DSHW-2024-005099

Northrop Grumman Systems Corporation
P.O. Box 98
Magna UT, 84044
www.northropgrumman.com
February 26, 2024
Mr. Doug Hansen, Director
Div of Waste 'v1anagerr>ent
and Radiation Control
FEB 2 S 2024
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah 84114-4880
NORTHROP1
GRUMMAN I
Re: Northrop Grumman Systems Corporation, NIROP Facility. EPA ID No. UT3170027277
Open Burning Report for Calendar Year 2023
Dear Mr. Hansen:
The Subpart X Treatment Permit for the NIROP Burning Grounds requires annual reporting on
open burning activities. Requirements for this report are identified in Permit Conditions 11.G.2.
through 11.G.2.f. Each of these Permit conditions is addressed in the attached report.
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.
Sincerely,
~
Kris H Blauer
Manager, Environmental Services
CC: Hao Zhu
2023 Annual Report on Open Burning Activities
Permit Conditions 11.G.2.a. & 11.G.2.b. -Permit conditions 11.G.2.a. and 11.G.2.b require
reporting on the types and quantities of reactive hazardous wastes treated at the NIROP Burning
Grounds including all donor and ignition materials as well as a calculation of the TCDD Toxic
Equivalents (TEQs) emitted from open burning activity. These quantities and corresponding
TCDD TEQs are presented in Table I in Attachment 1. The total amount of reactive waste
burned on site in calendar year 2023 was 81,918 pounds. The amount of donor and ignition
materials required to support open burning (labeled as ignition powder, combustibles, and diesel
fuel in Table I) was 9,735 pounds. Combining these two amounts results in the total amount of
material burned in calendar year 2023 of 91,653 pounds. This is less than the maximum
allowable of 160,000 pounds as specified in permit condition IV.C.1.f.
Permit condition 11.G.2.b. limits the amount of TCDD TEQ that can be released annually from
the NIROP Burning Grounds to 2.32 milligrams per year. This is calculated by multiplying the
weight of each type of waste burned by a corresponding emission factor listed in Permit
condition 11.G.2.b.
Table I lists the dioxin TEQ emission factor assigned to each type of waste. Table II provides a
rationale for how the appropriate dioxin TEQ emission factor was assigned to each category.
Summing the contribution of each type of waste burned arrives at 1.03 milligrams of TCDD
TEQs emitted in calendar year 2023. This is less than the permitted allowable of 2.32 milligrams
per year.
Note that one category of waste (dry ingredients) and one category of donor material (diesel fuel)
had to be split into two separate subcategories to permit an accurate calculation of TCDD TEQ.
These categories were split into one subcategory reflective of Class 1.1 waste (lower TCDD
TEQ emission factor) and another subcategory reflective of Class 1.3 waste (higher TCDD TEQ
emission factor).
Permit Condition 11.G.2.c. -Permit condition 11.G.2.c. requires an evaluation of the emission
factors used in the Human Health Risk Assessment (HHRA) conducted in support of the NIROP
Burning Grounds.
The emission factors used for the HHRA were developed based on analytical testing conducted
at the Bang Box at the Dugway proving ground in 1997. After amendment based upon review
by the Division, emission factors from the Bang Box were accepted for use in the HHRA in
2004. The tests were conducted on a mixture of Class 1.1 propellant and ancillary materials
(wipes, gloves, plastic, etc.) used in the production of this Class 1. 1 propellant.
No material change has occurred to either the ingredients, formulation process or ancillary
materials used to manufacture this Class 1.1 propellant since completion of the Bang Box testing
in 1997. Northrop Grumman Systems Corporation (NGSC) believes that the Bang Box emission
factors are and continue to be representative of the emissions produced from open burning of
these materials at the NIROP Burning Grounds.
The other main product produced at the NGSC Bacchus facility is Class 1.3 propellant. While
most Class 1.3 waste is shipped to the NGSC Promontory facility for treatment, a small amount
that cannot be easily shipped remains at the Bacchus facility for treatment. Class 1.3 emission
factors were developed based upon testing conducted at the Dugway ODOB facility in 2006.
These emission factors have since been incorporated into the NIROP Subpart X permit in
condition 11.G.2.b. as a replacement for previously used estimates.
Permit Condition 11.G.2.d. -Permit condition 11.G.2.d. requires a review of the HHRA to
determine whether 1) cancer slope factors and reference doses used in the HHRA are still
applicable and 2) whether the potential human health risk scenarios identified in the HHRA have
not changed.
This review is partly addressed by a report from Geosyntec consultants included as Attachment
2. Geosyntec is an environmental contractor assisting NGSC with risk assessment matters. This
report concludes that there has been no change to slope factors and reference doses for
carcinogenic and non-carcinogenic chemicals of concern for the HHRA in the last year.
With regard to human health risk scenarios, the HHRA completed in September 2005 was
divided into a Tier 1 analysis for adult and child residents and a Tier 2 analysis for a subsistence
farmer. Risks for adult and child residents were found to be acceptable at the location of
maximum impact along the NGSC fence line.
The Tier 2 analysis for the subsistence farmer found that the risk to the farmer exceeded the risk
goal of 1 x 10-6 in the nearest area zoned for agricultural activity with the determined risk being 4
x 10-6 . The risk was primarily driven by exposure to TCDD TEQ from ingestion of dairy
products. While the risk goal was not met, it was also determined that this risk pathway was
incomplete as no subsistence farmers live in the nearby agricultural area. A recent review of this
agricultural area has determined that this pathway is still incomplete as neither subsistence
farmers nor dairy cows exist in this area.
No other human health exposure pathways have been discovered since completion of the
HHRAs.
After review of the human health scenarios, NGSC believes that operation of the NIROP
Burning Grounds poses acceptable health risks to residents provided the facility is operated
within the constraints of the NIROP Subpart X permit. NGSC will continue to monitor the
nearby agricultural area for the presence of a subsistence farmer to assure that further
consideration can be given to this pathway if it is completed.
Permit Condition 11.G.2.e. -Permit condition 11.G.2.e. requires a review of the acute human
health risk assessment (hereafter referred to the acute HHRA) that was accepted by the Division
on March 10, 2010. The review is to determine if any of the reference doses or one-hour
exposure factors for non-carcinogenic health effects have changed. The applicability of the
exposure model used in the acute HHRA must also be reviewed.
Two different sets of exposure factors were used for the acute HHRA including 1) Acute
Exposure Guideline Levels (AEGLs) developed by the EPA and 2) Toxic Screening Levels
(TSLs) developed by the Utah Division of Air Quality (DAQ).
The list of AEGLs was not updated by the EPA in Calendar year 2023. None of the exposure
values for any of the interim and final AEGLs changed this year. In summary, there were no
changes to AEGLs this year that affected the acute HHRA. TSLs as listed on the DAQ website
were not updated in Calendar year 2023. No new acute chemicals were added to the TSL list.
Based on the same list of AEGLs and TSLs, the overall conclusion of the acute HHRA remains
the same in that no acute health risks were identified from exposure to NIROP Burning Grounds
emissions.
With regard to the exposure model used for the acute HHRA, the exposure model is based on the
modeling performed for the overall NIROP Burning Grounds HHRA described in the above
discussion for Permit Condition 11.G.2.c. Both NGSC and the Division agreed upon use of the
Open Burning and Open Detonation Model (OBODM) for this document.
Permit Condition 11.G.2.f. -Permit condition 11.G.2.f. requires a discussion of soil sampling as
described by the Soil Monitoring Plan (Attachment 9 to the NIROP Subpart X Permit).
Note that the frequency for soil sampling is set by Permit condition IV.K.4. and can be adjusted
via a letter from the Division. The soil monitoring report for Calendar year CY2015 provided a
rationale for why NGSC believed that this sampling frequency could be reduced to every 5 years.
The Division reviewed and accepted this change via a letter dated April 26, 2016. Accordingly,
soil sampling was not conducted in CY2023 and is not due until CY2025.
Attachment 1
Open Burning Amounts and Dioxin TEQ Calculation for Calendar Year 2023
Ca lendar Year
2023
(All Va lu es in
Po und s except
for Diox in TEQ
em itted )
Wa ste St ream
Ass o ci ated Di ox in TEQ
Em issi on Factor
Li qu id Explosives Class 1.1 Prop ell ant &
Contam inated
2.89E -1 1 2.89E -11
10959 195 92
Table I
Open Burning Amounts and Dioxin TEQ Calculation for Calendar Year 2023
Ca t ch Ta nk Laborat ory W ast e Cla ss 1.1 Dry Clas s 1.3 Dry Cla ss 1.3 Bul k Cla ss 1.3 NG Rem over To t al Weig ht Ignitio n Powde r Combust ibles Total Diese l Fue l Die sel Fuel prorated for Diese l Fuel Prorat ed for Mill igrams of
(K044 was t e) In gredients Ingredients Prop ell ant Contaminat ed for Period (Ba se Grai n) (c ardbo ard, wood ) Cla ss 1.1 materi al s Class 1.3 m at eria ls Dioxin TEQ emitted
2.89E -11 2.89E -11 2.89 E-11 1.28 E-10 5.20E -12 1.28E -10 2.89 E-11 2.89 E-11 2.89E -11 2.89 E-11 1.28E -10
529 7445 12306 1588 29381 11 8 0 81 9 18 5401 54 9 3785 2349 1436 1.03
Table II
Rationale for Assignment of Dioxin TEQ Emission Factors
No ammonium perchlorate (AP) in liquid explosive slums, less chlorine than Class 1.1 propellant waste -use Class
Liquid Explosives 1.1 em ission factor.
Basis for the Class 1.1 em ission factor
Class 1.1 Propellant & Contaminated
Only operations that produce K044 waste is wet machining of Class 1.1 propellant, use Class 1.1 emission factor
Catch Tank (K044 Waste)
Nearly all laboratory work associated with the manufacture of nitroglycerine or chemical stability analysis of Class
Laboratory Waste 1.1 propellant. Very little Class 1.3 propellant or AP in lab waste, use Class 1.1 emission factor.
Dry ingredients generated in same proportion as Class 1.1 propellant, use Class 1.1 emission factor.
Class 1.1 Dry Ingredients
Dry ingredients generated in same proportion as Class 1.3 propellant, use Class 1.3 emission factor.
Class 1.3 Dry Ingredients
Use Class 1.3 emission factor for bulk Class 1.3 p r opellant that does not contain any contaminated materials.
Class 1.3 Bulk Propellant
Use Class 1.3 emission factor
Class 1.3 Contaminated
No ammonium perchlorate (AP) in NG remover waste, less chlorine than Class 1.1 propellant waste -use Class 1.1
NG Remover emission factor.
No ammonium perchlorate (AP) in ignition powder, less chlorine than Class 1.1 propellant waste -use Class 1.1
Ignition Powder (Base Grain) emission factor.
Combustibles primarily used to support burning of Class 1.1 waste including cardboard used with liquid explosive
Combustibles (cardboard, wood) waste and pallets used to help burn wet Class 1.1 machining waste -use Class 1.1 emission factor
Diesel Fuel prorated for Class 1.1 Prorated for the amount of Class 1.1 waste burned -use Class 1.1 emission factor
Materials
Diesel Fuel prorated for Class 1.3 Prorated for the amount of Class 1.3 waste burned -use Class 1.3 emission factor
Materials
Attachment 2
Geosyntec Report
Review of Toxicological Dose-Response Factor for Human Health Risk Assessment Drivers
Geosyntec C>
consultants
Date: February 7, 2024
Memorandum
215 South State Street, Suite 500
Salt Lake City , UT 84111
PH 801.853 .8308
www.geosyntec .com
To: Robert Weston, Northrop Grumman Systems Corporation (NGSC)
Bacchus Facility, Magna, Utah
From:
Subject:
Caitlin Johnson , Ph.D., and Juliann Chen , MPH, Geosyntec Consultants
Annual Review of Toxicological Dose-Response Factors for Human
Health Risk Assessment Drivers for the Bacchus Open Burning Permit
INTRODUCTION
The purpose of this memorandum is to provide the results of an annual review of toxicological
dose-response factors related to the compounds identified as risk-driving compounds of concern
(COCs) in the Bacchus facility Burning Grounds human health risk assessment (HHRA) to
determine if they have changed since the last review was conducted by Geosyntec in 2023
(Geosyntec 2023). This work is conducted annually to support NGSC's compliance with the
Bacchus Facility Resource Conservation and Recovery Act (RCRA) Subpart X condition 11.G.2.d.
The COCs for Bacchus are the chemical compounds 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD),
dibenz[ a,h ]anthracene (OBA), benzo(a)pyrene (B[a]P), hexachlorobenzene , pentachlorophenol,
and perchlorate (URS 2005 ; Geosyntec 2023). This memorandum does not address or review
changes in draft documents that have not been finalized by the United States Environmental
Protection Agency (EPA).
The hierarchy used in this review is consistent with the letter from the Utah Department of
Environmental Quality (UDEQ), Division of Solid and Hazardous Waste (DSHW) dated June 18 ,
2012, to Mr. Robert Ingersoll, A TK, and is as follows:
Tier 1 -EP A's Integrated Risk Information Systems (IRIS) Database -The United States
Environmental Protection Agency's (EPA's) peer reviewed on-line toxicological database
(2024a). IRIS includes documents that have undergone peer review and approval through EPA's
review process. Based on EPA' s 2003 memorandum on the selection of dose-response information
(EPA 2003), IRIS is the first and primary source of toxicological information.
engineers I scientists I innovators
Dose-Response Factor Review
February 7, 2024
Tier 2-EPA's Provisional Peer Reviewed Toxicity Values (PPRTVs)-The Office of Research
and Development/National Center for Environmental Assessment/Superfund Health Risk
Technical Support Center (STSC) develops PPRTVs on a chemical specific basis when requested
by EPA's Superfund program.
Tier 3 -Other Toxicity Values -Tier 3 includes additional EPA and non-EPA sources of toxicity
information. Priority should be given to those sources of information that are the most current, the
basis of which is transparent and publicly available, and which have been peer reviewed.
The above guidance on the hierarchy for the selection of toxicological dose-response factors was
followed in this review.
COCREVIEW
Tier 1 -COC Review
An online search of the IRIS database (EPA 2024a) was conducted in January 2024 to determine
whether there have been any changes to toxicity data since 2023. There were no changes to the
noncancer or cancer dose-response values in IRIS since the last review in 2023 (Geosyntec 2023).
Tier 2 -COC Review
An online search of the PPRTVs database (EPA 2024b) was conducted in January 2024 to
determine whether there have been any changes to toxicity data since 2023. There were no changes
to the noncancer or cancer dose-response values in the PPRTV database since the last review in
2023 (Geosyntec 2023).
Tier 3 -COC Review
The EPA's Regional Screening Levels (RSLs) Table (EPA 2024c) was used as the primary source
for Tier 3 sources of dose-response information for the listed COCs. There were no changes to
Tier 3 dose-response values for TCDD or pentachlorophenol since the last review in 2023.
Tier 3 dose-response values were available from California Environmental Protection Agency
(CalEPA). The process for evaluating TCDD toxic equivalents (TCDD-TEQ) has not changed
between 2023 and 2024, and the toxicological dose-response information used by URS in 2005,
2012 and 2013 (URS 2005; URS 2012; URS 2013) remains the same (CalEPA 2008; CalEPA
2009).
CalEPA (2011) has an Inhalation Unit Risk Factor for pentachlorophenol. This was used by URS
and has not subsequently been revised by the EPA or CalEP A.
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February 7, 2024
CONCLUSION
Based on our review, the dose-response factors shown in Table 1 are the most current and inclusive
of Tiers 1, 2, and 3 ofEPA's hierarchy for the COCs identified for Bacchus. The dose-response
factors required by the Utah Division of Waste Management and Radiation Control for the COCs
are the most likely to be required in a subsequent Open Bum/Open Detonation HHRA, until these
factors change.
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February 7, 2024
REFERENCES
CalEPA 2008
CalEPA 2009
CalEPA 201 I
EPA 1988
EPA 1991
EPA 1993
EPA 2003
EPA 2005
2,3, 7,8 -Te trachlorodib enzo-p-dioxin and related compounds. Chronic REL.
California Office of Environmental Health Hazard Assessment (OEHHA)
Accessed in January 2024.
https ://oehha.ca.gov/media/downloads/crnr/appendixd3final.pdf
2,3, 7,8-Tetrachlorodib enzo-p-dioxin and relate d compounds. Cancer
Potency Information. California Office of Environmental Health Hazard
Assessment (OEHHA) accessed in January 2024.
https :/ /oehha.ca.gov /chemicals/23 78-tetrachlorod ibenzo-p-dioxin-and-
related-compounds
Pe ntachlorophenol , Cancer Potency Information . California Office of
Environmental Health Hazard Assessment (OEHHA) accessed in January
2024. https://oehha.ca.gov/chemicals/pentachlorophenol
Hexachlorob e nzene , Noncancer Assessment, Integrated Risk Information
System , EPA On-line database accessed in January 2024 .
https://iris .epa.gov/ChemicalLanding/&substance nmbr=374
Hexachlorobe nze ne, Cancer Assessment, Integrated Risk Information
System , EPA On-line database accessed m January 2024.
https://iris.epa.gov/Chemica!Landing/&substance nmbr=374
Provisional Guidance for Quantitative Ris k A ssessm ent of Polycyclic
Aromatic Hydrocarbons , EPA/600 /R-93/089 , July 1993 , Environmental
Criteria and Assessment, Office of Health and Emergency Assessment, U.S.
Environmental Protection Agency , Cincinnati , OH, 45268
Human Health To x icity Values in Superfund Risk Assessment, OSWER
Directive 9285.7-53 , Office of Solid Waste and Emergency Response , U .S.
Environmental Protection Agency , Washington D.C ., December
Perchlorate (Cl04) and Perchlorate Salts, Integrated Risk Information
System , EPA On-line database , accessed m January 2024.
https://iris.epa.gov/ChemicalLanding/&substance nmbr=I 007
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Dose-Response Factor Review
February 7 , 2024
EPA 2010a
EPA 2010b
EPA 2012
EPA 2017
EPA 2024a
EPA 2024b
EPA 2024c
Geosyntec 2023
URS 2005
Development of a Relative Potency Factor (RPF) Approach for Polycyclic
Aromatic Hydrocarbon (PAH) Mixture s (External Review Draft). U.S.
Environmental Protection Agency , Washington D.C., EPA/635/R-08 /012A.
Pentachlorophenol, Integrated Risk Information System,
database, accessed m January
https://iris.epa.gov/ChemicalLanding/&substance nmbr=86
EPA On-line
2024.
2, 3, 7, 8-Tetrachlorodibenzo-p-dioxin , Integrated Risk Information
EPA On -line database , accessed in January
https :/ /iris.epa.gov /Chem icalLanding/ &substance nmbr= 1024
System ,
2024.
Benzo[a]pyrene (BaP), Integrated Risk Information System , EPA On-line
database , accessed m January 2024 .
https://iris.epa.gov/ChemicalLanding/&substance nmbr=l 36
Integrated Risk Information System . U .S. Environmental Protection Agency
(EPA) Center for Public Health and Environmental Assessment, Office of
Research and Development. Website accessed in January 2024.
https://www.epa .gov /iris
EPA Provisional Peer Reviewed Toxicity Values for Superfund; accessed in
January 2024. https://www.epa.gov/pprtv /provisional-peer-reviewed-
toxicity-values-pprtvs-assessments
Regional Screening Levels for Chemical Contaminants at Superfund Sites ,
accessed in January 2024. https://www.epa.gov/risk/regional-screening-
levels-rsls
Literature Review of Toxicological Dose-response Factors for Human Health
Risk Assessment Drivers for the Bacchus Open Burning Permit, a
Memorandum from Caitlin Johnson and Stephen Foster to Robert Weston ,
Bacchus Facility , Magna, Utah, January 24.
Human Health Risk Assessment in Support of the Alliant Techsystems '
Bacchus Works RCRA Subpart X Activities, Prepared for Alliant
Techsystems, Inc., Magna , Utah. Prepared by URS Corporation, Salt Lake
City , Utah , September
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URS 2012
URS 2013
Bacchus Worker Human Health Risk Assessment in Support of the ATK
Aerospace Bacchus Works RCRA Subpart X Activities, Prepared for Alliant
Techsystems, Inc., Magna, Utah. Prepared by URS Corporation, Salt Lake
City, Utah, October
Addendum to the Human Health Risk Assessment in Support of the ATK
Aerospace Bacchus Works RCRA Subpart X Activities, Prepared for Alliant
Techsystems, Inc., Magna, Utah. Prepared by URS Corporation, Salt Lake
City, Utah, February
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Table 1
Summary of COC Dose-Response Values Available for Use at Bacchus
Compounds of Reference Reference Oral Cancer
Dose Source Concentration Source Slope Factor Source Concern (mg/kg-day) (mg/m3) (mg/kg-day)·1
2,3,7,8-TCDD 7 X lQ•lO EPA2012 4 X 10"8 CalEPA 1.3 X 105 CalEPA
2008 2009
Benzo[a]pyrene 3 X 10-4 EPA 2017 2 X 10"6 EPA 2017 1.0 EPA 2017
Dibenz[ a,h ]anthracene Not available Not available 1.0 EPA 2017t
Hexachlorobenzene 8x 10-4 EPA 1988 Not available 1.6 EPA 1991
Perchlorate ( as 7 X 10-4 EPA2005 Not volatile Not a EPA2005 ammonium salt) carcmogen
Pentachlorophenol 5 X 10"3 EPA 2010b Not available 4 X 10"1 EPA 2010b
Abbreviations and Notes
mg/kg-day milligrams per kilogram per day
mg/m 3 milligrams per cubic meter
(µg/m3)"1 risk per microgram per cubic meter
2,3,7,8-TCDD 2,3, 7 ,8-tetrachlorodibenzo-p-dioxin
IRIS Integrated Risk Information System
EPA U.S. Environmental Protection Agency
t Based on Benzo[a]pyrene toxic equivalent, Table 2 (EPA 2010a).
7
Inhalation
Unit Risk Source
(µg/ml)-1
3.8 X 10 1 CalEPA2009
6x 10-4 EPA 2017
6x 10-4 EPA2017t
4.6 X 10-4 EPA 1991
Not a EPA2005 carcinogen
5.1 X 10"6 CalEPA 2011
Dose-Response Factor Review
February 7, 2024
Table2
Relative Potency of Polynuclear Aromatic Hydrocarbonstt
Polynuclear Aromatic Hydrocarbons Potency Relative to Benzo[a]pyrene
Benzo [ a ]pyrene 1.0
Benzo [ a ]anthracene 0.1
Benzo[b ]fluoranthene 0.1
Benzo [k ]fluoranthene 0.01
Dibenz[ a,h ]anthracene 1.0
Chrysene 0.001
Indeno[l ,2,3-cd]pyrene 0.1
tt Based on EPA, 1993
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