DSHW-2005-005313 - 0901a06880158181

ATK
ALLIANT TECHSYSTEMS
ATK Thiokol Inc. Tel [phone]
P.O. Box 707 Fax [phone]
Brigham City, UT 84302-0707
4August2oo5 HAND DELIVERED
8200-FY06-ST018 05^-0<^^5S
AUG 0 h 2005
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste UTAH DIVISION OF
288 North 1460 West ^OLID & HAZARDOUS WASTE
P. O. Box 144880
Salt Lake City, Utah 84114-4880
Attention: Jeff Vandel
Subject: ATK Thiokol Inc. Promontory Facility Risk Assessment Process
Description and Waste Characterization
Dear Mr. Vandel
Attached are the ATK Thiokol Promontory Facility Risk Assessment Process Description
and Waste Characterization. This is a response based on the meetings that have been held
with the Division of Solid and Hazardous Waste, and the comments that were received
from you department on our Risk Assessment Protocol that was previously submitted.
Please contact Blair Palmer at [phone] if you have any questions conceming these
documents. My telephone number is [phone].
Sincerely
G. E. Gooch, Manager
Environmental Compliance
ATK THIOKOL INC. PROMONTORY FACILITY PROCESS DESCRIPTION
The ATK Thiokol Inc. Promontory facility is located in a remote area of east Box Elder County, Utah,
approximately 30 miles northwest of Brigham City, and approximately 11 miles north of the Great Salt
Lake (See Figure 1). The facility was purchased by Thiokol in 1956 and, with the exception of a 1,500-
acre tract that was sold to the U.S. Air Force in 1958 and then repurchased in 1995, has been held in its
entirety since purchase. A drawing showing fhe Thiokol property boundary, the location of the M-136 and
M-225 treatment units, and the on-site meteorological monitoring station are shown in Figure 2. Also
located within the boundary of the Promontory facility and shown on Figure 2 is the Autoliv facility
(formerly Morton, Inc.). This facility produces activators for automobile air bag restraint systems. Autoliv
operates as an independent commercial business and is not associated with ATK Thiokol Inc. However,
explosive and propellant waste materials generated at Autoliv, are treated by the Promontory facility at
the M-136 treatment unit.
1 FACILITY OPERATIONS
Both hazardous and non-hazardous solid wastes are generated and managed at the facility. Hazardous
wastes generated at the facility include waste such as solvents, metals (primarily aluminum and silver),
and reactive wastes including 1.1 propellant, 1.3 propellant, propellant contaminated waste, reactive
laboratory waste, waste solid rocket motors, propellant ingredients such as nitroglycerin, ammonium
perchlorate, aluminum, cyclotetraethylenetetranitramine (HMX), and similar propellant, explosive and
pyrotechnic ingredients. Reactive wastes are subjected to open burning treatment at the M-136 Unit and
open burning or open detonation at the M-225 Unit. The location of the M-136 and M-225 treatment units
is shown in Figure 2.
2 TERRAIN AND SITE DESCRIPTION
The Promontory facility is located in the Blue Spring Valley (whioh, is bounded on the east by the Blue
Spring Hills and on the west by Engineer Mountain) and the Promontory Mountain ranges respectively
(see Figure 2). Within the Blue Spring Valley, the terrain is characterized by topography that slopes down
from the mountain crest at an elevation of approximately 6,050 feet above mean sea level (AMSL) toward
the center of the Blue Creek Valley at an elevation of 4,250 feet AMSL. As a result, the surrounding
environment-extending out to 10 kilometers (km) from each treatment unit can be characterized as
complex terrain.
OB/OD Process Description
Page 1 of 7
Blue Creek is the only perennial stream in the valley drainage basin and is the closest water body to the
M-136 treatment unit. Blue Creek, originates some 15 miles north of the Promontory facility, flows along
the western boundary of the facility (see Figure 2).
The Promontory area is characterized as very sparsely populated rural region, with primarily dry farms
and ranching activities. Low growing perennial grasses and shrubs characterize the vegetation in the
area. The ecological habitat found at the Promontory facility includes many head of mule deer and large
populations of various birds, rabbit, and predator species.
3 TREATMENT UNIT LOCATIONS
Open burning of reactive wastes is conducted at two facilities. One, at the main facility M-136 located
centrally to the two main manufacturing sites. Two, at M-225 located in a remote development location
called Plant III. The location of these two treatment units (in relationship to the Promontory facility
boundary) is shown in Figure 2. Detailed drawings of the M-136 and M-225 treatment units are shown in
Figures 3 and 4, respectively. A description of the treatment activities that are conducted at each unit is
presented in Sections 3.1 and 3.2
3.1 M-136 Treatment Activities
M-136 is the primary treatment unit for conducting open burning at the Promontory facility. M-136 is a
secured fenced facility within the main facility fence. The layout of the M-136 treatment unit (showing all
burn stations) is provided in Figure 3.
The M-136 Burn Grounds is comprise of 14 burn stations. The burn stations are located in three general
areas and are aligned in an east-west direction across the treatment unit. The change in elevation
between the three general areas is relatively minor (less than 20 feet per area). Burn Stations 1 through
12 are located in one treatment area that measures approximately 250 x 175 meters, are located within a
120-meter radius of the center of the area represented by the active burn stations. Burn Station 13 is
located approximately 250 meters due east. Burn Station 14 is located approximately 250 meters due
east of Burn Station 13.
The ATK Thiokol Promontory facility conducts OB treatment at ground level in burn trays. Burning trays
are constructed in several different sizes such as, 4X10, 5X16, 8X8, and 8X20. These trays are
constructed from steel plate A36 grade steel ranging thicknesses of 3/8, 1/2, 3/4, and 1 inch. Lids for the
burn trays are used during the wet weather months to keep moisture out of the trays. If the trays are
empty, they are usually turned upside down to avoid the collection of moisture in the empty trays. If
OB/OD Process Description
Page 2 of 7
excess water exists in the burn trays, a sump truck is used to remove the water and then taken to the M-
705 wastewater treatment facility. The trays may be lined with soil to facilitate burning operations,
however, most trays do not contain soil during the burn event. The number of trays at each burn station
varies. Burn stations 1 through 12 typically have a maximum of 15 trays. Burn Station 13 typically has a
maximum of 6 trays. Burn station 14 is used to open burn motors and does not have a burn tray.
Operation of this station is described below. Trays may be moved between stations as needed.
The M-136 Burn Grounds also has three specially designed disposal units that are used to handle the
disposal of rocket motor igniters, small rocket motors, and other items that have the potential to become
propulsive. These disposal units are the clamshell disposal tray, sandbox disposal tray, and small motor
disposal vaults which are used to contain the propulsive force of the igniters and small rocket motors, but
allow for safe disposal.
The Clamshell Disposal tray is used for the disposal of closed end rocket motor igniters, and other items
that have the potential to be propulsive. It is a square welded box 1-inch thick, A36 steel plate with a
vented lid that enables the igniters to be burned, while safely containing the propulsive energy.
The Sandbox Disposal tray is used for the disposal of open-end rocket motor igniters, and other items
that have the potential to be propulsive. It is constructed of 1-inch thick A36 steel plate welded into a
square box that is filled with sand, and has four 1-inch thick steel tubes sitting on end in the sand. The
rocket motor igniters are placed in the tubes allowing the exhaust to vent out of the open end of the steel
tubes. Steel bars are then slid into the end of the exposed tubes to safely contain the igniters.
The two Small Motor Disposal Vaults are constructed from a concrete 10x10 foot sump filled with sand.
The small rocket motors such as the STAR motor are placed into the sand with the aft end exposed
perpendicular to the ground. The motors are then burned with the propulsive force directed into the
concrete sump and the sand. These small motor disposal vaults are located in burn station 9.
Large-scale obsolete rocket motors are open burned at Burn Station 14. The rocket motor is positioned
near Station 14 and offloaded by a mobile crane. The obsolete motor is placed on sand or wooden blocks
in station 14. Systems of Linear Shaped Charges (LSC) are then placed on the rocket motor to split the
rocket motor case, rendering it non-propulsive allowing the open burning of the rocket motor while it is still
being burned within the existing rocket motor case. This also allows the rocket motor case to act as the
"burn tray" for the burning propellant.
OB/OD Process Description
Page 3 of 7
The firing stanchions electrical circuits for each burn station are buried underground throughout the
Burning Grounds. Burn Stations 1 through 12 contain a multiple firing stanchions (firing posts) for each
burn station. Burn Stations 13 and 14 have a single firing stanchion for each burn station. The electrical
components for the relays, power supply, etc. are located in Bunker M-136. A heavy steel pylon is
located in each firing stanchion containing the ignition wire. This steel pylon is to protect the electrical
equipment from the intense heat generated during the open burning event. An electrical igniter is placed
in a minimum of one tray for each firing stanchion for the burn event.
Several safety interlocks are in place to prevent inadvertent ignition of the system while operators are in
the Burning Grounds. Ignition of all the burning pans is completely remote and controlled by a system of
switches in the M-136 control bunker. Before initiating a burn, the resistance of each circuit is tested to
ensure all of the connections have been made properly. Pressing the System Activation button activates
a warning siren. A siren will sound for approximately 40 seconds and the ignition system is then armed
and ready to fire. The ignition switches located in the control bunker can then ignite the rows and
stanchions that are selected. Generally, all firing stanchions that contain waste to be burned are ignited
consecutively with only a few minuets delay between ignitions of firing stanchions. The burn is observed
and recorded in the control bunker via a closed circuit television system.
No entrance is allowed into the M-136 Burn Grounds during the burning process. After a burn, a 12-hour
waiting period is normally required prior to entering the Grounds. Entrance is then permitted and a
thorough check for abnormalities that may have occurred during the burn is done. This check is done
looking for reactive material that was not completely treated and may have left the burn trays during the
burn event, or resulted from an unplanned detonation. Any unbumed reactive material is collected and
placed in the nearest tray to be re-burned. A forklift is then used to carry and dump the trays containing
the burn ash to the Industrial Waste Trench (IWT) located in the far east end of the M-136 Burn Grounds.
If a burn event occurs at the end of the working week such as Thursday, the ash generally is not
transported to the IWT until the beginning of the next workweek. A forklift or a backhoe is used to carry
the large-scale obsolete rocket motor cases for disposal in the IWT.
The maximum allowable treatment quantity limits per burn station per event at Burn Stations 1 through 13
are: (1) HMX and/or RDX = 500 pounds, (2) neat 1.1 propellant/contaminated materials = 20,000
pounds, and (3) neat 1.3 propellant/contaminated materials = 50,000 pounds. The maximum limit for
treating motors at Burn Station 14 is 50,000 pounds per event. The maximum quantity of waste that may
be burned at M-136 is 106,500 lbs/day. The Utah Division of Air Quality (UDAQ) established this limit
based on HCl emissions.
OB/OD Process Description
Page 4 of 7
Open burning at M-136 can occur once a day, five days a week (Tuesday through Saturday). However,
treatment usually takes place 3 days a week (Tuesday through Thursday) during the afternoon hours
when dispersion parameters are most favorable. When wind velocity exceeds 15 miles per hour, disposal
by burning cannot occur. No treatment activities are conducted on Sunday or Monday unless a significant
safety issue is present. Disposal operations are normally conducted between the hours of 1000 and 1800
hours.
Waste material is delivered to the Burn Grounds and packaged in a variety of containers and sizes
including but not limited to super sacks, conductive/static dissipative bags, and buckets. The Bacchus
waste is received in conductive/static dissipative bags and cardboard/wood containers. Autoliv waste is
received in high-density polyethylene bags and cardboard containers.
Some waste materials are desensitized prior to transporting to the M-136 Burn Grounds with shingle oil,
diesel fuel, or triacetin. The requirement to desensitize is identified in the waste profile system. This is
done to ensure the safe handling of static sensitive materials.
Material delivered to M-136 may be offloaded from the vehicle into the burn trays by hand, knuckle-boom-
crane, or by forklift. The vehicle is parked next to the receiving tray, then the appropriate side rails on the
trailer are lowered and the web belts are removed if necessary allowing the material to be offloaded and
placed into the burn tray.
Typical waste treated at M-136 include but are not limited to 1.1 propellant, 1.3 propellant, propellant
contaminated waste, reactive laboratory waste, waste solid rocket motors, propellant ingredients such as
nitroglycerin, ammonium perchlorate, aluminum, cyclotetraethylenetetranitramine (HMX), and similar
propellant, explosive and pyrotechnic ingredients. Similar wastes are also received from Autoliv, ATK
Thiokol Bacchus, and on rare occasion from other Department of Defense/government facilities. All
wastes received from off-site such as Autoliv and Bacchus waste are burned within 24 hours.
Open burning of reactive waste can be conducted at any station identified 1-13. However, our operating
convention is to open burn reactive laboratory waste at station 13, although some laboratory wastes such
as propellant test loafs may be burned at stations 1 through 12. Operation of station 14 has been
described previously.
Reactive wastes with listed EPA waste numbers are identified, and isolated from other material enabling
the ash to be collected and shipped offsite for disposal. F003 Contaminated Ash is not required to be
collected and shipped, as it is exempted under the Hazardous Waste Identification Rule.
OB/OD Process Description
Page 5 of 7
3.2 M-225 Treatment Unit
The M-225 treatment unit receives small amounts of the reactive waste materials from the Plant III
propellant development area. These materials are treated via open burning or open detonation. M-225
is surrounded with an 8-foot high chain link fence. The open burning treatment quantities are limited to
500 pounds per tray of neat propellants, and 1000 pounds per tray of propellant contaminated material.
The maximum quantity of waste that may be treated is 1500 lbs/day. The open detonation treatment
quantity is limited to 500 pounds per event. The layout of M-225 is shown in Figure 4.
Within the M-225 Burn Grounds are four burn stations with one burn stanchion in each station, and one
tray per station. Unlike M-136 operations the trays at M-225 are not moved from one burn station to
another. Burn tray construction is comparable to those used in the M-136 Burn Grounds. There are two
soil lined burns trays and two unlined burn trays that are used for open burning at M-225. The two soil
lined burn trays are for treatment of high-energy wastes and composite propellant waste. The other two
trays are for treatment of listed and miscellaneous reactive wastes.
Treatment activities at M-225 are very similar to the operations at M-136 with only a few differences.
Usually, treatment takes place only once or twice per month and involves small quantities (600 pounds or
less) of waste materials. During the burn event a burn tray is ignited and allowed to burn down, and then
the next tray is ignited. This routine is followed until all the trays have been burned completing the
monthly burn event. The re-entry waiting time following a burn event at M-225 is 16 hours. Open
detonation is conducted at one location within the M-225 fenced area. Detonation pits are prepared by
using a backhoe or other equipment. Soon after, the reactive wastes are then placed into the pit and
detonated. The M-225A building is the control bunker that contains the system for firing the igniters that
are placed in the burn trays. The firing system functions the same as the M-136 process that was
previously described.
The reactive wastes treated by open burning at M-225 include neat double base (1.1) propellants and
composite propellants (1.3), as well as, reactive contaminated materials such as cloth and paper wipes,
metal containers, plastics, and propellant ingredients. Reactive wastes are collected in a variety of
containers and sizes including but not limited to super sacks, and buckets lined with conductive/static
dissipative bags that may contain desensitized ingredients that are the same as those used for wastes at
M-136.
OB/OD Process Description
Page 6 of 7
Ash resulting from the treatment of reactive wastes with listed EPA waste numbers is collected and
shipped for offsite disposal. All other ash is sent for disposal in the M-136 IWT. The burn tray that
contains the reactive wastes with listed EPA waste numbers remains covered except when a burn event
is occurring. Accumulation of water in the burn trays at the M-225 burn grounds has not been an issue
since two of the trays contain soil, one tray is covered, and the other tray receives sufficient evaporation.
OB/OD Process Description
Page 7 of 7
ATK Thiokol
Promontory Plant
OB/OD Waste Characterization
The wastes open bumed at M-136 and M-225 are classified into company-defined
reactive categories, delineated in Table 1. In order to facilitate the safe handling ofthese
reactive wastes, we fiirther characterize these materials into waste profiles. Each waste
profile is addressed with specific, in-house handling and disposal instructions in order to
avoid potential accidents fi'om mishandling ofthese highly energetic materials.
Table 2 contains the profile reference number and waste characterization for each
reactive category. A description ofthe acronyms used in this table is found in Table 4.
TABLE 1
Reactive Waste Categories
A i Class 1.3 Composite Propellant Without HMX, RDX, or CXM-3
B ! Class 1.3 Composite Propellant With HMX, RDX, or CXM-3
C i Class 1.1/1.3 Nitrate Ester Containing Materials
D j High Explosive Materials
I—
E Class 1.3 Pyrotechnic, llluminants. Metal Powders, or Autoliv ASP Products
' F ' Oxidizers (Does Not hiclude High Explosives Such as HMX, RDX, or CXM-3
G • Development Material - R&D Lab Use Only / Indicate Suspected Category A-F
H ! Unique Waste - Indicate Disposal Profile Number Below:
PR15 Aziridine cured
aluminized HC
polymer
HC (CTPB) Polymer with Antioxidants/Chelating
agents/Peroxide or acid scavenger additives; Aziridine
curatives; Plasticizers: DOA, DOS, IDP, Polybutene;
Ammonium Perchlorate; Aluminum powder; Bum rate
catalysts: Iron oxide, aluminum oxide, iron linoleate; epoxy
additives
OB/OD Waste Characterization
Page 1 of22
TABLE 2
Waste CharacterizatioD
Reac^vity
Groiqp
A
A
A
A
A
A
FroIHe
Nwnjber
PR17
PRI 9
PR21
PR22
PR23
PRS6
Geaeral
DescriptJon
GAP KP boron
propellant
Aluminized HB,
HC or HA
polymer -
propellant
Aluminized
HTPB, isocyanate
(with catocene) -
propellant
Aluminized
HTPB, isocyanate
(no catocene) -
propellant
Low smoke HTPB
propellant without
nitramines
AP melt pour, no
RDX or
aluminum, (PAX-
24 and similar)
Materials
GAP (Glycidal Azide Polymer); Isocyanate Curatives or
Processing aids: IPDI, DDI, N-100, TMXDI, ODI; Boron;
Potassium Perchlorate
HB (PBAN), HC (CTPB) Polymer or HA (PBAA) Polymer
with Antioxidants; Epoxy curatives; Plasticizers: DOA,
DOS, IDP, Oleic Nitrile; Ammonium Perchlorate;
Aluminum powder; Bum rate catalysts: Iron oxide,
aluminum oxide; Thixotropic Powder; Stabilizers: PBNA
(phenyl-beta-napthylamine), TDPA (thiodiphenylamine),
DPPDA (N, N'-Bis(l,4-dimethyl pentyl) para-
phenylenediamine), MNA (n-methyl p-nitroaniline); Cure
Catalysts: Chromium Octoate
HTPB Polymer with Antioxidants/Chelating agents/Peroxide
or acid scavenger additives; Isocyanate Curatives or
Processing aids: IPDI, DDI, N-100, TMXDI, ODI; Cure
catalysts; TPB, MA, TPTC; Ammine based bonding agents
(TEP ANOL, TEP AN, TET); Plasticizers: DOA, DOS;
Ammonium Perchlorate; Aluminum powder; Bum rate
catalysts: Catocene, Ferrocene
HTPB Polymer with Antioxidants/Chelating agents/Peroxide
or acid scavenger additives; Isocyanate Curatives or
Processing aids: IPDI, DDI, N-lOO, TMXDI, ODI; Cure
catalysts: TPB, MA, TPTC; Bonding agents: difunctional
aziridines (HX-752, PFAZ-752), ammine based bonding
agents (TEPANOL, TEP AN, TET); Plasticizers: DOA, DOS,
IDP, Oleic Nitrile, DOZ; Ammonium Perchlorate;
Aluminum powder; Bum rate catalysts: Iron oxide,
aluminum oxide; Epoxy resin additives
HTPB Polymer with Antioxidants/Chelating agents/Peroxide
or acid scavenger additives; Isocyanate Curatives or
Processing aids: IPDI, DDI, N-100, TMXDI, ODI; Cure
catalysts: TPB, MA, TPTC; Bonding agents: difunctional
aziridines (HX-752, PFAZ-752), ammine based bonding
agents (TEPANOL, TEP AN, TET); Plasticizers: DOA, DOS,
IDP, Oleic Nitrile; Ammonium Perchlorate; Aluminum
powder, carbon black, zirconium carbide; Bum rate
catalysts: Iron oxide, aluminum oxide. Ferric Floride; Bum
rate suppressant: oxamide
2-,4-dinitoanisole; n-methyl p-nitroaniline; Ammonium
Perchlorate
OB/OD Waste Characterization
Page 2 of 22
TABLE2
Waste Characterization
ReMivity
Grenp
A
A
B
B
B
B
ihtim»
Nnmber
PRS 8
PR50
PR12
PR24
PRS 7
PRS 9
General
Descr^rtion
R & D lab use
only
Talley Defense
Systems
Aluminized HTPB
with nitramines &
isocyantes
Low smoke HTPB
propellant with
nitramines
AP&RDX/HMX
(PAX 2 land
similar)
R & D lab use
only(HMX, RDX,
CL-20)
Matoials
Oxidizers (AP, AN, KP, NaNOS, KNOS, ADN, KDN); Inert
or energetic class 1.3 polymer (Butadiene family, GAP,
oxetanes); Curing agents (isocyanates, epoxies, aziridines);
Bonding agents (ammine based, aziridine based); Metal fuel
and other fuel (aluminum, magnesium, alum/mag alloys,
carbon, ZrC); Inert or energetic class 1.3 plasticizers (DOA,
DOS, DOZ, IDP, GAP, polybutene); Cure Catalysts (TPB,
TPTC, DBTDL, MA); Ballistic Catalysts (Fe203, A1203,
Iron Linoleate, Catocene, Ferrocene); Antioxidants, chemical
stabilizers
Cariiflex IR-S09; Ammonium Nitrate; DOZ; Pepton65;
Carbon Black; p-Quinone dioxime; Iron Blue; Sulfer
HTPB Polymer with Antioxidants/Chelating agents/Peroxide
or acid scavenger additives; Isocyanate Curatives or
Processing aids: IPDI, DDI, N-100, TMXDI, ODI; Cure
catalysts: TPB, MA, TPTC; Bonding agents: difunctional
aziridines (HX-752, PFAZ-752), ammine based bonding
agents (TEPANOL, TEP AN, TET); Plasticizers: DOA, DOS,
EDP, Oleic Nitrile; Ammonium Perchlorate; Aluminum
powder; Bum rate catalysts: Iron oxide, aluminum oxide.
Ferric Fluoride; Nitramines: RDX, HMX
HTPB Polymer with Antioxidants/Chelating agents/Peroxide
or acid scavenger additives; Isocyanate Curatives or
Processing aids: IPDI, DDI, N-100, TMXDI, ODI; Cure
catalysts: TPB, MA, TPTC; Bonding agents: difunctional
aziridines (HX-752, PFAZ-752), ammine based bonding
agents (TEPANOL, TEP AN, TET); Plasticizers: DOA, DOS,
IDP, Oleic Nitrile; Ammonium Perchlorate; Aluminum
powder, carbon black, zirconium carbide; Bum rate
catalysts: Iron oxide, aluminum oxide. Ferric Fluoride; Bum
rate suppressant: oxamide; Nitramines: RDX, HMX
HMX; RDX; 2-,4-dinitoanisole; n-methyl p-nitroaniline;
Ammonium Perchlorate
Oxidizers (AP, AN, KP, NaNOS, KN03, ADN, KDN); Inert
or energetic class 1.3 polymer (Butadiene family, GAP,
oxetanes); Curing agents (isocyanates, epoxies, aziridines);
Bonding agents (ammine based, aziridine based); Metal fuel
and other fiiel (aluminum, magnesium, alum/mag alloys,
carbon, ZrC); Inert or energetic class 1.3 plasticizers (DOA,
DOS, DOZ, IDP, GAP, polybutene); Cure Catalysts (TPB,
TPTC, DBTDL, MA); Ballistic Catalysts (Fe20S, A1203,
Iron Linoleate, Catocene, Ferrocene); Antioxidants, chemical
stabilizers; Nitramines (HMX, RDX, CXM-3, CL-20)
OB/OD Waste Characterization
Page 3 of22
TABLE2
Wiffite Charactai3»tion
Reactivity
Gronp
B
B
C
C
c
c
c
TrttOe
NuBber
PR40
PR51
PR7
PR29
PRSO
PRSl
PR32
General
Descrqrtion
R & D lab use
only
Aluminized HTPB
Class 1.3
Propellants, with
nitramines,
isocyanate cured.
NG based lacquers
NG crosslinked
double based,
depleted MNA
NG crosslinked
double based -
nitramines
Nitramines & AP,
NG double based
NG contaminated
waste
Materials
Oxidizers (AP, AN, KP, NaNOS, KNOS, ADN, KDN); Inert
or energetic class 1.3 polymer (Butadiene family, GAP,
oxetanes); Curing agents (isocyanates, epoxies, aziridines);
Bonding agents (ammine based, aziridine based); Metal fuel
and other fuel (aluminum, magnesium, alum/mag alloys,
carbon, ZrC); Inert or energetic class 1.3 plasticizers (DOA,
DOS, DOZ, EDP, GAP, polybutene); Cure Catalysts (TPB,
TPTC, DBTDL, MA); Ballistic Catalysts (Fe20S, A120S,
Iron Linoleate, Catocene, Ferrocene); Antioxidants, chemical
stabilizers; Nitramines (HMX, RDX, CXM-3, CL-20)
HTPB Polymer with Antioxidants/Chelating agents/Peroxide
or acid scavenger additives; Isocyanate Curatives or
Processing aids: IPDI, DDI, N-100, TMXDI, ODI; Cure
catalysts: TPB, MA, TPTC; Bonding agents: difunctional
aziridines (HX-752, PFAZ-752), ammine based bonding
agents (TEPANOL, TEP AN, TET); Plasticizers: DOA, DOS,
EDP, Oleic Nitrile; Ammonium Perchlorate; Aluminum
powder; Bum rate catalysts: Iron oxide, aluminum oxide.
Ferric Fluoride; Nitramines: RDX, HMX
Methylene Chloride; Acetone; NG (Nitroglycerin); PEG
polymer; NC (Nitrocellulose); Stabilizers (MNA, 2-NDPA,
4-NDPA)
NG (Nitroglycerin); Stabilizers (2-NDPA, 4-NDPA);
Isocyanate Curatives or Processing aids: IPDI, HDI, N-100,
N-3200 ; Cure catalysts: TPB; NC (Nitrocellulose);
Polyether/Polyester Polymers ; Ammonium Perchlorate;
Aluminum powder; Carbon Black; Nitramines
(HMX,RDX); Mixed acid; Soda Ash
NG (Niti-oglycerin); Stabilizers (MNA, 2-NDPA, 4-NDPA);
Isocyanate Curatives or Processing aids: IPDI, HDI, N-100,
N-S200; Cure catalysts: TPB; NC (Niti-ocellulose);
Polyether/Polyester Polymers; Ammonium Perchlorate;
Aluminum powder; Carbon Black; Nitramines
(HMX,RDX); Mixed acid; Soda Ash
NG (Nitroglycerin); Stabilizers (2-NDPA, 4-NDPA); Inert
Plasticizers (triacetin); Resorcinol; NC (Nitrocellulose);
Ammonium Perchlorate; Aluminum powder; Nitramines
(HMX,RDX)
Triacetin; NG (Niti-oglycerin); Methylene Chloride;
Acetone
OB/OD Waste Characterization
Page 4 of22
TABLE 2
Waste Characterization
Reactivity
Gveqp
c
c
c
c
Nimber
PR41
PR42
PR47
PR55
General
Description
R & D lab use
only
R & D lab use
only
Pelletized
nitrocell.(PNC)
heptane wetted
Developmental
Material - R&D
Lab use only /
suspected group C
Class 1.3
Materials
Oxidizers (AP, AN, KP, NaNOS, KNOS, ADN, KDN);
Niti-amines (HMX, RDX, CXM-3, CL-20); Inert polymer
(Polyethers, Polyesters); Energetic polymers (GAP, PGN,
Oxetanes); Energetic Gel Polymers (NC, PNC, CDN,
nih-ated carbohydrates); Isocyanate Curatives or Processing
aids: IPDI, ODI, HDI, N-100, N-3200, DDI, PAPl; Metal
fiiel and other fliel (aluminum, magnesium, alum/mag alloys,
carbon, aluminum trihydride [Alane]); Energetic plasticizers
(nitrate esters, NENAs); Inert plasticizers (Polybutene,
Triacetin); Cure Catalysts (TPB, TPTC, DBTDL, MA);
Ballistic Catalysts and stabilizers (TPB, carbon black);
Chemical stabilizers (MNA, 2-NDPA, 4-NDPA) and
antioxidants
Oxidizers (AP, AN, KP, NaNOS, KN03, ADN, KDN);
Nitramines (HMX, RDX, CXM-3, CL-20); Inert polymer
(Polyethers, Polyesters); Energetic polymers (GAP, PGN,
Oxetanes); Energetic Gel Polymers (NC, PNC, CDN,
nitrated carbohydrates); Isocyanate Curatives or Processing
aids: IPDI, HDI, N-100, N-S200; Metal fuel and other fuel
(aluminum, magnesium, alum/mag alloys, carbon); Energetic
plasticizers (nitrate esters, NENAs); Inert plasticizers
(Polybutene, Triacetin); Cure Catalysts (TPB, TPTC,
DBTDL, MA); Ballistic Catalysts and stabilizers (TPB,
carbon black); Chemical stabilizers (MNA, 2-NDPA, 4-
NDPA) and antioxidants
PNC (Pelletized Nitro cellulose); Heptane
Oxidizers (AP, AN, KP, NaNOS, KNOS, ADN, KDN);
Nitramines (HMX, RDX, CXM-S, CL-20); Inert polymer
(Polyethers, Polyesters); Energetic polymers (GAP, PGN,
Oxetanes); Energetic Gel Polymers (NC, PNC, CDN,
nitrated carbohydrates); Isocyanate Curatives or Processing
aids: IPDL HDI, N-lOO, N-3200; Metal fuel and other fuel
(aluminum, magnesium, alum/mag alloys, carbon); Energetic
plasticizers (nitrate esters, NENAs); Inert plasticizers
(Polybutene, Triacetin); Cure Catalysts (TPB, TPTC,
DBTDL, MA); Ballistic Catalyst - containing lead;
Chemical stabilizers (MNA, 2-NDPA, 4-NDPA) and
antioxidants
OB/OD Waste Characterization
Page 5 of22
TABT,F, 2
Waste Charactoization
««w#p|ty
Gnuf
D
D
D
D
D
D
D
D
D
D
D
D
Nnndier
PR4
PRS
PR9
PRM
PRI 6
PR20
PRS3
PR35
PR43
PR44
PR48
PR49
General
Description
TATB&
intermediate
ADN
contaminated
Aluminum/teflon
CL-20
recrystalization
ETPE gun
propellant
Nitramines (HMX,
RDX CL-20)
Nitroguanidine
HMX & RDX
(PAX -2A and
similar)
HMX or RDX
(PAX-S or similar)
R & D lab use
only
Primary explosive
(no lead)
Primary explosive
(with lead)
Materials
TATB (l,3,5-ti-iamino-2,4,6-tinniti-obenzene); TETNB
(l,S,5-triethoxy-2,4,6-tinitrobenzene) Intermediate 2; TNPG
(1,3,5-trinitrophloroglucinol) Intermediate 1; Methanol;
Ethanol; TEOF (Triethyl-orthoformate); Hydrochloric Acid;
Sodium Nitrite; Sodium Nitrate; Sodium Chloride;
Phloroglucinol (Benzene-1,3,5-triol
ADN
Teflon (PTFE); Aluminum
Isopropanol; Ethyl Acetate; Benzyl formate; Stan Plas-100;
CL-20
Acetone; Ethyl Acetate; Niti-amines (RDX, HMX, CL-20);
Energetic Binders (CE-BAMO, BAMO/GAP,
BAMO/AMMO, BAMO/NMMO); Nitiro guanidine;
Carbazole dioxazine violet; TEX
Nitramines (HMX, RDX, CL-20)
Nitroguanidine
HMX; RDX; BDNPA/F; CAB; Zonyl fluoroadditive
(chemical makeup similar to Teflon)
Niti-amines (HMX or RDX); BDNPA/F; CAB; Zonyl
fluoroadditive (chemical makeup similar to Teflon);
Aluminum
Niti-amines (HMX, RDX, CXM-3, CL-20); Nitro aromatics
(TNT, HNS, nitro anisoles & phenols); PETN; Oxidizers
(AP,AN, KP, NaNOS, KNOS); Inert binders/fillers
(plastics, rubbers, waxes, carbon); Metal fuels (aluminum,
magnesium, alum/mag alloys, Zirconium, Titanium);
Energetic plasticizers (A/F, niti-ate esters); Energetic Binders
(nitrocellulose, BAMO/AMMO); Chemical stabilizers
(MNA, 2-NDPA, 4-NDPA) and antioxidants
Water/Glycol mixture; Non-lead containing primary
explosives (DDNP, Tetracene, Styphnic Acid, Sodium
Picramate); Non-lead containing metal styphnate complexes;
Non-lead containing metal picramate complexes; CL-20
based primary explosive formulations that do not contain
water reactive metals
Lead containing primary explosives (Lead Styphnate [44%
Pb], Lead Azide [71% Pb]); Metallic Fuels (Zirconium,
Titanium, Aluminum, Magnesium); Oxidizers (AP, AN, KP,
KNOS, NaNOS); Inert Binders/fillers (plastics, rubbers,
waxes, carbon)
OB/OD Waste Characterization
Page 6 of22
TABLE2
Waste Characterization
RMCttvj^
Gr^p
D
D
E
E
E
E
E
E
E
E
E
lumber
PR52
PR54
PRI
PR5
PR6
PRll
PRIS
PR26
PR27
PR28
PR45
G^wral
Description
Magnesium Teflon
and Viton or
thermoplastic
Primary
Explosives that do
not contain lead
but contain water
reactive metals
Tin, indium,
bismuth based
reactives
Moisture resistant
black powder
llluminants - Mag,
KCL, strontium
nitrate
Boron potassium
niti-ate (BKNOS)
Cesium &
potassium based
llluminants
Mag & AP based
llluminants
Magnesium,
potassium
perchlorate,
strontium niti-ate -
illuminant
Magnesium &
sodium nitrate
illuminant
R & D lab use
only
Materials
Acetone; Teflon (PTFE); Viton A; Thermoplastic (poly-
styrene, PVC, etc.); Magnesium; Dimethyl phalate (DMP);
Iron Oxide; Graphite
Kerosene; Diesel fuel; Shingle Oil; MIC based primary
explosive formulations that contain water reactive metals;
CL-20 based primary explosive formulations that contain
water reactive metals
Tin; Indium; Bismuth; Potassium Perchlorate;
Ethanol; Potassium Nitrate; Potassium Perchlorate;
Phenolphthalein; Poly(Vinyl Acetate); Ethyl Cellulose
Magnesium; Potassium Perchlorate; Strontium Nitrate;
Hexachlorobenzene; Polyvinyl Chloride; Asphaltum;
Linseed Oil; Dextrin; Caster Oil
Boron; Potassium Nitrate; Nylon; Graphite
CsNOS; KNOS; Witco Resin; Iron Oxide; Hexamine;
Silicon; Boron; ERL0510; MgCOS
Magnesium; Ammonium Perchlorate; R45M; IPDI
Curative; TPB; DOA; Anthracene; Iron Oxide
Magnesium; Potassium Perchlorate; Strontium Nitrate;
Hexachlorbenzene; Polyvinyl Chloride; Asphaltum;
Linseed Oil; Dextrin; Caster Oil
Magnesium; Sodium Nitrate; Witco Polyester Resin;
Epoxy Curative; Iron Linoleate; Succinic Acid
Oxidizers (AP, AN, KP, NaNOS, KNOS, (SrN0S)2, metal
peroxides, oxides, Cu2(OH)3NOS, Teflon); Inert or
energetic class 1.3 Polymers; Curatives: IPDI, HDI, N-100,
N-S200, Epoxies; Metal fuels (aluminum, magnesium,
alum/mag alloys, Zr, B, Si); Other fuels (sulfur, carbon,
phenolphthalein, organic nitrates, tetrazoles, metal hydrides);
Inert or energetic plasticizers; Cure Catalysts (TPB, TPTC,
DBTDL, MA); Ballistic Catalysts and stabilizers (TPB,
carbon black); Chemical stabilizers (MNA, 2-NDPA, 4-
NDPA) and antioxidants
OB/OD Waste Characterization
Page 7 of 22
TABLE 2
Waste Characterisation
Reactivi^;
Qrmp
E
F
G
G
G
G
H
H
Profile
PR46
PRIO
PR2
PRI 8
PRS4
PR5S
PRS
PR25
General
Desaiption
Various metal
powders
< 15 micron AP
ETPE energetic
thermo
Glycidal Azide
Oxetanes
Peroxide forming
chemicals
Poly Oxetane
Iron linoleate
contaminated
cotton
Materials
Calcium powder; Magnesium powder; Lithium powder;
Strontium powder; Zirconium powder; Zinc powder;
Titanium Dibromide powder; Cupric oxide and Aluminum
powder
Ammonium Perchlorate (AP)
Methanol; Teti-ahydrofurane (THF); Poly (1,3-Bis-
(azidomethyl)-methyl Oxetane) (Poly(BAMO), PB); Poly(l-
azidomethyl-S-methyl Oxetane (AMMO)) (Poly(AMMO),
PA); Poly(l-nitromethyl-3-methyl Oxetane) (Poly(NMMO),
PN); Glycidal Azide Polymer (GAP-multiftinctional);
Toluene Diisocyanate; Di-butyl-tin-di-laurate; 1,4-Butane-
diol; ETPE (Various hardblock-softblock);
Xylene; Toulene; Ethyl Acetate; Glycidal Azide Polymer
(GAP)
Acetone; Ethyl acetate; Toluene; Methylene chloride;
Methyl chloroform; Oxetanes: AMMO (S-azidomethyl 3-
methyl oxetane), BAMO (3,3-bis (azidomethyl) oxetane),
NMMO (S-Niti-ato methyl, 3-methyl oxetane), PolyAMMO,
PolyBAMO
See Table 3
Methanol; Methylene Chloride; 1 ,S-Bis-(azidomethyl)-
methyl Oxetane (BAMO); 1-azidomethyl-3-methyl Oxetane
(AMMO); l-nitromethyl-3-methyl Oxetane (NMMO);
Poly(BAMO); Poly(AMMO); Poly(BAMO-co-AMMO);
Poly(BAMO-co-NMMO); Poly(NMMO); Diphenyl-tin-
dichloride; 1,4-Butane-diol
Iron Linoleate or Linseed Fatty Acid
TABLE 3
Reactive Group G, Profile Number PR53
Reactive & Unstable lab waste chemicals / Burned List
2,4,6-Trifluoronitrobenzene CAS #315-14-0
2-Nitroethanol CAS # 625-48-9
Tetranitromethane CAS # 509-14-8
Acryloyl Chloride 96% CAS # 814-68-6
4-Nitrobenzenediazcnium Tetrauoroborate CAS # 456-27-9
OB/OD Waste Characterization
Page 8 of 22
TABLES
Reactive Group G, Profile Number PR53
Reactive & Unstable lab waste chemicals / Burned List
Iron Pentacarbonyl CAS # 13463-40-6
lodotrimethylsilane 97% CAS # 16029-98-4
Nitrosylsulfuric Acid, CA 95% CAS # 7782-78-7
1,4-Dioxane, 99+% CAS # 123-91-1
4-Nitroaniline CAS # 100-01-6
Sec-Butyllithium, 1.3M Solution In Cyclohexane CAS # 598-30-1
6,6-Dimethylfulvene, 99% CAS 2175-91-9
lodotrimethylsilane, 97% CAS # 16029-98-4
Methyllithium, low Chloride, 1.6 M CAS # 917-54-4 In Diethyl Ether CAS # 60-29-7
Isoprene, 99% Cas # 78-79-5
Propargyl Alcohol 99% CAS # 107-19-7
Butyllithium, 2.5M Solution In Hexanes CAS # 109-72-8
Lithium Aluminum Hydride, Powder, 95% CAS # 16853-85-3
Sodium Hydride, 60% in Mineral Oil CAS # 7646-69-7
Cyanuric Chloride, 99% CAS # 108-77-0
Succinyl Chloride, 95% CAS # 543-20-4
Sodium Peroxide CAS # 1313-60-6
Diethlyzinc, 15 wt. % (1.1m) Solution In Toluene CAS # 577-20-0
Silver Perchlorate Hydrate CAS # 14242-05-8
Ethylmagnesium Bromide, 3.0m Soiurion In Diethyl Ether CAS # 652-90-6
2,4-Dinitroanisole, 98% CAS # 119-27-7
2,4-Dinitrophmol CAS #51-28-5
2-4-Dinitrophenylhydrazine, 97% Moistened With Water CAS # 119-26-6
Lithium Borohydride, 95% CAS #16949-15-8
Sodium Ethoxide, 96% CAS # 141-52-6
Triethyloxonium Tetrafluoroborate, 1.0m Soiurion In Dichloromethane CAS # 386-39-8
Boron Trifluoride Ethylamine Complex CAS # 75-23-0
Collodion, Flexible, U.S.?. CAS # 9004-70-0 ( Niri-ocellulose) CAS # 60-29-7 ( Diethyl Ether)
Aluminum Iodide, Anhydrous, Powder, CAS # Aluminum 7429-90-5 CAS # Iodide 7553-56-2
Potassium Borohydride, 98% CAS #13762-51-1
Calcium Hypochlorite CAS # 7778-54-3
Potash, Sulfurated CAS # 39365-88-3
Dodecaoyl Peroxide CAS # 105-75-8
Decahydronaphthalene, Anhydrous, 99+% CAS #91-17-8
Sodium Hypophosphite CAS #7681-53-0
Acrylic Acrylate CAS # 3667-52-5
Ammonium Iodide CAS # 12027-06-4
Potassium Iodide CAS # 7681-11-0
Potassium Tert-Butoxide CAS # 856-47-4
Ethyl Ether CAS # 60-29-70
Barium Azide CAS # 18810-58-7
Iminodiacetonitrile CAS # 628-87-5
OB/OD Waste Characterization
Page 9 of 22
TABLE 3
Reactive Group G, Profile Number PR53
Reactive & Unstable lab waste chemicals / Burned List
Phosphours Trichloride CAS # 7719-12-2
2,5-Dimethyl-2,5-di-(benzoylperoxy) Hexane CAS #2618-77-1
PSAN CAS # 33363-00-7 ( Zinc Diammine Dinin-ate) CAS # 6484-52-2 (Ammonium Nitrate)
Nickle (II) Perchlorate, Hexahydrate CAS # 13520-61-1
2,2'-Azobis(2-methylpropionitrile), 98% CAS # 78-67-1
Borane-tetrahydrofuran Complex CAS #14044-65-6
Titanium (IV) Chloride, 99.9 % CAS # 7550-45-0
Trigonox ( Organic Peroxides / Alkyl Peroxides) CAS # 995-33-5
VUL-CUP 40KE ( Organic Peroxide) CAS # 25155-25-3
Hydrogen Peroxide 30% CAS # 7722-84-1
Lupersol 231 (Organic Peroxide) CAS # 6731-36-8
l,l-Di-(tert-butylperoxy)cyclohexane CAS # 3006-86-8
Varox DBPH 50 CAS # 78-63-7 ( Peroxide)
Tert-Butyl Perbenzoate CAS # 614-45-9
Di-Cup 40KE CAS # 80-43-3 ( Organic Peroxide)
Vamox 130 XL CAS #1068-27-5 ( Organic Peroxide)
MEK Peroxide CAS #1338-23-4
Dibenzyl Peroxide CAS # 94-36-0
TABLE 4
Acronym List
Acronym
AND
/iMMO
Description
Ammonium Dinitramide
1-azidomethyl-3-methyl Oxetane
AN
/VP
BAMO
Ammonium Nitrate
BDNPA/F
CL-20
Ammonium Perchlorate
1,3-Bis-(azidomethyl)-methyl Oxetane
bis-(2,2-dinitropropyl) acetal/formal
gun propellant (trade secret)
CXM-3 RDX + Dioctyl Maleate
DBTDL
DDI
Dibutyl Tin Dil urate
Aliphatic Diisocyanate
OB/OD Waste Characterization
Page 10 of 22
1
1
1
1
i
Acronym
DDNP
DMP
DOA
DOS
DOZ
DPPDA
ERL0510
ETPE
GAP
HA (PBAA) Polymer
HB (PBAN)
HC (CTPB) Polymer
HDI
HMX
HTPB Polymer
IDP
IPDI
KDN
KNOS
KP
MA
MNA
N-100
N-S200
TABI
Acrony
LE4
mL
;
i
1
i
OB/OD Waste Cha
Page 11 0
ist
Description
Diazodinitrophenol
Dimethyl phalate
Dioctyl Adipate
Dioctyl Sebacate i
2-Ethyl-4-methylimidzaoIe
N, N'-Bis( 1,4-dimethyl pentyl) para- '
phenylenediamine
AralditeMY0510 !
1
Energetic Thermoplastic Elastomer
Glycidal Azide Polymer
Polybutadiene Acrylic Acid Polymer
Polybutadiene Acrylic Acid Acrylonitrile
Polymer
HYCAR CTPB 2000X172 Polymer
1,6-Hexamethylene Diisocyanate
cyclotetramethylene tetranitramine
Hydroxyl Temiinated Polybutadiene
Isodecyl Pelargonate
Isophorone Diisocyanate
Potassium Dinitramide
Potassium Nitrate
Potassium Perchlorate
Maleic Anhydride
1
racte
F22
n-methyl p-nitroaniline
CyanamerN-100 Polyacrylamide
Methylene Chloride N-S200 Solution
rization
,
1
i
Acronym
NaNOS
NDPA
NMMO
ODI
PBNA
R45M
RDX
TDPA
TEPAN
TEPANOL
TET
THF
TMXDI
TPB
TPTC
TABLE 4
Acronym List
1 Description
Sodium Nitrate
Nitrodiphenylamine
l-nitromethyl-3-methyl Oxetane
Octadecyl isocyanate
Phenyl-beta-napthylamine
Poly BD R45M
Cyclotrimethylene h-initramine
Thi odiphenylamine
j Partially cyanoacrylated tetraethylenepentamine
TetraethylenepPentamine acrylonitrile glycidol
reaction product
TMXDI
Triethylenetetramine
Tetrahydrofurane
(meta) Aliphatic Isocyanate
Triphenyl Bismuth
Triphenyl Tin Chloride
Nearly all buming is conducted at M-136. During calendar years 2003 and 2004, the
total waste bumed at M-225 was 17,000 pounds, while at M-136 nearly 5 million pounds
was bumed during the same period. M-225 activity represents less than one percent of
the total open buming conducted at our Promontory plant and is not significantly
different fi-om the type of waste bumed at M-136. Accordingly, we will focus the
remainder ofthis discussion upon further characterization ofthe waste bumed at M-136.
Charts 1 through 8 compare the total waste bumed at M-136 (excluding contaminated
trash, which is approximately 5% ofthe total bumed) with the amount of each reactive
category bumed. The charts show the date each bum was conducted and the amount of
waste bumed that day. The period charted is fi-om January 2003 through June 2005.
Data prior to 2003 was excluded from this analysis due to the questionable categorization
of waste bumed.
OB/OD Waste Characterization
Page 12 of 22
<
a.
3 2 CD
T-
t «
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B o 1-I
o
'C
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is <N
(J r2
=0 CO
^ OH
Q
o
o
(0
6
CD
3
o
3
CQ
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.o
\
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cfl
_N 'C <u
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m o
u
c
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Ul
ID
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tfl cfl
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o o o o •>*•
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c-l
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ra
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D.
UJ Q.
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o
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0 0 0 0 (D
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0
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Q CO
0
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o o o o oo
o o o o to
o o o o
o o o o
CM
o o o o o o o o o 00
ooo ooo ooo ooo
CO •* CM
As can be seen from the charts. Reactivity Group A accounts for the vast majority of the
waste bumed and will dominate the risk assessment. The contribution of other reactivity
groups to the risk assessment will be limited to specific toxic concems that are not
already addressed by the Group A category.
Additionally, the impact from open buming the heavy metals listed in Table 5 will be
addressed. These metals have either been bumed in the past or may be bumed in the
future. Molybdenum was intentionally left off the list because its open buming is
prohibited under a consent decree.
Table 5
Potential Metals
Arsenic
Barium
Cadmium
Cesium
Chromium
Cobalt
Lead
Mercury
Selenium
Silver
The relative amount bumed at each M-136 bum station is shown in Chart 9. This chart
illustrates the percentage of total material bumed at each of the 14 bum stations for the
five-year period beginning in January 2000 and ending in December 2004.
OB/OD Waste Characterization
Page 21 of 22
ra
in
o> ** o
t 3? f^
J E o
"^§
CQ c., 'w c .2
n
g I
u
cfl CN
• <« O Ea
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CN
c«
Cfl
o •.^ iS CO
3=; (D CM
C o
ra
^p
&^ CO
CO
CO
g ^ CO
B
CO
cfl
Q O
g