DSHW-2003-007749 - 0901a06880160353

August 26, 2003

George Gooch, Manager
Environmental Services
ATK Thiokol Propulsion – Promontory
P.O. Box 707
Brigham City, UT 84302-0707

RE: Revised Closure Cost Estimate and Closure Plan, ATK Thiokol Propulsion – Promontory, EPA I.D. #UTD009081357

Dear Mr. Gooch:

This letter addresses the revised closure cost estimate and closure plan for the eleven hazardous waste management units at the ATK Thiokol Propulsion – Promontory (Thiokol) facility.
The Division of Solid and Hazardous Waste (the Division) has been in communication with Gene Curtis regarding the revised closure cost estimate and received a letter from Credit Lyonnais
on June 9, 2003 requesting confirmation of a reduced dollar amount of financial assurance for closure of the units. The Division responded to the request on July 10, 2003
by stating that it did not agree with the reduction in financial assurance since the revised cost estimate had not been reviewed.

Cost estimates for closure of hazardous waste management units are based on closure plans. Thiokol’s closure plan is an important part of the Hazardous Waste Storage Permit (the Permit),
which was issued to the facility in 1992. Since hazardous waste permits are issued for a period of ten years, Thiokol submitted a request to have the permit reissued last year. The
closure plan that was submitted with the permit application is, with a few exceptions, essentially the same as the original plan. Due to the reasons discussed below, the original closure
plan is outdated and will require significant changes before the closure cost estimate can be reviewed and the permit reissued. A review of the closure cost estimate that is based on
the outdated closure plan would be incomplete. Therefore, the Division requests that Thiokol update the closure plan and resubmit the document.

It appears that the most significant closure plan modifications required are for the two burn grounds. For example, when the burn grounds were inspected in 2002, Thiokol was burning
third stage Minuteman motors in an unlined trench. Plans for closing this “unit” are not included in the closure plan for the M-136 burn grounds. The closure plan also does not address
how the gravel and dirt-filled burn pans at M-136 and M-225 will be handled. Like the Minuteman motor burn trench, it appears that the gravel and soil-filled burn pans were added to
the burn grounds after the permit was issued in 1992.

General Comments

The closure plan for the units where soil samples will be collected calls for the collection of three background samples. The plan states that background levels for constituents of
concern (COCs) will be defined as the mean of the three samples plus three standard deviations. This plan for setting background values is unchanged from the original plan. Is Thiokol
proposing to follow this instead of using background data compiled for the RCRA Facility Investigation? If so, this method needs revision.

It appears that, for most of the sites where soil samples will be collected, the constituents to be analyzed are based on the TCLP constituent list. COCs should be based on a complete
list of materials that were handled at each site (waste profiles). The TCLP should not be used on samples that have been collected to determine if a release has occurred at the site.

The Division has implemented Cleanup Action and Risk-Based Closure Standards (R315-101) since the permit was issued in 1992. These standards provide a framework for making decisions
on the need for corrective action. Site investigations are conducted to determine if COCs have been released and if they present a threat to human health and the environment, not to
determine if soil at the site contains hazardous waste. The sections in the closure plan that address corrective action (removal of soil that contains hazardous waste) need to be updated.

References to specific hazardous waste management rules throughout the document need to be checked. Many of the cited rules in the document are wrong (such as R315-8.7.2 on Page One
of Section Four) and need to be updated.

Many of the references to table numbers in the document are wrong (such as Table 4.2A on Page Three of Section 4.1). Please check these and correct them as necessary.

There are a number of references to sections of the original permit application (for example, Section 02 on Page Eight of Section 4.2) in the document that are confusing. What are these
sections? Should they be attachments to the closure plan?

A number of figures are referenced in the document (for example, “see Figure 13.02A” on Page 18 of Section 4.4) that appear to be missing from the closure plan and the permit in general.
Where are the figures?

The closure plan calls for treatment of hazardous waste and wastewater on-site, presumably by Thiokol personnel. The regulations applying to the cost estimate for closure [40 CFR §264.142(a)(2)]
state “The closure cost estimate must be based on the costs to the owner or operator of hiring a third party to close the facility. A third party is a party who is neither a parent
nor a subsidiary of the owner or operator…The owner or operator may use costs for on-site disposal if he can demonstrate that on-site disposal capacity will exist at all times over the
life of the facility.” It appears that the closure plan and closure cost estimate need to be modified to comply with this requirement.

Specific Comments

Specific comments are provided for the M-136 Burn Grounds only due to the large number of comments that would be needed if the entire document was included. These comments are provided
to give Thiokol an idea of the extensive problems with the closure plan as it currently exists.

4.4 Closure Plan, M-136 Burning Grounds

A paragraph on closure and post-closure activities, including the post closure permit, for the old LTTAs should be included in this section to identify the parts of the burn grounds
at M-136 that have been closed and are now managed under the Post-Closure Permit. The closure plan must then include all other areas at the burn grounds not previously closed.

Under “Steps for Closure,” ATK Thiokol Propulsion should notify the Division of its intent to close, not the Utah Solid and Hazardous Control Board.

It is stated in this paragraph that a closure plan will be submitted upon notification of closure. A closure plan must be submitted with the permit application and approved by the Executive
Secretary as part of the permit issuance procedures [40 CFR 264.112(a)(1)]. The closure plan can be amended as outlined in 40 CFR 264.112(c).

What or where is Appendix 13.A? It couldn’t be found in the closure plan or the permit.

How will the dirt and gravel that fills some of the burn trays be managed upon closure?

Part of the third paragraph under the heading “Steps for Closure” has been removed. The following sentence in the paragraph, regarding “the next analysis” doesn’t make sense. Will
the burn trays be rinsed out like stated in the closure plan for the M-225 burn grounds? Will samples of rinse water from the trays be collected? Analytical costs for samples of rinse
water are not included in the closure cost estimate.

The Executive Secretary can not approve the proposal for sampling the burn grounds at M-136 and M-225, as it exists. As proposed, the investigation at M-136 would depend on one composite
sample for every 33,750 ft2. This approach is more suited to sampling an area with no prior knowledge of activities at the site. A sampling plan for closure of the burn grounds should
be designed to accomplish two things. First, to determine if contaminants were released at areas like the Minuteman trench and the dirt and gravel-filled trays and second, to determine
if contaminants were released on a larger scale adjacent to the burn stations. At a minimum, samples will be needed from the Minuteman trench and from the areas around the dirt and
gravel-filled trays in addition to samples from a tighter grid than proposed. In addition, composite samples should be limited to three or four aliquots, and are not appropriate for
organic analyses. Please re-write the sampling plans for the M-136 and M-225 burn grounds and include maps which show the active area of the grounds with the locations of burn stations
and proposed sample locations.

The second-to-last sentence in the first paragraph on Page 20 states, “Any area containing a sample that has a hazardous waste or has hazardous constituents above background levels will
be permitted hazardous waste facility.” What does this mean?

The last sentence in the first paragraph on Page 20 states: “It is not anticipated that any contaminated soils will be found at the Burning Grounds.” Contaminated soil (above risk-based,
residential screening levels for cobalt at M-136 and molybdenum at M-225) has already been observed at the burn grounds. RCRA closure requirements should be addressed in the closure
plan under a section on the closure performance standard.

Every paragraph on Page 20 needs revising. The sixth paragraph talks about analyzing for TCLP constituents. Please correct this. The seventh paragraph either needs to be removed or
significantly changed, because the substance of it is outdated.

The list of constituents to be analyzed for in M-136 soil samples needs further attention. Analysis of the samples should not be done using the TCLP method. The list includes “underlying
hazardous constituents.” What constituents does this include? A number of metals need to be added to the list (most notably cobalt). Should samples be analyzed for VOCs, sodium azide,
or pyridine? As mentioned above, the list of constituents should be based on the profiles of hazardous wastes that were burned or otherwise managed at the site.

The closure plan that was submitted is inadequate. The document needs extensive revision. A copy of the closure plan for the Utah Test and Training Range (UTTR), Thermal Treatment
Unit (OB/OD) is enclosed with this letter. Although, the enclosed closure plan is not directly applicable to Thiokol, the Division recommends that it be used as guidance for revising
your closure plan. It is also recommended that the outline, or structure of the UTTR closure plan be used in Thiokol’s plan. Please update and revise the entire closure plan as needed
and submit a copy of it to our office within 45 days of the receipt of this letter.

If you have any questions regarding this matter, please contact Jeff Vandel at 538-9413. Thank you for your cooperation.

Sincerely,

Original Document Signed by Dennis R. Downs on 8/26/03

Dennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board

DRD\jv\kk

c: John C. Bailey, M.D., M.S.P.H., Health Officer/Director, Bear River Health Dept.
Mary Wu, USEPA Region VIII

TN200301735.doc
file to: Thiokol

August 26, 2003
Page 5

Michael O. Leavitt
Governor
Dianne R. Nielson, Ph.D.
Executive Director
Dennis R. Downs
Director

Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
[phone]
[phone] Fax
[phone] T.D.D.
www.deq.utah.gov