface Water Discharge SWMU Investigation Report #2 1. SWMU #630 – M-72 Drain field Lab data for the soil sample that was collected from Grid #31, the 10 foot depth, is not included in
the RFI Report. Can a copy of this data be found? Please submit it, if possible. The maximum amount of arsenic detected at the SWMU slightly exceeds the maximum background concentration (but the UCL95 concentration for the SWMU does not exceed the maximum
background). Is there any reason to believe that arsenic was released at the SWMU? Was arsenic detected in the waste water sample that was collected, as discussed in the RFI Report, “Waste Characteristics” section? Please see the general comment above regarding the random sampling method that was used at the
drain field SWMUs. 2. SWMU #483 - Building M-197 – Building Surface Discharge
The COPCs identified for this SWMU were VOCs although the discharge is characterized as BAC
cooling water. Also, analytical results are included in the RFI Report for metals but not VOCs. In addition, the Report states that the lab analyzed the samples as a liquid matrix and reported the results in ug/L, but the metals results are reported in ug/g.
NFA appears appropriate based on the metals analysis results for the two-foot depth samples and the statement in the RFI Report that no VOCs were detected at levels above the reporting limit, but please clarify the discrepancies identified above. Does a copy of the VOC analytical results still exist?
3. SWMU #673 - Building M-120 – Building Surface Discharge It is stated in the RFI Report that Building M-120 was a propellant ingredient premix preparation and polymer building, and the discharge consisted of cooling tower bleed-off water. Was building wash-down water included with the discharge?
Drawing No. M673-1 shows “Grid #1” located 32 feet downgradient from the end of the culvert and “Grid #2” 25 feet beyond that, which appears to be consistent with the Sample IDs shown on the lab report, but the text in the RFI Report states that the samples were collected at the point of discharge and 25 feet downgradient.
There is no mention of sample grids in the text of the RFI. Do the “Grids” referred to in the Drawing represent sample locations?
Was the point of discharge sampled? 4. SWMU #632 – M-193-N Septic Drain Field Please see the general comment above regarding the random sampling method that was used at the drain field SWMUs.
The UCL95 arsenic concentration calculated for SWMU #632 slightly exceeds the maximum background concentration. Was there a potential source of arsenic discharge at Building M-193-N?
Was arsenic detected in the waste water sample that was collected in 1992, as discussed in the RFI Report, “Waste Characteristics” section? In addition, the RFI indicates that the wastewater discharge from SWMU #632 included building wash-down. Was the wastewater sample that was collected in 1992 analyzed for perchlorate?

5. SWMU #631 – M-191-S Septic Drain Field Please see the general comment above regarding the random sampling method that was used at the drain field SWMUs.
The RFI indicates that the wastewater discharge from SWMU #631 included building wash-down. Was the wastewater sample that was collected in 1992 analyzed for perchlorate? 6. SWMUs #451 and #560 Building A-002 Building Surface Discharges
Based on the RFI Report, SWMUs #451 and #560 were two separate surface water discharges, both from Building A-002. The SWMU #451 discharge was characterized as waste water from a sink and the SWMU #560 discharge was characterized as rinse and developer waste water from a small photo lab.
Sampling was conducted at the point of discharge, 25 feet downgradient from the point of discharge and at a third point further downgradient below the confluence of the two discharges.
The waste water discharge for SWMU #560 was sampled, and the results are shown in Table 3-K, Appendix 7.1, of the RFI Report. Constituents that were detected in the discharge include toluene, methylene chloride, cadmium and boron. Drawing No. A2-1 in the RFI Report doesn’t show the location of the two discharges from the building. Was the point of discharge where the soil sample was collected for the sink or photo lab waste water?