DSHW-2005-005933 - 0901a06880165a8e (4)

June 17, 2005

Paul Hancock, Manager
Environmental Remediation
ATK Thiokol Inc. – Promontory
P.O. Box 707
Brigham City, UT 84302-0707

Re: OB/OD Risk Assessment Protocol Documents
ATK Thiokol – Promontory
EPA ID #009081357

Dear Mr. Hancock:

Thank you for meeting with Division of Solid and Hazardous Waste staff members on May 24, 2005 to discuss the review of the three OB/OD Subpart X permit protocol documents (Waste Characterization
and Air Dispersion Modeling, Human Health Risk Assessment, and Ecological Risk Assessment) submitted by ATK Thiokol - Promontory. The purpose of this letter is to summarize the results
of our discussion on OB/OD permitting issues at the Promontory facility.

Calculating the potential risks from OB/OD emissions requires sequential steps beginning with identifying what wastes will be treated followed by determining the appropriate emission
factors, air dispersion modeling, estimates of exposure, and calculation of risks. Many deficiencies in each of these steps were identified during the staff’s preliminary review of
the protocol documents. Some of these deficiencies were provided to ATK as discussion points for the meeting. A comprehensive review cannot be completed because of the interdependency
of each of the steps. Division staff and ATK agreed that the most efficient path forward in the permitting process is for ATK to sequentially revise and resubmit the documents.

The next step is for ATK to submit a thorough process description for both burn grounds and a comprehensive characterization of hazardous wastes that Thiokol expects to treat by OB/OD.
It is necessary to complete these components of the OB/OD operation before appropriate emission factors can be determined and used in the risk assessments. The process description
and waste characterization report will be considered a portion of the Subpart X, Part B Permit Application.

After the process description and waste characterization report is approved, the following steps will be needed:

Prepare a report on the characterization of OB/OD emissions for hazardous waste groups that will be treated at the burn grounds.
Conduct the air dispersion and deposition modeling analysis and submit report.
Conduct the human health and ecological risk assessments.

The Division suggests that a meeting be held prior to beginning each new step to discuss the applicable comments and questions that have been provided. In addition, the Division encourages
an open dialogue while working through this process to avoid numerous iterations of written comments and revised documents.

During the meeting, ATK committed to submit the process description and waste characterization report within two months. The Division requests that this report be submitted by July
29, 2005. If you have any questions, please contact Jeff Vandel at [phone].

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 6/17/05

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

DRD\JV\ts

c: Lloyd C. Berentzen, M.B.A., Health Officer, Bear River Health Department
Mike Gansecki, U.S. Environmental Protection Agency, Region VIII

File to: ATK Thiokol Inc. - Promontory

TN200500757.doc
288 North 1460 West • PO Box 144880 • Salt Lake City, UT 84114-4880 • phone [phone] • fax [phone]
T.D.D. [phone] • www.deq.utah.gov

State of Utah

Department of Environmental Quality

Dianne R. Nielson, Ph.D.
Executive Director

DIVISION OF SOLID AND HAZARDOUS WASTE
Dennis R. Downs
Director

JON M. HUNTSMAN, JR.
Governor

GARY HERBERT
Lieutenant Governor