DSHW-2007-008782 - 0901a0688016313d (6)

David P. Gosen, P.E.
Director, Environmental Services
ATK Launch Systems – Promontory
P.O. Box 707
Brigham City, UT 84302-0707

RE: Comments on the Draft Post-Closure Permit
ATK Launch Systems – Promontory Facility
EPA ID# UTD009081357

Dear Mr. Gosen:

The Division of Solid and Hazardous Waste has completed its review of the comments you provided, dated September 7, 2007, on the Draft Post-Closure Permit that was out for public comment.
Enclosed with this letter are our responses to your comments.

Thank you for your cooperation. If you have any questions, please contact Jeff Vandel of my staff at 538-6170.

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 9/25/07
Dennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board

DRD\JV\tjm

c: Paul Hancock, ATK Launch Systems

File to: ATK Launch Systems - Promontory

The Module, permit condition or attachment of interest is shown first, followed by ATK’s comment, the Division’s response to comment, and finally any changes made to the permit as a
result of ATK’s comment.

________________________________________________________________________

II.D.5.a. The Permittee shall install, on its premises, equipment appropriate to measure and record precipitation and wind speed in order to determine the occurrence of storm events.

ATK’s comment:

Since there is not a requirement to monitor wind speed in the permit, this not needed and should be removed.

Division response: The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

II.D.5.a. The Permittee shall install, on its premises, equipment appropriate to measure and record precipitation in order to determine the occurrence of storm events.
________________________________________________________________________

II.H.1. The Permittee shall demonstrate continuous compliance with R315-8-8 including the requirements to have and maintain hazardous waste liability coverage for sudden accidental occurrences
(in accordance with 40 CFR 264.147(a), incorporated by reference under R315-8-8).

ATK’s comment:

The requirement for liability insurance for a sudden accidental occurrence on closed, capped units like the LTTA’s is unnecessary due to the nature of the coverage and the characteristics
of the LTTAs. We ask that this requirement be removed.

Division response: The Division agrees with ATK. Permit Condition II.H.1. has been removed from the Permit. In the final Post-Closure Permit, Condition II.H.1. now applies to liability
coverage for non-sudden accidental occurrences. It is shown below:

II.H.1. The Permittee shall demonstrate continuous compliance with the requirements of 40 CFR 264.147(b) to have and maintain liability coverage for non-sudden accidental occurrences
(in accordance with 40 CFR 264.147(b), incorporated by reference under R315-8-8).

________________________________________________________________________

Module IV – General Comment

ATK’s comment:

The use of the term Groundwater Protection “Standard” implies that these are actual promulgated standards; we suggest the term be changed to Groundwater Protection “Action Levels” or
“Goals”

Division response: In the context of the RCRA Groundwater Protection regulations (R315-8-6), the term “Groundwater Protection Standard” is used when establishing concentrations, in
a facility’s permit, for hazardous constituents that will trigger the need to begin a corrective action program [R315-8-6.3 and R315-8-6.10(h)(2)]. Provisions are included in the Permit
for applying for alternate concentration limits (Permit Condition IV.C.2.). The term “Groundwater Protection Standard” will continue to be used in the Permit.

________________________________________________________________________

IV.A.1. Hazardous constituents have been released from the M-136 Burning Area, M-508 and other suspected sources of groundwater contamination. The Permittee shall monitor groundwater
in the impacted aquifers as described in this Module and Attachment 3. The Permittee shall maintain compliance with R315-8-6 Groundwater Protection during the post-closure care period
as defined in Condition IV.A.6.

ATK’s comment:

This language is confusing as this is a post-closure permit for specific HWMUs as previously defined.

Division response: The Division agrees with ATK. The language identified has been removed from the Permit Condition. The edited condition, as it appears in the final permit is shown
below:

IV.A.1. Hazardous constituents have been released from the M-136 Burning Area and the M-508 Photographic Waste Discharge Site. The Permittee shall monitor groundwater in the impacted
aquifers as described in this Module and Attachment 3. The Permittee shall maintain compliance with R315-8-6 Groundwater Protection during the post-closure care period as defined in
Condition IV.A.6.

_________________________________________________________________________

Attachment 1, Security and Maintenance Plan

I.C.1.c. The Permittee shall prevent run-on and run-off from eroding or otherwise damaging the final cover, or caps. Run-on and run-off at the M-136 Burning Grounds and LTTA caps are
controlled by diversion, collection ditches and trenches. Diversion ditches direct run-on around the M-136 area. Run-off is collected in a ditch on the west end of the area which drains
towards Blue Creek. The diversion and collection ditches shall be kept clean of debris and vegetation. If debris or vegetation is found in these structures during inspections that
may result in inadequate drainage, action shall be initiated within 72 hours to clear the drainage structures. The LTTA caps within the M-136 area are included in the ATK Launch Systems
zone of engineering control.

ATK’s comment:

Suggest clarifying this statement: The diversion and collection ditches shall be kept clean of debris and vegetation that may prevent adequate drainage.

Division response: The Division agrees with ATK. ATK’s suggested language has been inserted into the Permit Condition. The edited condition, as it appears in the final permit is shown
below:

I.C.1.c. The Permittee shall prevent run-on and run-off from eroding or otherwise damaging the final cover, or caps. Run-on and run-off at the M-136 Burning Grounds and LTTA caps are
controlled by diversion, collection ditches and trenches. Diversion ditches direct run-on around the M-136 area. Run-off is collected in a ditch on the west end of the area which drains
towards Blue Creek. The diversion and collection ditches shall be kept clean of debris and vegetation that may prevent adequate drainage. If debris or vegetation is found in these
structures during inspections that may result in inadequate drainage, action shall be initiated within 72 hours to clear the drainage structures. The LTTA caps within the M-136 area
are included in the ATK Launch Systems zone of engineering control.

1

September 25, 2007

TN200701078
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

Richard W. Sprott
Executive Director

DIVISION OF SOLID AND HAZARDOUS WASTE
Dennis R. Downs
Director

JON M. HUNTSMAN, JR.
Governor

GARY HERBERT
Lieutenant Governor