DSHW-2002-001717 - 0901a068801325b7

rtECEIVED
A\J^Kr>e. MAY 0 6 2002
ALLIANT TECHSYSTEMS ^^ 02^.0^^^>2M'
Division of Solid & Zardous Waste
»9h nanartmpnt nf Fnvironmental Qualif
Thiokol Propulsion Corp, Tel [phone]
P,0,Box707 Fax [phone]
Brigham City, UT 84302-0707
25 April 2002
8200-FY03:ST006
Mr. Dennis R. Downs, Executive Secretary
StateofUtah
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 N. 1460 W.
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Dear Mr. Downs
Attention Jeff Vandel
Subject: Meeting Notes for March 13, 2002; Open Buming Risk Assessment Protocol for
ATK Thiokol Promontory EPA ID # UTD009081357
On March 13, 2002, ATK Thiokol Propulsion met with representatives from your
Division to discuss the protocol that should be used for the development ofthe ATK
Thiokol Propulsion Promontory Open Buming Risk Assessment. Attached are notes
from that meeting and our understanding of what was agreed and discussed. We request
that you review these notes and respond if they are acceptable to your staff and if there
are changes need to be made before we proceed.
If you have any questions please contact Paul Hancock at (435) 863- 3344.
Thank you for your assistance in this effort.
Susan JeWj-GDirector
Environmental Services
DRAFT FINAL MEETING MINUTES
THIOKOL PROPULSION MEETING WITH UTAH DEQ DSHW
OB/OD HEALTH AND ECOLOGICAL RISK ASSESSMENTS
MARCH 13,2002
The UDEQ is requiring Thiokol Propulsion (TP) to prepare health and ecological risk
assessments as part of the RCRA Subpart X permitting process for the 1^136 opening burning
and M225 open burning/open detonation units located at the Promontory manufacturing facility.
TP has contracted with Tetra Tech NUS (TINUS) to prepare the risk assessments. A meeting
was held on March 13, 2002 among TP, UDEQ, and TtNUS to discuss requirements for the risk
assessments. The meeting was held in Salt Lake at UDEQ offices. Following is a list of the
attendees and a synopsis of topics discussed including directions provided by UDEQ for certain
topics.
Attendees
Utah Department of Environmentai Quality Division of Soiid and Hazardous Waste (UDEQ)
Chris Bittner (801.538.6813, e-mail - [e-mail])
Brad Maulding (801.538.6170)
Jeff Vandel (801.538.6170)
Bill Wallner (801538.6170, e-mail - [e-mail])
Thiokol Propulsion
Paul Hancock (435.863.3344, e-mail [e-mail] )
Susan Jew (435.863.2287, e-mail [e-mail])
Jay Whimpey (435.863.8406, e-mail [e-mail])
Tetra Tech NUS
Joe Lucas (412.921.8882, e-mail [e-mail])
Bill Starkei (770.413.0965, e-mail [e-mail])
Ralph Basinski (412.921.8308, e-mail [e-mail])
Applicable Guidance: The U.S. EPA guidance for human health (1998 version) and ecological
risk (1999 version) assessments at combustor facilities must be followed. One run must include
aii default exposure assumptions and toxicity factors. UDEQ is willing to consider modifications
of defaults if a sound technical case can be made. It was recommended by UDEQ that
modifications to defaults be reviewed informally prior to implementation and presentation in the
risk assessment report.
Protocols: Waste characterization/Air Dispersion l^odeling. Health Risk Assessment, and
Ecological Risk Assessment Protocols will be developed and submitted to UDEQ for approval.
Qnce approved, the protocols will be the standard by which UDEQ will review the risk
assessment.
Review Process: UDEQ intends to use TechLaw for review of the air dispersion modeling
because DSHW does not have air dispersion modeling expertise and Air Division is not able to
support DSHW on this project. UDEQ staff will be the primary reviewer of the facility
characterization (including waste and emissions characterization) and both risk assessments.
TechLaw will review the air dispersion modeling versus the UDEQ-approved air dispersion
modeling protocol.
UDEQ Access to Software: Software developed by Lakes Environmental will be utilized by
TtNUS for the risk assessment. This software incorporates all of the U.S. EPA guidance
algorithms, default exposure factors, toxicity factors, etc. UDEQ has access to the IRAP h-View
software for health risk assessment. UDEQ does not currently have access to the ECOView
software for ecological risk assessments. Typically, Lakes Environmental provides the software
free of charge to regulatory agencies. UDEQ (Chris Bittner) will contact Lakes Environmental to
obtain a free copy. If UDEQ is not able to obtain a free copy, then this software cannot be used.
Waste and Emissions Characterization: Thiokol Propulsion profiles will be used to develop
waste composition data. Wastes will be grouped by class (e.g. A, B, C, D, E, F, G, and H for M-
136). Representative wastes will be determined for each group. These representative wastes
will be used to estimate emissions of waste constituents. 100 percent of metals will be emitted
and available for downwind transport unless otherwise demonstrated. A destruction removal
efficiency (DRE) will be assumed for organics. This DRE will range from 99.99 percent to
99.9999 percent. Justification for the assumed DRE will be provided.
Products of incomplete combustion (PICs) will be based on available test data. Thiokol
Propulsions has requested available applicable test data from the Defense Army Ammunition
Center (DAC). In addition to providing data on PICs this data will be used to estimate DREs for
organic waste constituents.
Particulate size data for OBOD emissions is not available. Therefore, it wiil be assumed that all
particulate emissions (organic and inorganic) are Pl\/i10.
Handling of Non-Detects from Emission Tests: Every compound analyzed but not detected
must be included in the risk assessment at one-half the detection limit. Average emissions will be
used for estimates of annual ambient air concentrations. Maximum emissions will be used for
estimates of short-term (twenty-four hour and less) impacts.
Confidential Material Composition Data: Certain material data may be confidential because it
is proprietary or because of national security concerns. UDEQ will need to review any data for
materials to be treated by OB/OD under the permit and used tor characterization of emissions in
the risk assessments. Thiokol must identify such data and follow procedures for submission of
confidential business information.
Facility Characterization (Treatment Scenario): The air dispersion modeling protocol will
include the waste and emissions characterization scenario.
Air Dispersion Model: Use of the OBODM is appropriate because of the unique (puff
characteristics of open burning and open detonation emissions. ISCST3 which, is specified in the
EPA guidance is designed for continuous releases from stacks. However, the protocol should
include a discussion to document why OBODM should be used in place of ISCST3 and reconcile
differences between the two models.
Fugitive Dust Emissions: The U.S. EPA guidance states that modeling of fugitive dust
emissions resulting from wind erosion is not required. However, UDEQ is requiring that the
protocol include a justification for exclusion of fugitive dust emissions based on site-specific
characteristics.
Dispersion Modeling Receptors: Two receptor networks will be used in the dispersion
modeling. A general receptor network will extend from each treatment unit out to 10 kilometers to
determine the maximum on-site and offsite air concentrations. A discrete (sensitive) receptor
network will be used to determine air concentrations at sensitive receptors both within the 10
kilometers and out to 50 kilometers. These sensitive receptors will include at least the following:
• Thiokol Ranch Pond
• Holmgren Ranch Pond
• Springs
• Adams Ranch
• Bear Creek Migratory Bird Refuge
• Salt Creek Waterfowl Management Area
• AutoLiv Plant
Meteorological Data: Thiokol maintains a meteorological station at M-225. This station is
maintained in compliance with EPA QA requirements. Therefore, the data can be used in air
dispersion modeling for regulatory purposes. UDEQ agrees that the data from the M-225 station
is also representative of meteorological conditions at M-136.
Site-specific mixing height data is not available. UDEQ is agreeable to using upper air data from
Salt Lake City to determine mixing heights for TP. However, the protocol will have to make a case
for using Salt Lake City upper air data.
Air Dispersion Factors (ADFs): A matrix of stability class/wind speed combinations will be
evaluated. Wind speed will range from 0 to 15 miles per hour. For short-term (24-hour and less)
standard the worst-case one-hour ADF will be extrapolated. For the annual case, average annual
ADFs will be calculated for the various receptors based on the frequency of occurrence of the
modeled wind speed stability class combinations. M-136 and M-225 will be modeled separately.
Risk and hazard calculations will be based on the cumulative impact at each receptor.
State Toxic Screening Levels: Utah Toxic Screening Levels must be considered only for the
general population.
Permit Conditions: Baseline risk assessment assumptions will be included as permit conditions.
Examples of baseline assumptions include the following.
• Meteorological conditions
• Hours of operation
• Quantities treated
• Types of materials treated
On-Site Worker Exposure: Onsite worker exposure must be considered for all non-OB/OD
workers in locations outside the quantity-distance (Q-D) arc prohibited access area. UDEQ
provided a memorandum of agreement between UDEQ and Region Vlli regarding this issue.
Risk and Hazard Thresholds: Chemical-specific human health risks for onsite workers are
considered significant if greater than 1.0 E-4. Chemical-specific human health risks for offsite
receptors are significant if above 1.0 E-6. Human health and ecological hazard is considered
potentially significant if above 1.0, in a Grey area between 1 and 10, and significant if above 10.
Chromium: Chromium present in propellants will be considered to be 100 percent emitted. It
will be assumed that chromium present in casing material (e.g. stainless steel) is not emitted.
For the inhalation pathway, all chromium will be assumed to be in the hexavalent state and in the
trivalent state for all other pathways.
Groundwater: The EPA guidance states that groundwater is not a pathway of concern for
indirect pathways. Therefore, the risk assessments will not quantitatively address groundwater.
Existing groundwater contamination will be addressed as required by R315-8-6. UDEQ will
establish corrective action requirements in the Permit. This rule will also be used by UDEQ to
establish groundwater-monitoring requirements in the Permit (as applicable) for operation of the
OB/OD units as permitted units.
Human Health: Ingestion of chicken, eggs, and pork will be retained because it can not be ruled
out.
Ecological: Wildfowl eating fish will be included as a pathway. Rare species will be reviewed for
inclusion as representative receptors, as will common reptiles and game species of mammals
and birds. Methyl-mercury will be the assumed mercury species in wetland-dominated systems,
like the Salt Creek and Bear River areas. Population-level effects will be considered for animals,
like small mammals, with small foraging ranges. Inhalation and dermal absorption pathways will
be acknowledged, then dismissed for lack of data and likely lack of importance.