DSHW-2018-003082 - 0901a068807e4713

ffi
State of Utah
GARY R. HERBERT
Govemor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DTVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
April 12,2018
Kris H. Blauer, Manager
Environmental Services
Orbital ATK Bacchus Facility: Plant I
P.O. Box 98
Magna, UT 84044-0098
RE: Class I Permit Modification
Attachment 8, Closure Plan
Hazardous Waste Storage Permit
Orbital ATK -Bacchus Plant 1 Facility
uTD001705029
Dear Mr. Blauer:
The Division of Waste Management and Radiation Control has completed its review of your
March 31, 2018 request for a Class 1 permit modification for Attachment 8, Closure Plan of the
Hazardous Waste Storage Permit for ATK Launch Systems-Bacchus Plant I facility. The modification
will revise the closure plans for ES-1, Segment Storage and Resthouse 1. The request is hereby
approved with minor changes of typos and references to the Utah Administrative Code. Enclosed please
find a copy of Attachment 8, Closure Plan, as modified.
The Division has updated its copy of the Hazardous Waste Storage Permit with the modified closure
plan. Please update all copies of the permit maintained by Orbital ATK.
If you have any questions, please call Hao Zhu at [phone].
Sincerely,
Scott T Anderson, Director
Division of Waste Management and Radiation Control
195 North 1950 West. Salt lake City, UT
Mailing Address: P.O. Box l,+4880. Salt lake Ciry, UT 84114-4880
Telephone [phone]. Fax [phone]. T.D.D. (801) 5364284
tntru.ileq.utah.goo
Printed on 1007o recycled paper
DSHW-2o18-003082
(Over)
STA/HZlkm
Enclosure: Attachment 8, Closure Plan
c: Gary Edwards, MS, Health Officer, Salt Lake County Health Dept.
Royal Delrgge, MPA, EHS, Environmental Health Director, Salt Lake County Health Dept.
Jesse Newland, USEPA, Region 8
Chris Falkenberg, Orbital ATK
ATK Launch Systems
Bacchus
uTD001705029
Part B Operation Plan
Closure Plan
Modified April 2018
ATTACHMENT 8
CLOSURE PLAN
ATK Launch Systems
Bacchus
uTD001705029
Part B Operation Plan
Closure Plan
Modified April 2018
8.0 CLOSURE PLAN
The closure plans described in this section of the permit identifies how ATK-Bacchus will close the
regulated units located on Plant 1. Plans have been developed for the closure of the following
hazardous waste storage units:HS-1, ES-1, Segment Storage, and RH-1.
8.1 CLOSURE PLANS AND CLOSURE COSTS ESTIMATBS
In developing closure plans for the hazardous waste storage units, ATK-Bacchus used the requirements
of R315-264-110 through 120 and R3l5-264-178 of the Utah Administrative Code (Utah Admin.
Code).Utah Admin. Code The closure cost estimates are to be submitted to the Director for review and
approval as required by the Permit and shall be made in accordance with R3l5-264-140 through 151 of
the Utah Admin. Code. The closure cost estimates shall be maintained in the operating record.
ATK-Bacchus assumed, for the purposes of estimating the closure costs, that all of the hazardous waste
management units were filled to their respective maximum waste storage capacities as identified in the
RCRA Part A Permit Application for Plant l. If storage capacities change, the Permit will be modified
and a revised cost estimate will be sent for review and approval.
Rocket motors stored at ATK-Bacchus that are classified as "hazardous waste," will be transported to
an off-site TSDF for treatment and disposal. On occasion, it may be necessary to treat a hazardous
waste rocket motor on-site due to transportation restrictions.
8.2 CLEAN.UP APPROACH
The Part A and Permit for Plant I only authorized ATK-Bacchus to store hazardous waste. The units
identified in the Part A have not been used for treatment or disposal of hazardous waste. The source of
any contamination occurring in these containment buildings should be limited to spills onto concrete or
asphalt surfaces during the operational life ofthese units. Storage units actively used to store hazardous
waste during the permit will be cleaned using steam and/or high-pressure water until surfaces are
decontaminated. This method has been routinely used at ATK-Bacchus to clean various areas as a part
of normal plant maintenance. Wash water will be collected using permanent berms and sumps, or if
necessary temporary berms to prevent contaminating the area sunounding the units. Past experience
indicates that contaminant levels in the cleanup wash water will be minimal, and after characterization
the water can meet discharge limits for a POTW or UPDES discharge permit. Therefore, it is not
anticipated that the wastewater generated during closure will require special handling. The wastewater
will be collected according to ATK-Bacchus practices, it will then be stored, tested, and disposed. If it
is determined that the wastewater cannot meet discharge limits, it will be characteized and disposed of
in accordance with applicable rules and regulations.Because of the hazardous nature of the explosive
materials on site and complex plant safety procedures, facility personnel will be involved in closure
activities more than would be the case at other types of facilities. For cost-estimating purposes, it was
assumed that a third-party consulting firm will be employed to clean the explosive storage units after
explosive materials have been removed, conduct verification sampling, and write the final closure
reports.
Once the hazardous waste storage units have been decontaminated and verified clean, ATK-Bacchus
will submit a written report to the Director requesting concurrence on the closure certification. Before
any unit is determined to be clean closed, ATK-Bacchus must have boncurrence from the Director of
the Utah Division of Solid and Hazardous Waste. The final disposition of any unit that has been clean
closed will be the prerogative of ATK-Bacchus or the current proprietor of the facility. If a unit cannot
be clean closed ATK-Bacchus will develop an appropriate and applicable post-closure care mechanism.
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CLEAN CLOSURE CRITERIA
For the purposes of estimating closure costs, it is assumed that all of the regulated units will be clean
closed. Clean closure can be achieved by meeting the clean closure equivalency as defined in R315-
101-6(cX1) of the Utah Admin. Code. All closures will assess real and potential impacts to human and
ecological exposures.
Three types of samples will be necessary to determine if these units can be clean closed including soil
samples, wipe samples and final rinse samples.
Soil samples will be evaluated using Regional Screening Levels for Contaminants of Concern at
Superfrrnd Sites, November 2017, (RSLs). RSLs are now used by USEPA Regions and will be used to
screen the data under a residential land-use scenario and a protection of gtound water soil screening
scenario. RSL goals will be established prior to implementing any of the closure plans in this section.
ATK will use the most current screening levels published by USEPA, or they can establish site-specific
risk-based clean closure goals in accordance with R315-101-5 .2 of the Utah Admin. Code. RSL
screening goals are developed in Section 8.4 below. Note that residential soil RSLs will be divided bv a
factor of l0 to account for cumulative risk.
Wipe samples will be evaluated using the Hehlth Risk Assessment Methods and Screening Levels for
Evaluating Office Worker Exposures to Contaminants on Indoor Surfaces Using Surface Wipe Data as
prepared by the U.S. Army Center for Health Promotion and Preventative Medicine. This document
developed surface wipe screening levels (SWSL) for numerous chemicals based on standard risk
assessment techniques. To account for cumulative risk, the SWSL screening levels developed by the
U.S. Army will be divided by a factor of 10. SWSL screening goals are developed in Section 8.4
below.
Note that wipe samples are not suitable for evaluation of volatile chemicals. Final rinse samples will be
taken where such analysis is required (HS-l only). Such samples will be taken at the completion of
cleaning activities from the final rinse of the applicable building. These will be aqueous samples with
results compared to RSL standards for residential tapwater. Note that residential tapwater RSLs will be
divided by a factor of l0 to account for cumulative risk.
VERIFICATION SAMPLING APPROACH
To determine whether each hazardous waste management unit has been successfully decontaminated
and cleaned up, ATK-Bacchus will use the following techniques:
o Core samples or subsurface soil samples will be collected from the floors in buildings
where liquid hazardous wastes were stored, and from locations where porous flooring
materials are present. Sample locations will be biased toward visible staining or other
indication of potential contamination, such as the source of the material, coloration, or floor
integrity. Cores obtained from the floors will penetrate the floor to a soil depth of at least 6
inches. The top 6 inches of soil will be used for taking soil samples. If additional material
is needed for analysis, additional cores will be collected by co-locating additional cores
near the original sample point. In situ samples will always be discrete samples and not
composited.
o Wipe samples will be collected from the wall and floor surfaces in the buildings when
applicable. The sample will be collected by wiping the surface of a designated area using a
10 cm X 10 cm template with a piece of solvent moistened gauze to remove any remaining
contaminants. The wipe will be placed in to a glass vial for storage and transport. Samples
will be handled according to applicable sample preservation and chain-of-custody
requirements.
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Modified April 2018
Final rinse water samples will be collected in buildings where nonJiquid hazardous wastes
were stored and from all non-porous surfaces. The rinse water samples will be analyzed
and evaluated to determine whether the exposed surfaces of the buildings have been
adequately decontaminated.
Soil samples will be collected where the potential existed for hazardous waste materials to
be transported to soil areas surrounding the designated building area. Samples will be
collected in areas with the greatest potential to have received waste materials, visible
staining of soil, or other indication of contamination. Each sample collected for volatile
organic compound analysis will be a discrete sample. However, the samples collected for
non-volatile compounds may be composited within the sample interval. Analytical results
will be compared with closure performance standard presented for the specific hazardous
waste management unit.
Prior to implementing the closure plans described in this section of the application, ATK-
Bacchus will develop Data Quality Objectives (DQOs) for all verification samples. The
DQOs will be submitted to the Director for approval prior to implementing any of the
closure plans.
Units ES-l, Rest House I (RH-l) and Segment storage are proposed for closure in CY
2018. The data quality objectives for this effort in terms of minimum reporting limits,
RSLs for residential soils, RSLs for ground water soil screening (ground water SSLs) and
SWSL screening levels for wipe samples are shown in Tables 8-2 and 8-3 below.
Note that the RSLs for soils and the SWSL screening levels for wipe samples have been
divided by 10 to account for cumulative risk. With regards to RSLs for ground water
protection, a Dilution Attenuation Factor of 20 has been used.
Note that there are no accepted SWSL or ground water SSL screening levels for
ammonium perchlorate. A specific risk evaluation will be conducted if soil or wipe
samples detect ammonium perchlorate.
The unit will be considered clean if the verification samples show that all contaminant
concentration levels are less than the risk-based clean closure equivalency as defined in
R315-101-6(c)(l) of the Utah Admin. Code. For the closure effort proposed in CY 2018,
these risk based values for soil samples and wipe samples are shown in Tables 8-2 and 8-3
below. If these risk values cannot be attained after initial closure activities. additional work
will be required which could include more cleaning or development of a site specific risk
assessment.
Sampling and handling will be conducted according to the requirement and protocols
established by the USEPA and the UDEQ.
All samples will be processed and analyzed by a Utah Certified Laboratory in accordance
with R444-14-3(2) of the Utah Admin. Code. Analytical and extraction methods to be used
are shown in Table 8-1.
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TABLE 8-1
Analytical Procedure
Volatiles SW-846:82608 SW-846; 5030B(W), 50355
Semi-Volatiles SW-846:8270C SW-846; 35 10C(w), 35508(5)
RCRA Metals SW-846:60108 SW-846; 3005A(W), 3050B(S)
Mercury SW-846: 7470N7471A SW-846; 7 47 0 A(VO, 747 I A(S)
Explosives SW-846: 8330 Modified SW-846: 8330 Modified
Perchlorate EPA 314.0 EPA 314.0
Tnnr,n 8-2
Mnrnon DnrncrroN GoALS AND RSL ScnnnNrxc Lnvnr,s Pnoposno
roR CY 2018 cr,osuRE oF SrcvrENr Sroucr
Parameter Soil IVIDT, .: .:.
m,glkE-,
Soil RSL"
,mg/kg
Ground WaFProtection
Soil Screening Levelb
ms/ks
Arsenic 0.01 0.068 0.03
Barium 0.9 1,500 3200
Cadmium 0.1 l.l 1.38
Chromium 1.1 N/A N/A
Lead 2 40 N/A
Mercury 0.03 2.3 0.66
Selenium -J 39 to.4
Silver 0.1 39 T6
Nitroglycerine 0.06 0.63 0.017"
HMX 0.04 390 26
RDX 0.1 0.6r 0.0054"
Perchlorate 0.06 5.5 N/A
a Soil RSL values divided by a factor of l0 to account for cumulative risk
Dilution Attenuation Factor (DAF) of 20
Method MDL for soil is higher than applicable sround water soil screenine level
b
Mrnroo DnrncrroN coALS ^-" Jil:Hfu" scnnnnnvc Lpvrm koposno
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FoR CY 2018 closuRn oF ES-l, RH-l,lNn Sncurnl,lT SToRAGE
Parametei
.,, ., '. ,'
Surface Wipe MDI
pgl100 cm2
Surface .Wipe Screening Level,l.,
|LgtlilOcm2'11''':' : ":'
Arsenic 2 o.2b
Barium 2 56
Cadmium 2 0.632b
Chromium (VI)0.02 0.0948
Chromium (trivalent)2 5,940
Lead N/A N/A
Mercury o.2 5t.2
Selenium )43r
Silver 2 57.6
Nitroglycerine I L2
HMX 2 3,760
RDX I 3.62
Perchlorate N/A N/A
u - Surface Wipe Screening kvels as developed by the U.S. Army have been divided
by a factor of 10 to account for cumulative risk.
b - Method MDL is higher than applicable surface wipe screening level
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8.5 HS.1
HS-l is a waste storage unit where non-explosive solid (non-liquid), semi-solid, and liquid hazardous and
non-hazardous wastes are stored. This unit is used to store and consolidate waste prior to off-site shipment
to an authorized TSDF. HS-l @gure 2-2.2) consists of Buildings 8562, 8567, 8568, and Sheds A-D
located south of the main structure. HS-l has a combined storage capacity of 15,900 gallons. Capacity for
each area is listed in Table 8-2 below.
',.':.: TABtn 8-4 :::l
Buu,oncc Srorucs Clpacrrres
Building
8562 4900
8567 tz00
8568 9350
Sheds A-D 450
8.5.1 Site Description
Indoor concrete floor surfaces are sealed with a commercial sealant, and the concrete joints are caulked
with silicone. The sealant provides ease of cleanup and mitigates leaks or spills from migrating into the
concrete pad.
Building 8562 (Figure 2-2.4) is an enclosed structure, built on a monolithic cement pad surrounded by a
minimum 6-inch curb on all sides. The inside dimensions of this building are 2l ft x 52 ft. The floor
slopes to the north and east. Any liquids released during the operational life of this building will be
contained and collected along the north and east side of the building. The average depth along the north
wall is 0.30 ft. The average depth along the east wall is 0.25 ft. To conservatively determine the
containment capacity the size of the containment was estimated based on a depth of 0.25 ft along both
the north and east wall. A width of 21 ft along the north wall and 35 ft along the east wall and will
cover approximately one-half the room, using a line that bisects the room running from the northwest
corner to a point about 35 ft along the east wall. The 35 ft distance along the east wall is based on the
floor elevation where liquids could start to flow through the door into the work area of Building 8657.
The containment volume for this area is calculated to hold about 700 gallons.
Building 8567 (Figure 2-2.4) is divided by a wall into two separate rooms. The west half of the building
is office space, and the east half is a work area. Wastes are only stored in the eastern half, work area, of
this building. The entire building is equipped with heat and lighting.
The floor in the work aiea of Building 8567 was constructed using a monolithic cast'concrete slab with
a 6-inch curb on the south and north walls. The inside dimensions of the work area is 24 ft x 20 ft. The
main concern is to ensure that liquids will be contained and not released through the north personnel
door. The area adjacent to the personnel door is approximately 0.12 ft higher than the surrounding floor
area. The floor forms the secondary containment in the area west of the personnel door with a liquid
collection trench forming the low point of the containment. The dimensions of the containment area are
approximately 12 ft x VI ft x O.l2 ft. The volume of this area can be approximated by calculating one-
half the volume of the rectangle or 17 ft3. The room also has a floor trench that is an architectural
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feature from the previous occupancy of the building. The average dimensions of the trench are 0.4 ft
deep, 0.5 ft wide, and24 ft long for a volume of about 5 ft'. The total volume contained in the trench
and area west of the personnel door is about22 ft3, or 165 gallons
Building 8568 @gures2-2.7 and2-2.8) is an enclosed wood-framed structure fitted with two large
overhead doors. It measures 30 ft wide x 60 ft long. This building has a concrete floor with no secondary
containment and is primarily used for the storage of nonJiquid wastes. Liquid wastes stored in this
building will be stored on pallets that provide secondary-containment.
The four wood-framed sheds each have approximate dimensions of 10 ft x 10 ft, and are located south of
Building 8562 (Figure 2-2.2). Actual dimensions vary slightly for each shed. The sheds are designated A,
B, C, and D. Shed A and B are used to store hazardous waste. Shed C is used to store supplies. Shed D is
a mechanical room for the facility. The sheds have a concrete floor with no secondary containment.
Shed A is used to store unique wastes such as gas cylinders and containers that may off-gas, such as water
wet aluminum powder. Waste materials are stored on shelves, in a cabinet, or on a containment pallet.
Shed B contains cabinets for storing small containers. The cabinets are constructed of steel with
dimensions 40 in. x 40 in. x 74 in. T\e storage cabinets are self-contained, with a l3-gallon capacity liquid
sump. No secondary containment is required in this shed. These small container cabinets are identical to
cabinets in Building 8562. Sheds C and D have not been used to store hazardous wastes or materials.
8.5.2 HS-l Closure Plan
The closure plan detailed in this section was developed with the assumption that HS-l can and will be
clean closed. The plan describes the procedures that will be used to clean, decontaminate, and verify
closure of all applicable structures and equipment at HS-I, and how closure standards will be
established. Any change or amendment to this plan will be done in accordance with R3l5-264-ll2(c)
and R315-264-110 through l20of the Utah Admin. Code.
8.5.3 ClosurePerformanceStandard
This unit will be clean closed by cleaning the unit until it meets the clean closure equivalency as
defined in R3l5-101-6(cXl) of the Utah Admin. Code. After closure, HS-l may be used for other
purposes, or may be demolished. Post-closure care for HS-l is not anticipated.
Numerical closure performance standards will be developed at the time of closure. It is anticipated
that the closure standards will be developed from the latest version of the following sources:
Soil samples - EPA Regional Screening Levels for Resident Soil
Soil samples - EPA Regional Screening Levels for Resident Soil to Groundwater. Initial
screening will be conducted assuming a dilution attenuation factor of 20.
Aqueous rinse samples - EPA Regional Screening Levels for Resident Tapwater (volatiles only).
' Wipe Samples - Health Risk Assessment Methods and Scfeening Levels for Evaluating Office
Worker Exposures to Contaminants on Indoor Surfaces Using Surface Wipe Data
as developed by the u.S. Army. Note that as per the listed guidance document,
wipe samples are not appropriate for volatiles analysis. Aqueous rinse samples
will be used for volatiles analysis.
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8.5.4 Operational History of Spills or Releases at HS-l
At the time this plan was written there was no history of any major spills occurring at HS-l. There
is a record of minor spills, less than one gallon, of waste material. Whenever a spill occurs, the
waste material was absorbed immediately and disposed according to the applicable regulations.
Prior to closure the operational history of HS-l will be reviewed to determine when and where
spills have occurred. It is anticipated that all spills or releases will have been contained within the
secondary containment, however, prior to closure ATK-Bacchus will examine the condition of the
floor and secondary containment and identify any cracks or gaps and determine whether the closure
plan needs to be amended.
8.5.5 Maximum Waste Inventory at HS-l
Wastes stored in HS-1 include: acids, bases, lab waste, organic compounds, paints, solvents, resins,
used oils, and other miscellaneous materials. Based on the operating history for this unit, the
maximum inventory of hazardous waste documented on-site is the maximum capacity shown in
Table 8-5.
Tmln 8-5
Suuulny oF SToRAGE CAPAcITIEs
Storage Unit Part A Capacity
HS-l (8562)4900 gal
HS-l (8s67)l2OO gal
HS-1 (8568)9350 gal
HS-l (Sheds A-D)450 gal
ES-I 20.000Ib.
Segment Storage 75.000Ib.
RH-1 150.000Ib.
8.5.6 Inventory Removal, Disposal, and Decontamination of Structure/Equipment
All hazardous wastes stored at the time of closure will be shipped to an approved TSDF. Only
authorized transporters and approved TSDFs facilities will be used. This activity will be completed
within 90 days after receiving the final volume of hazardous waste. Container storage areas,
equipment, structure, etc., will be decontaminated by steam cleaning and/or washing with high
pressure water and scrub brushes. An environmentally safe detergent or degreaser may be used.
Decontamination water will be squeegeed into the concrete sumps at the edge of the building. The
decontamination process is expected to generate approximately 500 gallons of wastewater and
residue. Structures and equipment requiring decontamination include but are not limited to the
following:
o Building floors;
o Walls where splashing may have caused contamination;
r Miscellaneous equipment permanently attached to the facility; and,
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o Building drains and sumps.
Decontamination water will be collected from the sumps or bermed areas of the floors using a wet/dry
vacuum, mop buckets, or transfer pumps into drums or containers, or will be removed by a vacuum
truck. The sumps will be cleaned using the above-described techniques and the additional
decontamination water will be collected.
8.5.7 Verification and QA/QC Samples
Verification samples will be collected separately from each storage and waste handling building at HS-
l. The storage and waste handling areas are: the chemical handling room in Building 8567, storage
areas in Building 8562 and Building 8568, and Sheds A and B.
From previous experience, contaminants in the decontamination wastewater are expected to be very
low. Wash water will be collected and, if possible, sent to a local POTW following approval or
verification that discharge limits can be met.
To demonstrate adequate decontamination, verification samples will be collected from each of the
storage and handling areas. Concrete core samples will be collected at two locations in both Buildings
8562 and 8567. Sample locations for the cores will be decided based on the discussion in Section
S.4.Final rinse samples of the floors and walls will be collected from the floor and/or sumps of all HS-l
buildings. If the area does not have a sump, then samples will be collected from bermed areas of the
floor designed to catch wash and rinse waters. One final rinse verification sample will be collected
from each building at HS-1. Wipe samples will be collected from two walls and the floor in Buildings
8562 and 8567. Wipe samples will be collected from the floor of Building 8568, Shed 'A' and Shed'B'. Samples will be collected according to the procedure described in Section 8.4.
In addition to the verification samples identified in Table 8-7 (found inthe Tables section following this
chapter), QA/QC samples will be collected as necessary. During closure activities, QA/QC samples
will be collected according to the bullets below:
o A field blank filled with de-ionized water will be exposed during sampling and analyzed for
accidental or incidental contamination.
o A trip blank sample will be collected by filling the bottle with de-ionized water and carried with
the decontamination/sampling crew to HS-1 on days where a sample-of-record will be collected
for volatile organic compound analyses. The trip blank bottles shall be handled identically to
the handling methods used for sample-of-record collection, transported within the same cooler,
and subjected to the same analyses.
o One (l) blind duplicate sample will be collected for each ten (10) verification samples collected
(rounded up to the next greatest multiple of 10).
Table 8-7 identifies the number of verification and QA/QC samples that will be collected form each
storage and handling building at HS-1. Samples will be properly labeled, sealed, and sent to a certified
analytical laboratory for testing. Samples will be handled under USEPA chain-of-custody and sample
preservation protocols. No residue'or contamination is expected to remain on or in the structureS and
equipment following the decontamination process. Structures and permanent fixtures may be kept for
future use. There is no intention to break up and dispose of the concrete pads or catch basins. prior to
re-use of the HS-1 facility, ATK-Bacchus will have the structural integrity of HS-l examined by a
competent structural engineer to determine whether it has been compromised. The engineer will
document the results of the examination.
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8.5.8 Closure Report and Certification
Upon completion of the closure a written report will be provided to the Director certifying that the
closure was completed in accordance with the plan. The report will include a summary of the
operational history of HS-1, copies of all analytical results generated during closure operations, copies
of the QA/QC data, data validation reports, copies of manifests that accompanied off-site shipments,
characterization of decontamination water/residue, documentation that the closure of HS-l met the
performance standard identified in Section 8.5.3, a closure certification, and a copy of the structural
integrity examination report. A certification of closure according to R315-264-1 15 of the Utah Admin.
Code will be submitted by registered mail to the Director within 60 days of the completion of the final
closure.
E.5.9 Schedule for Closure
Final closure is expected to be initiated within 30 days of receipt of the final volume of hazardous
wastes. If more time is required, ATK-Bacchus will submit a request to the Director. All hazardous
wastes will be removed or treated within 90 days of (l) plan approval, or (2) after receiving the final
volume of hazardous waste, whichever comes latest. Final closure activities will be completed within
180 days of (1) plan approval, or (2) after receiving the final volume of hazardous waste, whichever is
later.
8.5.10 Post-Closure Care
The closure plan described above anticipates that HS-l will be clean closed and will not require post-
closure care. ff at the conclusion of the closure activities it is determined that any part of HS- 1 cannot
be clean closed, ATK-Bacchus will develop an appropriate and applicable post-closure care plan for all
areas of this unit that cannot be clean closed. Any proposal for post-closure care will be developed in
accordance with R315-264-110 through 120 andR3I5-264-I40 through 151 of the Utah Admin. Code,
and submitted to the Director for approval.
8.5.11 Closure Cost Estimate
The cost estimate for the closure of HS-l will be maintained in the operating record.
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8.6 ES-l
ES-l is a hazardous waste storage unit that is used by ATK-Bacchus for the storage of propellant
and explosive wastes.
8.6.1 Site Description
ES-l is a totally enclosed concrete and steel structure, with a leadlined floor. The building was
originally constructed in 1961 for storing and weighing dry propellant ingredients. Except for the
south-facing dock area, the sides are bunkered with gravel and sand. The earthen berm is held in
place by wooden beams on the south side. The purpose of the berm is to minimi ze the potential
hazard to facilities, equipment, and personnel in the event of a detonation within the building. ES-1
has the capacity to store up to 20,000 pounds of explosives or flammable solids. Figure 2-2.10
provides a floor plan and a typical storage configuration. The building is shown inFigure 2-2.9.
ES-l has two storage areas that are separated for the storage of non-compatible containerized
wastes. The floor is electrically-conductive for the continuous grounding of personnel. The floor is
elevated to truck-bed height to facilitate loading and unloading operations. The building is
protected by a deluge sprinkler system. Fire symbols appropriate for the greatest explosive waste
hazard are clearly posted on the exterior of the building.
8.6.2 ES-l Closure Plan
The closure plan detailed in this section was developed with the assumption that ES-1 will be clean
closed. The plan describes the procedures that will be used to clean, decontaminate, and verify closure
of all applicable structures and equipment at ES-1, and how the closure standard will be established.
Any change or amendment to this plan will be done in accordance with R3l5-264.112(c) andR3l5-
264-110 through l2O of the Utah Admin. Code.
8.6.3 ClosurePerformanceStandard
This unit will be clean closed by cleaning the unit until it meets the clean closure equivalency as
defined in R315-101-6(cX1) of the Utah Admin. Code. After closure. ES-l will be demolished.
Post-closure care for ES-1 is not anticipated.
8.6.4 Operational History of Spills or Releases at ES-l
All wastes stored at ES-l are solid materials kept in closed containers. While unlikely, the source
of any contamination in the building would be limited to spills onto the floor of the building.
Inspection of the building on January 19,2018 did not show any cracks or gaps that would allow a
spill to migrate past the floor.
As of March 2018, there is no history of any major spills occurring at ES-l. Whenever a minor
spill occurred, it was immediately cleaned up. Based upon this operational history, chemical
contamination of the floor and walls inside the building is expected to be minimal.
8.6.5 Maximum Waste Inventory at ES-l
Based on our operating history, the maximum inventory of hazardous waste documented on-site
was equal to capacity, approximately 20,000 pounds. The principal wast'e stored at ES-l during
interim status was HMX staged for transportation and disposal at an off-site TSDF. During thepermit, waste stored at the building consisted of HMX packaged for offsite disposal and Class 1.1
wastes stored while awaiting treatment at the NIROP Burning Grounds. This Class 1.1 waste
included cleaning materials (rags, wipes) contaminated with Class 1.1 propellants or dry ingredients
packaged in cardboard boxes.
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8.6.6 Inventory Removal, Disposal, and Decontamination of Structure/Equipment
All waste explosives in storage at the time of closure will be shipped to an approved TSDF or taken
to the NIROP Burning Grounds for treatment. The building is presently empty and it is very
unlikely that any additional wastes will be placed in this building prior to closure activities. The
storage areas, structure, and all equipment will be cleaned and decontaminated by steam cleaning
and/or washing with high pressure water and scrub brushes. A temporary berm will be constructed
using plastic and railroad ties or a similar structure to contain wash water. Wash water will be
collected from the bermed areas of the floor using a wet/dry vacuum, mop buckets, transfer pumps
into drums or containers or will be removed by a vacuum truck. An environmentally safe
detergent, if necessary, may be used. The decontamination process is expected to generate
approximately 500 gallons of wastewater and residue.
The building may be subdivided into more than one area for cleaning purposes. Structures and
equipment requiring decontamination include but are limited to the following:
o The concrete floor in the building;
o Walls that may have been exposed to contamination; and
o Miscellaneous equipment permanently attached to the facility. All material used to
construct the temporary berm will be collected, characterized, and discarded according to applicable
and appropriate waste management rules.
Past experience and the operational history of ES-1 indicates that the contaminant levels in the cleanup
wash water will be minimal. It is expected that that after characterization the water can meet discharge
limits for a POTW or UPDES discharge permit. It is not anticipated that the wastewater generated
during closure will require special handling. ff it is determined that the wash water cannot meet
discharge limits, it will be charactenzed and disposed of in accordance with applicable rules and
regulations.
8.6.7 Verification and QA/QC Samples
Decontamination and verification samples will be collected from both the upper and lower storage areas
at ES-1. Wipe samples will be collected from two walls and the floor in each storage area. Samples
will be collected according to the procedure described in Section 8.4. Table 8.8 summarizes the
verification samples that will be taken after cleaning efforts.
In addition to the clean closure verification samples identified in Table 8-8, the following QA/QC
samples will be collected during each day of verification sampling:
o I field blank filled with de-ionized water will be exposed during sampling, and then
analyzed to detect accidental or incidental contamination, during each day of sampling.
o One (1) blind duplicate sample will be collected for each ten (10) verification samples collected
(rounded up to the next greatest multiple of 10).
Samples will be properly labeled, sealed, and sent to a Utah Certified Laboratory for testing.
Samples will be handled under USEPA chain-of-custody and sample preservation protocols. No
residue or contamination is expected to remain on or in the structures and equipment following the
decontamination process
8.6.8 Closure Report and Certification
Upon completion of the closure, a report will be provided to the Director certifying that the closure
was completed in accordance with the plan. The report will include a surnmary of the operational
history of ES-1, copies of the analytical results, copies of the QA/QC data, data validation report(s),
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copies of manifests that accompanied off-site shipments of wastes, characterization of
decontamination water/residue, documentation that the closure of ES-l met the performance
standard identified in Section 8.6.3, and a closure certification. A certification of closure according
to R315-264.115 of the Utah Admin. Code will be submitted by registered mail to the Director
within 60 days of the completion of the final closure.
8.6.9 Schedule for Closure
A permit modification is being processed in early 2018 to provide updated closure information for
ES- 1 . Final closure is expected to be initiated within 30 days of completion of the permit
modification. If more time is required, ATK-Bacchus will submit a request to the Director. All
hazardous wastes will be removed or treated within 90 days of incorporation of this permit
modification. Final closure activities will be completed within 180 days of incorporation of this
permit modification..
8.6.10 Post-Closure Care
The closure plan described above anticipates that ES-1 will be clean closed and will not require post-
closure care. If at the conclusion of the closure activities it is determined that ES-l cannot be clean
closed, ATK-Bacchus will develop an appropriate and applicable post-closure care plan for all areas of
this unit that cannot be clean closed. Any proposal for post-closure care will be developed in
accordance withUtah Admin. Code R315-264-110 through 120 and R3l5-264-I40 through 151 of the
Utah Admin. Code, and submitted to the Director for approval.
8.6.11 Closure Cost Estimate
The cost estimate for the closure of ES-l will be maintained in the operating record.
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8.7 SEGMENT STORAGE
Segment Storage is a hazardous waste storage unit constructed for the storage of large rocket
motors and containers of Class 1.3 explosives. Segment Storage is used for the storage of Class 1.3
explosive, explosive ingredients, and explosive wastes.
8.7.1 Site Description
The facility is located just to the southeast of HS-1 in Plant 1, and consists of an asphalt pad 100 ft
x75 ft; a total of 7,500 square feet. The facility is protected from lightning by a "tent" system (a
telephone pole at each corner of the pad connected with a conductive wire). The pad and "tent"
system are shown in Figure 2-2.11. The pad is bisected by a concrete strip running in an east/west
direction. The concrete strip provides better support for the landing gear of trailers parked on the
pad as shown in Figure 2-2.11. The storage capacity for Segment Storage is 75,000 pounds;
equivalent to one large rocket motor segment (e.g., GEM-60). For closure cost purposes it is
assumed that one large rocket motor would be onsite at the time of closure.
8.7.2 Segment Storage Closure Plan
The closure plan detailed in this section was developed with the assumption that Segment Storage
will be clean closed. The plan describes the procedures that will be used to verify closure of all
applicable structures and equipment at Segment Storage, and how the closure standard will be
established. Any change or amendment to this plan will be done in accordance with R315-Utah
Admin. Code264.I12(c) of the Utah Admin. Code.
8.7.3 ClosurePerformance Standard
The closure criteria for the pad and surrounding soil will be to clean close. Sampling will
determine if contamination at the unit meets the clean closure equivalency as defined in R315-101-
6(c)(l) of the Utah Admin. Code. If the pad can be clean closed, the pad may be used for other
purposes, or may be demolished. No specific Segment Storage post-closure monitoring is planned.
8.7.4 Operational History of Spills or Releases at Segment Storage
No waste has been stored at Segment Storage during the permit. During interim status, the pad was
used for storage of waste rocket motors. These motors were loaded on shipping trailers and
covered with waterproof tarps prior to shipment to the Utah Test and Training Range for disposal,
primarily in the late spring and summer months. A typical trailer containing two rocket motors is
shown in Figure 2-2.11. While covered, the open pad allowed the trailers/motors to be exposed to
precipitation.
Segment Storage has also been used for storage of obsolete or decommissioned tooling prior to
disposition. The equipment has been visually cleaned of explosives prior to placement on the pad.
This tooling is not considered hazardous waste while awaiting final disposition. As above, this
equipment was exposed to precipitation.
There is no history of any spills occurring at Segment Storage either during interim status or during
the permit. Contaminated soil is not expected; however, limited sampling will be conducted to
verify that it does not exist.
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8.7.5 Maximum Waste Inventory at Segment Storage
Segment Storage has a storage capacity of 75,000 pounds of Class 1.3 propellant or explosives. No
waste has been stored at Segment Storage during the permit.
During interim status, Segment Storage had a higher waste storage capacity of 312,000 pounds of
explosive waste. The maximum amount of waste stored on the pad at any one time would have
been two C-4 first stage motors and two C-4 second stage motors. This combines to a total
maximum weight of 119,608 pounds.
8.7.6 Inventory Removal and Decontamination of Pad
No waste is stored at Segment Storage at the time of this closure plan and there are no plans to
place any waste on the pad between now and closure. While not expected, any waste placed on the
pad between now and closure will be taken to an approved TSDF for treatment and disposal.
Rocket motors stored at Segment Storage during interim status were completely enclosed
containers that were protected from precipitation by water proof tarps. It is unlikely that explosive
contamination reached either the asphalt or the surrounding soil.
No decontamination of the pad is proposed given that it has been at least 9 years since waste was
stored on the pad and there have been numerous rain storms during this period. Verification
samples described below will determine if any contamination has passed through the somewhat
porous asphalt or has been transported to nearby soils.
If soils contamination is identified that exceeds RSLs, ATK-Bacchus will submit a supplemental
closure plan to the Director designed to assess magnitude and extent of the contamination. This
supplemental plan will be submitted within 60 days of determining that soil contamination has
occurred.
8.7.7 Verification and QA/QC Samples
To determine if any contamination exists, verification samples will be collected from the storage
pad and specific soil locations. Core samples of the asphalt will be collected at two locations.
Locations for the cores will be based on how trailers containing waste rocket motors were parked
on the pad using the concrete strip as support for the trailer landing gear. Locations for the cores
will be decided based on the procedures described in Section 8.4. A total of four soil samples will
be collected from the area adjacent to the pad. Three samples will be collected in the general
direction of water runoff, i.e., to the south and east. One soil sample will be collected adjacent to
the west side of the pad. In addition to the verification samples, QA/QC samples will be collected
during each day of verification sampling. During closure activities field blanks will be collected
daily and duplicate samples will also be collected according to the bullet below:
o A field blank filled with de-ionized water will be exposed during sampling and analyzed
for accidental or incidental contamination.
o One (1) blind duplicate verification sample will be collected for each ten (10) verification
samples collected (rounded up to the next greatest multiple of l0).
Table 8-9 identifies the number of verification and QA/QC samples ATK-Bacchus will collect
during the closure of Segment Storage. Samples will be properly labeled, sealed, and sent to a Utah
Certified Laboratory for testing. Samples will be handled under USEPA chain-of-custody and
sample preservation protocols. No residue or contamination is expected to remain on the pad or
any of the equipment associated with Segment Storage after the cleaning process is complete,
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therefore, the pad may be kept for future use. There is no intention to break up and dispose of the
pad as part of the closure.
8.7.8 Closure Report and Certification
Upon completion of the closure a report will be submitted to the Director certifying that the closure
was accomplished in accordance with the approved plan. The report will include a summary of the
operational history of Segment Storage, copies of the analytical results, copies of the QA/QC data,
data validation report(s), copies of any manifests that accompanied off-site shipments of wastes,
characterization of all cleanup waste or residues, documentation that the closure of Segment
Storage met the performance standard identified in Section 8.7.3, and a closure certification. A
certification of closure according to R315-264.1 15 of the Utah Admin. Code will be submitted by
registered mail to the Director within 60 days of the completion of the final closure.
8.7.9 Schedule for Closure
A permit modification is being processed in early 2018 to provide updated closure information for
Segment Storage. Final closure is expected to be initiated within 30 days of completion of the
permit modification.. If more time is required, ATK-Bacchus will make a request to the Director.
All hazardous wastes will be removed or treated within 90 days of incorporation of this permit
modification. Final closure activities will be completed within 180 days of incorporation of this
permit modification.
8.7.10 Post-Closure Care
The closure plan described above anticipates that Segment Storage will be clean closed and will not
require post-closure care. If at the conclusion of the closure activities it is determined that Segment
Storage cannot be clean closed, ATK-Bacchus will develop an appropriate and applicable post-closure
care plan for this unit. Any proposal for post-closure care will be developed in accordance with R315-
264 ll0 through 120 of the Utah Admin. Code, and submitted to the Director for approval.
8.7.11 Closure Cost Estimate
The cost estimate for the closure of Segment Storage will be maintained in the operating record.
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8.8 RH-l
RH-1 is a hazardous waste storage unit used for the storage of waste rocket motors and explosives.
RH-1 is permitted for 150,000 pounds of hazardous/explosive waste.
8.8.1 Site Description
RH-l is a wood-framed, earthen-covered structure similar to ES-1. The northwest-facing front of
the building is not earthen covered and consists of two large double doors (1 | ft x 37 ft). A set of
rails enter the building through these doors enabling rocket motors to be brought in on rail dollies.
Figure 2-2.13 is a schematic of the building showing the location of the doors and the building
dimensions. The area permitted for storage of hazardous wastes is only a portion of the building.
The hazardous wastes include waste rocket motors, explosive ingredients, large sections of motors,
and smaller pieces of propellant on pallets or in wooden boxes. The exterior of the building is
shown in Figure 2-2.12. The interior of the building is shown in Figure 2-2.14.
8.8.2 RH-l Closure Plan
The main use for RH-l is for storage of C-4 first stage rocket motors as products. It has been used
for this purpose for 40 years and continues to be used for this purpose.
Use of this building for waste purposes was intended for waste rocket motors that needed
development work to identify an acceptable disposal method. RH-1 was used for this purpose
between CY 2001 and 2006 for three separate waste rocket motors. The only other time that waste
was stored in RH-l was in 1999 when waste inventory increased while addressing an explosion at
the NIROP Burning Grounds that occurred in 1998. These wastes were all solid materials stored in
closed containers.
As described above, very little waste has ever been stored at RH-1. No waste has been stored in
RH-l during the current permit which commenced in September 2008. As of March 2018, it has
been 12 years since waste rocket motors have been stored at RH-1 and l8 years since production
waste has been stored at RH-l. As developed in Section 4.5 below, there were no spills during
these storage periods and very little opportunity for waste explosive material to escape their
containers.
Based upon this operating history, ATK-Bacchus does not believe the building is contaminated as
result of explosive waste storage. Cleaning of the building is not warranted especially since
product rocket motors would have to be removed from the building to provide access for cleaning.
For closure, ATK Bacchus proposes to take wipe samples from the walls and floor at RH-1 as
described in Table 8-10. Sample locations will be biased towards locations where waste was stored
in the building during interim status.
Utah Admin. Code8.8.3 Closure Performance Standard
RH-l will be clean closed as verified by wipe samples to meet the clean closure equivalency as
defined in R315-101-6(cX1) of the Utah Admin. Code. The results of the wipe samples will be
compared to the surface wipe screening levels listed in Table 8-3. After closure, RH-1 will
continue to be used for storage of product rocket motors. Post-closure care for RH-1 is not
anticipated.
8.8.4 Operational History of Spills or Releases at RH-l
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Limited storage of explosive waste occurred at RH-l as described in Section 8.8.2 above. All
wastes were solid materials stored in closed containers. There is no history of any spills that
occurred during storage.
8.8.5 Maximum Waste Inventory at IUI-I
The maximum amount of waste ever stored in RH-l was in CY 2004 when sections from three
different rocket motors were kept in the building. The total weight of waste at that time was 6,724
pounds. Of this, 6,676 pounds were associated with a Small ICBM motor cut into two sections and
48 pounds were associated with two hyper velocity motors each cut up into three sections.
8.8.6 Inventory Removal, Disposal, and Decontamination of Structure/Equipment
There is no waste currently stored in RH-l and no plans to place waste in this building prior to
closure. Product C-4 rocket motors remain in the buildins and will continue to remain in the
building.
No washing or decontamination procedures are proposed for the building. Subject to wipe sample
results, no structures, equipment or cleaning materials will be removed from the building.
8.8.7 Verification and QA/QC Samples
Wipe samples and QA/QC samples will be collected from RH-l as described in Table 8-10.
Sample locations will be biased towards locations where waste was stored in the building during
interim status. Two wipe samples will be taken from the walls of the building while one wipe
sample will be taken from the floor.
In addition to the clean closure verification samples identified in Table 8-10, QA/QC samples will
be collected during each day of the verification sampling. During each day of verification sampling
the following QA/QC samples will be collected:
o { field blank filled with de-ionized water will be exposed during sampling then analyzed to
detect accidental or incidental contamination.
o One (1) blind duplicate verification sample will be collected for each ten (10) verification
samples collected (rounded up to the next greatest multiple of 10).
Samples will be properly labeled, sealed, and sent to a Utah Certified Laboratory for testing.
Samples will be handled under USEPA chain-of-custody and sample preservation protocols. No
residue or contamination is expected to remain on or in the structures and equipment following the
decontamination process. Structures and permanent fixtures may be kept for future use. There is
no intention to break up and dispose ofthe building as part ofthe closure.
8.8.8 Closure Report and Certification
Upon completion of the closure a report will be provided to the Director certifying that the closure
was completed in accordance with the plan. The report will include a summary of the operational
history of RH-l, copies of the analytical results, copies of the QA/QC data, data validation
report(s), documentation that the closure of RH-l met the perforrnance standard identified in
Section 8.8.3, and a closure certification. A certification of closure according to R315-264.115 of
Utah Admin. Code will be submitted by registered mail to the Director within 60 days of the
completion of the final closure.
8.8.9 Schedule for Closure
A permit modification is being processed in early 2018 to provide updated closure information for
RH-l. Final closure is expected to be initiated within 30 days of completion of the permit
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modification. If more time is required, ATK-Bacchus will submit a request to the Director. All
hazardous wastes will be removed or treated within 90 days of incorporation of this permit
modification. Final closure activities will be completed within 180 days of incorporation of this
permit modificationf.
8.8.10 Post-Closure Care
The closure plan described above anticipates that RH-l will be clean closed and will not require post-
closure care. If at the conclusion of the closure activities it is determined that RH-lcannot be clean
closed, ATK-Bacchus will develop an appropriate and applicable post-closure care plan for this unit.
Any proposal for post-closure care will be developed in accordance with R3l5-264-ll0 through 120
and R315-140-l5l of the Utah Admin. Code, and submitted to the Director for approval.
8.8.11 Closure Cost Estimate
The cost estimate for the closure of RH-l will be maintained in the operating record.
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8.9. SUMMARY OF STORAGE CAPACITY
Table 8-6 below surnmarizes the Part A storage capacities of the facilities described in this
document.
.',j,.:,:, TABLES-6 . -:::
S nv oFSToRAGE CAPAcrrrEs-
::]. .:.:.: ]
Storage Unit P"i.l Capacity
HS-l (8562)4900 gal
HS-1 (8s67)1200 gal
HS-1 (8568)9350 gal
HS-l (Sheds A-D)450 gal
ES-r 20,000Ib.
Segment Storage 75,000Ib.
RH-1 150,0001b.
8.9.1 Changes in Closure Plans
If it becomes necessary to change, amend or modify the closure plans for any of the regulated units,
a written request submitted to the Director for a permit modification in accordance with R3l5-Utah
Admin. Code264.l12(c) and R3l5-264-ll0 through 120 of the Utah Admin. Code.
8.9.2 Closure Cost Updates
Closure costs will be updated annually by July 30ft. The cost estimate shall be adjusted for
inflation using the Implicit Price Deflator for the Gross Domestic Product typically found on the
Utah Division of Solid and Hazardous Waste website.
Other necessary adjustments to the closure costs resulting from changes in storage capacity, early
closure of certain units, or other factors, will be made through a new engineering cost estimate for
the applicable items and inflation updates for other items and explained in the annual cost update.
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TABLES
S^llvrpr,n VEnrrrc,lTroN
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TABLE 8-7
:HS-l SAMPLE YBRIFICATION
Area
Analytical Procedure
Volatiles Semi-Volatiles
:'.r :... l,'.,'
Mctals/IIg
::1,:;,
ExptosiveV
PerChlorate
Bldg.8562
Floor (Core)
Floor (Final Rinse)
Floor (Wipe)
Walls (Wipe)
2
I
0
0
2
0
I
2
2
0
I
2
2
0
1
2
Bldg.8567
Floor (Core)
Floor (Final Rinse)
Floor (Wipe)
Walls (Wipe)
2
1
0
0
2
0
I
2
2
0
I
2
0
I
Bldg. 8568
Floor (Final Rinse)
Floor (Wipe)
I
0
0
1
0
I
0
1
Shed'A'
Floor (Final Rinse)
Floor (Wipe)
I
0
0
I
0
I
0
1
Shed'B'
Floor (Final Rinse)
Floor (Wipe)
I
0
0
I
0
1
0
I
Field Blank 2 2 2 2
Trip Blank 2
Blind Duplicate 2 2 2 2
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TABLE 8-8 : ,
ES.l SAMPLE YERIFICATION
Area
Analytical Procedure
Elplosives/Perchlorate RCRAMetals
Floor (Wipe)2 2
Walls (Wipe)4 4
Field Blank I I
Blind Duplicate I I
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Area
Anatvtical Procedure
RCRA Metals Exol osives/Perchlorate
Segment Storage Pad
(Cores)2 2
Surrounding Soil 4 4
Field Blank I 1
Blind Duplicate I I
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TABLE 8-10RII.I SAMPLE VERIFICATION
Analytical Procedure
Walls (Wipe)
Floor (Wipe)
Blind Duplicate
8-2s