DSHW-2018-003027 - 0901a068807e2cbc

Orbital ATK
April 03, 2018
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: Reappliation for ATK-Bacchus Plant 1 Permit
EPA ID# UTD001705029
Dear Mr. Anderson:
DIv of Waste Management
and Radation Control
APR - 3 2018
954W-2,018 - 003017
ATK Launch Systems, Inc. (ATK) currently has a RCRA Part B operating permit for the
Bacchus facility Plant 1 location that will expire on September 30, 2018. Pursuant to Condition
I.G.1. of this permit and R315-270-30(b) of the Utah Administrative Code, ATK is reapplying
for a new Part B permit. As part of this process, please find attached a revised Subtitle C ID
form, a revised Part A form and a revised Part B permit. Proposed changes for the Part B permit
are shown in red in the attached document.
Changes to these documents anticipate operating conditions that will be in effect when the permit
expires on September 30, 2018. Not all of these changes are currently in place. Listed below are
some of the more significant proposed changes to the Permit including those that will come into
effect in the next 6 months:
1. Northrup Grumman Corporation is in the process of purchasing Orbital ATK. Orbital
ATK will become a wholly owned subsidiary of Northrup Grumman and will be renamed
Northrup Grumman Innovation Systems, Inc. This transaction is expected to close in the
near future. Accordingly, Northrup Grumman Innovations Systems is identified as the
facility owner on the revised Subtitle C ID form and in the text of the revised Part B. ATK
Launch Systems, Inc. is the legal entity that will continue to operate the ATK Bacchus
Plant 1 facility. As this change is not yet in effect, the Subtitle C ID form included with
this submission is not yet signed.
2. ATK is currently pursuing certain property transactions involving Bacchus West and the
east side of Plant 1. These transactions are expected to be completed in the near future. At
that point, ATK will own and operate the Plant 1 and Bacchus West portions of the
Bacchus facility. The U.S. Navy will continue to own the NIROP section of Bacchus with
ATK Launch Systems, Inc as the operator.
Note that Building 2440 will remain a part of the Bacchus facility. However, it will no
longer be contiguous with the rest of the plant. Separate access and fencing will be
provided for this building. Figures in the revised Part B, such as Figure 2-1.1, Figure 2-
5.10 and Figure 5-1.1 reflect the revised property boundaries and the noncontiguous
location for Building 2440.
3. The abovementioned property transactions will require the closure of ES-1 which is a
hazardous waste management unit (HWMU) for storage of explosive waste on Plant 1.
Segment Storage and Resthouse 1 are two other HWMUs on Plant 1 that will be closed at
the same time since neither of them have been used during the current permit. Closure of
these three units is expected before September 30th and are therefore not referenced in the
revised Part A form or the revised Part B.
4. Reference to Utah Division of Solid and Hazardous Waste has been replaced with the
Utah Division of Waste Management and Radiation Control.
5. References to R315 of the Utah Administrative Code have been replaced with the new
numbering system implemented by the Division last year. The new numbering system
more closely aligns with federal environmental regulations (40 CFR).
6. Discussion of explosive waste management in Attachment 4 has been updated to more
closely align with similar discussion in the NIROP Part B permit.
7. Table 1 of Attachment 9 has been updated with latest status of solid and hazardous waste
management units.
For additional information on this issue, please contact Chris Falkenberg of my staff at (801)
251-5313.
I cert0, 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 qualOed 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 offine and imprisonment for knowing violations.
Sincerely,
Kris Blauer
Manager, Environmental Services