DSHW-2025-000663

Northrop Grumman Systems Corporation 
Space Systems 

Flight Systems Group 
5000 South 8400 West  
WVC, UT 84120

February 3, 2025

Mr. Doug Hansen, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880

Re: Quarterly Progress Report – 4QCY24
Northrop Grumman Systems Corporation - Bacchus
UTD001705029

Dear Mr. Hansen:
Pursuant to Module IV.C and IV.I.1 of the Plant 1 Bacchus RCRA Permit, Northrop Grumman
Systems Corporation (NGSC) is submitting the corrective action progress report for the period
cited above. An updated copy of Table 1 is attached.

CURRENT PROJECTS

SWMU BP-2
Solid Waste Management Unit Burn Pan 2 (SWMU BP-2) is an old burn pan area used in the
early 1900’s for dynamite wastes. The northern end of SWMU BP-2 is located within an over-
pressure area south of the nitroglycerin operations. The available window for access into the
area opened for a few weeks in March and April of 2020. During this window trenches were cut
perpendicular to the filled in drainage ditch. These trenches were cut across the fill material
from what appears to be clean/native material to clean/native material on the opposite side.
However, during this time the full extent of the impacted soils was not delineated. Continued
excavation will occur, depending on the nitroglycerin production scheduling, to find the extent of
impacted soils. After the perimeter has been established further discussions will occur with the
Division as to the best approach to close SWMU BP-2.

SWMU Group 6
SWMU Group 6 is comprised of 17 individual SWMUs. Fourteen of the SWMUs are closed
with unrestricted land use. Three SWMUs are currently under investigation. These three include
the following abandoned sumps; S-19, S-31 North, and S-39. A RCRA Facility Investigation
Sampling and Analysis Plan was submitted to the Division and approved in July 2020. An
investigation of SWMU Group 6 began the fourth quarter of 2020 and continues through 2025.
A brief description of each of the SWMU Group 6 sumps that have not been closed follows
below.

February 3, 2025
Utah Division of Waste Management and Radiation Control
 S-19 consisted of two earthen sumps that received waste from a small-scale propellant
molding facility. This facility was removed prior to the 1989 RCRA Facilities
Assessment and S-19 had been graded smooth making S-19 no longer visible. The
location of S-19 is based on aerial photographs and the Division approved 1991 RCRA
Facility Investigation Work Plan. The investigation October 2020 located the sump.
Several additional VOC samples were collected October 2021. Due to high Arsenic
levels, further investigation will occur, depending on the Nitrator shut-down schedule. A
RCRA Facility Investigation (RFI) Report is expected to follow the investigation.

 S-31 consists of a 150-yard earthen ditch that received waste from two spent acid
processing buildings. During the time of the 1989 RCRA Facilities Assessment a 1,000-
gallon tank had replaced the ditch. The tank and buildings were later removed.
However, the ditch is still visible and intact. The investigation began October 2020 and
likely end spring of 2023 based on the ability to remove high lead soils along the north
end of the S-31 adjacent to the Nitrator. This is dependent on the Nitrator being shut
down long enough to perform this work. Due to construction along the south end of S-31
the SWMU was split into two sections, a north and south. A RFI was submitted for the
south portion April 11, 2022. A no further action was granted for S-31 South. An RFI
for S-31 North will be submitted 2025. Remediation will occur as soon as possible,
based on Nitrator schedule.

 S-39 consisted of an earthen sump that collected waste from a building that processed
nitroglycerine. The building and S-39 were removed in the 1960’s. The sump is no
longer visible. The location is based on the Division approved 1991 RCRA Facility
Investigation Work Plan. The investigation began October 2020. Materials along the
north portion were stockpiled above the south portion to allow for the construction of an
access road for a new building. An RFI was submitted to the Division August 2022.
During the removal of materials arsenic impacted soils were found under a steam-line
which is still in use. This S-39 will have to be moved into a list to be completed after
demolition of structures. A letter to this effect was submitted to the Division September
of 2023.

SWMU SI-2
SWMU SI-2 is an abandoned plastic lined earthen impoundment that received waste from an
experimental propellant manufacturing facility located in the center of Plant 1. The waste from
this building was also placed in a tank. Both the tank and impoundment were used to neutralize
the waste. The tank has been removed and only the impoundment remains. The plastic liner has
since degraded and no longer functions as a barrier to prevent water from saturating the soils
below the impoundment. A RCRA Facility Investigation Sampling and Analysis Plan was
submitted to the Division and approved in July 2020. An investigation of SWMU SI-2 occurred
August 2023. An RFI Report was submitted summer of 2024 with comments from the Division
to be addressed by NGSC.

February 3, 2025
Utah Division of Waste Management and Radiation Control
SWMU SL-2
SWMU SL-2 is an abandoned earthen lagoon that received discharge wastewater from a
biological wastewater treatment plant. The wastewater treatment plant treated domestic sewage,
laboratory waste, and untreated photograph process water. SL-2 was abandoned in 1987. Due to
its location adjacent to the Nitrator, coordinating contractors in this area can be difficult. A
RCRA Facility Investigation Sampling and Analysis Plan was submitted to the Division and
approved in December 2021. It is anticipated that sampling will occur in 2025. Depending on
results of this sampling an RFI will follow.

SWMU SL-3
SWMU SL-3 is an abandoned earthen lagoon that received discharge wastewater from a
biological wastewater treatment plant. The wastewater treatment plant treated domestic sewage,
laboratory waste, and untreated photograph process water. SL-3 was abandoned in 1987. Due to
its location adjacent to the Nitrator, coordinating contractors in this area can be difficult. A
RCRA Facility Investigation Sampling and Analysis Plan was submitted to the Division and
approved in December 2021. Sampling occurred summer of 2024. An RFI will be submitted in
2025.

SWMU SS-5
SWMU SS-5 is an abandoned septic system adjacent to building 8123. SS-5 received photo
processing waste and domestic waste from Building 8123 from 1960- to 1968. In 1968 SS-5 was
replaced with a 1,000-gallon tank. An RFI Work Plan was approved by the Division in
December 2021. Field work began May 2022. December 2023 the Division issued a letter
placing SS-5 in a deferral status until adjacent high powerlines are no longer in use and can be
removed, allowing safe excavation of the site.

PROJECTS

SWMU SL-4
SWMU SL-4 is an abandoned sewage lagoon that collected sanitary waste from a small portion
of the NIROP facility. SWMU SL-4 is located immediately north of the Burning Grounds. A
work plan, including SWMU SL-4 along with other units, was previously submitted to the
Division. The SWMU SL-4 portion of the investigation was not conducted because funding had
not been secured from the US Navy and the lagoon generally contained a couple feet of standing
water in the southern portion. An updated work plan has been submitted and approved by the
Division. Field work timing is still to be determined. Based upon Division approval, NGSC had
hoped to begin the study when funding can be secured from the Navy.

SWMU BW-10
SWMU BW-10 is burned waste site or landfill that was operated west of the wastewater
treatment facility at Plant 1 from 1960 through 1970. This waste site is located along the top
edge and steep side of a ridge above Coon Creek. An RFI Work Plan was approved by the
Division in March 2022. Field work timing is still to be determined.
i:ehruar 2( )2.
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N RTHROP
GRUMMAN
Should there be any questions or comments concerning this submittal, please contact Tim
Jimenez @ 801.251.2142 or [e-mail].
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. Jam aware that there are signfi cant penalties for submitting false information,
including the possibility offine and imprisonment for knowing violations.
Sincerely,
Blair G. Palmer
Manager, Environmental Services
cc: P. Walton, DWMRC
Table 1 ‐ SWMU/HWMU Status
S-1 C Designated as NFA following RFI.
S-2 C
S-3 C
S-4 C
S-5 C
S-6 C
S-7A C
S-7B C
S-8 C
S-10 C Designated as NFA following RFI.
S-11 C Closure for Unrestricted Land Use, 12/19/2013
S-12 C Designated as NFA following RFI.
S-17 C
S-20 C
S-21 C Designated as NFA following RFI.
S-22 C Closure for Unrestricted Land Use, 12/19/2013
S-32 C Designated as NFA following RFI.
S-37 C Designated as NFA following RFI.
N-4 C
N-5 C
N-6 C
N-7 C
N-10 C Designated as NFA following RFI.
Gr
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2
BW-1 C Initially closed under an Industrial Scenario. Later qualified for
Residential NFA, 3/10/2010
BW-2 C
BW-3 C
BW-11 C
SA-2 C
BP-3 C
BW-4 C
BW-5 C
BW-7 C Closure for Unrestricted Soil Use, 11/19/2015
BW-9 C Closure for Unrestricted Land Use, 3/28/2013
Group SWMU
No.
Status
(Open/Closed)Comments/Notes
Closure for Unrestricted Land Use, 12/19/2013
Closure for unrestricted soil use, 9/21/2015.
Gr
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3
Industrial Closure determination based on soil-gas results, 10/29/2012
Closure for Unrestricted Land Use, 9/27/2012
Gr
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4
a
Closure for Unrestricted Land Use, 3/28/2013
Gr
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1
Closure for Unrestricted Land Use, 12/19/2013
Updated: 1/9/2025
Table 1 ‐ SWMU/HWMU Status
Group SWMU
No.
Status
(Open/Closed)Comments/Notes
BW-12 C Closure for unrestricted soil use, 9/15/2017.
BW-13 C Closure for unrestricted soil use, 6/29/2016
SA-3 C
S-38 C
S-13 C
S-14 C
S-15 C
S-16 C
S-33A C
S-33B C
S-9A C
S-9B C
S-19 R
Earthen sump associated with operations that did not involve NG
production. RFI Work Plan approved July 2020. Investigation began
October 2020 and has extended as needed, depending on Nitrator
scheduling.
S-23 C Closure for Unrestricted Land Use, 9/6/2016
S-25 C
S-28 C
S-29 C Closure for Unrestricted Land Use, 9/27/2013
S-30 C Closure for unrestricted soil use.
S-31 R Investigation began October 2020 and has extend into 2023. An RFI was
submitted April 2022. An RFI will be submited 2025 for North Area.
S-34A C
S-34B C
S-35 C Closure for unrestricted soil use.
S-39 R
Investigations began October 2020. An RFI was submitted August
2022. 2023 investigation showed contamination under structures. This
SWMU will have to be finished after demolition of structures.
SP-3 C
SP-4 C
SP-5 C
SP-23 C Closure for Unrestricted Land Use, 9/1/2011
BP-1 O Old Burning Grounds
BP-2 R
RFI sampling performed March and April 2020. Delineation will continue
as needed. Division coordination to occur after delineation.
BW-10 R Buried waste site (BW) RFI Work Plan was approved March 2022.
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4
b
Closure for unrestricted soil use, 9/15/2017 .
Gr
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5
Closure for Unrestricted Land Use, 10/31/2023
Closure for Unrestricted Land Use, 9/6/2016
Closure for Unrestricted Land Use, 4/20/2011
Closure for unrestricted soil use on all units received.
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6
Closed with No Further Action and Corrective Action Complete with
Controls Determination for Groundwater 9/28/2021.
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7
Updated: 1/9/2025
Table 1 ‐ SWMU/HWMU Status
Group SWMU
No.
Status
(Open/Closed)Comments/Notes
SS-2 C
Closed with No Further Action and Corrective Action Complete with
Controls Determination for Groundwater 9/28/2021.
SS-4 C Closure for Unrestricted Land Use, 11/09/2023
SS-5 R
Abandoned sumps. RFI Work Plan approved December 2021. SS-5
will impact power lines and will cleaned when poles are abandoned.
SS-11 C Closure for Unrestricted Land Use, 9/6/2016
SL-2 R
SL-3 R
SI-1 C Closure for Unrestricted Land Use, 10/31/2023
SI-2 R
Surface Impoundment (SI) receiving discharge from experimental
propellant compounds. An RFI was sumbitted summer 2024. The
Division responded with Comments for NGSC to respond to.
SA-5 C Closure for Unrestricted Land Use, 4/2017
SP-6 C Closure for Unrestricted Land Use, 10/3/2013
SP-9 C
SP-11 C
SP-12 C
SP-14 C
SP-16 C
SP-18 C
SP-19 C
SP-21 C
SP-22 C
SP-28 C Closure for Unrestricted Land Use, 4/2017
SP-29 C Closure for Unrestricted Land Use, 5/2017
SP-30 C Closure for Unrestricted Land Use, 4/2017
SP-32 C Corrective Action Completed. Report in process.
N-1 C Closure for unrestricted soil use, 9/21/2015.
N-2 C Closure for unrestricted soil use, 9/21/2015.
N-8 C Closure for unrestricted soil use, 9/21/2015.
SS-1 C Closure for unrestricted soil use, 1/31/2018.
OD-1 C
OD-2 C
OD-3 C
BP-4 C
SS-3 C Closure for Unrestricted Land Use, 9/4/2013
Gr
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1
1
Gr
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1
2
Pit 38, RFI report to be submitted July 2018.
Gr
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9
Gr
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1
0
Closure for Unrestricted Land Use, 4/2017
Closure for Unrestricted Land Use, 4/2017
Closure for Unrestricted Land Use, 4/2017
Gr
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8
Old sewage lagoons (SL) in Coon Creek basin. RFI Work Plan
approved May 2022. Investigation has begun.
Updated: 1/9/2025
Table 1 ‐ SWMU/HWMU Status
Group SWMU
No.
Status
(Open/Closed)Comments/Notes
S-24 O Non-rag discharge into sump will need to be re-routed.
S-26 O
S-27 O
S-36 O To be studied upon closing of Building 2440.
SP-15 O
SP-20 O
SP-26 O
SP-27 O
SP-31 O Cleaning pad piped to tank at 2440.
SL-4 R
RFI Work Plan approved December 2019. Work to begin when Navy
funding approved.
BG-1 O
OD-4 O
BW-6 O
Total 108
Closed 85 Closure determination has been granted from the DWMRC.
Remaining 23 12 units will require operational shutdowns to evaluate (Group 13).
Currently
Available 11
RFI/CMI
Process
Initiated
10 Includes RFI or CMI Plan submitted for approval or Field Investigation
initiated
Closure
Submitted 0 Includes RFI or CMI Report submitted for approval.
Note: Gray shading indicates unit will remain "Open" until process area is permanently closed.
Earthen sumps now covered by Building 2300. Evaluate after process
building no longer needed.
Gr
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1
3
NIROP/Environmental Garages - Evaluate after buildings are closed.
Will not be studied until wastewater tanks associated with spills are
closed and removed.
Note: Red lettering designates the unit is a HWMU.
Units will be studied following closure of burning grounds.
Updated: 1/9/2025