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HomeMy WebLinkAboutDSHW-2019-001303 - 0901a068809a9649Div of Waste Managernent and Radiation Control January 31, 2019 8200-FY19-007 JAN 3 1 2019 DSHW-2019 -001303 Rusty Lundberg, Interim 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 RE: Post-Closure Permit, ATK Launch Systems Inc. Promontory Facility, EPA ID# UTD009081357, Surface Water Discharge SWMU Investigation On October 17th of 2018 Jeff Vandel from your office visited the Promontory facility to inspect and investigate a group of 21 Solid Waste Management Units (SWMUs) primarily related to surface water discharges. The attached report describes the results of that investigation and a request for no further action on these SWMUs. If you have questions, or need additional information, please contact Paul Hancock at (435) 863-3344. Kris H. Blauer, Manager, Environmental Services ATK Launch Systems, Inc. • P.O. Box 707 Brigham City, Utah 84321 • (801)250-5911 ATK Launch Systems Promontory Facility Surface Water Discharge SWMUs Investigation GRWOMN ATK Launch Systems, Inc. Promontory Facility January 2019 ATK Launch Systems Surface Water Discharge SWMUs Investigation 8 Promontory, Utah January 2019 ATK Launch Systems Surface Water Discharge SWMUs Investigation The ATK Launch Systems, Inc. (ATK) Promontory Post Closure Permit lists the Solid Waste Management Units (SWMUs) at the Promontory site. This list of SWMUs is part of the RCRA Facility Investigation (RFI) phase of the facility corrective action. These SWMUs were initially identified and assessed through the RCRA Facility Assessment (RFA) conducted by the Utah Division of Solid and Hazardous Waste (UDSHW) now called the Utah Division of Waste Management and Radiation Control (UDWMRC). The RFA report was completed by the UDSHW in 1990. A RCRA Facility Investigation (RFI) was conducted by ATK under approval of the UDSHW and a subsequent report submitted in August 2000. The report describes the investigation, results and conclusions associated with many SWMUS at ATK including a group of surface water discharges from various buildings. These surface water discharges were predominantly characterized as boiler blowdown, boiler condensate, Baltimore Aircoil cooling towers (BAC) and once through non-contact cooling. These discharges typically went to the building drainage systems that included storm water runoff. In 1995 all of these types of building discharges were connected to two biological waste water treatment facilities. On October 17, 2018 Jeff Vandel with the UDWMRC visited the Promontory Facility to inspect a group of 21 SWMUs that were primarily these building surface water discharges. This report summarizes the findings of that investigation and inspection. Four SWMUs included in this report were not visited but were discussed with Mr. Vandel. These four SWMUs were building surface discharges of the same type and location as closed in 2016 and were part of the investigation for the South Storm Channel included in the RFI 2000 report. The report proposes that these 21 SWMUs be designated as requiring no further action under the RFI and therefore be dropped from the SWMU listing in the Post Closure Permit. The reasons for this conclusion include: 1. The RFI 2000 report concluded that most of these surface water discharge SWMUs required no further investigation as constituents were below risk based levels or represented background levels. Comparison of these detected constitute concentrations to the current (November 2018) Regional Screening Levels for residential exposure showed that they are also below these screening standards. Two SWMUs required additional investigation for higher cyanide concentrations. An investigation plan was developed on site with Mr. Vandel and a separate report was submitted on the results of that investigation. 2. All building flows of this type were connected to waste water treatment facilities in 1995 This report includes a brief description of each of the SWMUs, including photos and justification for no further action. Additional details for most of the surface water discharge SWMUs are found in the August 2000 RFI report. ATK Launch Systems Surface Water Discharge SWMUs Investigation 8 Promontory, Utah January 2019 A listing of SWMUs included in this report that were part of the October 17th, 2018 investigation is in Table 1. Table 1 SWMUs Included in this Report Investigated on October 17, 2018 BL_Lr;_glin SWMU# Description 1. T-111 355 Surface Building Discharge 2. T-51A 402 Surface Building Discharge 3. T-15A 397 Surface Building Discharge 4. T-14A 493 Surface Building Discharge 5. T-53A 353 Surface Building Discharge 6. T-3 446 Surface Building Discharge 7. T-21A 559 Surface Building Discharge 8. 1-5 667 Septic System Drain Field 9. M-113 114 Surface Building Discharge 10. M-014 345 Building Discharge 11. M-702 620 Building Discharge Additional investigation 12. M-570 285 Building Discharge Additional investigation 13. M-514 618 Surface Building Discharge 14. M-640 381 Surface Building Discharge 15. M-348 395 Dry Well Sump 16. A-2 191 Septic System Drain Field 17. T-112 674 Drain Leak Waste Water Line 18. M-111 253 Surface Building Discharge 19. M-113 358 Surface Building Discharge 20. M-113 359 Surface Building Discharge 21. M179 431 Surface Building Discharge SWMUs Building Description NFA Justification 355 T-111 SWMU 355 is a dry well associated with the T-111 boiler discharge consisting of boiler condensate, blowdown, BAC cooling and water softener. It was investigated by ATK and reported in the 2000 RFI report. The RFI investigation showed no constituents of concern exceeded risk based values and were similar to background. No further action was recommended. In 1995 the flow was connected to the waste water treatment facility. The photo is from the October 17th, 2018 inspection. ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 SWM Us Building 402 T-51A SWMU 402, T-51A location of surface discharge ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 Description SWMU 402 is a surface discharge from boiler building T-51A consisting of boiler condensate, blowdown, BAC cooling and water softener waste water. In 1995 the flow was connected to the waste water treatment facility. It was investigated and reported in the 2000 RFI report. NFA Justification There is no history of releases. The RFI investigation showed no constituents of concern exceeded risk based values and were similar to background. No further action was recommended. The photo is from the October 17th, 2018 inspection. ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 SWMUs Building Description NFA Justification 397 T-15A SWMU 397 is associated with a wastewater discharge to a dry well at T-15A. It was comprised of boiler blowdown and boiler condensate. In 1995 the flow was connected to the waste water treatment facility. This was investigated and reported in the 2000 RFI report. The RFI investigation determined that no constituents of concern exceeded background values NFA was recommended. This site was viewed during the October 17, 2018 inspection. ATK Launch Systems Promontory, Utah Water Discharge SWMU Investigation 8 January 2019 SWMU 493 is associated with a wastewater discharge to a dry well at T-14A. It was comprised of boiler blowdown and boiler condensate. In 1995 the flow was connected to the waste water treatment facility. This was investigated and reported in the 2000 RFI report. The RFI investigation determined that no constituents of concern exceeded background values. NFA was recommended. This site was viewed during the October 17, 2018 inspection. SWM Us Building Description NFA Justification 493 T-14A ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 SWMUs Building Description NFA Justification T-53A SWMU 353 is associated with a wastewater discharge to a dry well at T-53A. It was comprised of boiler blowdown and boiler condensate. In 1995 the flow was connected to the waste water treatment facility. This was investigated and reported in the 2000 RFI report. The RFI investigation determined that no constituents of concern exceeded background values. NFA was recommended. This site was viewed during the October 17, 2018 inspection. ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 NFA Justification SWMUs Building Description SWMU 446 is associated with a wastewater discharge to a dry well at T-3. It was comprised of boiler blowdown and boiler condensate. In 1995 the flow was connected to the waste water treatment facility. This was investigated and reported in the 2000 RFI report. 446 T-3 RFI Report demonstrated no constituents were above risk based levels and no further action was recommended. This site was visited during the Oct 17, 2018 inspection. Building Description SWMUs NFA Justification 559 T-21A SWMU 559 is a boiler discharge from T-21A boiler to a small pit. It was comprised of boiler blowdown and boiler condensate. In 1995 the flow was connected to the waste water treatment facility. This was investigated and reported in the 2000 RFI re ort. The RFI Report demonstrated no constituents were above risk based levels and no further action was recommended. This site was visited during the Oct 17, 2018 inspection. ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 SWM Us 667 Building 1-5 Description SWMU 667 is the old septic system for building 1-5. The tank was cleaned out sent offsite for disposal and filled with sand and gravel. Operational dates are the early 1960's to 1995 when the flow was connected to the wastewater treatment facility. NFA Justification The RFI investigation as reported in the 2000 RFI Report demonstrated no constituents were above background or risk based levels and no further action was recommended. This site was visited during the Oct 17, 2018 inspection. The RFI investigation as reported in the 2000 RFI Report demonstrated no constituents were above risk based levels and no further action was recommended. This site was visited during the Oct 17, 2018 inspection 114 M-13 SWMU 114 is the location of an old concrete sump that was removed in 1988. The building was used for propellant ingredient processing. SWM Us Building Description NFA Justification ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 ATK Launch Systems Promontory, Utah Water Discharge SWMU Investigation 8 January 2019 620 M-702 SWMU 620 is a discharge area for industrial flows of boiler condensate. Operational dates are approximately 1980- 1995 when it was connected to the wastewater treatment facility. The RFI investigation as reported in the 2000 RFI Report demonstrated that cyanide was above risk based levels and further action was recommended. This site was visited during the Oct 17, 2018 inspection and agreement was reached on the additional sampling plan for the investigation. A separate investigation report was submitted. SWMU 620 M-702 SWMUs Building Description NFA Justification NFA Justification Description SWMUs Building SWMU 285 is a surface building discharge generated by BAC cooling and softening wastewater. It flowed into a surface drainage system. Operational dates are approx. 1970 to 1995 when it was connected to the wastewater treatment system. The RFI investigation as reported in the 2000 RFI Report demonstrated that cyanide was above risk based levels and further action was recommended. This site was visited during the Oct 17, 2018 inspection and agreement was reached on the additional sampling plan for the investigation. A separate investigation report was submitted. 285 M-570 ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 ATK Launch Systems Promontory, Utah Water Discharge SWMU Investigation 8 January 2019 618 M-514 SWMU 618 surface discharge at building M-514 consisting of BAC cooling water. 1962 to 1995 when it was connected to the wastewater treatment facility. The RFI investigation reported in the 2000 RFI Report found the constituent cyanide was below background and less than risk based standards. This site was visited during the Oct 17, 2018 inspection. SWMUs Buildint Description NFA Justification NFA Justification Descri s tion SWMUs Buildin SWMU 381 is a surface discharge at building M-640 Operational dates are approximately 1962 to 1995 when the flow was connected to the wastewater treatment facility The RFI investigation as reported in the 2000 RFI Report demonstrated that constituents were within background levels and no further action was recommended. This site was visited during the Oct 17, 2018 inspection. 381 M-640 SWMU 381 at M-640 old Surface water discharge ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 SWMUs Building Description NFA Justification vfr- 4,14,•esAto, tt t". * -46 Oh* ;•-• 4414 44,v1.404.9itiv- dr A,6.+4,0e, Aye • IroviimidwaknorAmaPIN A ''''49111144•4441, SWMU 395, old drywell for surface water discharge SWMU 395 was a surface discharge that drained to a dry well. The discharge consisted BAC cooling water boiler blowdown and condensate, eye wash, and water softening waste water. Operational dates are approximately 1989 to 1995 when it was connected to the waste water treatment facility. 395 M-348 The RFI investigation as reported in the 2000 RFI Report demonstrated that constituents were below risk based standards and no further action was recommended. This site was visited during the Oct 17, 2018 inspection. ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 SWM Us Building Description NFA Justification 191 A-2 SWMU 191 was a septic drain field that received a small amount of photographic processing waste water. Operational dates are approximately the 1960s to 1975. The RFI investigation as reported in the 2000 RFI Report demonstrated that constituents were similar to backg-ound and below risk based values and no further action was recommended. This site was visited during the Oct 17, 2018 inspection. ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 SWMUs NFA Justification The RFI investigation was reported as part of a 3/7/2002 SWMU Progress Report. Soil samples were collected after the remediation. The sampling demonstrated that constituents were below risk based levels and no further action was recommended. This site was visited during the Oct 17, 2018 inspection. However the building was shut down and locked, Jeff Vandel said it was not necessary to see the location as we had a picture in the report. 674 T-112 SWMU 674 is the location of an old floor drain in building T-112 flair liner facility that flowed to a wastewater sump. The concrete around the drain was removed and evidence of a leak was noticed. The contaminated soil was removed and sent to a disposal facility. Operational dates are 1980's to 2002. Building Descri e tion Surface Water Discharge SWMUs itcr SWMUs 253, 358, 359, 431 Google Earth SWMUs 253, 358, 35, 431 surface water discharges Nort Storm Drain L ne ATK Launch Systems Water Discharge SWMU Investigation 8 Promontory, Utah January 2019 SWM Us Buildings Descri tion N FA Justification 253 358, 359 431 M-111 M-113 M-179 These SWMUs are waste water discharges from inert manufacturing buildings associated with once through cooling, boiler blowdown and condensate flows. These flowed to the South storm drainage line. Operational dates are approximately 1962 to 1995. The RFI investigation as reported in the 2000 RFI Report investigated similar flows and constituents that day lighted at the south drainage sample location. Constituents were within background levels and no further action was recommended. Other discharges to this same location were NFA closed in a DWMRC Sept 22 letter.